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HomeMy WebLinkAboutPlanning Commission 2022-01-11 Agenda Packet
Planning Commission
Regular Meeting
Tuesday, January 11, 2022, 7:00 P.M.
AGENDA
Virtual Meeting
Watch on Webinar: https://tinyurl.com/pc-2022-01-11
Watch on YouTube: http://www.youtube.com/cityofsanrafael
Telephone: (669) 900-9128
Meeting ID: 872-0645-4435#
One Tap Mobile: US: +16699009128,,87206454435#
CORONAVIRUS (COVID-19) ADVISORY NOTICE
In response to Assembly Bill 361, the City of San Rafael is offering teleconference
without complying with the procedural requirements of Government Code section
54953(b)(3). This meeting will be held virtually using Zoom.
How to participate in the meeting:
• Submit public comments in writing. Correspondence received by 5:00 p.m. the
Wednesday before this public hearing will be provided with the agenda materials
provided to the Commission. Correspondence received after this deadline but by
5:00 p.m. the day of the hearing will be conveyed to the Commission as a
supplement. Send correspondence to the project planner and to
planningpubliccomment@cityofsanrafael.org
• Join the Zoom webinar and use the 'raise hand' feature to provide verbal public
comment.
• Dial-in to Zoom's telephone number using the meeting ID and provide verbal
public comment.
Any member of the public who needs accommodations should contact the City Clerk
(email city.clerk@cityofsanrafael.org or phone at 415-485-3066) who will use their best
efforts to provide reasonable accommodations to provide as much accessibility as
possible while also maintaining public safety in accordance with the City procedure for
resolving reasonable accommodation requests.
Members of the public may speak on Agenda items.
CALL TO ORDER
RECORDING OF MEMBERS PRESENT AND ABSENT
APPROVAL OR REVISION OF ORDER OF AGENDA ITEMS
PUBLIC NOTIFICATION OF MEETING PROCEDURES
ORAL COMMUNICATIONS FROM THE PUBLIC
Remarks are limited to three minutes per person and may be on anything within the subject
matter jurisdiction of the body. Remarks on non-agenda items will be heard first, remarks on
agenda items will be heard at the time the item is discussed.
CONSENT CALENDAR
The Consent Calendar allows the Commission to take action, without discussion, on Agenda
items for which there are no persons present who wish to speak, and no Commission
members who wish to discuss.
1. Approval of the Planning Commission Meeting Minutes of December 14, 2021
Recommended Action – Approve minutes as submitted
2. Tiscornia Marsh Restoration Project, North of Canal Street
Request for a Use Permit and Environmental and Design Review Permit to approve the
Tiscornia Marsh Restoration Project. The Tiscornia Marsh Restoration Project proposes
to restore the 23-acre tidal marsh/mudflats and shoreline levee located north and
outboard of Canal Street, as well as the five-acre, City-owned diked marsh located
north of the Albert J. Boro Center/Pickleweed Park Playfields. APNs: 009-142-01, 009-
032-08 and -09; Planned Development- Wetland Overlay (PD-WO) and Parks/Open
Space-Wetland and Canalfront Review Overlay (P/OS-WO-C) Districts. Applicant:
Marin Audubon Society; Property Owners: Marin Audubon Society and City of San
Rafael.
Project Planner: Leslie Mendez Leslie.mendez@cityofsanrafael.org
Recommended Action - Adopt a resolution certifying the Tiscornia Marsh Restoration
Project Final Environmental Impact Report (FEIR); Adopt a resolution adopting CEQA
Findings of Fact and approving a Mitigation Monitoring and Reporting Program; and
Adopt a resolution approving Use Permit UP21-001 and Environmental and Design
Review Permit ED21-002
ACTION ITEMS
3. Northgate Mall Redevelopment Project (5800 Northgate Drive)
Scoping meeting for the Notice of Preparation of an Environmental Impact Report (EIR)
for a Rezone to the Planned Development (PD) zone, a Use Permit, an Environmental
and Design Review Permit, and a Tentative Map to allow the comprehensive
redevelopment of the existing Mall into a new, phased mixed-use development with
retail and approximately 1,443 residences on a 44.76-acre site. APNs: 175-060-12, -40,
-59, -61, -66 &-67; General Commercial (GC) District; MeloneGeier Partners,
owner/applicant; File Nos: ZC21-001, UP21-007, ED21-024, TS21-002, IS21-002 &
DA21-001
Project Planner: Tricia Stevens Tricia.Stevens@cityofsanrafael.org
Recommended Action - Accept public comment and direct staff to prepare a Draft
Environmental Impact Report (DEIR)
4. Annual Meeting 2022
Annual Meeting of Planning Commission for 2022 to include: a) election of officers; and
b) review of Planning Commission “Rules and Procedures”; and c) selection of liaisons
to DRB meetings
Project Planner: Leslie Mendez Leslie.mendez@cityofsanrafael.org
Recommended Action - Elect a new Chair and Vice Chair for 2022; Consider and
accept any proposed changes to the Planning Commission “Rules and Procedures;”
and Select Planning Commission liaisons to the DRB for 2022
DIRECTOR’S REPORT
COMMISSION COMMUNICATION
ADJOURNMENT
Any records relating to an agenda item, received by a majority or more of the Commission
less than 72 hours before the meeting, shall be available for inspection online. Sign Language
interpreters may be requested by calling (415) 485-3066 (voice), emailing
city.clerk@cityofsanrafael.org or using the California Telecommunications Relay Service by
dialing “711”, at least 72 hours in advance of the meeting. Copies of documents are available
in accessible formats upon request.
The Planning Commission will take up no new business after 11:00 p.m. at regularly
scheduled meetings. This shall be interpreted to mean that no agenda item or other business
will be discussed or acted upon after the agenda item under consideration at 11:00 p.m. The
Commission may suspend this rule to discuss and/or act upon any additional agenda item(s)
deemed appropriate by a unanimous vote of the members present. Appeal rights: any person
may file an appeal of the Planning Commission's action on agenda items within five business
days (normally 5:00 p.m. on the following Tuesday) and within 10 calendar days of an action
on a subdivision. An appeal letter shall be filed with the City Clerk, along with an appeal fee
of $350 (for non-applicants) or a $4,476 deposit (for applicants) made payable to the City of
San Rafael, and shall set forth the basis for appeal. There is a $50.00 additional charge for
request for continuation of an appeal by appellant.
Minutes subject to approval at the meeting of January 11, 2022
Planning Commission
Regular Meeting
Tuesday, December 14, 2021, 7:00 P.M.
MINUTES
Virtual Meeting
Watch on Webinar: https://tinyurl.com/pc-12-14-21
Watch on YouTube: http://www.youtube.com/cityofsanrafael
Telephone: (669) 900-9128
Meeting ID: 872-0645-4435#
One Tap Mobile: US: +16699009128,,87206454435#
CORONAVIRUS (COVID-19) ADVISORY NOTICE
In response to Assembly Bill 361, the City of San Rafael is offering teleconference
without complying with the procedural requirements of Government Code section
54953(b)(3). This meeting will be held virtually using Zoom.
How to participate in the meeting:
• Submit public comments in writing. Correspondence received by 5:00 p.m. the
Wednesday before this public hearing will be provided with the agenda materials
provided to the Commission. Correspondence received after this deadline but by
5:00 p.m. the day of the hearing will be conveyed to the Commission as a
supplement. Send correspondence to the project planner and to
planningpubliccomment@cityofsanrafael.org
• Join the Zoom webinar and use the 'raise hand' feature to provide verbal public
comment.
• Dial-in to Zoom's telephone number using the meeting ID and provide verbal
public comment.
Any member of the public who needs accommodations should contact the City Clerk
(email city.clerk@cityofsanrafael.org or phone at 415-485-3066) who will use their best
efforts to provide reasonable accommodations to provide as much accessibility as
possible while also maintaining public safety in accordance with the City procedure for
resolving reasonable accommodation requests.
Present: Chair Samudzi
Commissioner Harris
Commissioner Haveman
Commissioner Lubamersky
Commissioner Saude
Absent: Commissioner Mercado
Vice Chair Previtali
Also Present: Leslie Mendez, Planning Manager
Steve Stafford, Senior Planner
Jayni Allsep, Contract Planner
Jeff Hamilton, Contract Planner
Sean Kennings, Contract CEQA Consultant
CALL TO ORDER
Chair Samudzi called the meeting to order at 7:00 p.m. He then invited Planning Manager
Leslie Mendez to call the roll. All commissioners were present, except Commissioner
Mercado and Vice Chair Previtali.
APPROVAL OR REVISION OF ORDER OF AGENDA ITEMS
None
PUBLIC NOTIFICATION OF MEETING PROCEDURES
Chair Samudzi invited Planning Manager Leslie Mendez who informed the community the
meeting would be streamed live to YouTube and members of the public would provide
public comment either on the telephone or through Zoom. She explained the process for
community participation on the telephone and Zoom.
Chair Samudzi reviewed the procedures for the meeting.
ORAL COMMUNICATIONS FROM THE PUBLIC
None
CONSENT CALENDAR
Chair Samudzi invited public comment; however, there was none.
Commissioner Lubamersky moved and Commissioner Haveman seconded to approve the
Consent Calendar.
1. Approval of the Planning Commission Meeting Minutes of October 26, 2021
Approved minutes as submitted
2. [UP21-006 & ED21-022] 800 Mission Ave. Project (“Aegis Living San Rafael”) –
Corrected Resolution
Resolution of the City of San Rafael Planning Commission amending the effective date
of Planning Commission Resolution No. 21-08
(Approval Of Development Permits For 800 Mission Avenue)
(APNS: 011-184-08 & -09)
Project Planner: Steve Stafford steve.stafford@cityofsanrafael.org
RESOLUTION NO. 21-09 - RESOLUTION OF THE CITY OF SAN RAFAEL
PLANNING COMMISSION AMENDING THE EFFECTIVE DATE OF PLANNING
COMMISSION RESOLUTION NO. 21-08 (APPROVAL OF DEVELOPMENT PERMITS
FOR 800 MISSION AVENUE) (APNS: 011-184-08 & -09)
3. Ross Terrace Street (39 & 41 Ross Street)
Request for a Lot Line Adjustment for property line adjustment, Exception, and
Environmental and Design Review Permits to allow for the: (1) Construction of a 2,646
square-foot, single-family residence on vacant hillside Lot 59; (2) Construction of a
2,697 square foot residence on vacant hillside Lot 60; and (3) Construction of a two
lane access driveway within the undeveloped Ross Street Terrace right-of-way
approximately 480 feet in length from Ross Street; APNs: 012-141-59 and 012-141-60;
Single-family Residential (R7.5) District; Coby Freidman, applicant. File No(s).: LLA19-
008, ED19-090, ED19-091, and EX20-006.
Project Planner: David Hogan dave.hogan@cityofsanrafael.org
Continued item
AYES: Commissioners: Harris, Haveman, Lubamersky, Saude & Chair Samudzi
NOES: Commissioners: None
ABSENT: Commissioners: Mercado & Previtali
ABSTAIN: Commissioners: None
Motion carried 5-0
ACTION ITEMS
4. Aldersly Retirement Community, 326 and 308 Mission Avenue - Scoping meeting for
Notice of Preparation of an Environmental Impact Report (EIR) to assess impacts of the
Aldersly Retirement Community Project. The project proposes phased improvements on
the Aldersly Campus, including demolition and renovation of existing buildings and
construction of new buildings. APNs: 014-054-31 and -32; Planned Development (PD-
1775) Zoning District; Applicant: Peter Lin, Greenbriar Development; Property Owner:
Peter Schakow, Aldersly Retirement Community.
Project Planner: Jayni Allsep jayni.allsep@cityofsanrafael.org
Leslie Mendez, Planning Manager introduced Jayni Allsep, Contract Planner who presented
the Staff Report.
Staff and Applicant Team responded to questions from the Commissioners.
Chair Samudzi invited public comment.
Speakers: Derek Cavasian, Tymber Cavasian
Staff and Applicant Team responded to further questions from the Commissioners.
Commissioners provided comments.
Commissioner Lubamersky moved and Commissioner Haveman seconded to accept public
comment and direct staff to prepare a Draft Environmental Impact Report (DEIR)
AYES: Commissioners: Harris, Haveman, Lubamersky, Saude & Chair Samudzi
NOES: Commissioners: None
ABSENT: Commissioners: Mercado & Previtali
ABSTAIN: Commissioners: None
Motion carried 5-0
5. Neighborhood at Los Gamos - Request for General Plan Amendment GPA 20-001
(from Hillside Resource Residential to Neighborhood Commercial Mixed Use); Zone
Change ZC 20-002 (from Planned District – Hillside Development Overlay District (PD-
H) and Residential – Hillside Development Overlay District (R2a-H) to Planned
Development District (PD); Vesting Tentative Parcel Map (to combine and adjust the
boundaries of the existing parcels); and Environmental and Design Review ED 20-058;
for a mixed-use project with 192 multi-family residential units; an approximately 5,600-
square-foot retail grocery store; a 5,000-square-foot community center; and 225 at-grade
and semi-subterranean parking spaces; on a 10.24 acre site located on Los Gamos Road
north of Oleander Drive; on APN 165-220-06 and 165-220-07; Christopher Hart,
Applicant and Property Owner; Mont Marin/San Rafael Park Neighborhood.
Project Planner: Jeff Hamilton jhamilton@migcom.com
Leslie Mendez, Planning Manager introduced Jayni Jeff Hamilton, Contract Planner who
presented the Staff Report. She also introduced Sean Kennings, Contract CEQA consultant
who is available for questions.
Staff responded to questions from the Commissioners.
Applicant Team gave a presentation.
Chair Samudzi invited public comment.
Speakers: Andrew Ward, Marin YMCA, Michele Hassid, San Rafael Chamber of
Commerce, Bob Pendoley, Marin Environmental Housing Collaborative MEHC, Zack
Zimmeran, BamCore, Jeff Bialik, Housing Crisis Action Marin Steering Committee, Rae
Dawn Hirsch, Grace Geraghty, Responsible Growth Marin
Staff and Applicant Team responded to further questions from the Commissioners.
Commissioners provided comments.
Commissioner Lubamersky moved and Commissioner Saude seconded to approve and
recommend going forward articles a-e and follow Staff’s recommendation.
AYES: Commissioners: Harris, Haveman, Lubamersky, Saude & Chair Samudzi
NOES: Commissioners: None
ABSENT: Commissioners: Mercado & Previtali
ABSTAIN: Commissioners: None
Motion carried 5-0
Adopted Resolutions recommending to the City Council a) adoption of the Mitigated Negative
Declaration and MMRP; b) approval of the General Plan Amendment; c) approval of the Zone
Change; d) approval of the Vesting Tentative Parcel Map with conditions; e) approval of the
Environmental and Design Review application with conditions
RESOLUTION NO. 21-10 - RESOLUTION OF THE CITY OF SAN RAFAEL PLANNING
COMMISSION RECOMMENDING TO THE CITY COUNCIL ADOPTION OF AN INITIAL
STUDY/MITIGATED NEGATIVE DECLARATION AND APPROVAL OF THE MITIGATION
MONITORING AND REPORTING PROGRAM FOR A GENERAL PLAN AMENDMENT (GPA
20-001), ZONE CHANGE (ZC 20-002), VESTING TENTATIVE PARCEL MAP, AND
ENVIRONMENTAL AND DESIGN REVIEW PERMIT (ED 20-058), FOR THE
CONSTRUCTION OF A MIXED-USE PROJECT CONSISTING OF 192 RESIDENTIAL
APARTMENT UNITS, A 5,600 SQUARE-FOOT MARKET, A 5,000 SQUARE FOOT
COMMUNITY CENTER, AND 225 AT-GRADE AND SEMI-SUBTERRANEAN PARKING
SPACES, ON A 10.24 ACRE SITE LOCATED AT THE SOUTHERLY TERMINUS OF LOS
GAMOS ROAD NORTH OF OLEANDER DRIVE (THE NEIGHBORHOOD AT LOS GAMOS)
(APNS: 165-220-06 AND 165-220-07)
RESOLUTION NO. 21-11 - RESOLUTION OF THE CITY OF SAN RAFAEL PLANNING
COMMISSION RECOMMENDING TO THE CITY COUNCIL APPROVAL OF A GENERAL
PLAN AMENDMENT FROM HILLSIDE RESOURCE RESIDENTIAL TO NEIGHBORHOOD
COMMERCIAL MIXED USE (GPA 20-001) AND ADOPTION OF AN ORDINANCE
REZONING CERTAIN PROPERTY FROM PLANNED DISTRICT – HILLSIDE
DEVELOPMENT OVERLAY DISTRICT (PD-H) AND RESIDENTIAL – HILLSIDE
DEVELOPMENT OVERLAY DISTRICT (R2A-H) TO PLANNED DEVELOPMENT DISTRICT
(PD) (ZC 20-002), FOR THE CONSTRUCTION OF A MIXED-USE PROJECT CONSISTING
OF 192 RESIDENTIAL APARTMENT UNITS WITH TEN BELOW MARKET RATE UNITS
AVAILABLE TO LOW INCOME HOUSEHOLDS, A 5,600 SQUARE-FOOT RETAIL
GROCERY SOTRE, A 5,000 SQUARE FOOT COMMUNITY CENTER, AND 225 AT-GRADE
AND SEMI-SUBTERRANEAN PARKING SPACES, ON A 10.24 ACRE SITE LOCATED AT
THE SOUTHERLY TERMINUS OF LOS GAMOS ROAD NORTH OF OLEANDER DRIVE
(THE NEIGHBORHOOD AT LOS GAMOS) (APNS: 165-220-06 AND 165-220-07)
RESOLUTION NO. 21-12 - RESOLUTION OF THE CITY OF SAN RAFAEL PLANNING
COMMISSION RECOMMENDING THAT THE CITY COUNCIL APPROVE A VESTING
TENTATIVE PARCEL MAP AND ENVIRONMENTAL AND DESIGN REVIEW PERMIT (ED
20-058), ON A 10.24 ACRE SITE LOCATED AT THE SOUTHERLY TERMINUS OF LOS
GAMOS ROAD NORTH OF OLEANDER DRIVE (THE NEIGHBORHOOD AT LOS GAMOS)
(APNS: 165-220-06 AND 165-220-07)
DIRECTOR’S REPORT
Planning Manager reported on the following items:
• The League of California Cities Planning Commissioners Academy to be held in March
2022 in San Ramon.
• On December 20, 2021, City Council will hear Senate Bill 9 (SB 9) guidelines and will
propose a new ordinance.
• Next Planning Commission meeting will be on January 11, 2022. At this meeting a new
Chair and Vice Chair will be selected and the 2022 schedule will be adopted.
COMMISSION COMMUNICATION
• Discussion regarding January meeting items and temporary shelter in the Canal.
• Commissioner Lubamersky announced his resignation.
ADJOURNMENT
Chair Samudzi adjourned the meeting at 9:21 p.m.
___________________________
LINDSAY LARA, City Clerk
APPROVED THIS _____DAY OF____________, 2022
_____________________________________
SHINGAI SAMUDZI, Chair
Community Development Department – Planning Division
Meeting Date: January 11, 2022
Agenda Item:
2
Case
Numbers:
UP21-001, ED21-002,
& IS21-001
Project
Planner:
Leslie Mendez,
Planning Manager
REPORT TO PLANNING COMMISSION
SUBJECT: Tiscornia Marsh Restoration Project, North of Canal Street – Request for a Use
Permit and Environmental and Design Review Permit to approve the Tiscornia Marsh Restoration
Project. The Tiscornia Marsh Restoration Project proposes to restore the 23-acre tidal
marsh/mudflats and shoreline levee located north and outboard of Canal Street, as well as the five-
acre, City-owned diked marsh located north of the Albert J. Boro Center/Pickleweed Park Playfields.
APNs: 009-142-01, 009-032-08 and -09; Planned Development- Wetland Overlay (PD-WO) and
Parks/Open Space-Wetland and Canalfront Review Overlay (P/OS-WO-C) Districts. Applicant:
Marin Audubon Society; Property Owners: Marin Audubon Society and City of San Rafael.
EXECUTIVE SUMMARY
Marin Audubon Society (MAS), project applicant, has filed Use Permit and Environmental and Design
Review Permit applications to pursue a restoration of the 23-acre Tiscornia Marsh, and the adjacent five-
acre, City-owned diked marsh located north of Canal Street. In late 2020, these planning applications and
restoration plans were reviewed by City staff, and it was determined that the project has the potential to
result in significant, physical environmental effects. Preparation of an Environmental Impact Report (EIR)
was initiated to assess the impacts of the project. In Fall 2021, a Draft EIR (DEIR) was prepared in
accordance with the CEQA Guidelines. A 45-day public review period for the DEIR was observed, and on
October 26, 2021, the Planning Commission held a public hearing to accept comments on the DEIR. The
DEIR found that all potentially significant impacts can be mitigated to a less-than-significant level through
implementation of recommended mitigation measures, and the Planning Commission directed that a Final
EIR (FEIR) be prepared. The FEIR has been completed and is available on the Tiscornia Marsh webpage.
An action to certify the FEIR is recommended (see Attachment 1), along with adopting of CEQA Findings
of Fact and approval of a Mitigation Monitoring and Reporting Program (MMRP) (see Attachment 2). These
actions must be taken prior to taking action on the planning applications.
As proposed and conditioned, the project is consistent with the pertinent policies and programs of the San
Rafael General Plan 2040 (see Attachment 4), and the provisions of the Planned Development – Wetland
Overlay (PD-WO) and Parks/Open Space – Wetland and Canalfront Review Overlay (P/OS-WO-C) zoning
districts. Approval of the Use Permit and Environmental and Design Review Permit applications is
recommended subject to conditions, which include the incorporation of the FEIR mitigation measures.
RECOMMENDATION
It is recommended that the Planning Commission take the following actions:
1. Adopt a resolution certifying the Tiscornia Marsh Restoration Project Final Environmental Impact
Report (FEIR) (Attachment 1);
2. Adopt a resolution adopting CEQA Findings of Fact and approving a Mitigation Monitoring and
Reporting Program (Attachment 2); and
3. Adopt a resolution approving Use Permit UP21-001 and Environmental and Design Review
Permit ED21-002 (Attachment 3).
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 2
PROPERTY FACTS
Address/Location: North of Canal Street Parcel Number(s): 009-142-01,
009-032-08 and 09
Property Size: 28 acres Neighborhood: Canal/Spinnaker Point
Site Characteristics
General Plan Designation Zoning Designation Existing Land-Use
Project Site: Conservation
Water
Parks, Recreation and Open
Space
PD-WO (Planned
Development –
Wetland Overlay)
District
P/OS-WO-C
(Parks/Open Space-
Wetland Overlay,
Canalfront Review
Overlay) District
Tidal marsh and
submerged tidelands
Upland shoreline levee and
access path
Undeveloped, diked marsh
North: Water
Parks, Recreation & Open
Space
Low-Density Residential
W
M-C
R7.5
San Rafael Canal,
Yacht Club
Single-Family Residences
South: Medium Density Residential
Parks, Recreation and Open
Space
PD-1255
P/OS-C
Townhomes
Community Center and Park
East: Water W Bay Tidelands
West: Parks, Recreation and Open
Space
Low-Density Residential
P/OS-C
R5-C
Community Center and Park
Single-Family Residences
Site Description & Setting:
The Tiscornia Marsh site covers 23 acres of tidal marsh and bay lands and well as 2,000 feet of shoreline
levee/trail located north of East Canal Street. The property, which is owned by MAS is bound to the: a)
south by a shoreline levee, Schoen Park (small City-owned park/playground) and Canal Street; b) west by
the Albert J Boro Community Center and Pickleweed Park; c) east by the San Rafael Bay; and d) north by
the San Rafael Creek. The neighboring Albert J Boro Community Center and Pickleweed Park covers
approximately 15 acres which includes an active community center, community park, and an expansive
playfield. Included in the City-owned holdings is an undeveloped, four-acre diked salt marsh, which is
located north of the large playfield. Although subject to flooding in the winter months, this diked salt marsh
is enclosed by a perimeter levee and contains a well-used, informal pedestrian trail, which loops through
the area.
The Tiscornia Marsh has experienced considerable erosion along its bayward edge, which is attributed to
direct wave action from the bay. Over the last 30 years, approximately three acres of the tidal marsh has
been lost to this erosion, which has dramatically impacted habitat for species such as the California
Ridgway’s Rail and Salt Marsh Harvest Mouse. Under current conditions, it is expected that this erosion
will continue and will likely increase as sea level rises. The second critical issue for this general area is
flooding. The adjacent Canal neighborhood is low-lying and is currently at risk to coastal flooding (as well
as sea level rise).
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 3
Figure 1: Tiscornia Marsh Restoration Project Location
History:
In June 2016, the voters of the nine Bay Area counties approved Measure AA, a parcel tax measure. The
tax measure is a $12.00 per year tax on every parcel in the Bay Area. The purpose of Measure AA is to
generate $500 million over a 20-year period for critical tidal marsh restoration projects around the San
Francisco Bay. The goal is to improve water quality, restore habitat for wildlife, protect communities from
flooding and increase shoreline public access.
Applications for Measure AA funds for local restoration projects are initiated annually by the San Francisco
Bay Restoration Authority. In fall 2018, a second call for applications was released and MAS applied for
funding. As required by the application process MAS was required to submit an endorsement of the
application by the local jurisdiction (City). On October 1, 2018, the City Council reviewed this request and
adopted Resolution No. 14592 authorizing the application endorsement. As part of this review, the City
Council acknowledged it role as the lead agency on this project for permitting and environmental review.
PROJECT DESCRIPTION
Marin Audubon Society is pursuing the restoration of the Tiscornia Marsh, which would include the
contiguous City-owned dike marsh. The project objectives are as follows:
• Restore the project area to improve ecological function and habitat quantity, quality, and
connectivity for native marsh species and marsh upland transition species, including special-status
species.
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 4
• Protect the project site marshlands from future marsh edge erosion.
• Increase the level of flood protection for the Canal neighborhood and other nearby communities of
Central San Rafael.
• Create sustainable benefits that consider future environmental changes such as sea level rise and
sedimentation.
• Maintain and improve public access to passive recreation and outdoor education opportunities
(e.g., hiking, jogging and bird watching).
Tiscornia Marsh would be restored to its former extent by beneficially reusing dredged material from local
sources. A coarse beach would be constructed along the bay ward edge of the restored marsh to resist
future erosion. Tidal action would also be restored to the City-owned diked marsh at the north end of
Pickleweed Park. Altogether, the project would reconstruct approximately four acres of eroded tidal marsh,
preserve, and protect the approximately eight remaining acres of Tiscornia Marsh, and restore
approximately five acres of diked marsh (City-owned area north of the Pickleweed Park playfields) by
reconnecting it to tidal inundation. The project also proposes to construct a new 600-foot setback levee
and improve approximately 1,100 feet of shoreline levee to achieve greater flood protection, public access,
and habitat benefits. In sum, the major project elements include the:
Introduction of a course, rocky beach;
Reconstruction of the eroded tidal marsh;
Restoring the diked marsh to the bay;
Shoreline levee improvements; and
Development of an ecotone slope.
Figure 2: Restoration Plan
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 5
Since the initial development of the restoration plan, minor revisions to the plan have been made to align
with several City-sponsored projects within the park and community center area. Among these projects is
a storm drain outfall and trash capture program, which, if implemented, would necessitate some
adjustments that would transition to and join with the elevated western levee in the restoration plan.
In January 2021 MAS filed Use Permit and Environmental and Design Review Permit applications for this
project. The grading and restoration of wetlands (including filling and cutting/dredging) requires a Use
Permit per SRMC Sections 14.13.030 and 14.13.050 (Wetland Overlay District). Grading as a primary use
(not linked to the construction of a building) requires an Environmental and Design Permit per SRMC
Section 14.25.040A.3.b, as it is considered a major site improvement (involves in excess of 1,000 cubic
yards of fill and 2,000 cubic yards of cut). Construction-related City permits required for this project include
a Grading Permit and a Tideland Permit. Permits and clearances are required by other regulatory agencies
including, but not limited to the US Army Corps of Engineers, Bay Conservation and Development
Commission (BCDC), California Department of Fish & Wildlife (CDFW), and the California Regional Water
Quality Control Board (RWQCB).
ANALYSIS
General Plan 2040 Consistency:
A detailed analysis of the project consistency with the General Plan 2040 has been prepared in table format
and is provided as Attachment 4 to this report. A summary of key policies and programs is provided below.
Staff has identified a number of key General Plan 2040 policies and programs that should be considered.
First, as proposed, the project is consistent with the pertinent policies of the Land Use Element including:
Policy LU-2,1 (Land Use Map and Categories – Parks/Recreation and Open Space, Water, and
Conservation); Policy LU-1.15 (Planned Development Zoning). The project proposes to maintain, expand,
and improve wetlands and the shoreline levee project, which are uses and improvements that: a) are
promoted in the applicable land use categories; and b) would facilitate orderly planning as required by the
PD (Planned Development) District zoning. Further, the project is appropriate for the project site area as
it would improve the bay front environment by creating new wetlands, promoting new wildlife habitat,
improving hydrology and stormwater drainage, and providing some defense to projected sea level rise.
Other key policies that are pertinent to this project are as follows:
Conservation and Climate Change Element
C-1.2. Wetlands and Sea Level Rise.
Optimize the role of wetlands in buffering the San Rafael shoreline against the future impacts of sea
level rise.
Response: As a whole, the project is designed to enhance and restore wetlands to their natural condition.
The project features include raising the shoreline levee and creating an “ecotone” (outboard, horizontal
levee), which are key to combating and adapting to sea level rise.
C-1.3. Wetland Protection and Mitigation.
In order to protect and preserve valued wetlands, loss of wetlands due to filling shall be avoided.
Compensatory mitigation for the loss of wetlands shall be required in the event that preservation is not
possible or practical due to conditions such as the location, configuration, and size of the wetland.
Response: As proposed, the project would not result in the loss of wetlands but would enhance wetlands
that are currently protected. Although the development of an “ecotone” in an area of submerged tidelands
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 6
and diked marsh will require some filling of the bay, this filling would be offset by the removal of fill in the
diked marsh area.
Parks, Recreation and Open Space Element
PROS-1.8. Linear Parks and Trails.
Encourage linear parks and trails along the Bay shoreline, the San Rafael Canal, local creeks, and
transportation corridors such as the SMART right-of-way. Where feasible, spur trails should connect
linear parks to nearby neighborhoods, parks, and open spaces.
The project would result in an improved and increased linear park and trails system for the Southeast San
Rafael neighborhood. The proposal to raise and shift the alignment of the shoreline levee will not only
mitigate increased flooding and combat projected sea level rise, but it would also provide for a more
protected and improved public trail that is well used by the community.
Safety Element
S-3.4. Mitigating Flooding and Sea Level Rise.
Consider and address increased flooding and sea level rise impacts in vulnerable areas (see Figure 8-
3) in development and capital projects, including resiliency planning for transportation and
infrastructure systems.
Response: The project features include raising the shoreline levee and creating an “ecotone” (outboard,
horizontal levee), which are key to mitigating increased flooding, as well as combating and adapting to
projected sea level rise.
S-3.7. Shoreline Levees.
Improve and expand San Rafael’s shoreline levee system. When private properties are developed or
redeveloped, require levee upgrading as appropriate, based on anticipated high tide and flood
conditions.
Response: The project would raise and realign the existing shoreline levee, which would reduce flooding
assist in adapting the area to projected sea level rise.
Neighborhoods Element
NH-3.6. Public Access.
Increase and improve public access to the Canal through the creation of waterfront promenades, a
potential new pedestrian bridge east of Grand Avenue, additional access points within new
development, and waterside access for boats.
Response: The project includes the raising and realignment of the shoreline levee that is within the project
area. The new levee top with be developed with a new pedestrian/bicycle path, which will be accessible to
the public. The path would improve public access.
NH-3.8. Flood Control Improvements.
Coordinate development and redevelopment of uses along the Canal with a comprehensive strategy
to reduce flood hazards, adapt to sea level rise and create a more resilient shoreline. This should
include improvements to levees and sea walls, pump stations, and storm drainage infrastructure.
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 7
Response: The project includes the raising and realignment of the shoreline levee that is within the project
area, along with the creation of new marshland in areas that are currently submerged tidelands and diked
marshland. As determined by the Tiscornia Marsh EIR, these improvements will improve flood control for
an area that is prone to flood risk.
As proposed and as conditioned, staff finds that overall, the project is consistent with these and all pertinent
policies and programs of the San Rafael General Plan 2040. The project has been designed to maintain
and improve public access along the bay front, while complimenting and minimizing impacts to neighboring
properties and improvements.
Zoning Ordinance Consistency:
SRMC Chapters 14.07 and 14.10 - Base District Regulations (PD and P/OS Districts)
The majority of the project site (23 acres) that is owned by MAS is located within the Planned Development
(PD) District. The purpose of the PD District is to customize the zoning regulations so as to “master plan”
the site for cohesive planning. The provisions set forth in Chapter 14.07 (PD District) of the San Rafael
Municipal Code (Zoning Ordinance) state that no use other than an existing use or a temporary use shall
be approved without a “development plan” (aka, “master plan”), which is adopted by ordinance of the City
Council. However, as the proposed project would not dramatically change but would enhance the existing
land use, no development plan is required. However, as provided in SRMC Section 14.07.020, approval
of a Use Permit is required. Proposed Use Permit UP21-001 complies with this requirement.
The five-acre, City-owned diked marsh portion of the project site is subject to the land use regulations and
development standards of the underlying Parks/Open Space (P/OS) zoning district, pursuant to Chapter
14.10 of the San Rafael Municipal Code (Zoning Ordinance). The project would not result in the conversion
of the existing diked marsh to a tidal marsh. The resulting use would be defined as a “wildlife preserves
or sanctuary,” which is consistent with and a permitted use within the P/OS District.
SRMC Chapters 14.13 and 14.15 - Overlay District Regulations (-WO and -C Districts)
Overlay Districts apply to areas and sites where there are special conditions, which require application of
additional regulations and requirements. Two Overlay Districts apply to the project site, the Wetland
Overlay (-WO) and Canalfront Review Overlay (-C) Districts.
The entire project area is located within the Wetland Overlay (-WO) District as it contains known wetlands
as defined and regulated by the US Army Corps of Engineers. The purpose of the -WO Overlay District is
to: protect wetlands as an environmental resource; discourage filling or destruction of wetlands; and to
require mitigation or replacement if wetlands are lost or destroyed to development. The project would be
consistent with the purposes of the -WO District (SRMC Section 14.13.010) in that it would: 1) preserve
and enhance wetlands; 2) contribute to improve water quality for the general area; 3) enhance wildlife
habitat, particularly for rare and endangered species; and 4) expand public recreational activities (shoreline
levee path) that would be compatible with the wetland habitat. Further, the project is consistent with the
provisions and requirements of SRMC Section 14.13.050 as the planning applications being considered
includes the subject Use Permit and a wetland restoration plan. Lastly, as conditioned, the project will be
subject to a wetland management plan.
The five-acre, City-owned diked marsh is within the Canalfront Review Overlay (-C) District. SRMC
Chapter 14.15 of the Zoning Ordinance sets forth general site and use regulations that are applicable to
the -C Overlay District. The project would be consistent with the purposes of this District (Section
14.15.010) in that it would: 1) improve and enhance public views to the canal front; 2) protect the unique
physical and social characteristics of the canal front area; and 3) would not impair or block the navigable
channel of the San Rafael Canal.
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 8
Chapter 14.22 – Use Permit
As discussed above, a Use Permit is required for the project grading (fill and dredging to achieve the
restoration) as the property is located within the -WO Overlay District. SRMC Section 14.22.080 requires
that findings be made to support the approval of a Use Permit. Further, special findings are required by
SRMC Section 14.13.070 (-WO Overlay District findings) As outlined in the attached resolution
(Attachment 3), the required findings can be made to support the approval of the Tiscornia Marsh
Restoration Project. Specifically, the project would: a) meet the applicable and pertinent General Plan 2040
policies and programs; b) comply with the provisions of the PD-WO and P/OS-WO/-C Districts and other
applicable provisions of the Zoning Ordinance including the criteria of SRMC Chapter 14.25
(Environmental and Design Review Permit, see below); and c) would not be detrimental to the public
health, safety, or welfare, or be materially injurious to properties or improvements in the vicinity. The
project would promote the continuation and improvement of an environmental resource, which is critical to
the protection of public safety and health to the community at large.
Chapter 14.25 – Environmental and Design Review Permit
The project is subject to the review criteria for Environmental and Design Review Permits, pursuant to
SRMC Section 14.25.050 (Review criteria: Environmental and Design Review Permits) of the Zoning
Ordinance. As proposed and as conditioned, the project complies with the criteria required to approve
Environmental and Design Review Permit ED21-002 as follows:
1. As proposed, the site plan is acceptable for the site and intended use is generally harmonious with the
other neighboring natural resources, as well as the variety of urban uses and improvements
surrounding the project site. The project site plan has been designed to minimize impacts to adjacent
properties, while maximizing opportunities for habitat enhancement, flood control and sea level rise
protection, and public shoreline access.
2. As proposed and as conditioned, the project presents a competent design which has been prepared
by environmental professionals (hydrologists and biologists) skilled in designing wetland restoration
projects. The competency of the project design has been confirmed by the findings presented in the
Tiscornia Marsh Restoration Project FEIR.
3. To address temporary impacts associated with project construction, as proposed and conditioned, the
project proposes site access and circulation that promotes safe access for construction vehicles and
apparatus without impairing street circulation.
ENVIRONMENTAL REVIEW
Completion of Final Environmental Impact Report (FEIR)
Pursuant to the requirements of the California Environmental Quality Act (CEQA) Guidelines, this project
is subject to environmental review. In early 2021, it was determined that the project has the potential to
result in significant impacts on the environmental, and that an Environmental Impact Report (EIR) should
be prepared to assess these potential impacts.
In Fall 2021, a Draft EIR (DEIR) was prepared in accordance with the CEQA Guidelines. The DEIR
presented the following conclusions and findings:
Of the topic areas that were assessed and studied, the restoration project would result in no
unavoidable adverse environmental impacts that cannot be mitigated.
The restoration project would result in 16 potentially significant impacts. However, the DEIR
recommends 13 mitigation measures that would reduce these impacts to a less-than-significant
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 9
level. Mitigation measures are recommended for potentially significant impacts to: a) air quality
(temporary impacts associated with grading and construction); b) biological resources; c) cultural
and tribal resources; and d) traffic and transportation (temporary impacts associated with project
construction).
A 45-day public review period was observed to accept comments on the DEIR. Comments were submitted
by one public agency (State of California Dept of Fish & Wildlife) and thirteen individuals. On October 26,
2021, the Planning Commission held a public hearing to accept and provide comments on the DEIR. The
Planning Commission: a) found the DEIR to be adequate and complete; and b) directed staff to proceed
with completing a Final EIR (FEIR), which is to include responding to all comments on the DEIR.
The FEIR has been completed and is available on the Tiscornia Marsh webpage. The FEIR includes a
response to all comments submitted on the DEIR. The DEIR comments have resulted in several minor
changes/edits in the DEIR text and to three of the recommended mitigation measures related biological
resource impacts. Staff recommends that the FEIR be certified as complete and adequate. A resolution
has been prepared, which recommends FEIR certification (see Attachment 1).
CEQA Findings and Mitigation Monitoring & Reporting Program:
Prior to taking action to approve/conditionally approve the planning applications (Use Permit and
Environmental and Design Review Permit), it must be determined that: a) the certified FEIR adequately
assesses the environmental impacts of the project to support this action; and b) the FEIR mitigation
measures are suitable for and can be incorporated into this action. A resolution has been prepared (see
Attachment 2), which presents detailed CEQA Findings of Fact supporting conditional approval of the
planning applications. Further, as required by the CEQA Guidelines, this resolution includes the approval
of a Mitigation Monitoring and Reporting Program (MMRP). The MMRP is required to demonstrate how
these measures are incorporated into the approval of the project, and how they will be implemented to
ensure that they effectively reduce or eliminate potential. Consistent with the recommendations of the
MMRP, the FEIR mitigation measures have been incorporated into the recommended conditions of
approval for the planning applications.
Tribal Consultation – AB 52
Consistent with the requirements and protocols of State Resources Code Section 21080.3.1 (AB 52) and
CEQA Guidelines Section 15064.5, the City, as a lead agency must offer an opportunity for early
consultation with the local Native American tribe. In February 2021, the City initiated the tribal consultation
process through a request with the Federated Indians of Graton Rancheria (FIGR).
City staff met with representatives of the FIGR in spring 2021, which included an exchange of the cultural
resources assessment prepared for the project area provide by ESA, Inc. In this meeting, there was a
discussion of the resources assessment as well as recommended grading and construction protocols and
requirements. These grading and construction protocols and requirements have been included as
mitigation measures in the cultural resource section of the FEIR, which have been carried over into the
MMRP and recommended conditions of approval for Environmental and Design Review Permit ED21-002.
PUBLIC OUTREACH AND CORRESPONDENCE
Property owners, residents, and businesses within 500 feet of the Tiscornia Marsh Restoration Project
site were provided notice of this public hearing, as well interested parties (see Attachment 5). In
REPORT TO PLANNING COMMISSION –
Case No: UP21-001, ED21-002 & IS21-001
Page 10
addition, a notice board was posted on the subject property informing the public about the scope of the
project and the date/time of the Planning Commission meeting.
Correspondence received as of the writing (or publication) of this staff report is Attachment 6
Correspondence received after Wednesday, January 5, 2022 to Tuesday, January 11, 2022 will be
forwarded to the Commission under separate cover and will be posted on the Tiscornia Marsh webpage.
OPTIONS
The Planning Commission has the following options:
1. Certify the FEIR and approve the project and planning applications as presented (staff
recommendation); or
2. Approve the project and planning applications with certain modifications, changes, or additional
conditions of approval; or
3. Continue the project to allow the applicant to address any of the Commission’s comments or
concerns; or
4. Deny the project and planning applications and direct staff to return with a revised resolution.
EXHIBITS
1. Resolution certifying the Tiscornia Marsh Restoration Project FEIR
2. Resolution adopting CEQA Findings of Face and approving a Mitigation Monitoring and Reporting
Program (MMRP) supporting action on the planning applications
Exhibit A: Mitigation Monitoring and Reporting Program
3. Resolution approving Use Permit UP21-001 and Environmental and Design Review Permit ED21-002
4. Preliminary Restoration Plans, prepared by ESA (available via link)
5. General Plan 2040 Consistency Table
6. Correspondence
FEIR, plans/documents and supportive studies can be accessed on the Tiscornia Marsh webpage.
EXHIBIT 1
1-1
RESOLUTION NO.
RESOLUTION OF THE SAN RAFAEL PLANNING COMMISSION CERTIFYING THE FINAL
ENVIRONMENTAL IMPACT REPORT (FEIR) (SCH #2021020362) PREPARED FOR THE
TISCORNIA MARSH RESTORATION PROJECT, EAST CANAL STREET
(CASE NOS. UP21-001, ED21-002, IS21-001)
WHEREAS, the Tiscornia Marsh covers 23 acres of tidal marsh and Baylands, as well as
over 2,000 lineal feet of shoreline levee that are bay ward of Albert J Boro Community Center and
Pickleweed Park. The Tiscornia Marsh is owned by Marin Audubon Society; and
WHEREAS, over the past decades, the Tiscornia Marsh property has experienced
considerable erosion along its bay ward edge, which is attributed to the wave action from the San
Francisco Bay. As a result, approximately three acres of valuable tidal marsh has been lost due
to erosion; and
WHEREAS, in June 2016, the Bay Area counties approved Measure AA, a parcel tax
measure which places a $12.00 per year tax on every parcel in the Bay Area. The purpose of the
Measure AA tax is to generate funds for marsh restoration projects around the San Francisco and
San Pablo Bays. The goal is to improve water quality, restore wildlife habitat, and to protect
communities from increased flooding and sea level rise; and
WHEREAS, in 2018, Marin Audubon Society applied for and successfully secured a
Measure AA grant to fund the design, permitting, and CEQA/environmental review for a
restoration of the Tiscornia Marsh. The Measure AA application was endorsed by the San Rafael
City Council on October 1, 2018 (adoption of City Council Resolution 14592). As part of the
Measure AA application process, the restoration project was expanded to incorporate/include the
City-owned, five-acre, diked marsh located north of the Pickleweed Park playfields; and
WHEREAS, on January 3, 2021, Marin Audubon Society applied for planning applications
(Use Permit, UP21-001 and Environmental and Design Review Permit ED21-002) to seek City
approval of the Tiscornia Marsh Restoration Project. Per the SRMC Title 14 (Zoning), these
applications are required as the project is located within the PD (Planning Development) and WO-
(Wetland Overlay) Districts; and
WHEREAS, the Tiscornia Marsh Restoration Project is defined as a “project” under the
California Environmental Quality Act (CEQA). Therefore, environmental review is required. The
City of San Rafael serves as the lead agency for CEQA/environmental review; and
WHEREAS, as the project is subject to environmental review, on January 28, 2021, in
accord with Public Resources Code Sections 5097.94, 21073, 21074, 21080.3.1, 21080.3.2
(SB52), the Community Development Department staff sent an offer for tribal consultation to the
representatives of the Federated Indians of the Graton Rancheria (Federated Indians). Tribal
consultation is required for all projects that require CEQA/environmental review. The purpose of
the tribal consultation is to consult with the local tribe representatives on potential impacts to
Native American places, features and objects described in the California Public Resources Code.
The prescribed 30-day period was observed for the Federated Indians to respond to the offer for
tribal consultation. On March 16, 2021, a tribal consultation meeting was held between the
Federated Indians and City of San Rafael staff; and
EXHIBIT 1
1-2
WHEREAS, on January 23, 2021, the City of San Rafael issued Notice of Preparation
(NOP) that announced the initiation of the Environmental Impact Report (EIR) preparation process
and to solicit comments regarding the scope of issues to be included and studied in the EIR. The
NOP provided a 30-day review period for public comment. On February 23, 2021, the Planning
Commission held an appropriately noticed public scoping hearing on the NOP. The Planning
Commission directed staff to prepare an EIR for the Project pursuant to the California
Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.) to address the
following issues, Aesthetics, Air Quality, Biological Resources, Cultural and Tribal Cultural
Resources, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials,
Hydrology and Water Quality, Land Use and Planning, Noise and Vibration, Public Services and
Recreation, Transportation, Utilities and Service Systems, Wildfire, and a reasonable range of
alternatives to the project. The topic areas of Agriculture and Forestry Resources, Energy, Mineral
Resources, and Population/Housing were dismissed from the scope of EIR study as the project
would result in no impacts to these topic areas; and
WHEREAS, per the CEQA Guidelines, the Draft EIR (DEIR) was prepared, released, and
circulated for a 30-day public review period (State Clearinghouse #2021020362). The DEIR
incorporates and is supported by technical studies and reports provided in Appendices of the
document; and
WHEREAS, on October 26, 2021, the Planning Commission held a duly noticed public
hearing to consider and accept comments on the DEIR. Based on written and oral comments
received from the public on the DEIR and its own review of the DEIR, the Planning Commission
directed staff to prepare a Final Environmental Impact Report (FEIR) and respond to comments
received on the DEIR; and
WHEREAS, pursuant to Public Resources Code Section 21091(d)(2)(A) and CEQA
Guidelines Sections 15088, 15089 and 15132, the City has responded to all the environmental
comments that were submitted on the DEIR during the public review period and a FEIR was
completed; and
WHEREAS, on December 28, 2021, Notice of Availability for the FEIR/Response to
Comments (FEIR), was mailed to responsible and trustee agencies, organizations, interested
persons and others including those persons and parties that provided written and oral comments
on the DEIR and was duly noticed in the Marin Independent Journal; and
WHEREAS, on January 11, 2022, the Planning Commission held a duly noticed public
hearing on the FEIR and considered it along with the land use and development applications filed
for this project (UP21-001 and ED21-002), accepting all public testimony and the written report of
the Community Development Department staff; and
WHEREAS, the custodian of documents which constitute the record of proceedings upon
which this decision is based, is the Community Development Department.
NOW, THEREFORE, BE IT RESOLVED, that the Planning Commission hereby certifies
the Tiscornia Marsh Restoration Project FEIR, based upon the following findings required by
CEQA Guidelines Section 15090:
1. The Final Environmental Impact Report (FEIR), which consists of the Draft Environmental
Impact Report (DEIR) dated September 2021, and the Response to Comments Document
dated December 28, 2021 has been prepared in accordance with CEQA, including Public
EXHIBIT 1
1-3
Resources Code Section 21083.3, and the provisions of the City of San Rafael Environmental
Assessment Procedures Manual.
2. The FEIR has been prepared and completed in compliance with the California Environmental
Quality Act (CEQA) Guidelines and the City of San Rafael Environmental Assessment
Procedures Manual by following the appropriate format, content, technical analysis of the
potential impact areas and project alternatives identified in the initially authorized scope of
work. Further, all prescribed public review periods and duly noticed hearings were held for the
project Notice of Preparation (NOP), Notice of Completion (NOC) for public review of the DEIR
and Notice of Availability following publication of the FEIR.
3. The Planning Commission has exercised its independent judgment in evaluating the FEIR
and has considered the comments received during the public review period on the DEIR.
4. The FEIR reflects the independent judgment and analysis of the City of San Rafael
Community Development Department and Planning Commission. The Planning Commission
has reviewed and considered all information contained in the FEIR prior to taking action on
the land use and development applications for the Tiscornia Marsh Restoration Project (UP
21-001 and ED21-002) finding that it:
a) Appropriately analyzes and presents conclusions on the impacts of the project;
b) Analyzes a reasonable range of alternatives to the project that could feasibly attain most
of the basic objectives of the project while avoiding or substantially lessening any
significant effect of the project;
c) Identifies or recommends mitigation measures to substantially lessen, eliminate or avoid
the otherwise significant adverse environmental impacts of the project, and
d) Includes findings and recommendations supported by technical studies prepared by
professionals experienced in the specific areas of study, and which are contained within
the document and/or made available within the project file maintained by the City of San
Rafael Community Development Department, the custodian of all project documents.
5. The information contained in the FEIR is current, correct, and complete for document
certification. As a result of comments submitted on the DEIR, the FEIR provides responses to
comments received on the DEIR and provides clarification and incorporates edits to the DEIR
text. No significant new information has been added to the DEIR that does not deprive the
public of meaningful opportunity to comment upon the significant adverse environmental effect
of the project or a feasible way to mitigate or avoid such an effect that the City has declined
to implement. Specifically, no new, significant information is presented in the FEIR that would
result in, disclose, or result in following:
a) A new, significant environmental impact resulting from the project or a new mitigation
measure needed to implement a new significant environmental impact;
b) A substantial increase in the severity of the impacts that were disclosed and analyzed in
the DEIR;
c) Any new feasible project alternatives or mitigation measures considerably different from
others previously analyzed that would clearly lessen significant environmental impacts of
the project, but which the City refuses to adopt; and
EXHIBIT 1
1-4
d) A finding that the DEIR is so fundamentally and basically inadequate and conclusory in
nature that meaningful public review and comment were precluded.
6. The FEIR presents factual, quantitative, and qualitative data and studies, which find and
support the conclusion that the project will result in several potentially significant impacts that
necessitate mitigation. At the time the Planning Commission considers action on the land use
and development applications for the Tiscornia Marsh Restoration Project, it will be necessary
to make complete and detailed findings pursuant to Public Resources Code Section 21081(a)
and CEQA Guidelines Section 15091(a). For each significant effect identified in the EIR, the
Planning Commission will be required to make one or more of the following findings:
a) That changes or alterations have been required in, or incorporated into, the project which
avoid or substantially lessen the significant environmental effect as identified in the final
EIR; that such changes or alterations are within the responsibility and jurisdiction of
another public agency and not the agency making the finding, and that such changes have
been adopted by such other agency or can and should be adopted by such other agency;
b) That specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible the
mitigation measures or project alternatives identified in the FEIR; and
c) As the project would result in several significant, unavoidable impacts, findings of
overriding consideration will be required. Such findings will require that the City weigh the
benefits of the project with the environmental impacts that cannot be mitigated.
7. The Planning Commission is taking an action to certify the FEIR for the project, recognizing it
as an informational document for assessment of the Tiscornia Marsh Restoration Project. The
CEQA Guidelines recognize that an environmental document is prepared for public disclosure
of potential project impacts and that it is used as an informational document to guide decision-
makers in considering project merits. Certification of the FEIR, as presented, would not result
in a land use entitlement or right of development for a specific project or site. When taking
action on land use and development applications for the Tiscornia Marsh Restoration Project,
the FEIR document must be reviewed to determine whether it adequately assesses the
impacts of the project.
The foregoing resolution was at the regular City of San Rafael Planning Commission meeting held
on the 11th day of January 2022.
Moved by Commissioner _____________ and seconded by Commissioner ______________.
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST: ______________________________ ______________________________
Leslie Mendez, Secretary Shingi Samudzi, Chair
EXHIBIT A
2-1
RESOLUTION NO.
RESOLUTION OF THE SAN RAFAEL PLANNING COMMISSION ADOPTING CEQA
FINDINGS OF FACT AND APPROVING A MITIGATION MONITORING & REPORTING
PROGRAM TO SUPPORT CONDITIONAL APPROVAL OF USE PERMIT (UP21-001) AND
AN ENVIRONMENTAL AND DESIGN REVIEW PERMIT (ED21-002) FOR THE
DEVELOPMENT OF THE TISCORNIA MARSH RESTORATION PROJECT,
EAST CANAL STREET
(CASE NOS. UP21-001, ED21-002)
WHEREAS, the Tiscornia Marsh covers 23 acres of tidal marsh and Baylands, as well as
over 2,000 lineal feet of shoreline levee that are bay ward of Albert J Boro Community Center and
Pickleweed Park. The Tiscornia Marsh is owned by Marin Audubon Society; and
WHEREAS, over the past decades, the Tiscornia Marsh property has experienced
considerable erosion along its bay ward edge, which is attributed to the wave action from the San
Francisco Bay. As a result, approximately three acres of valuable tidal marsh has been lost due
to erosion; and
WHEREAS, in June 2016, the Bay Area counties approved Measure AA, a parcel tax
measure which places a $12.00 per year tax on every parcel in the Bay Area. The purpose of the
Measure AA tax is to generate funds for marsh restoration projects around the San Francisco and
San Pablo Bays. The goal is to improve water quality, restore wildlife habitat, and to protect
communities from increased flooding and sea level rise; and
WHEREAS, in 2018, Marin Audubon Society applied for and successfully secured a
Measure AA grant to fund the design, permitting, and CEQA/environmental review for a
restoration of the Tiscornia Marsh. The Measure AA application was endorsed by the San Rafael
City Council on October 1, 2018 (adoption of City Council Resolution 14592). As part of the
Measure AA application process, the restoration project was expanded to incorporate/include the
City-owned, five-acre, diked marsh located north of the Pickleweed Park playfields; and
WHEREAS, on January 3, 2021, Marin Audubon Society applied for planning applications
(Use Permit, UP21-001 and Environmental and Design Review Permit ED21-002) to seek City
approval of the Tiscornia Marsh Restoration Project. Per the SRMC Title 14 (Zoning), these
applications are required as the project is located within the PD (Planning Development) and WO-
(Wetland Overlay) Districts; and
WHEREAS, pursuant to the provisions of the California Environmental Quality Act (CEQA)
Guidelines, the Tiscornia Marsh Restoration Project is subject to environmental review. It was
determined that the project has the potential to result in potentially significant environmental
effects, and the preparation of an Environmental Impact Report was recommended. Following the
provisions of the CEQA Guidelines, and Environmental Impact Report was prepared to assess
the impacts of the restoration project (Tiscornia Marsh Restoration Project Final Environmental
Impact Report [FEIR]). The Planning Commission has: a) reviewed the FEIR finding it to be
adequate and complete; and b) certified the FEIR by separate resolution; and
WHEREAS, prior to taking action to approve the planning applications for the project, the
CEQA Guidelines require that the findings and recommendations of the FEIR be considered, and
that all FEIR mitigation measures be incorporated into this action. To comply with this
requirement, by separate resolution, the Planning Commission has adopted CEQA Findings of
EXHIBIT A
2-2
Fact and adopting a Mitigation Monitoring and Reporting Program (MMRP) to support action on
the planning applications; and
WHEREAS, on January 11, 2022, the Planning Commission held a duly noticed public
hearing to review the draft CEQA Findings of Fact and the MMRP and considered all oral and
written public testimony and the written report of the Community Development Department.
NOW, THEREFORE, BE IT RESOLVED, the Planning Commission of the City of San
Rafael hereby: a) adopts the following CEQA Findings of Fact; b) approves the MMRP presented
in Exhibit A, finding that the MMRP has been prepared in accordance with the CEQA Guidelines:
FINDINGS OF FACT
I. California Environmental Quality Act (CEQA)
A. Final EIR
By separate Resolution, the Planning Commission reviewed and certified the
FEIR. As part of this action and as outlined in this separate resolution, the Planning
Commission reaffirms the findings made in the separate Planning Commission
Resolution that: a) supported the certification of the FEIR; b) found that the FEIR
has been prepared in accordance with the CEQA Guidelines and the City of San
Rafael Environmental Assessment Procedures Manual; and c) found and
concluded that the FEIR adequately assesses the environmental effects of the
Project and represents the independent judgment of the City.
B. Incorporated Documents/ Record of Proceedings
The following information is incorporated by reference and made part of the record
supporting these findings:
• All Project plans and application materials, including supportive technical reports
and drawings;
• The DEIR and Appendices (September 2021) and FEIR (December 28, 2021),
and all documents relied upon, cited therein or incorporated by reference;
• The Mitigation Monitoring and Reporting Program (MMRP) prepared for the
Project;
• The City of San Rafael General Plan 2020 and General Plan 2020 FEIR;
• Zoning Ordinance of the City of San Rafael (SRMC Title 14);
• Subdivision Ordinance of the City of San Rafael (SRMC Title 15);
• All records of decision, resolutions, staff reports, memoranda, maps, exhibits,
letters, synopses of meetings, summaries, and other documents approved,
reviewed, relied upon, or prepared by any City commissions, boards, officials,
consultants, or staff relating to the Project;
• Any documents expressly cited in these findings, in addition to those cited above;
and
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• Any other materials required for the record of proceedings by case law and/or
Public Resources Code section 21167.6, subdivision (e).
Pursuant to CEQA Guidelines Section 15091(e), the documents and other materials that
constitute the record of proceedings upon which the City has based its decision are
located in and may be obtained from the City’s Department of Community Development,
Planning Division, at 1400 Fifth Street, Third Floor, San Rafael, CA 94901.
II. Findings of Fact in Support of Project Action
The FEIR, prepared in compliance with CEQA, evaluates the potentially significant
environmental impacts that could result from approval of the Project. Because the FEIR
concludes that implementation of the Project would result in potentially significant
environmental impacts associated with the Project and specifies measures designed to
mitigate adverse environmental impacts to less than significant, the City is required by
CEQA to make certain findings with respect to these impacts (CEQA Guidelines
Section 15091). These findings list and describe the following, as analyzed in the EIR: a)
impacts determined to be not applicable or have no impact in the EIR; b) impacts found to
be less than significant in the EIR; c) significant impacts that can be avoided or reduced
with mitigation; and d) Project alternatives that were developed and studied as provided
in the CEQA Guidelines.
These findings are supported by substantial evidence in the entirety of the record of
proceedings before the City, which is incorporated herein by this reference. Further
explanation of these environmental findings and conclusions can be found, without
limitation, in the DEIR and FEIR, and these findings hereby incorporate by reference the
discussion and analysis in those documents supporting the FEIR determinations regarding
mitigation measures and the Project’s impacts and mitigation measures designed to
address those impacts. In making these findings, the Planning Commission ratifies,
adopts, and incorporates in these findings the determinations and conclusions of the DEIR
and FEIR relating to environmental impacts and mitigation measures, except to the extent
any such determinations and conclusions are specifically and expressly modified by these
findings.
A. IMPACTS DETERMINED TO NOT APPLICABLE OR NO IMPACT
During the Project’s scoping period and Initial Study development, the City determined
that some resource topics would not be affected by the Project resulting in a determination
of non-applicability or no impact, including Agriculture and Forestry Resources; Geology
& Soils (rupture of known earthquake fault, soils capable of supporting septic tanks,
paleontological resources); Hazards & Hazardous Materials (Cortese List hazardous
materials sites, airport land use plan); Land Use & Planning; Mineral Resources; Noise &
Vibration (airport land use plan); Population & Housing, Public Services (schools), Utilities
& Service Systems (wastewater treatment), and Wildfire (cumulative). For these topics, in
accordance with CEQA Guidelines Section 15128, no need for further environmental
assessment was required for the preparation of the FEIR.
Finding: The Project’s DEIR contains brief statements identifying possible impacts that
were determined to be insignificant, along with the reasons for those determinations. The
Planning Commission adopts those statements and concludes that the referenced
environmental effects are insignificant and no further analysis in the FEIR is required.
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B. IMPACTS DETERMINED TO BE LESS-THAN-SIGNIFICANT
The NOP and scoping period identified a number of potential environmental impacts to be
analyzed in the DEIR. Through that analysis, impacts relating to Aesthetics, Greenhouse
Gas Emissions, Hydrology and Water Quality, Energy, Geology and Soils, Hazards and
Hazardous Materials, Noise, Public Services, Recreation, Utilities and Service Systems,
and Wildfire were determined to be less-than-significant and, thus, no mitigation measures
are necessary or required, as noted below.
Finding: The Planning Commission adopts these statements and concludes that the
referenced environmental impacts would be less than significant for the reasons stated
below and contained within the entirety of the record of proceedings.
1) Aesthetics
a. The Project will not have a substantial adverse effect on a scenic vista.
Facts in Support of Finding: As discussed on pages 3.2-15 to 3.2-19 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the Project will not have a substantial adverse effect on a scenic
vista. Project construction will not have a substantial adverse effect on a scenic
vista because there is only a limited number of public vantage points with views
onto the Project site that present scenic or panoramic views, and a lack of
gathering places for contemplative views of the site. Upon Project completion, the
existing views of the site will remain largely unchanged, benefiting from the
expanded and restored tidal marsh systems and the Project will create new
opportunities for visitors to access scenic views within the Project site on more
accessible trails and improved vantage points from the soccer field. This impact
will therefore be less than significant.
b. The Project will not conflict with regulations governing scenic quality.
Facts in Support of Finding: As discussed on page 3.2-20 of the DEIR and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not conflict with regulations governing scenic quality due to
maintaining structural setbacks in proximity to San Rafael Creek and San Rafael
Bay, and developing the coarse beach and levees to heights much lower than the
“low-scale” building development allowed by the site’s Canalfront Review Overlay.
By protecting sensitive wildlife areas, enhancing habitat, adding seating and
signage to the new trails, encouraging natural vegetation, and improving public
access, the Project will advance the policies and programs set forth in the General
Plan 2040 and the recommendations in the Canalfront Conceptual Design Plan.
This impact will therefore be less than significant.
c. The Project will not create a new source of substantial light or glare that
would adversely affect day or nighttime views.
Facts in Support of Finding: As discussed on pages 3.2-21 of the DEIR and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not increase light and glare due to construction occurring during
daylight hours and no permanent lighting being associated with the Project. Project
construction will occur during the daylight hours and will not use portable lighting,
and Project operation does not call for the installation of any permanent lighting.
The Project will not create a new source of substantial light or glare that will
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adversely affect day or nighttime views in the area. This impact will therefore be
less than significant.
d. The Project will not result in cumulative aesthetic impacts.
Facts in Support of Finding: As discussed on pages 3.2-21 to 3.2-22 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the Project will not result in cumulative visual impacts. The timing of
the Project construction will not overlap with some cumulative projects. A
cumulative project would require closure of the soccer field, which would reduce
the already limited potential public vantage points of the Project site. An ongoing
creek dredging maintenance project would use equipment similar to the barge and
offloading equipment used by the Project. The Project, in combination with other
projects in the cumulative scenario, will not cause a significant, adverse cumulative
impact on aesthetic resources, and thus this impact will be less than significant.
2) Air Quality
a. The Project will be consistent with the Bay Area Clean Air Plan.
Facts in Support of Finding: As discussed on DEIR pages 3.3-18 to 3.3-19 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will be consistent with the 2017 Clean Air Plan. The 2017 Clean Air
Plan Transportation Control Measure TR22, Construction, Freight, and Farming
Equipment, is the only measure that addresses emissions from a construction
project. It provides incentives for the early deployment of electric, Tier 3, and Tier 4
off-road engines used in construction. The measure is designated for
implementation by the Bay Area Air Quality Management District to provide
incentives and would not be applicable to individual project applicants.
Consequently, the Project will be consistent with the 2017 Clean Air Plan. This
impact will be less than significant.
b. The Project will not result in emissions that lead to odors affecting a
substantial number of people.
Facts in Support of Finding: As discussed on DEIR pages 3.3-24 to 3.3-25 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not generate substantial odors because diesel combustion
emissions from Project construction will be temporary, intermittent, and spatially
dispersed. Associated odors will dissipate quickly. During excavation, organic
materials will be temporarily exposed to the air. Such exposure is not anticipated
to result in substantial emission of odors, because water levels will be drawn down
below the organic layer, allowing sediments to partially dry out, rather than
stagnating and generating odors. Also, Project construction activities will include
covering this layer early in the construction period, allowing associated odors to
dissipate quickly. Therefore, Project impacts related to odors will be less than
significant.
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3) Biological Resources
a. The Project will not have substantial adverse effects on jurisdictional
wetlands and waters.
Facts in Support of Finding: As discussed on DEIR pages 3.4-42 to 3.4-45 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not have substantial adverse effects on jurisdictional wetlands and
waters because construction impacts will be temporary and minor and permanent
impacts will be offset by a net gain in wetland and water function and values after
Project implementation. Temporary impacts on wetlands and waters as a result of
a temporary access road, crane platform, and barge offloading location will affect
less than 1 percent of wetland and waters habitat, and these areas can naturally
reestablish. Due to sea level rise, the Project site is expected to gain future benefits
to existing habitats due to increased ecological connectivity, improved tidal
hydrology, and marsh erosion protection over the next 50 years, which will enhance
wetlands, waters, and upland areas in and adjacent to the Project site. Although
there will be some conversion of wetland and water types and a nominal loss of
approximately 0.40 acre of wetlands and waters, the Project will increase the
ecological function and long-term benefits of 24 acres of wetlands and waters on
site including an increase in over 6 acres of tidal marsh. This impact will be less
than significant.
b. The Project will not have a substantial adverse effect on any riparian habitat
or other sensitive natural community.
Facts in Support of Finding: As discussed on DEIR pages 3.4-48 to 3.4-49 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not have substantial adverse effects on riparian habitat or other
sensitive natural community because there is no riparian habitat or eelgrass beds
in the Project area, and Pickleweed Mat Alliance habitat will increase under the
Project. This impact will be less than significant.
4) Cultural Resources
a. The Project will not cause a substantial adverse change in the significance
of a historical resource.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-6 to B-7 and supported
by evidence contained within the entirety of the record of proceedings, the Project
will not cause a substantial adverse change in the significance of a historical
resource because no historical resources are present within the Project site. This
impact will be less than significant.
5) Energy
a. The Project will not waste energy resources.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-10 to B-11 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not result in a potentially significant environmental impact due to
wasteful, inefficient, or unnecessary consumption of energy. Construction activities
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and corresponding fuel energy consumption will be temporary and localized, as
the use of diesel fuel and heavy-duty equipment will not be a long-term condition
of the Project. The total fuel use during construction will be equivalent to less than
3.4 percent of the total diesel fuel sold in Marin County in 2019, and approximately
0.0004 percent of the gasoline fuel sold in Marin County. In addition, there are no
unusual Project characteristics that will require the use of less energy efficient
construction equipment. This impact will be less than significant.
b. The Project will not conflict with a plan for renewable energy or energy
efficiency.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-11 and supported by
evidence contained within the entirety of the record of proceedings, the Project
will not conflict with or obstruct a state or local plan for renewable energy or energy
efficiency. With respect to transportation energy, the Project will comply with the
Low Carbon Fuel Standard, standards established by the U.S. Environmental
Protection Agency and California Air Resources Board, and the energy-related
measures of the City of San Rafael Final Draft Climate Change Action Plan 2030.
The Project will not involve waste disposal as no demolition is proposed.
Excavated materials will be reused on-site. The Project therefore will not conflict
or obstruct a state or local plan for renewable energy or energy efficiency. This
impact will be less than significant.
c. The Project, in combination with reasonably foreseeable future projects,
will not result in significant energy impacts.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-12 and supported by
evidence contained within the entirety of the record of proceedings, the adverse
Project-related impacts on electricity demand will be negligible, and will not
significantly impact peak or base power demands during construction, operation,
or maintenance. Accordingly, the Project’s less-than-significant incremental
contribution to cumulative peak and base demands will not be cumulatively
considerable. This impact will be less than significant.
6) Geology & Soils
a. The Project will not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving strong seismic
ground shaking.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-15 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
not directly or indirectly cause potential substantial adverse effects involving strong
seismic ground shaking. The restoration and enhancement of marsh habitats will
not require protection from seismic shaking because no structures will be
constructed, and the Project will not substantially increase visitation to the site due
to shoreline levee/trail improvements, as compared to existing conditions.
Therefore, impacts relative to seismic shaking during Project construction and
operation will be less than significant.
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b. The Project will not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving seismic-related
ground failure, including liquefaction.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-15 to B-16 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not directly or indirectly cause potential substantial adverse effects
involving seismic-related ground failure, including liquefaction. While seismic-
induced liquefaction may damage trails and restored habitat areas, the damage
will not result in risks to people, and the damaged trails and habitat could be easily
repaired. During the operational phase, the Project will not change the risk of
liquefaction or ground failure from existing conditions, which include the same
structure types. Therefore, impacts relative to seismic-induced ground failure such
as liquefaction will be less than significant.
c. The Project will not directly or indirectly cause potential substantial adverse
effects, including the risk of loss, injury, or death involving landslides.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-16 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
not directly or indirectly cause potential substantial adverse effects involving
landslides. The relatively flat topography of the area makes landslides unlikely in
the Project site; landslide risk maps show no risk areas in the Project site. The
Project’s wetland restoration activities will not create slopes susceptible to
landsliding. Therefore, impacts relative to seismically induced landslides will be
less than significant.
d. The Project will not result in substantial soil erosion or the loss of topsoil.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-16 to B-17 and
supported by evidence contained within the entirety of the record of proceedings,
the Project will not result in substantial erosion or the loss of topsoil. The Project
will comply with the requirements of the Construction General Permit requiring
preparation and implementation of a Stormwater Pollution Prevention Plan, which
requires applications of best management practices to control runon and runoff
from construction work sites. Once constructed, the restored wetland habitats will
be largely self-maintaining after the initial period of vegetation establishment. With
compliance with existing regulations and implementation of the adaptive
management activities, impacts associated with erosion will be less than
significant.
e. The Project will not be located on a geologic unit or soil that is unstable, or
that would become unstable as a result of the Project, and potentially result
in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or
collapse.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-17 and supported by
evidence contained within the entirety of the record of proceedings, neither
construction nor operation of the Project includes the extraction of groundwater or
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oil and will not otherwise create soil that is unstable. Therefore, impacts will be less
than significant.
f. The Project will be located on expansive soil, as defined in Table 18 1 B of
the Uniform Building Code (1994), but will not create substantial direct or
indirect risks to life or property.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-17 and supported by
evidence contained within the entirety of the record of proceedings, soils within the
Project site primarily include xerorthents, a soil with a low potential to expand. In
addition, the site is underlain by Bay Mud, which has expansive properties. The
presence of expansive soils will not prevent the restoration of tidal habitat. While
expansive soils may cause cracks in trails, the cracks will be a minor nuisance that
will be easily repaired with minor maintenance, assuming the cracks were large
enough to become an issue. In addition, soils used for levee improvements will be
imported from an upland source, which will further minimize the expansive
properties of the soils at the Project site. Therefore, impacts relative to expansive
soils will be less than significant.
g. The Project, in combination with reasonably foreseeable future projects,
will not result in significant cumulative impacts related to geology and soils.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-18 and supported by
evidence contained within the entirety of the record of proceedings, there are no
rare or special geological features or soil types on the Project site that will be
affected by Project activities and no other known activities or projects with activities
that affect the geology and soils of this site. In addition, the Project, as with all
foreseeable projects, will be required to comply with the applicable state and local
requirements, such as the Construction General Permit. Therefore, the Project’s
contribution to cumulative geotechnical and soil impacts is less than significant.
7) Greenhouse Gas Emissions
a. The Project will not generate greenhouse gas emissions that would exceed
the Bay Area Air Quality Management District’s threshold of significance for
greenhouse gas emissions.
Facts in Support of Finding: As discussed on pages 3.5-11 to 3.5-12 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the Project’s construction over the three-year construction period will
generate a total of 1,307 metric tons of carbon dioxide equivalent emissions. The
Project’s total amortized construction and operational greenhouse gas emissions
(including if truck transport is required to accommodate additional export and
import of foundational soil), based on a 30-year Project life span, will be below the
Bay Area Air Quality Management District’s operational threshold of significance
for nonstationary sources, as adjusted to reflect year 2030 emission reduction
targets. Therefore, this impact will be less than significant.
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b. The Project will not conflict with applicable plans, policies, and regulations
adopted for the purposes of reducing greenhouse gas emissions.
Facts in Support of Finding: As discussed on pages 3.5-13 of the DEIR and
supported by evidence contained within the entirety of the record of proceedings,
the Project will be consistent with the City of San Rafael’s Final Draft Climate
Change Action Plan 2030. The Project will comply with construction and demolition
debris plan requirements because the Project will not involve waste disposal, as
no demolition is proposed, and excavated materials will be reused on-site. The
Project will support the Climate Change Action Plan 2030’s requirements to
prepare for and adapt to rising sea level. One of the primary goals of the Project is
to create sustainable benefits that consider future environmental changes such as
sea-level rise and sedimentation. The Project will be in conformance with the Bay
Area Air Quality Management District’s greenhouse gas emissions thresholds, and
Project construction will generally be consistent with applicable provisions of the
2017 Scoping Plan Update. Therefore, the Project will comply with the City’s
applicable plans, policies, and regulations for reducing greenhouse gas emissions,
and this impact will be less than significant.
c. Cumulative Greenhouse Gas Impacts
Facts in Support of Finding: As discussed on pages 3.5-13 to 3.5-14 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the greenhouse gas emissions from an individual project, even a very
large development project, would not individually generate sufficient greenhouse
gas emissions to measurably influence global climate change, and thus, the
assessment of greenhouse gas emissions impacts is inherently cumulative. The
evaluation of cumulative greenhouse gas impacts evaluates whether the Project
will make a considerable contribution to cumulative climate change effects. As
such, the analysis in Findings discussion 7a above (The Project will not generate
greenhouse gas emissions that would exceed the Bay Area Air Quality
Management District’s threshold of significance for greenhouse gas emissions)
considers the potential greenhouse gas cumulative impacts of the Project.
Implementation of the Project will not result in a cumulatively considerable
contribution to annual greenhouse gas emissions. As such, implementation of the
Project will not result in a cumulatively considerable impact.
8) Hazards & Hazardous Materials
a. The Project will not create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous
materials or through reasonably foreseeable upset and accident conditions
involving the release of hazardous materials into the environment.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-22 to B-23 and
supported by evidence contained within the entirety of the record of proceedings,
hazardous materials (e.g., fuels, oils, and lubricants) will be routinely transported,
stored, and used at the Project site during construction. Because the Project will
result in soil disturbance greater than 1 acre, management of soil and hazardous
materials during construction will be subject to the requirements of the
Construction General Permit, which requires preparation and implementation of a
Stormwater Pollution Prevention Plan that lists hazardous materials; describes
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spill prevention measures, equipment inspections, equipment, and fuel storage;
identifies protocols for responding immediately to spills; and describes best
management practices for controlling site runoff. The transportation of hazardous
materials will be regulated by the United States Department of Transportation,
California Department of Transportation, and the California Highway Patrol. In the
event of a hazardous materials spill, a coordinated response will occur at the
federal, state, and local levels, including the involvement of the Marin County
Hazardous Materials Response Team. After construction, maintenance for the
tidal marsh, ecotone slope, and coarse beach during the 3- to 5-year establishment
period will include the removal of invasive plants using localized herbicides or
mechanical means, and temporary irrigation of ecotone slope plantings. The
California Department of Pesticide Regulation, California Code of Regulations
(Title 3. Food and Agriculture) Division 6, Pesticides and Pest Control Operations
(Sections 6000 – 6960) will regulate the use of herbicides at the site. Compliance
with the laws and regulations that govern the transportation, use, handling, and
disposal of hazardous materials will limit the potential for hazardous conditions due
to the use or accidental release of hazardous materials, and, therefore, the impact
will be less than significant.
b. The Project will not emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile
of an existing or proposed school.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-23 to B-24 and
supported by evidence contained within the entirety of the record of proceedings,
construction equipment and vehicles will use low toxicity materials including
gasoline, diesel fuel, oil, and lubricants, which are all commonly used in
construction. After construction, maintenance for the tidal marsh, ecotone slope,
and coarse beach during the 3- to 5-year establishment period will include the
removal of invasive plants using localized herbicides or mechanical means, and
temporary irrigation of ecotone slope plantings. While two schools are located
within 0.25 mile of the Project, the low toxicity of the materials associated with
construction and maintenance, and required compliance with the laws and
regulations that govern the transportation, use, handling, and disposal of
hazardous materials will reduce impacts on area schools to a less-than-significant
level.
c. The Project will not impair implementation of or physically interfere with an
adopted emergency response plan or emergency evacuation plan.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-24 to B-25 and
supported by evidence contained within the entirety of the record of proceedings,
there is no emergency response plan or evacuation plan actions specific to the
Project site or immediate vicinity; the nearest designated evacuation route is Point
San Pedro Road (on the north side of San Rafael Creek from the Project site),
which serves as a primary wildfire evacuation route. Construction activities will
occur within the habitat area to be restored and not on public roads. Spinnaker
Point Drive, Canal Street, and other nearby City streets may be used for access
but will not require closure or restriction of any lanes. Materials and equipment will
be transported to and from the site via barge. In addition, in-water work will occur
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in an area with existing boating and personal boat docks. As such, water traffic will
occur near the Project site. Boat traffic may be temporarily reduced during
construction for safety reasons, but boaters will be able to pass around the Project
site. After construction, access for Project maintenance and inspections will occur
via Spinnaker Point Drive and Canal Street, but will not require the closure or
restriction of any lanes. As a result, the Project will not impair implementation of
an adopted emergency response plan or emergency evacuation plan. Thus, the
impact will be less than significant.
d. The Project will not expose people or structures, either directly or indirectly,
to a significant risk of loss, injury or death involving wildland fires.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-25 and supported by
evidence contained within the entirety of the record of proceedings, the Project site
is within a Local Responsibility Area and is designated by CAL FIRE as Non-Very
High Fire Hazard Severity Zone. The use of mechanized equipment during
Project construction or operation/maintenance could cause a wildfire if
spark-arresting equipment is not installed on hot surfaces such as mufflers.
However, the California Vehicle Code, Section 38366, requires spark-
arresting equipment on vehicles that travel off-road. This code applies to
the Project, and vehicles that work in off-road areas will be required to have
spark-arresting equipment to reduce the risk of wildfires. Therefore, the
Project will have a less-than-significant impact related to wildland fire hazards.
e. The Project, in combination with reasonably foreseeable future projects,
will not result in significant cumulative impacts related to hazards and
hazardous materials.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-25 to B-26 and
supported by evidence contained within the entirety of the record of proceedings,
the contribution of hazardous materials use and hazardous waste disposal
associated with the Project is minimal, and combined hazardous materials effects
from past, present, and reasonably foreseeable projects within the City and
immediate area will not be significant. Project construction and operation will
involve the use of potentially hazardous materials (e.g., localized herbicides,
solvents, and diesel and petroleum fuels), that when used correctly and in
compliance with existing laws and regulations, will not result in a significant hazard
to visitors or workers in the vicinity of the Project site. Impacts associated with the
potential to encounter unknown hazardous debris and waste that may exist on site
during construction will be reduced to a less-than-significant level through
environmental review pursuant to CEQA. Furthermore, the Project and all other
projects in the cumulative area are required to comply with the existing regulations
related to hazards and hazardous materials. Consistency with federal, state, and
local regulations will prevent the Project, as well as other projects, from creating
cumulative impacts in terms of hazards and hazardous materials. For the reasons
outlined above, implementation of the Project will not result in an incremental
contribution to cumulative impacts related to hazards and hazardous materials that
are cumulatively considerable; therefore, cumulative hazards and hazardous
materials impacts are considered less than significant.
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9) Hydrology and Water Quality
a. The Project will not violate water quality standards or waste discharge
requirements or otherwise substantially degrade water quality.
Facts in Support of Finding: As discussed on pages 3.6-16 to 3.6-17 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, construction activities have the potential to adversely affect water
quality through the release of pollutants associated with construction equipment
(e.g., fuel, motor oil) or sediments released due to excavation and fill placement.
The Project will comply with the requirements of the Construction General Permit
and local stormwater ordinances, including implementation of a Stormwater
Pollution Prevention Plan requiring the use of best management practices to
control runon and runoff from construction. With compliance with existing
regulations, impacts associated with water quality during construction will be less
than significant. Once constructed, the restored wetland habitat will be largely self-
maintaining after the vegetation has been re-established. To ensure the Project
performs as anticipated, the Project will include performance monitoring and
adaptive management activities. With compliance with existing regulations and
implementation of performance monitoring and adaptive management activities,
construction and operation impacts associated with water quality will be less than
significant.
b. The Project will not substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or
river or through the addition of impervious surfaces, in a manner that will
result in substantial erosion or siltation on or off site; substantially increase
the rate or amount of surface runoff in a manner that will result in flooding
on or off site; create or contribute runoff water that would exceed the
capacity of existing or planned stormwater drainage systems or provide
substantial additional sources of polluted runoff; or impede or redirect
flood flows.
Facts in Support of Finding: As discussed on pages 3.6-18 to 3.6-19 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, construction of the Project will include earthmoving activities such as
excavation, trenching, grading, and importation of fill. Compliance with the
Construction General Permit, the Stormwater Pollution Prevention Plan, and City
of San Rafael Best Management Practices for construction activities will control
the volume and velocity of runoff, if any. The Project will include the installation of
a sediment curtain outboard of the in-water construction areas to prevent
sediment from being discharged to the Bay. In addition, construction will be
phased so that the coarse beach is installed first to contain the dredged material
and provide sediment control during placement to prevent erosion, siltation,
flooding, and pollution. Upon completion, the goal of the Project is to enhance the
ecological function of the Tiscornia Marsh and increase flood protection for the
Canal neighborhood. The Project will include performance monitoring at 1-, 3-, 5-
, and 10-years post-construction for permit compliance and to meet performance
objectives. Compliance with the Construction General Permit, existing regulations,
and implementation of the performance monitoring activities will reduce
construction and operation impacts relative to altering the existing drainage pattern
to a less-than-significant level.
EXHIBIT A
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c. The Project will not risk the release of pollutants in flood hazard, tsunami,
or seiche zones.
Facts in Support of Finding: As discussed on pages 3.6-19 to 3.6-20 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the Project site is located entirely within the 100-year flood zone,
partially within the tsunami hazard zone, and partially within a seiche zone due to
its proximity to San Rafael Creek. Required preparation and implementation of the
Stormwater Pollution Prevention Plan will include best management practices to
contain chemicals (e.g., fuel, motor oil) from being released during construction,
including straw wattles, silt fences, and sediment curtains. These measures will be
in place during the unlikely event of a flood, tsunami, or seiche. Upon completion,
the goal of the Project is to enhance the ecological function of the Tiscornia Marsh
and increase flood protection for the Canal neighborhood. The levees will be
restored to heights above the base flood elevation, reducing the potential for
flooding. The restored wetland habitat, jetty, and coarse beach constructed
outboard of the levees will provide additional protection from flooding, tsunamis,
and seiches by absorbing much of the energy of such events. The Project will
include performance monitoring at 1-, 3-, 5-, and 10-years post-construction for
permit compliance and to meet performance objectives. With compliance with
existing regulations and implementation of best management practices and
performance monitoring activities, construction and operation impacts associated
with flooding, tsunamis, and seiches will be less than significant.
d. The Project will not conflict with or obstruct the implementation of a water
quality control plan or sustainable groundwater management plan.
Facts in Support of Finding: As discussed on pages 3.6-20 to 3.6-21 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the Project is not located within a medium or high priority
groundwater basin and is therefore not subject to a sustainable groundwater
management plan. Required preparation and implementation of the Stormwater
Pollution Prevention Plan will include best management practices to contain
chemicals (e.g., fuel, motor oil, sediment) from being released during construction,
including straw wattles, silt fences, and sediment curtains. These measures will
reduce the potential for construction activities to adversely affect water quality,
which will make the Project consistent with the Basin Plan. Once constructed, the
restored wetland habitat will be largely self-maintaining after the vegetation has
been re-established. Project operations will include the removal of invasive plants
using localized herbicides or mechanical means, and the temporary irrigation of
ecotone slope plantings. In addition, the flood protection levees and trails will
require periodic inspection to identify maintenance and adaptive management
needs. The Project will include physical and biological monitoring at 1-, 3-, 5-, and
10-years post-construction to meet performance objectives, which will include
preventing sediments from being released into the Bay. With compliance with
existing regulations, implementation of BMPs, and physical and biological
monitoring, impacts relative to the Basin Plan during construction and operation
will be less than significant.
EXHIBIT A
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e. The Project, combined with cumulative development in the Project vicinity,
will not result in significant cumulative impacts relative to hydrology or
water quality.
Facts in Support of Finding: As discussed on pages 3.6-21 to 3.6-23 of the DEIR
and supported by evidence contained within the entirety of the record of
proceedings, the state Construction General Permit will require each project that
disturbs 1 or more acres to prepare and implement a Stormwater Pollution
Prevention Plan during construction. The Stormwater Pollution Prevention Plans
will describe best management practices to control runoff and prevent erosion and
flooding for each project. Through compliance with this requirement, construction-
related runoff and erosion impacts on water quality will be controlled and will not
be cumulatively considerable. Once constructed, the restored wetland habitat for
the Project will be largely self-maintaining after the vegetation has been re-
established. Performance monitoring will ensure that the levees are maintained to
prevent erosion and adverse water quality impacts. The Project and all cumulative
projects with stormwater runoff that drain into the City’s stormwater system are
required to comply with the State Water Resources Control Board Stormwater
National Pollutant Discharge Elimination System Permit for small municipal
separate storm sewer systems (also known as MS4s), including Provision E.12,
Post-Construction Stormwater Management Program. This provision mandates
municipalities to require specified features and facilities to control pollutant
sources; control runoff volumes, rates, and durations; and to treat runoff before
discharge from the site. With compliance with MS4 requirements, the operation of
the Project and cumulative projects will not have a cumulatively considerable
contribution to the cumulative impact on water quality. No significant cumulative
impacts are identified.
10) Noise & Vibration
a. The Project will not result in the generation of a substantial temporary or
permanent increase in ambient noise levels in the vicinity of the Project in
excess of established standards.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-35 to B-37 and
supported by evidence contained within the entirety of the record of proceedings,
construction activities of all phases of the Project will generate noise levels at the
nearest sensitive receptors below the 90 dBA criterion of Section 8.13.050(A) of
the San Rafael Municipal Code. Once all construction activities are completed, the
Project will not create any new permanent noise sources (e.g., pumps,
generators). Periodic maintenance of the levee and restoration areas will be similar
to existing conditions. Operation and maintenance of the Project will not generate
a substantial increase in noise levels in excess of standards established in the
local general plan or noise ordinance. The temporary increase in ambient noise
levels during Project construction and operation will result in a less-than-significant
impact.
b. The Project will not result in the generation of excessive ground-borne
vibration or ground-borne noise levels.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-37 to B-38 and
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supported by evidence contained within the entirety of the record of proceedings,
the construction of the Project will include compaction and pile driving, which can
generate significant levels of vibration. For adverse human reaction, the analysis
applies the “strongly perceptible” threshold of 0.9 inch/second peak particle
velocity for transient sources, and a threshold of 0.3 inch/second peak particle
velocity to assess damage risk for buildings. There are no historic structures in the
vicinity of the Project site that could be adversely affected by Project construction-
related vibration. There are single-family residences located 470 feet north of the
proposed temporary crane platform where driving of piles will occur. These single-
family residences will be exposed to a vibration level of less than 0.026
inch/second peak particle velocity, well below the applied human annoyance and
building damage threshold. Compaction activities for the new levee will occur as
close as 150 feet east of existing residences at the terminus of Sorrento Way.
These single-family residences will be exposed to a vibration level of less than
0.029 inch/second peak particle velocity, also well below the applied human
annoyance and building damage threshold. Consequently, existing sensitive
receptors and structures near the Project site will not be affected by substantial
ground-borne vibration during Project construction. This impact will therefore be
less than significant.
c. The Project, in combination with reasonably foreseeable future projects,
will not result in significant noise or vibration impacts.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-38 to B-39 and
supported by evidence contained within the entirety of the record of proceedings,
the construction activities of the Project will generate noise levels of up to 74.4 dBA
at the nearest receptors, which is below the 90 dBA criterion of Section 8.13.050(A)
of the San Rafael Municipal Code. It is unlikely that either of the two relevant
cumulative projects, individually, will result in an equivalent intensity of construction
activity as that of the Project. However, if it were conservatively assumed that each
of these two projects will generate the same noise levels as those of the Project,
the resultant noise level will be up to 79.2 dBA, which will still be below the 90 dBA
criterion of Section 8.13.050(A) of the San Rafael Municipal Code. Consequently,
the cumulative noise impact will be less than significant. Neither of the two relevant
cumulative projects will be expected to involve the use of vibration-generating
construction equipment. Therefore, because the Project will have a less-than-
significant construction impact with respect to vibration, as discussed above, the
cumulative vibration impact will also be less than significant.
11) Public Services
a. The Project will not result in substantial adverse physical impacts
associated with the provision of government facilities, the construction of
which could cause significant environmental impacts, in order to maintain
acceptable performance objectives for fire protection.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-44 and supported by
evidence contained within the entirety of the record of proceedings, Project
construction will not significantly increase the demand for fire protection services
throughout the Project vicinity due to population growth and will not change any
uses on the site. For these reasons, the Project will not be expected to substantially
EXHIBIT A
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affect the San Rafael Fire Department’s ability to maintain service ratios, response
times, or other performance objectives or require new or physically altered
facilities. For this reason, and because Project operations will be consistent with
existing conditions, the Project’s impact with respect to fire services will be less
than significant.
b. The Project will not result in substantial adverse physical impacts
associated with the provision of government facilities, the construction of
which could cause significant environmental impacts, in order to maintain
acceptable performance objectives for police protection.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-44 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
not be expected to substantially affect the City of San Rafael Police Department’s
ability to maintain service ratios, response times, or other performance objectives
or require new or physically altered facilities. The Project’s impact with respect to
the provision of police protection during construction and operations will be less
than significant.
c. The Project will not result in substantial adverse physical impacts
associated with the provision of government facilities, the construction of
which could cause significant environmental impacts, in order to maintain
acceptable performance objectives for parks.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-45 and supported by
evidence contained within the entirety of the record of proceedings, the Project site
includes unpaved segments of the Bay Trail at the existing levee crest. The Project
will improve and pave these trail segments and will add educational signage. The
Project will not result in increased population such that there will be additional
demand for park facilities during or after construction, and the completed Project
will expand accessibility to the trail segments within the Project site. The Project’s
impacts related to new or expanded park facilities to maintain acceptable service
ratios will be less than significant.
d. The Project will not result in substantial adverse physical impacts
associated with the provision of government facilities, the construction of
which could cause significant environmental impacts, in order to maintain
acceptable performance objectives for other public facilities.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-45 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
not involve the employment of new permanent employees or residents, and Project
operations will be consistent with existing conditions; therefore, it is not expected
to increase the use of other public facilities (such as libraries or hospitals), and the
impact with respect to other public facilities will be less than significant.
e. The Project, in combination with reasonably foreseeable future projects,
will not result in significant cumulative impacts on public services.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-45 and supported by
EXHIBIT A
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evidence contained within the entirety of the record of proceedings, the geographic
scope of potential cumulative public services impacts encompasses the Project
site and its vicinity. Cumulative scenario projects include the Pickleweed Field and
Park Project and the Schoen Park Conversion to Parking. However, the Project
and cumulative projects will replace existing land uses, or result in a new land use
that is compatible with existing land uses, and will not result in an increase in
population or visitation that will require the construction of new public service
facilities. Therefore, a cumulative public services impact will not occur, and the
Project’s contribution to cumulative public services impacts will not be cumulatively
considerable.
12) Recreation
a. The Project will not increase the use of existing recreational facilities such
that substantial physical deterioration would occur. The Project includes
recreational facilities or requires the construction or expansion of
recreational facilities which might have an adverse physical effect on the
environment.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-46 to B-47 and
supported by evidence contained within the entirety of the record of proceedings,
the Project includes the construction and operation of a recreational resource, the
implementation of which could cause adverse physical effects on the environment.
The impacts that could result from Project construction and operation are
addressed in the corresponding topical sections of the EIR. However, construction
and operation of the Project is not expected to have substantial adverse effects
related to increased use of nearby parks or facilities such that deterioration or
degradation will occur. The Project will include changes to the existing shoreline
levee that traverses the Project site, which is currently used as a recreational trail.
During Project construction, the levee trail will be closed to access; however, use
of the soccer field and Pickleweed Park play areas and community facility will not
be affected. Trail users will be able to continue along the Bay Trail by utilizing the
pedestrian sidewalk along Spinnaker Point Drive during construction. It is not
anticipated that existing recreation users will use other recreation resources at a
level that will result in the deterioration of other nearby recreation facilities. Under
Project operation, the levee trails will be improved and new signage and seating
will be added. Implementation of the Project will not result in the increased use of
other recreational facilities that will result in substantial physical deterioration of the
facilities. This impact will therefore be less than significant.
b. The Project, in combination with reasonably foreseeable future projects,
will not result in significant cumulative impacts on recreation resources.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-47 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
result in the temporary closure of access to the levee trail during construction. It is
anticipated that local users will detour to the pedestrian sidewalk along Spinnaker
Point Drive to continue on the Bay Trail. Cumulative scenario projects that could
result in a restriction of access to recreational opportunities include the Pickleweed
Field and Park Project and the Schoen Park Conversion to Parking. The potential
for active construction on elements of these projects that will affect access to
EXHIBIT A
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recreational facilities during the same period as the Project is expected to be
limited. Even if closures to recreational facilities were to co-occur with the Project,
several other parks and recreational facilities in the vicinity will remain open and
unaffected by construction of the Project or of the cumulative scenario projects.
Therefore, the Project’s contribution to a cumulative loss of recreational
opportunities, or to cumulative increases in the use of parks or recreational
facilities, will not be cumulatively considerable and will be less than significant.
13) Transportation
a. The Project will not conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit, roadway, bicycle, and
pedestrian facilities.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-49 to B-52 and
supported by evidence contained within the entirety of the record of proceedings,
direct traffic impacts from construction of the Project will be short term and
temporary. The maximum number of truck trips generated by construction activity
at the Project site will be 16 daily round trips, or 32 one-way trips (16 inbound, 16
outbound), and the truck trips will be spread over the course of an 8-hour workday.
The maximum number of construction workers on site at any given time will be 19,
which will generate 38 daily one-way trips, conservatively assuming that all
workers will drive alone and not carpool. Construction-generated traffic will be
temporary and, therefore, will not result in any long-term degradation in operating
conditions on any locally used roadways for the Project. Drivers could experience
delays if they were traveling behind a heavy truck; however, as noted above, only
32 trucks per day (16 inbound, 16 outbound) are expected to travel to/from the
Project site during the peak of construction activities, and those truck trips will
occur over the course of the 8-hour workday. Construction-related traffic from the
Project will not be substantial in relation to traffic flow conditions on U.S. 101, I-580,
or local access roadways. Project trips will fall within the daily fluctuations of traffic
volumes on U.S. 101 and I-580 (not perceptible to the average motorist), and so
while the traffic generated by construction activities will be noticeable (i.e., would
represent a higher percent increase in traffic volumes) on the local-serving
roadways serving the construction site, the effect on traffic flow will be less than
significant.
In terms of pedestrian, bicycle, and transit facilities, construction of the Project will
neither directly nor indirectly eliminate existing or planned alternative
transportation corridors or facilities (i.e., bike paths, lanes, etc.), including changes
in policies or programs that support alternative transportation, nor construct
facilities in locations where future alternative transportation facilities may be
planned. As such, the Project will not conflict with adopted policies, plans, and
programs supporting alternative transportation. Construction activities associated
with the Project will not generate traffic volume increases that will significantly
affect traffic flow on area roadways. The performance of public transit, in-street
bicycle, and pedestrian facilities in the area likewise will not be adversely affected.
Operational vehicle trips will be for monitoring and maintenance, and potentially
for adaptive management. The number of workers and equipment required to
perform operations and maintenance activities will be lower than for Project
construction, and will generate no more than 20 one-way daily vehicle trips.
EXHIBIT A
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Therefore, construction and operation of the Project will not conflict with any
adopted policies, plans, or programs related to public transit or bicycle and
pedestrian facilities, nor will it affect the safety of such services/facilities, and
impacts will be less than significant.
b. The Project will not conflict or be inconsistent with CEQA Guidelines
Section 15064.3, Subdivision (b).
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-53 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
meet the Small Developments criterion of the City of San Rafael vehicle miles
traveled screening criteria and thresholds, which states that projects that generate
fewer than 110 trips per day will result in a less-than-significant vehicle miles
traveled impact. The Project will generate a maximum of 70 daily vehicle trips (32
one-way truck trips and 38 one-way construction worker trips) during Project
construction, and no more than 20 daily vehicle trips during Project
operation/maintenance. Since the Project meets the Small Developments criterion,
the Project will result in a less-than-significant impact related to CEQA Guidelines
Section 15064.3.
c. The Project will not result in inadequate emergency access.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-54 and supported by
evidence contained within the entirety of the record of proceedings, the Project is
located in an area with multiple access roads allowing adequate egress/ingress to
the Project site in the event of an emergency. During construction, heavy
construction-related vehicles could interfere with emergency response to the site
or emergency evacuation procedures in the event of an emergency (e.g., slowing
vehicles traveling behind the truck). However, construction-related traffic from the
Project will not be substantial in relation to traffic flow conditions on U.S. 101, I-580,
or local access roadways. After construction, the Project will include internal
access roadway improvements and will allow for adequate emergency access.
Operational traffic will not cause a significant increase in congestion and will not
significantly affect roadway operations. Furthermore, the Project will not require
the closures of public roads, which could inhibit access by emergency vehicles.
This impact will therefore be less than significant.
14) Utilities & Service Systems
a. The Project will not require the relocation or construction of new or
expanded water, wastewater treatment, stormwater drainage, electric
power, natural gas, or telecommunications facilities, the construction or
relocation of which could cause significant environmental effects.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-61 to B-62 and
supported by evidence contained within the entirety of the record of proceedings,
the Project site supports two PG&E towers, a stormwater drain, and a sanitary
sewer. The Project does not include any modifications to the PG&E towers or
sanitary sewer line. Construction will have the potential to damage power lines and
expose construction workers to hazardous conditions, particularly through the use
EXHIBIT A
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of vertical construction equipment such as cranes. To avoid this potential damage,
construction workers will follow the Power Line Safety standards from the
Department of Industrial Relations. With respect to the stormwater drain, there are
two options for tying the west end of the new levee into the shoreline that may
involve some modification of the stormwater drain. Neither option will require a
change in capacity or service of the stormwater line, nor will result in its relocation
or construction of new or expanded facilities. No other utilities or
telecommunication facilities will be affected in the course of the construction or
operation of the Project. This impact will therefore be less than significant.
b. The Project will have sufficient water supplies available to serve the Project
and reasonably foreseeable future development during normal, dry, and
multiple dry years.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-62 and supported by
evidence contained within the entirety of the record of proceedings, Project
construction will require the intermittent use of potable water for drinking and
sanitary needs at the site over an approximately 6-month construction window for
3 to 4 years. Project construction will also require water for dust control, which the
construction contractor will obtain from available water sources near the Project
site and/or will store on the Project site. Irrigation water will be required for new
plantings in upland and transition zones for the first 3 years, or until plants have
matured. Irrigation water will be purchased by the landscaping contractor or
through temporary connections to the adjacent Pickleweed Park landscape
irrigation system. Post-construction operations will not require water use beyond
the temporary irrigation of plantings via drip irrigation. Given that the Project has
relatively minimal demands for water supply during construction and no long-term
water use requirements, there will be a less-than-significant impact on water
supplies available to serve the Project.
c. The Project will be served by a landfill with sufficient permitted capacity to
accommodate the Project’s solid waste disposal needs and will not impair
the attainment of solid waste reduction goals.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-63 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
generate approximately 9,500 cubic yards of excavated material from earthwork.
The intent is to store excavated material on site for reuse in the marsh
reconstruction phase, but any contaminated soils will be off-hauled and disposed
of at an approved hazardous waste landfill in the area. However, even if all
excavated material were removed from the site, the amount of off-hauled materials
will be negligible and will not contribute substantially to landfill capacity reduction.
Recreational uses during Project operation may generate solid waste, but the
intensity of recreational usage is expected to be consistent with existing conditions
and will not be substantial compared to City-wide solid waste generation. Local
landfill usage for the City of San Rafael is limited to the Potrero Hills Landfill and
Redwoods Landfill. The Redwoods Landfill is planned for closure in 2024, but the
Potrero Hills Landfill has operational capacity through 2048, and the City also
works with landfills across the state as needed. The Project will also comply with
Zero Waste Marin’s waste reduction goals, which support the solid waste reduction
EXHIBIT A
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mandates of the state. As a result, the Project will have a less-than-significant
impact on the sufficiency of landfill capacity and solid waste reduction goals.
d. The Project will comply with federal, state, and local management and
reduction statues and regulations related to solid waste.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-63 and supported by
evidence contained within the entirety of the record of proceedings, excavated soil
will be used on site to the extent practicable during construction. However, in the
event that some soil is contaminated or can otherwise not be used for the Project,
the contaminated soil will be disposed of at the nearest landfill capable of accepting
the excavated materials. The potential disposal need will be negligible and will not
contribute substantially to landfill capacity reduction. Project operation will
generate solid waste from recreating visitors and will be similar to current
conditions. The Project will also comply with applicable local, state, and federal
regulations concerning solid waste management, including the solid waste
diversion initiatives administered by Zero Waste Marin. Impacts will be less than
significant.
e. The Project, in combination with reasonably foreseeable future projects,
will not result in significant cumulative impacts related to disruption of
utility service or relocation of utilities.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-64 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
not require additional facilities to serve the Project and reasonably foreseeable
future development during normal, dry, and multiple dry years. It will not combine
with impacts from other cumulative scenario impacts and, therefore, will not result
in a cumulatively considerable impact related to water supply and utilities. With
respect to solid waste, the Project could require disposal of excavated materials.
However, none of the other cumulative projects identified in the EIR are anticipated
to require disposal of large volumes of waste in landfills. Therefore, the waste
disposal impacts of the Project will not combine with waste disposal impacts from
other cumulative scenario projects, and will not result in a cumulatively
considerable impact on solid waste. This impact will therefore be less than
significant.
15) Wildfire
a. The Project will not substantially impair an adopted emergency response
plan or emergency evacuation plan.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-65 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
result in an increase of construction-related traffic. However, the increased
construction-related traffic will not cause a significant increase in congestion and
will not significantly affect roadway operations. Additionally, the Project will not
require the closures of public roads or block access along local roadways. For
these reasons, the Project will not impair an adopted emergency response plan or
emergency evacuation plan. This impact will therefore be less than significant.
EXHIBIT A
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b. Due to slope, prevailing winds, and other factors, the Project will not
exacerbate wildfire risks, and thereby expose Project occupants to,
pollutant concentrations from a wildfire or the uncontrolled spread of a
wildfire.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-66 and supported by
evidence contained within the entirety of the record of proceedings, the Project is
not located within or near state responsibility areas or lands classified as very high
fire hazard severity zones. Construction activities will require the use of heavy
equipment, vehicles, and temporary storage areas that could lead to an increased
risk of ignition, which could ignite a fire in an area with flammable vegetation or
material. However, the risk of igniting a wildfire will be low because the Project site
consists of highly eroded marshlands, a shoreline levee, and recreational trails
with relatively flat topography. Additionally, contractors will be required to comply
with hazardous materials storage and fire protection regulations, which will reduce
the potential for wildfire. This impact will therefore be less than significant.
c. The Project will not require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources, power
lines, or other utilities) that may exacerbate fire risk or that may result in
temporary or ongoing impacts on the environment.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on page B-66 and supported by
evidence contained within the entirety of the record of proceedings, the Project will
result in the construction of approximately 600 feet of new levee and restore
approximately 1,100 feet of shoreline levee. No new roads or other infrastructure
will be installed as part of the Project. The Project will not induce a need for housing
or otherwise result in population growth in the area necessitating the installation of
fuel breaks, water sources, power lines, or other utilities that may exacerbate fire
risk, and the impact will be less than significant.
d. The Project will not expose people or structures to significant risks,
including downslope or downstream flooding or landslides, as a result of
runoff, post-fire slope instability, or drainage changes.
Facts in Support of Finding: As discussed in Appendix B, Topics Not Requiring
Detailed Environmental Analysis, of the DEIR on pages B-66 to B-67 and
supported by evidence contained within the entirety of the record of proceedings,
under existing conditions, portions of the Project site (i.e., shoreline segments on
the Tiscornia and Pickleweed Park properties) are currently at risk of overtopping
during extreme coastal flood events, which would result in flooding of low-lying
portions of the adjacent Canal neighborhood. Implementation of the Project will
result in beneficial impacts to prevent flooding by increasing the level of flood
protection for the Canal neighborhood and other nearby communities of central
San Rafael. While the restored wetland habitats will be largely self-maintaining, it
is anticipated that operation and maintenance activities (i.e., removal of invasive
plants, temporary irrigation of ecotone slope plantings, and physical and biological
monitoring) will be needed up to10 years post-construction. However, these
activities will not expose people or structures to significant risks, such as flooding
or landslide as a result of runoff, post-fire slope instability, or drainage changes. In
addition, the Project site’s flat topography and moist soils will not exacerbate fire
EXHIBIT A
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risk or create post-fire conditions involving slope instability, landslides, downslope
or downstream flooding, or changes in drainage. Therefore, the Project will not
expose people or structures to significant post-fire changes, and this impact will be
less than significant.
C. SIGNIFICANT IMPACTS THAT CAN BE AVOIDED OR REDUCED WITH MITIGATION
The Planning Commission, as authorized by Public Resources Code Section 21081 and
CEQA Guidelines Sections 15091 and 15092, identifies the following significant impacts
that can be eliminated or reduced to a less-than-significant level with the implementation
of mitigation measures recommended in the EIR. As identified in the Summary Chapter,
Table S-1, Summary of Impacts and Mitigation Measures (pages S-3 to S-25) of the DEIR
and supported by evidence contained within the entirety of the record of proceedings,
these mitigation measures are hereby adopted and incorporated into the description of
the Project and their implementation will be monitored through the Mitigation Monitoring
and Reporting Program (Exhibit A: Mitigation Monitoring and Reporting Program).
1) Air Quality
a. Impact 3.3-2: The Project could result in a cumulatively considerable net
increase of a criteria air pollutant for which the San Francisco Bay Area
Air Basin is in nonattainment under applicable federal and state ambient
air quality standards.
Significant Impact
As discussed on pages 3.3-19 to 3.3-22 and summarized in the Summary Chapter
(pages S-3 to S-4) of the DEIR, and supported by evidence contained within
the entirety of the record of proceedings, Project-related construction activities at
the Project site may cause emissions of fugitive dust that could generate
particulate matter into the atmosphere representing a nuisance impact. For
mitigation of fugitive dust emissions, the Bay Area Air Quality Management District
recommends using specific best management practices to control fugitive dust
emissions to a less than significant level. (Exhibit A: Mitigation Measure 3.3-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.3-1
will reduce this impact to a level of less than significant. As authorized by Public
Resources Code Section 21081(a)(1) and Title 14, California Code of Regulations
Section 15091(a)(1), the Planning Commission finds that changes or alterations
have been required herein, incorporated into the Project, or required as a condition
of Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
EXHIBIT A
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b. Impact 3.3-3: The Project could expose sensitive receptors to substantial
pollutant concentrations.
Significant Impact
As discussed on pages 3.3-22 to 3.3-24 and summarized in the Summary Chapter
(page S-4) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, construction activities at the Project site
could expose existing sensitive receptors to substantial pollution concentrations
resulting in an incremental cancer risk greater than the Bay Area Air Quality
Management District threshold, a potentially significant impact. Use of EPA Tier 4
engines will reduce cancer risks from Project construction to below the applicable
threshold to a less than significant level. The Project applicant will implement Bay
Area Air Quality Management District Basic Construction Measures to minimize
the generation and emission of dust during construction and control fugitive dust
emissions to a less than significant level. (Exhibit A: Mitigation Measure 3.3-1
and Mitigation Measure 3.3-2).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.3-1
and Mitigation Measure 3.3-2 will reduce this impact to a level of less than
significant. As authorized by Public Resources Code Section 21081(a)(1) and Title
14, California Code of Regulations Section 15091(a)(1), the Planning Commission
finds that changes or alterations have been required herein, incorporated into the
Project, or required as a condition of Project approval, which mitigate or avoid the
significant environmental impact listed above. The Planning Commission further
finds that the change or alteration in the Project or the requirement to impose the
mitigation as a condition of Project approval is within the jurisdiction of the City to
require, and that this mitigation is appropriate and feasible. Therefore, with the
identified mitigation, this impact will be less than significant.
c. Impact 3.3-5: The Project could result in cumulative emissions of air
pollutants.
Significant Impact
As discussed on pages 3.3-25 to 3.3-27 and summarized in the Summary Chapter
(page S-4) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, Project-related construction activities at the
Project site will cause emissions of toxic air contaminants exposing sensitive
receptors to an incremental cancer risk. The cumulative Health Risk Assessment
for both the unmitigated and the mitigated Project established pollutant
concentrations will be below the Bay Area Air Quality Management District
cumulative cancer risk threshold. Use of EPA Tier 4 engines will reduce cancer
risks from Project construction to well below the applicable threshold. The health
risk impact will not be cumulatively considerable, and the cumulative impact will be
less than significant with mitigation. (Exhibit A: Mitigation Measure 3.3-2).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.3-2
will reduce this impact to a level of less than significant. As authorized by Public
Resources Code Section 21081(a)(1) and Title 14, California Code of Regulations
EXHIBIT A
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Section 15091(a)(1), the Planning Commission finds that changes or alterations
have been required herein, incorporated into the Project, or required as a condition
of Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
2) Biological Resources
a. Impact 3.4-1: Construction or operation of the Project could have a
substantial effect on special-status birds, common nesting migratory
birds, or raptors in the study area.
Significant Impact
As discussed on pages 3.4-28 to 3.4-32 and summarized in the Summary Chapter
(pages S-4 to S-7) of the DEIR, and supported by evidence contained within
the entirety of the record of proceedings, equipment staging and Project
construction could render the Project site temporarily unsuitable for breeding rails
and other special-status and protected breeding birds due to noise, vibration, and
increased activity levels and human presence. These activities could cause the
direct destruction of an active nest, or cause birds that have established a nest
prior to the start of construction to change their behavior or abandon an active nest,
putting eggs and nestlings at risk for mortality, a potentially significant impact.
However, this impact will be reduced to a less-than-significant level by requiring
worker environmental awareness training, limiting construction vehicle speeds,
avoiding plastic erosion control netting, avoiding construction during the breeding
season to the extent feasible and during extreme high tides, conducting
species/nest surveys, and requiring a biological monitor. (Exhibit A: Mitigation
Measure 3.4-1, Mitigation Measure 3.4-2, and Mitigation Measure 3.4-3).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-1,
Mitigation Measure 3.4-2, and Mitigation Measure 3.4-3 will reduce this impact to
a level of less than significant. As authorized by Public Resources Code Section
21081(a)(1) and Title 14, California Code of Regulations Section 15091(a)(1), the
Planning Commission finds that changes or alterations have been required herein,
incorporated into the Project, or required as a condition of Project approval, which
mitigate or avoid the significant environmental impact listed above. The Planning
Commission further finds that the change or alteration in the Project or the
requirement to impose the mitigation as a condition of Project approval is within
the jurisdiction of the City to require, and that this mitigation is appropriate and
feasible. Therefore, with the identified mitigation, this impact will be less than
significant.
EXHIBIT A
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b. Impact 3.4-2: The Project could have substantial adverse effects on salt
marsh harvest mouse and salt marsh wandering shrew.
Significant Impact
As discussed on pages 3.4-32 to 3.4-34 and summarized in the Summary Chapter
(pages S-8 to S-9) of the DEIR, and supported by evidence contained within
the entirety of the record of proceedings, construction activities could directly and
indirectly impact salt marsh harvest mouse and salt marsh wandering shrew,
including earthwork associated with the levees and ecotone slope, excavating the
new tidal channel, constructing a temporary access road across the marsh, and
potentially, equipment staging. Direct impacts that could occur include mortality or
mutilation. Indirect impacts could occur if construction activity render otherwise
suitable habitat temporarily unsuitable. These impacts are considered a potentially
significant impact. However, the impacts will be reduced to a less-than-significant
level by requiring worker environmental awareness training, limiting construction
vehicle speeds, avoiding plastic erosion control netting, avoiding ground
disturbance in suitable habitat to the extent feasible, utilizing wildlife exclusion
fencing, using low ground pressure equipment, scheduling construction activity to
avoid extreme high tides, and requiring a biological monitor. (Exhibit A: Mitigation
Measure 3.4-1 and Mitigation Measure 3.4-4).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-1
and Mitigation Measure 3.4-4 will reduce this impact to a level of less than
significant. As authorized by Public Resources Code Section 21081(a)(1) and Title
14, California Code of Regulations Section 15091(a)(1), the Planning Commission
finds that changes or alterations have been required herein, incorporated into the
Project, or required as a condition of Project approval, which mitigate or avoid the
significant environmental impact listed above. The Planning Commission further
finds that the change or alteration in the Project or the requirement to impose the
mitigation as a condition of Project approval is within the jurisdiction of the City to
require, and that this mitigation is appropriate and feasible. Therefore, with the
identified mitigation, this impact will be less than significant.
c. Impact 3.4-3: Construction or operation of the Project could have a
substantial effect on special-status plants.
Significant Impact
As discussed on pages 3.4-34 to 3.4-36 and summarized in the Summary Chapter
(pages S-9 to S-10) of the DEIR, and supported by evidence contained within
the entirety of the record of proceedings, implementation of the Project could
result in direct impacts on existing populations of special-status plant species, if
present. Earthwork associated with the Project could result in direct removal or
trampling of special-status plants, a potentially significant impact. However,
impacts will be reduced to a less-than-significant level by requiring worker
environmental awareness training, limiting construction vehicle speeds, avoiding
plastic erosion control netting, conducting a special-status plant survey,
establishing appropriate buffer areas for each special-status plant population,
installing temporary fencing, following plan guidance to minimize impacts on
EXHIBIT A
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special-status plants, and monitoring seeded/planted/relocated special-status
plants. (Exhibit A: Mitigation Measure 3.4-1 and Mitigation Measure 3.4-5).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-1
and Mitigation Measure 3.4-5 will reduce this impact to a level of less than
significant. As authorized by Public Resources Code Section 21081(a)(1) and
Title 14, California Code of Regulations Section 15091(a)(1), the Planning
Commission finds that changes or alterations have been required herein,
incorporated into the Project, or required as a condition of Project approval, which
mitigate or avoid the significant environmental impact listed above. The Planning
Commission further finds that the change or alteration in the Project or the
requirement to impose the mitigation as a condition of Project approval is within
the jurisdiction of the City to require, and that this mitigation is appropriate and
feasible. Therefore, with the identified mitigation, this impact will be less than
significant.
d. Impact 3.4-4: The Project could have a substantial adverse effect, either
directly or through habitat modification, on marine species identified as a
candidate, sensitive, or special-status species in local or regional plans,
policies, or regulations, or by the California Department of Fish and
Wildlife, U.S. Fish and Wildlife Service, or National Oceanic and
Atmospheric Administration.
Significant Impact
As discussed on pages 3.4-36 to 3.4-42 and summarized in the Summary Chapter
(pages S-10 to S-11) of the DEIR, and supported by evidence contained within
the entirety of the record of proceedings, implementation of the Project will require
earth-moving construction activities, and some activities will occur within, or
adjacent to, the aquatic environment having the potential to impact special-status
marine species or protected habitat. The construction of Project elements,
including a temporary crane platform, will require substantial amounts of work
within the intertidal and aquatic environment. Most of this work will occur in the
form of fill placement in support of the conversion of habitat from intertidal and
mudflat into restored tidal marsh and coarse beach. Installation and removal of the
temporary crane platform’s 12 to 16 steel piles vibratory hammer driven to a depth
of 60 to 70 feet will create underwater noise at a level harmful to protected fish and
marine mammal species, a potentially significant impact. However, this impact will
be reduced to a less-than-significant level by preparing and implementing a sound
attenuation monitoring plan to protect fish and marine mammals and adhering to
National Marine Fisheries Service-approved in-water work windows. Maintenance
and monitoring work within the tidal, wetted channel could disrupt aquatic species
and habitat, a potentially significant impact. Similarly, this impact will be reduced
to a less-than-significant level by limiting maintenance work to June 1 through
November 30 to minimize the potential presence of special-status aquatic species
within the Project site. (Exhibit A: Mitigation Measure 3.4-6).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-6
will reduce this impact to a level of less than significant. As authorized by Public
EXHIBIT A
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Resources Code Section 21081(a)(1) and Title 14, California Code of Regulations
Section 15091(a)(1), the Planning Commission finds that changes or alterations
have been required herein, incorporated into the Project, or required as a condition
of Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
e. Impact 3.4-6: The Project could interfere substantially with the movement
of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the
use of native wildlife nursery sites.
Significant Impact
As discussed on pages 3.4-45 to 3.4-47 and summarized in the Summary Chapter
(page S-11) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, central San Francisco Bay serves as a
migration corridor for special-status anadromous fish species as they move
between spawning habitat and the Pacific Ocean. The presence of marine
mammals in San Francisco Bay is related to the distribution and presence of prey
species and foraging habitat, and the presence of marine mammals in the Project
area is likely to be confined to a few rafting or foraging individuals. Project-related
construction activities could interfere with the movement of special-status marine
species, a potentially significant impact. Given the rarity and transient nature of
regionally occurring special-status species, no sustained presence of special-
status aquatic species is expected occur. With a low-likelihood of occurrence of
special-status marine species, a substantial impact on marine movement corridors
would be unlikely. Nevertheless, preparing and implementing a sound attenuation
monitoring plan to protect fish and marine mammals and adhering to National
Marine Fisheries Service-approved in-water work windows will ensure that any
construction-related impacts on marine movement corridors will be less than
significant. (Exhibit A: Mitigation Measure 3.4-6).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-6
will reduce this impact to a level of less than significant. As authorized by Public
Resources Code Section 21081(a)(1) and Title 14, California Code of Regulations
Section 15091(a)(1), the Planning Commission finds that changes or alterations
have been required herein, incorporated into the Project, or required as a condition
of Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
f. Impact 3.4-7: Construction and operation of Project could conflict with
local policies or ordinances protecting biological resources; and could
conflict with the provisions of an adopted Habitat Conservation Plan,
EXHIBIT A
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Natural Community Conservation Plan, or other approved local, regional,
or state habitat conservation plan.
Significant Impact
As discussed on pages 3.4-47 to 3.4-48 and summarized in the Summary Chapter
(page S-11) of the DEIR and supported by evidence contained within the
entirety of the record of proceedings, the City provides for the protection of street
trees, and outlines requirements for removal and replacement of certain street
trees in the Municipal Code Section 11.12 and 14.25.050. The Project will remove
approximately one native and seven non-native trees to accommodate Project
construction; and construction activities will occur in the vicinity of trees located
adjacent to Spinnaker Point Drive. The native tree to be removed will be replaced
as part of the Project. However, if the Project proponent does not implement tree
removal and replacement and protection of trees to be retained on site in
accordance with Municipal Code Section 11.12 and 14.25.050, an impact will
occur. Any tree-related work (removal, planting, or pruning) will adhere to the
requirements of Municipal Code Section 11.12 and 14.25.050, including obtaining
a written permit before removing, planting or pruning of street trees. As a result,
construction-related impacts will be less than significant. (Exhibit A: Mitigation
Measure 3.4-7).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4-7
will reduce this impact to a level of less than significant. As authorized by Public
Resources Code Section 21081(a)(1) and Title 14, California Code of Regulations
Section 15091(a)(1), the Planning Commission finds that changes or alterations
have been required herein, incorporated into the Project, or required as a condition
of Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
g. Impact 3.4-9: Cumulative loss of sensitive biological resources during
construction and operations.
Significant Impact
As discussed on pages 3.4-49 to 3.4-52 and summarized in the Summary Chapter
(page S-12) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, cumulative impacts related to terrestrial
biological resources and fisheries resources are summarized below.
Terrestrial Biological Resources. The Project could adversely affect special-
status birds (California Ridgway’s rail, California black rail, northern harrier, salt
marsh common yellowthroat, San Pablo song sparrow, and other nesting migratory
birds and raptors), special-status mammals (salt marsh harvest house and salt
marsh wandering shrew), and special-status plant species, which would be
potentially significant impacts. However, these Project impacts will be reduced to
a less-than-significant level by requiring worker environmental awareness training,
limiting construction vehicle speeds, avoiding plastic erosion control netting,
EXHIBIT A
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avoiding construction during the breeding season to the extent feasible and during
extreme high tides, conducting species/nest surveys, avoiding ground disturbance
in suitable habitat to the extent feasible, establishing appropriate buffer areas,
utilizing wildlife exclusion fencing, and requiring a biological monitor. The
cumulative projects could also have the potential to affect these species, and could
result in similar effects as the Project. However, each of these cumulative projects
would be required to complete CEQA analysis similar to that completed for the
Project, but it is unknown whether the CEQA process would identify and mitigate
potential terrestrial biological resources impacts associated with those projects.
Impacts on special-status birds, mammals, and plants would be cumulatively
considerable pre-mitigation, but less than cumulatively considerable with
adherence to the biological resources mitigation measures. (Exhibit A: Mitigation
Measure 3.4-1, Mitigation Measure 3.4-2, Mitigation Measure 3.4-3, Mitigation
Measure 3.4-4, and Mitigation Measure 3.4-5).
Fisheries Resources. The direct impacts of the Project will include impacts on
special-status native fish species and their aquatic habitat during Project
construction, including underwater noise impacts, a potentially significant impact.
However, this Project impact will be reduced to a less-than-significant level by
preparing and implementing a sound attenuation monitoring plan to protect fish
and marine mammals and adhering to National Marine Fisheries Service-approved
in-water work windows. Cumulative projects that involve in-water construction and
that, in combination with the Project, have the potential to result in significant
cumulative impacts on marine resources are limited to ongoing operations and
maintenance actions within San Rafael Creek, which primarily consist of the
periodic dredging of the San Rafael Creek channel and adjacent environment of
San Rafael Bay. Having last been partially dredged by the U.S. Army Corps of
Engineers in 2011, dredging is slated to commence summer 2022 within San
Rafael Creek. As the commencement of construction for the Project will not be until
2023, no overlap in timing will occur between these two projects. Thus, any
cumulative impacts as a result of Project implementation are expected to be less
than significant with mitigation. (Exhibit A: Mitigation Measure 3.4-6).
Finding
The Planning Commission finds that implementation of Mitigation Measure 3.4 1,
Mitigation Measure 3.4 2, Mitigation Measure 3.4 3, Mitigation Measure 3.4 4,
Mitigation Measure 3.4-5, and Mitigation Measure 3.4 6 will reduce this impact to
a level of less than significant. As authorized by Public Resources Code Section
21081(a)(1) and Title 14, California Code of Regulations Section 15091(a)(1), the
Planning Commission finds that changes or alterations have been required herein,
incorporated into the Project, or required as a condition of Project approval, which
mitigate or avoid the significant environmental impact listed above. The Planning
Commission further finds that the change or alteration in the Project or the
requirement to impose the mitigation as a condition of Project approval is within
the jurisdiction of the City to require, and that this mitigation is appropriate and
feasible. Therefore, with the identified mitigation, this impact will be less than
significant.
EXHIBIT A
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3) Cultural Resources
a. Impact B.3-b: Will the Project cause a substantial adverse change in the
significance of an archaeological resource as defined in Section 15064.5?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on pages B-7 to B-8 and summarized in the Summary
Chapter (pages S-14 to S-15) of the DEIR, and supported by evidence contained
within the entirety of the record of proceedings, in the unlikely event that a
previously unrecorded archaeological resource were identified during Project
ground-disturbing activities and found to qualify as a historical resource or a unique
archaeological resource, any impacts on the resource resulting from the Project
could be potentially significant. By ensuring that work is halted in the vicinity until
a qualified archaeologist can make an assessment and provide additional
recommendations if necessary, including contacting Native American tribes, the
potentially significant impact will be reduced to less than significant. (Exhibit A:
Mitigation Measure CUL-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-1
will reduce this impact to a level of less than significant. As authorized by Public
Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
b. Impact B.3-c: Will the Project disturb any human remains, including those
interred outside of formal cemeteries?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on page B-8 and summarized in the Summary Chapter (page
S-15) of the DEIR, and supported by evidence contained within the entirety of the
record of proceedings, there is no indication from the archival research that any
part of the Project area has been used for human burial purposes in the recent or
distant past. Therefore, it is unlikely that human remains will be encountered during
construction of the Project. However, the possibility of inadvertent discovery
cannot be entirely discounted, and would result in a potentially significant impact.
This impact will be reduced to a less-than-significant level by requiring work to halt
in the vicinity of a find and immediately notifying the County coroner, and if the
human remains are Native American, the California Native American Heritage
Commission and following all recommendations. (Exhibit A: Mitigation Measure
CUL-2).
EXHIBIT A
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Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-2
will reduce this impact to a level of less than significant. As authorized by Public
Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
c. Impact B.3-d: Will the Project, in combination with reasonably foreseeable
future projects, result in significant cumulative impacts on archeological
resources or human remains?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on page B-9 and summarized in the Summary Chapter (page
S-15) of the DEIR, and supported by evidence contained within the entirety of the
record of proceedings, there are no known archaeological resources or human
remains within the Project site. While there is the potential for the Project to
encounter archaeological resources, which could include prehistoric archeological
features or deposits, or human remains, the Project will not be expected to result
in significant impacts even if such resources are found. There are reasonably
foreseeable future projects, specifically the Pickleweed Field and Park Project and
the Schoen Park Conversion to Parking, that could impact the same archaeological
resources as the Project, if any such resource is identified. However, these
projects would involve the implementation of similar types of mitigation measures
as the Project, which will reduce potential for impacts on these resources and any
other as-yet undiscovered resources to a less-than-significant level. (Exhibit A:
Mitigation Measure CUL-1 and Mitigation Measure CUL-2).
Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-1
and Mitigation Measure CUL-2 will reduce this impact to a level of less than
significant. As authorized by Public Resources. Code Section 21081(a)(1) and Title
14, and California Code of Regulations Section 15091(a)(1), the City finds that
changes or alterations have been required herein, incorporated into the Project, or
required as a condition of Project approval, which mitigate or avoid the significant
environmental impact listed above. The Planning Commission further finds that
the change or alteration in the Project or the requirement to impose the mitigation
as a condition of Project approval is within the jurisdiction of the City to require,
and that this mitigation is appropriate and feasible. Therefore, with the identified
mitigation, this impact will be less than significant.
EXHIBIT A
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4) Transportation
a. Impact B.13-c: Will the Project substantially increase hazards due to a
geometric design feature (e.g., sharp curves or dangerous intersections)
or incompatible uses (e.g., farm equipment)?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on pages B-53 to B-54 and summarized in the Summary
Chapter (page S-22) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, the land uses adjacent to and included in the
Project vicinity include single- and multi-family residential, community uses (i.e.,
community center, library, park), and an elementary school. Due to the proximity
of these uses to the Project site, this area is frequented by residents and visitors
on a regular basis. As such, the temporary introduction of construction equipment
required to construct the Project on roadways in and around the Project site will
not be compatible with existing uses and will pose a potential safety hazard, a
potentially significant impact. However, impacts will be reduced to a less-than-
significant level by defining truck haul routes that avoid residential streets, utilizing
temporary signing and traffic control devices, providing construction personnel to
direct traffic at the driveway on Spinnaker Point Drive, notifying San Rafael
Schools at least 2 months in advance of all construction activities, and requiring
the construction contractor to ensure Project construction does not inhibit access
to Bahia Vista Elementary School. (Exhibit A: Mitigation Measure TRAN-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure
TRAN-1 will reduce this impact to a level of less than significant. As authorized by
Public Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
b. Impact B.13-e: Will the Project, in combination with reasonably
foreseeable future projects, result in significant cumulative impacts on
transportation?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on page B-55 and summarized in the Summary Chapter
(page S-22) of the DEIR, and supported by evidence contained within the entirety
of the record of proceedings, impacts on traffic associated with construction (e.g.,
an intermittent reduction in street and intersection operating capacity, potential
conflicts with pedestrians/ bicyclists, overlap with construction of nearby related
projects) are typically considered as potential short-term impacts. As noted under
Impact B.13-c, the Project will result in a potentially significant traffic impact during
EXHIBIT A
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construction activities. However, construction impacts on transportation facilities
will be reduced to a less-than-significant level by defining truck haul routes that
avoid residential streets, utilizing temporary signing and traffic control devices,
directing traffic at the driveway on Spinnaker Point Drive, notifying schools in
advance of construction activities, and ensuring school access is not inhibited.
Each of the cumulative projects would be required to comply with jurisdictional
requirements regarding haul routes and would implement mitigation measures
and/or include project characteristics, such as traffic controls and scheduling to
reduce potential traffic impacts during construction. Accordingly, Project-related
contributions to cumulative construction traffic conditions during construction will
be less than significant with mitigation. (Exhibit A: Mitigation Measure TRAN-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure
TRAN-1 will reduce this impact to a level of less than significant. As authorized by
Public Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
5) Tribal Cultural Resources
a. Impact B.14-a.i: Will the Project cause a substantial adverse change in the
significance of a tribal cultural resource, defined in PRC Section 21074 as
either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or
object with cultural value to a California Native American tribe, and that is
listed or eligible for listing in the California Register of Historical
Resources, or in a local register of historical resources as defined in PRC
Section 5020.1(k).?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on pages B-57 to B-58 and summarized in the Summary
Chapter (page S-23) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, there are no known tribal cultural resources
at the Project site. In the event that tribal cultural resources are identified during
Project construction or operation, any impacts on the resource resulting from the
Project could be potentially significant. This impact will be reduced to a less-than-
significant level by ensuring that work is halted in the vicinity of a find until a
qualified archaeologist and a Native American tribal representative can make an
assessment and provide additional recommendations. (Exhibit A: Mitigation
Measure CUL-1).
EXHIBIT A
2-36
Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-1
will reduce this impact to a level of less than significant. As authorized by Public
Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
b. Impact B.14-a.ii: Would the Project cause a substantial adverse change in
the significance of a tribal cultural resource, defined in PRC Section 21074
as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or
object with cultural value to a California Native American tribe, and that is
a resource determined by the lead agency, in its discretion and supported
by substantial evidence, to be significant pursuant to criteria set forth in
Subdivision (c) of PRC Section 5024.1? In applying the criteria set forth in
Subdivision (c) of PRC Section 5024.1, the lead agency shall consider the
significance of the resource to a California Native American tribe.
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on page B-58 and summarized in the Summary Chapter
(page S-23) of the DEIR, and supported by evidence contained within the entirety
of the record of proceedings, there are no known tribal cultural resources at the
Project site. In the event that tribal cultural resources are identified during Project
construction or operation, any impacts on the resource resulting from the Project
could be potentially significant. This impact will be reduced to a less-than-
significant level by ensuring that work is halted in the vicinity of a find until a
qualified archaeologist and a Native American tribal representative can make an
assessment and provide additional recommendations. (Exhibit A: Mitigation
Measure CUL-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-1
will reduce this impact to a level of less than significant. As authorized by Public
Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
EXHIBIT A
2-37
c. Impact B.14-b: Will the Project, in combination with reasonably
foreseeable future projects, result in significant cumulative impacts on
tribal cultural resources?
Significant Impact
As discussed in Appendix B, Topics Not Requiring Detailed Environmental
Analysis, of the DEIR on pages B-58 to B-59 and summarized in the Summary
Chapter (page S-23) of the DEIR, and supported by evidence contained within the
entirety of the record of proceedings, there are no known tribal cultural resources
within the Project site. While there is the potential for the Project to encounter
archaeological resources, which could include prehistoric archeological features
or deposits considered tribal cultural resources, the Project will not be expected to
result in significant impacts even if such resources are found. There are reasonably
foreseeable future projects, specifically the Pickleweed Field and Park Project and
the Schoen Park Conversion to Parking, that could impact the same archaeological
resources as the Project, if any such resource is identified. However, these
projects would involve the implementation of similar types of mitigation measures
as the Project, which will reduce potential for impacts on these resources and any
other as-yet undiscovered resources to a less-than-significant level. (Exhibit A:
Mitigation Measure CUL-1).
Finding
The Planning Commission finds that implementation of Mitigation Measure CUL-1
will reduce this impact to a level of less than significant. As authorized by Public
Resources. Code Section 21081(a)(1) and Title 14, and California Code of
Regulations Section 15091(a)(1), the City finds that changes or alterations have
been required herein, incorporated into the Project, or required as a condition of
Project approval, which mitigate or avoid the significant environmental impact
listed above. The Planning Commission further finds that the change or alteration
in the Project or the requirement to impose the mitigation as a condition of Project
approval is within the jurisdiction of the City to require, and that this mitigation is
appropriate and feasible. Therefore, with the identified mitigation, this impact will
be less than significant.
D. IMPACT OVERVIEW
1) Growth–Inducing Impacts
Section 15126.2(e) of the CEQA Guidelines requires that an environmental impact
report discuss:
[T]he ways in which the proposed project could foster economic or population
growth, or the construction of additional housing, either directly or indirectly, in the
surrounding environment. Included in this are projects which would remove
obstacles to population growth (a major expansion of a wastewater treatment plant
might, for example, allow for more construction in service areas)… It must not be
assumed that growth in any area is necessarily beneficial, detrimental, or of little
significance to the environment.
The Project will not directly induce growth because it does not involve the development
of new housing or job centers that will attract an additional population. Project
construction will not extend roads or include other infrastructure that could indirectly
EXHIBIT A
2-38
induce growth. Given the relatively small size of the construction workforce
(approximately 19 construction workers), construction of the Project will not be
expected to induce demand for housing by attracting workers from outside the area,
as workers are expected to be drawn from the local labor pool. Long-term operations
and maintenance activities associated with the Project will be similar to existing
activities, and will not increase the number of workers employed by the City of San
Rafael.
As described in Chapter 2, Project Description, of the DEIR the goal of the Project is
to enhance the ecological function of the Tiscornia Marsh property and increase flood
protection for the Canal neighborhood, while maintaining the community value of the
Albert J. Boro Community Center and Pickleweed Park. The Project will use existing
water supplies and will not create or expand a water supply source that could remove
water supply limitations as a potential obstacle to growth.
Based on the preceding and on the entirety of the record of proceedings, the Planning
Commission consequently finds that no significant growth-inducing effects will result
from implementation of the Project.
2) Significant Unavoidable Impacts
In accordance with CEQA Section 21100(b)(2)(A) and Sections 15126(b) and
15126.2(c) of the CEQA Guidelines, the purpose of this section is to identify
environmental impacts of the Project that could not be eliminated or reduced to a less-
than-significant level with implementation of the mitigation measures identified in
Chapter 3, Environmental Setting, Impacts, and Mitigation Measures, or Appendix B,
Topics Not Requiring Detailed Environmental Analysis, of the DEIR. No significant
unavoidable impacts have been identified in this EIR.
Based on the preceding and on the entirety of the record of proceedings, the Planning
Commission consequently finds that no significant unavoidable impacts will result from
implementation of the Project.
3) Significant Irreversible Environmental Changes
CEQA Section 21100(b)(2)(B) and CEQA Guidelines Section 15126.2(d) require that
an EIR identify significant irreversible environmental changes caused by
implementation of a project. Construction of the Project will indirectly result in the
commitment of nonrenewable natural resources used in the construction process.
These may include gravel, soils, petroleum products, construction-related chemicals,
steel, and other materials. The Project will also result in the commitment of slowly
renewable materials, such as wood products. This will not, however, be considered a
significant adverse irreversible environmental change, given the availability of these
products and the Project’s relatively small need for these products compared to their
overall regional use.
Based on the preceding and on the entirety of the record of proceedings, the Planning
Commission consequently finds that no significant irreversible effects will result from
implementation of the Project.
E. REVIEW OF PROJECT ALTERNATIVES
CEQA requires that an EIR describe and evaluate a reasonable range of feasible
alternatives to a project, or to the location of a project, that would attain most of the project
EXHIBIT A
2-39
objectives and avoid or substantially lessen significant project impacts. Section 15126.6(e)
of the CEQA Guidelines requires that an EIR alternatives analysis must include the “No
Project Alternative” as a point of comparison. The No Project Alternative includes existing
conditions and reasonably foreseeable future conditions that would exist if the project were
not approved (CEQA Guidelines Section 15126.6(e)(2)). Based on the “rule of reason”
governance in the CEQA Guidelines, an EIR is required to “set forth only those alternatives
necessary to permit a reasoned choice” and alternatives need to attain most of the project
objectives in order to be considered feasible (CEQA Guidelines Section 15126.6(f). The
following discussion describes the three alternatives evaluated in detail in this EIR.
The Project Alternatives analyzed in the following sections include:
• Alternative 1: No Project Alternative
• Alternative 2: Reduced Project – Reduce Tiscornia Marsh Restoration
• Alternative 3: Reduced Project – Eliminate Diked Marsh Restoration
1. Alternative 1: No Project Alternative: (as required by CEQA). In the event that the
City does not approve the Project, the restoration of Tiscornia Marsh and the City-
owned diked marsh would not occur. The eroded area outboard of the existing
Tiscornia Marsh would not be reconstructed, and the diked marsh would not be
reconnected to tidal activity. The new levee north of the soccer field would not be
constructed, and the levees to the west and south of Tiscornia Marsh would not be
raised and/or widened. In addition, the coarse beach feature would not be
constructed to prevent additional erosion of the marsh. The levee trails would not be
resurfaced with asphalt.
Ability to Meet Project Objectives
The No Project Alternative would not meet any of the objectives of the Project.
Finding
The Planning Commission (1) rejects this Alternative 1: No Project Alternative on the
basis that it fails to meet basic project objectives and (2) finds that each and any of
these grounds separately and independently provide sufficient justification for rejection
of this Alternative.
Facts in Support of Finding
The Alternative 1: No Project Alternative fails to meet any of the Project objectives,
specifically:
• This alternative would not restore tidal marsh on the Project site to
improve ecological function and habitat quantity, quality, and connectivity
(including upland transition zones) for native marsh species and marsh-
upland transition species, including special status species.
• This alternative would not protect Project site marsh lands from future
marsh edge erosion; increase the level of flood protection for the Canal
neighborhood and other nearby communities of central San Rafael.
• This alternative would not create sustainable benefits that consider future
environmental changes such as sea level rise and sedimentation.
EXHIBIT A
2-40
• This alternative would not maintain and improve public access to passive
recreational and outdoor education opportunities (e.g., hiking, jogging, bird
watching).
• Tiscornia Marsh would continue to erode, and the low-lying Canal
neighborhood adjacent to Tiscornia Marsh would be further at risk to coastal
flooding.
• The existing levee trail would be retained, and passive recreation would
continue; however, the trail surface would not be replaced and outdoor
education opportunities would not be improved.
2. Alternative 2: Reduced Project – Reduce Tiscornia Marsh Restoration:
Alternative 2 would include the same Project elements as the Project; however, the
south side of the marsh would be reduced; therefore, reducing the total fill required
and the overall amount of construction activities. Specifically, the portion of restored
tidal marsh and constructed coarse beach would not be extended to the location of
the tidal channel.
Ability to Meet Project Objectives
Alternative 2 would meet the objectives related to enhanced flood protection of the
adjacent areas, because new/raised levees would be created and would protect the
adjacent areas. The alternative would meet the objective of maintaining and
improving public access, as it would include new trail surfacing along the levees, and
other passive recreation components (same as under the Project). However, the
amount of tidal marsh restoration would be reduced as compared to the Project, and
without the extension of the marsh to the south to the tidal channel, a portion of the
site would be subject to ongoing marsh erosion and would be vulnerable to the
ongoing effects of sea level rise. Further, without the protection of the coarse beach
at the southern portion of the Project site, ongoing erosion would extend from the
southern portion of the site northward, and it is expected that the overall project
efficacy and timeline would be reduced compared to the Project.
Finding
The Planning Commission (1) rejects this alternative on the basis that it fails to meet
basic project objectives, and (2) finds that each and any of these grounds separately
and independently provide sufficient justification for rejection of this Alternative.
Facts in Support of Finding
• This Alternative achieves some, but not all, of the Project objectives,
including failing to achieve primary Project objectives, such as fully
restoring tidal marsh on the Project site, and protecting Project site
marshlands from future marsh edge erosion.
• The amount of tidal marsh restoration would be reduced as compared to
the Project, and without the extension of the marsh to the south to the tidal
channel, a portion of the site would be subject to ongoing marsh erosion
and would be vulnerable to the ongoing effects of sea level rise.
• Without the protection of the coarse beach at the southern portion of the
Project site, ongoing erosion would extend from the southern portion of the
EXHIBIT A
2-41
site northward, and it is expected that the overall Project efficacy and
timeline would be reduced compared to the Project
• Alternative 2 would meet the objectives related to enhanced flood
protection of the adjacent areas, because new/raised levees would be
created and would protect the adjacent areas.
• The alternative would meet the objective of maintaining and improving
public access, as it would include new trail surfacing along the levees, and
other passive recreation components.
3. Alternative 3: Reduced Project – Eliminate Diked Marsh Restoration:
Alternative 3 would include most of the same Project elements on the eastern side
of the site as the Project and would include the restoration of Tiscornia Marsh,
construction of the coarse beach, raised southern and eastern levee, and
constructed southern ecotone. However, the diked marsh would not be converted
to tidal marsh; the new levee between the diked marsh and Pickleweed Park would
not be constructed, and the new tidal channels at the north end of the site would not
be constructed. Alternative 3 would require the least amount of construction, other
than the No Project Alternative.
Ability to Meet Project Objectives
Alternative 3 would meet the objective related to maintaining and improving public
access, as it would include new trail surfacing along the improved levees, and other
passive recreation components (same as under the Proposed Project). However, the
amount of tidal marsh restoration would be substantially reduced as compared to the
Project, because the diked marsh would not be converted to tidal marsh. Further,
without restoration, the diked marsh would continue to be isolated from bay
sediments, which would help marshes accrete (or build up) to keep pace with sea
level rise. Without the new levee and ecotone, and restoring tidal action to the diked
marsh, the western portion of the site would be more vulnerable to extreme tidal
flooding and sea level rise compared to the Project.
Finding
The Planning Commission (1) rejects this alternative on the basis that it fails to meet
basic project objectives, and (2) finds that each and any of these grounds separately
and independently provide sufficient justification for rejection of this Alternative.
Facts in Support of Finding
• This Alternative achieves some, but not all, of the Project objectives, including
failing to achieve primary Project objectives, such as fully restoring tidal marsh
on the Project site, and protecting Project site marshlands from future marsh
edge erosion.
• The amount of tidal marsh restoration would be substantially reduced as
compared to the Project, because the diked marsh would not be converted
to tidal marsh.
• Without restoration, the diked marsh would continue to be isolated from
bay sediments, which would help marshes accrete (or build up) to keep
pace with sea level rise.
EXHIBIT A
2-42
• Without the new levee and ecotone, and restoring tidal action to the diked
marsh, the western portion of the site would be more vulnerable to extreme
tidal flooding and sea level rise.
• This alternative would meet the objective related to maintaining and
improving public access, as it would include new trail surfacing along the
improved levees, and other passive recreation components.
Environmental Superior Alternative
Consistent with CEQA Guidelines Section 15126.6(e), an environmentally superior
alternative must be identified among the alternatives that were studied. The DEIR
concludes (Chapter 5; pages 5-12 to 5-13) that the Environmentally Superior
Alternative is Alternative 3: Reduced Project – Eliminate Diked Marsh Restoration
project for the following reasons:
• Alternative 1 would eliminate the short-term construction effects relative to
the Project. However, under Alternative 1, the restoration of Tiscornia
Marsh and the City-owned diked marsh would not occur and the existing
levees would not be raised and improved; thus, the adjacent areas would
continue to be vulnerable to flooding. Alternative 1 would not meet any of
the Project objectives.
• Alternative 2 would not avoid the significant effects of the Project; however,
the impacts would be lessened with the reduced construction footprint.
Alternative 2 would only partially meet Project objectives, by eliminating
restoration of the southern portion of the marsh. Thus, Alterative 2 provides
a reduced habitat benefit. Further, without improvement of the southern
part of the Project, ongoing erosion would extend into the northern portion
of the Project site, affecting the efficacy of the project, and somewhat
reducing the expected lifetime of the improved levees from 2070 (as under
the Project).
• Alternative 3 includes the least amount of construction activity, other than
the No Project Alternative. While Alternative 3 would not avoid the
significant effects of the Project, the impacts would be lessened with the
reduced construction footprint. Thus, Alternative 3 is the environmentally
preferred alternative. However, Alternative 3 would only partially meet
Project objectives, by eliminating restoration of the diked marsh to tidal
marsh and eliminating the new northern levee and ecotone.
Rejection of Environmentally Superior Alternative:
Alternative 3 is the environmentally superior alternative. Compared to the Project,
Alternative 3 restoration would be significantly reduced, which would not meet the
identified tidal marsh restoration, Project site marshlands protection, increased flood
protection, and sustainable benefits as sea level rises objectives for the Project. By
eliminating restoration of the diked marsh to tidal marsh and eliminating the new
northern levee and ecotone, Alterative 3 provides the least habitat benefit and
smallest flood protection benefit, other than the No Project Alternative. Further,
without improvement of the diked marsh, the northwestern part of the Project area
would be more vulnerable to extreme tidal flooding and sea level rise, and the
expected lifetime of the improved levees would be less than 2070 (as under the
EXHIBIT A
2-43
Project). For these reasons, the Planning Commission rejects Alternative 3, the
environmentally superior alternative.
F. ADOPTION OF MITIGATION MONITORING AND REPORTING PROGRAM
Pursuant to Public Resources Code section 21081.6, the Planning Commission hereby
adopts the Mitigation Monitoring and Reporting Program attached to this Resolution as
Exhibit A, to be made a condition of approval of the Project. In the event of any
inconsistencies between the Mitigation Measures as set forth herein and the Mitigation
Monitoring and Reporting Program, the Mitigation Monitoring and Reporting Program shall
control.
G. STAFF DIRECTION
A Notice of Determination shall be filed with the County of Marin and the State
Clearinghouse within five (5) working days of final Project approval.
The foregoing resolution was at the regular City of San Rafael Planning Commission meeting held
on the 11th day of January 2022.
Moved by Commissioner _____________ and seconded by Commissioner ______________.
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST: ______________________________ ______________________________
Leslie Mendez, Secretary Shingi Samudzi, Chair
Exhibit A – Mitigation Monitoring and Reporting Program (MMRP)
Exhibit A-1
EXHIBIT A
EXHIBIT A: MITIGATION MONITORING AND REPORTING PROGRAM
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
AIR QUALITY, EIR SECTION 3.3
Mitigation Measure 3.3-1: BAAQMD Basic Construction
Measures. The Project applicant and/or its construction
contractors shall comply with the following applicable
BAAQMD Basic Construction Mitigation Measures:
BAAQMD Basic Construction Measures
1. All exposed surfaces (e.g., parking areas, staging
areas, soil piles, graded areas, and unpaved access
roads) shall be watered two times per day.
2. All haul trucks and railcars transporting soil, sand, or
other loose material off-site shall be covered.
3. All visible mud or dirt track-out onto adjacent public
roads shall be removed using wet power vacuum
street sweepers at least once per day. The use of dry
power sweeping is prohibited.
4. All vehicle speeds on unpaved roads shall be limited
to 15 mph.
5. All roadways, driveways, and sidewalks to be paved
shall be completed as soon as possible. Building pads
shall be laid as soon as possible after grading unless
seeding or soil binders are used.
6. Idling times shall be minimized either by shutting
equipment off when not in use or reducing the
maximum idling time to five minutes (as required by
the California airborne toxics control measure Title 13,
Section 2485 of the California Code of Regulations
[CCR]). Clear signage shall be provided for
construction workers at all access points.
7. All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
certified visible emissions evaluator.
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, and at
time of contract
specifications
Exhibit A-2
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
8. Post a publicly visible sign with the telephone number
and person to contact at the City of San Rafael
regarding dust complaints. This person shall respond
and take corrective action within 48 hours. BAAQMD’s
phone number shall also be visible to ensure
compliance with applicable regulations.
Mitigation Measure 3.3-2: EPA Tier 4 Engines. The
Project applicant and/or its construction contractors shall
be required to use off-road diesel construction equipment
compliant with EPA Tier 4 nonroad engine standards.
Before construction activities begin, the construction
contractor and/or the Project applicant shall prepare an
equipment list that identifies each piece of off-road
equipment to be operated at the Project site by its
equipment identification number and demonstrates that
each piece of equipment meets EPA Tier 4 nonroad
engine standards. The list shall be made available at the
construction site and shall be updated when new or
replacement construction equipment is brought to the site.
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, and at
time of contract
specifications
BIOLOGICAL RESOURCES, EIR SECTION 3.4
Mitigation Measure 3.4-1: General Construction-
related Mitigation Measures
• A qualified biologist (4-year college degree in biology
or related field and demonstrated experience with the
species of concern) shall provide Worker
Environmental Awareness Training (WEAT) to field
management and construction personnel.
Communication efforts and training shall take place
during pre-construction meetings so that construction
personnel are aware of their responsibilities and the
importance of compliance. WEAT shall identify the
types of sensitive resources located in the study area
and the measures required to avoid impacts on these
resources. Materials covered in the training program
shall include environmental rules and regulations for
the specific Project and requirements for limiting
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, and at
time of contract
specifications
Exhibit A-3
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
activities to the construction right-of-way and avoiding
demarcated sensitive resource areas.
• If new construction personnel are added to the Project,
the contractor shall ensure the new personnel receive
WEAT before starting work. A sign-in sheet of those
contractor individuals who have received the training
shall be maintained by the Project proponent. A
representative shall be appointed during the WEAT to be
the contact for any employee or contractor who might
inadvertently kill or injure a listed species or who finds
a dead, injured, or entrapped individual.
• All vehicle operators shall limit speed to 15 miles per
hour (mph) within the Project site.
• No erosion control materials shall contain any plastic
or monofilament netting.
To avoid attracting predators, all food-related trash items
shall be bagged and removed daily.
Mitigation Measure 3.4-2: Avoid and Minimize Impacts
on California Black Rail and California Ridgway’s Rail
• To minimize or avoid the loss of individual California
black rail and California Ridgway’s rail, construction
activities, including vegetation management activities
requiring heavy equipment, adjacent to the tidal
marsh areas (within 500 feet [150 meters] or a
distance determined in coordination with the USFWS
or CDFW based on site specific conditions, shall be
avoided during the breeding season from February 1
through August 31.
• If areas within or adjacent to rail habitat cannot be
avoided during the breeding season, protocol-level
surveys shall be conducted to determine rail nesting
locations. The surveys shall focus on potential habitat
that could be disturbed by construction activities
during the breeding season to ensure that rails are
not breeding in these locations.
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, at time of
contract
specifications, and at
time of encounter of
species (as
applicable)
Exhibit A-4
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
Survey methods for rails shall follow the Site-Specific
Protocol for Monitoring Marsh Birds, which was
developed for use by USFWS and partners to
improve bay-wide monitoring accuracy by
standardizing surveys and increasing the ability to
share data (Wood et al. 2017). Surveys are
concentrated during the approximate period of peak
detectability, January 15 to March 25, and are
structured to efficiently sample an area in three
rounds of surveys by broadcasting calls of target
species during specific periods of each survey round.
Call broadcasts increase the probability of detection
compared to passive surveys when no call
broadcasting is employed. This protocol has since
been adopted by the Invasive Spartina Project (ISP)
and Point Blue Conservation Science to survey
California Ridgway’s rails at sites throughout San
Francisco Bay Estuary, including at Tiscornia Marsh.
The survey results and protocols from the ISP shall
be used, or a survey protocol developed in
coordination with CDFW and USFWS incorporating
both species simultaneously and with the same level
of effort as protocols currently in use by ISP shall be
used. The survey protocol for California Ridgway’s rail
is summarized below.
− Previously used survey locations (points) should
be used when available to maintain consistency
with past survey results. Adjacent points should
be at least 200 meters apart along transects in or
adjacent to areas representative of the marsh.
Points should be located to minimize
disturbances to marsh vegetation. Up to eight
points can be located on a transect.
− At each transect, three surveys (rounds) are to be
conducted, with the first round of surveys initiated
between January 15 and February 6, the second
round performed February 7 to February 28, and
the third round March 1 to March 25. Surveys
Exhibit A-5
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
should be spaced at least 1 week apart, and the
period between March 25 to April 15 can be used
to complete surveys delayed by logistical or weather
issues. A FESA Section 10(a)(1)(A) permit is
required to conduct active surveys.
− Each point on a transect shall be surveyed for 10
minutes each round. A recording of calls available
from the USFWS is broadcast at each point. The
recording consists of 5 minutes of silence,
followed by a 30-second recording of California
Ridgway’s rail vocalizations, followed by 30
seconds of silence, followed by a 30-second
recording of California black rail, followed by 3.5
minutes of silence.
• If no breeding California black rail or California
Ridgway’s rail are detected during surveys, or if their
breeding territories can be avoided by 500 feet (150
meters), or a distance determined in coordination with
the USFWS or CDFW based on site specific
conditions, then Project activities may proceed at that
location.
• If protocol surveys determine that breeding California
black rail and/or California Ridgway’s rail are present
in the Project area, the following measures would
apply to Project activities conducted during their
breeding season (February 1- August 31):
− Construction activities would not occur within 500
feet of a detected Ridgway’s rail or black rail call
center.
− A USFWS- and CDFW-approved biologist shall
be on site during construction activities occurring
within 50 feet 500 feet (150 meters) of any other
suitable rail breeding habitat.
− All other biologists that may need to access the
tidal marsh outside of the active construction
Exhibit A-6
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
period or be on site during construction for
activities beyond 500 feet from suitable rail
breeding habitat and 500 feet from rail call
centers, shall be trained in black rail and
Ridgway’s rail biology, identification, and
vocalizations, and shall be familiar with both
species of rail and their nests.
− The qualified biologist/biological monitor shall have the
authority to stop all work if a Ridgway’s rail or black rail
enters or is discovered within 50 feet of the active work zone.
All nearby work shall halt and not continue until the
Ridgway’s rail or black rail leaves the area on its own
accord or until approving agencies have been consulted. The
no work zone shall be large enough as determined by the
qualified biologist/biological monitor in order to avoid impacts
to all special-status species. If a California black rail or
California Ridgway’s rail vocalizes or flushes
within 10 meters, it is possible that a nest or
young are nearby. If an alarmed bird or nest is
detected, work shall be stopped, and workers
shall leave the immediate area carefully and
quickly. An alternate route shall be selected that
avoids this area, and the location of the sighting
shall be recorded to inform future activities in the
area.
− All construction crews working in the marsh
during rail breeding season shall be trained and
supervised by a USFWS- and CDFW-approved
rail biologist.
− If any activities shall be conducted during the rail
breeding season in California black rail or
California Ridgway’s rail-occupied marshes,
biologists shall have maps or global positioning
system (GPS) locations of the most current
occurrences on the site.
Exhibit A-7
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
Mitigation Measure 3.4-3: Nesting Bird Protection
Measures
The City and/or its contractor(s) shall implement the
following during construction of the Project:
• Removal of trees and scrub vegetation shall occur
outside the bird nesting season (February 1 to August
31), to the extent feasible.
• If removal of trees and vegetation cannot be fully
accomplished outside of the nesting season, a
qualified biologist shall conduct pre-construction
nesting surveys within 7 days prior to the start of such
activities or after any construction breaks of 10 days or
more. Surveys shall be performed for the study area
and suitable habitat within 250 feet of the Project site
to locate any active raptor (birds of prey) nests or
rookeries.
• If active nests are located during the pre-construction
bird nesting survey, the qualified biologist shall
evaluate if the schedule of construction activities could
affect the active nests and the following measures
shall be implemented based on their determination:
− If construction is not likely to affect the active nest,
it may proceed without restriction; however, a
biologist shall regularly monitor the nest to confirm
there is no adverse effect and may revise their
determination at any time during the nesting
season. In this case, the following measure would
apply.
− If construction may affect the active nest, the
biologist shall establish a no-disturbance buffer in
coordination with CDFW. Typically, these buffer
distances are 100 feet for passerines and 250 feet for
raptors. These distances may be adjusted
depending on the level of surrounding ambient
activity (e.g., if the Project site is adjacent to a road
or active trail) and if an obstruction, such as a
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, at time of
contract
specifications, and at
time of encounter of
species/active nests
(as applicable)
Exhibit A-8
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
building, is within line‐of‐sight between the nest and
construction. For bird species that are federally
and/or state‐listed sensitive species (i.e., fully
protected, endangered, threatened, species of
special concern), a City representative or qualified
biologist shall coordinate with the USFWS and/or
CDFW regarding modifications to nest buffers,
prohibiting construction within the buffer, modifying
construction, or removing or relocating active nests
that are found on the site.
− Any birds that begin nesting within the Project area
and survey buffers amid construction activities are
assumed to be habituated to construction-related
or similar noise and disturbance levels. A qualified
biologist shall coordinate with the USFWS and/or
CDFW and determine if no work exclusion zones
shall be established around active nests in these
cases.
Mitigation Measure 3.4-4: Avoid and Minimize Impacts
on Salt Marsh Harvest Mouse and Salt Marsh
Wandering Shrew
• Ground disturbance to suitable salt marsh harvest
mouse habitat (including, but not limited to
pickleweed, and emergent salt marsh vegetation)
shall be avoided to the extent feasible. Where salt
marsh harvest mouse habitat cannot be avoided
(such as for channel excavation, access routes and
grading, or anywhere else that vegetation could be
trampled or crushed by work activities), vegetation
shall be removed to ground level from the ground
disturbance work area plus a 5-foot buffer around the
area, as well as any access routes within salt marsh
harvest mouse habitat, utilizing mechanized hand
tools or by another method approved by the USFWS
and CDFW. Vegetation height shall be maintained at
or below 5 inches above ground. Vegetation removal
in salt marsh harvest mouse habitat shall be
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, at time of
contract
specifications, and at
time of encounter of
species (as
applicable)
Exhibit A-9
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
conducted under the supervision of the USFWS- and
CDFW-approved biologist(s). The number of biologists
needed to effectively inspect vegetational removal for the presence
of mice and nests depends on the site characteristics and
vegetation removal methods and may be determined in
coordination with approving agencies.
• To protect salt marsh harvest mouse from
construction-related traffic, access roads, haul routes,
and staging areas within 50 feet of salt marsh harvest
mouse habitat shall be bordered by temporary
exclusion fencing; or other wildlife exclusion fencing
as specified in federal or state permits. The fence
should be made of a material that does not allow salt
marsh harvest mouse to climb or pass through, of a
minimum above-ground height of 30 inches, and the
bottom should be buried to a depth of at least 6
inches so that mice cannot crawl under the fence.
Any supports for the salt marsh harvest mouse
exclusion fencing (e.g., t-posts) shall be placed on the
inside of the Project site. The last 5 feet of the fence
shall be angled away from the road to direct wildlife
away from the road. A USFWS- and CDFW-approved
biologist with previous salt marsh harvest mouse
experience shall be on site during fence installation
and shall check the fence alignment prior to
vegetation clearing and fence installation to ensure
that no salt marsh harvest mice are present.
• Salt marsh harvest mouse marsh habitat that must be
accessed by mini-excavators or other vehicles to
complete Project construction (e.g., excavating smaller
channels) shall be protected through use of low ground
pressure (LGP) equipment, wooden or PVC marsh
mats, or other method approved by the USFWS and
CDFW following vegetation removal (see 2nd bullet,
above).
• Construction activities related to restoration and
infrastructure shall be scheduled to avoid extreme
high tides when there is potential for salt marsh
Exhibit A-10
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
harvest mouse to move to higher, drier grounds, such
as ruderal and grassland habitats. No Project
activities shall be conducted within 50 feet of suitable
tidal marsh or other salt marsh harvest mouse habitat
within 2 hours before and after an extreme high tide
event (6.5 feet or higher measured at the Golden
Gate Bridge and adjusted to the timing of local high
tides) or when the adjacent marsh is flooded unless
wildlife exclusion fencing has been installed around
the work area.
• All construction equipment and materials shall be
staged on existing roadways and away from suitable
salt marsh harvest mouse habitat when not in use. All
construction equipment shall be visually inspected
prior to work activities each day for signs of salt
marsh harvest mouse or any other wildlife.
• Vegetation shall be removed from all non-marsh
areas of disturbance (driving roads, grading and
stockpiling areas) to discourage the presence of salt
marsh harvest mouse.
• A USFWS- and CDFW-approved biologist with
previous salt marsh harvest mouse monitoring and/or
surveying experience shall be on site during
construction activities occurring in suitable habitat.
The USFWS- and CDFW-approved biologist has the
authority to stop Project activities if any of the
requirements associated with these measures are not
being fulfilled. If a harvest mouse is observed in the
work area, construction activities shall cease in the
immediate vicinity of the potential salt marsh harvest
mouse. The individual shall be allowed to leave the
area before work is resumed. If the individual does
not move on its own volition, the USFWS-approved
biologist would contact USFWS (and CDFW if
appropriate) for further guidance on how to proceed.
• If the USFWS- and CDFW-approved biologist has
requested work stoppage because of take of any of
Exhibit A-11
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
the listed species, or if a dead or injured salt marsh
harvest mouse is observed, the USFWS and CDFW
shall be notified within 1 day by email or telephone.
Mitigation Measure 3.4-5: Special-Status Plant
Protection
• Prior to the start of construction, a qualified biologist
shall conduct a properly timed special-status plant
survey for Marin knotweed (Polygonum marinense),
Suisun Marsh aster (Symphyotrichum lentum),
Congested-headed hayfield tarplant (Hemizonia
congesta subsp. congesta), and Point Reyes bird's-
beak (Chloropyron maritimum ssp. palustre) within the
species’ suitable habitat within the Project work limits.
The survey shall follow the CDFW Protocols for
Surveying and Evaluating Impacts on Special Status
Native Plant Populations and Sensitive Natural
Communities (CDFW 2018). If special-status plant
species are identified within the Project work limits,
then the biologist shall establish an appropriate buffer
area for each plant population to exclude activities that
directly remove or alter the habitat of, or result in
indirect adverse impacts on, the special-status plant
species. A qualified biologist shall oversee installation of
a temporary, mesh-type construction fence (Tensor
Polygrid or equivalent) at least 4 feet (1.2 meters) tall
around any established buffer areas to prevent
encroachment by construction vehicles and personnel.
The qualified biologist shall determine the exact
location of the fencing. The fencing shall be strung
tightly on posts set at maximum intervals of 10 feet
(3 meters) and shall be checked and maintained weekly
until all construction is complete. The buffer zone
established by the fencing shall be marked by a sign
stating:
− “This is habitat of [list rare plant(s)], and must not be disturbed.
This species is protected by [the ESA of 1973, as
amended/CESA/California Native Plant Protection Act].”
Marin Audubon
Society and
contractors
City Prior to start of
construction, during
construction, at time of
contract
specifications, and at
time of encounter of
species (as
applicable)
Exhibit A-12
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
• If direct impacts cannot be avoided, the City shall
require the project sponsor to prepare a plan for
minimizing the impacts by one or more of the following
methods: (1) salvage and replant plants at the same
location following construction; (2) salvage and
relocate the plants to a suitable off-site location with
long-term assurance of site protection; (3) collect
seeds or other propagules for reintroduction at the site
or elsewhere; or (4) payment of fees in lieu of
preservation of individual plants, to be used for
conservation efforts elsewhere. The City shall review
and approve the plan.
• The success criterion for any seeded, planted, and/or
relocated plants shall be full replacement at a 1:1 ratio
after 5 years. Monitoring surveys of the seeded,
planted, or transplanted individuals shall be conducted
for a minimum of 5 years, to ensure that the success
criterion can be achieved at year 5. If it appears the
success criterion would not be met after 5 years,
contingency measures may be applied. Such
measures shall include, but not be limited to:
additional seeding and planting, altering, or
implementing weed management activities, or
introducing or altering other management activities.
• Any special-status plant species observed during
surveys shall be reported to the CDFW and submitted
to the CNDDB and reported to USFWS, if federally
listed.
Mitigation Measure 3.4-6: Fish and Marine Mammal
Protection During Pile Driving
Prior to the start of any in-water construction that would
require pile driving, the Project sponsor shall prepare a
NOAA and CDFW-approved sound attenuation
monitoring plan to protect fish and marine mammals, and
the approved plan shall be implemented during
construction. This plan shall provide detail on the sound
attenuation system, detail methods used to monitor and
Marin Audubon
Society and
contractors
City Prior to start of and
during in-water
construction, at time of
contract
specifications, and at
time of exceedance of
sound criteria or
encounter of species
(as applicable)
Exhibit A-13
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
verify sound levels during pile driving activities (if required
based on projected in-water noise levels), and describe
methods to reduce impact pile-driving in the aquatic
environment to an intensity level less than 120 dB (RMS)
continuous noise level for marine mammals at a distance
of 1,640 feet. The plan shall incorporate, but not be
limited to, the following elements:
• All in-water construction shall be conducted within the
established environmental work window between June
1 and November 30, designed to avoid potential
impacts on fish species.
• To the extent feasible, vibratory pile drivers shall be
used for the installation of all support piles. Vibratory
pile driving shall be conducted following the USACE
“Proposed Procedures for Permitting Projects that will
Not Adversely Affect Selected Listed Species in
California.” The USFWS and NMFS completed
Section 7 consultation on this document, which
establishes general procedures for minimizing impacts
on natural resources associated with projects in or
adjacent to jurisdictional waters.
• If NOAA sound level criteria for marine mammals are
exceeded during vibratory hammer pile installation, a
NOAA-approved biological monitor shall be available
to conduct surveys before and during pile driving to
inspect the work zone and adjacent waters for marine
mammals. The monitor shall be present as specified
by NMFS during impact pile driving and ensure that:
− The safety zones established in the sound
monitoring plan for the protection of marine
mammals are maintained.
− Work activities are halted when a marine mammal
enters a safety zone and resumed only after the
animal has left the area or has not been observed
for a minimum of 15 minutes.
Exhibit A-14
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
Mitigation Measure 3.4-7: Tree Ordinance
• Any tree-related work (removal, planting, or pruning)
shall adhere to the City of San Rafael Municipal Code
Section 11.12. Specifically, written permit must be
issued to cut, prune, break, injure, or remove any
living tree in, upon, or along any public street,
sidewalk, or walkway in the city or cut, disturb, or
interfere in any way with the roots of any tree in, upon,
or along any street, sidewalk, or walkway, or spray
with any chemical or insecticide any tree in, upon, or
along any public street, sidewalk, or walkway, or place
any sign, poster, or other fixture on any tree or tree
guard, or injure, misuse, or remove any device placed
to protect any tree in, upon, or along any public street,
sidewalk, or walkway in the city.
Whenever any tree shall be cut down or removed in or
from any sidewalk area, its butt and roots shall be dug
up and removed, or cut level with the ground, as
directed by the public works department.
• In the erection or repair of any building or structure,
guards shall be placed around all nearby trees in,
upon, or along the public streets, sidewalks, and
walkways within the city as shall prevent injury to
them.
Marin Audubon
Society and
contractors
City of San Rafael
Public Works
Department
Prior to start of
construction, during
construction, and at
time of contract
specifications
CULTURAL RESOURCES, APPENDIX B. INITIAL STUDY SECTION B.3
Mitigation Measure CUL-1: Cultural Resources
Awareness Training and Inadvertent Discovery of
Archaeological Resources or Tribal Cultural
Resources
Prior to authorization to proceed, a qualified
archaeologist, defined as an archaeologist meeting the
U.S. Secretary of the Interior’s Professional Qualification
Standards for Archeology, shall conduct a training
program for all construction and field workers involved in
site disturbance. On-site personnel shall attend a
mandatory pre-Project training that shall outline the
Marin Audubon
Society and
contractors
City Prior to authorization
to proceed, at time of
contract
specifications, and at
time of resource
encounter, as
applicable
Exhibit A-15
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
general archaeological sensitivity of the area and the
procedures to follow in the event an archaeological
resource and/or human remains are inadvertently
discovered.
If pre-contact or historic-era archaeological resources are
encountered during Project implementation, all
construction activities within 100 feet shall halt, and a
qualified archaeologist shall inspect the find within
24 hours of discovery and notify the City of the initial
assessment. Pre-contact archaeological materials might
include obsidian and chert flaked-stone tools (e.g.,
projectile points, knives, scrapers) or toolmaking debris;
culturally darkened soil (“midden”) containing heat-
affected rocks, artifacts, or shellfish remains; stone milling
equipment (e.g., mortars, pestles, handstones, or milling
slabs); and battered stone tools, such as hammerstones
and pitted stones. Historic-era materials might include
building or structure footings and walls, and deposits of
metal, glass, and/or ceramic refuse.
If the City determines, based on recommendations from a
qualified archaeologist and a Native American
representative (if the resource is pre-contact indigenous
related), that the resource may qualify as a historical
resource or unique archaeological resource (as defined in
CEQA Guidelines Section 15064.5) or a tribal cultural
resource (as defined in Public Resources Code [PRC]
Section 21080.3), the resource shall be avoided if
feasible. Consistent with Section 15126.4(b)(3), this may
be accomplished through planning construction to avoid
the resource, incorporating the resource within open
space, capping and covering the resource, or deeding the
site into a permanent conservation easement.
If avoidance is not feasible, the City shall consult with
appropriate Native American tribes (if the resource is pre-
contact indigenous related), and other appropriate
interested parties to determine treatment measures to
avoid, minimize, or mitigate any potential impacts to the
resource pursuant to PRC Section 21083.2, and CEQA
Exhibit A-16
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
Guidelines Section 15126.4. This shall include
documentation of the resource and may include data
recovery (according to PRC Section 21083.2), if deemed
appropriate, or other actions such as treating the resource
with culturally appropriate dignity and protecting the
cultural character and integrity of the resource (according
to PRC Section 21084.3).
Mitigation Measure CUL-2: Inadvertent Discovery of
Human Remains
If potential human remains are encountered, all work shall
halt within 100 feet of the find and the City shall be
contacted by on-site construction crews. The City shall
contact the Marin County coroner in accordance with
PRC Section 5097.98 and Health and Safety Code
Section 7050.5. If the coroner determines that the
remains are Native American, the coroner shall contact
the NAHC. As provided in PRC Section 5097.98, the
NAHC shall identify the person or persons believed to be
the Most Likely Descendant (MLD). The MLD shall make
recommendations for the means of treating, with
appropriate dignity, the human remains and any
associated grave goods, as provided in PRC Section
5097.98.
Marin Audubon
Society and
contractors
City At time of contract
specifications and at
time of remains
discovery, as
applicable
TRANSPORTATION AND TRAFFIC, APPENDIX B. INITIAL STUDY SECTION B.13
Mitigation Measure TRAN-1: Construction Traffic
Control Plan
Prior to the issuance of construction permits, the
construction contractor shall prepare and submit a
Construction Traffic Control Plan to the City of San Rafael
Public Works Department for approval. The Construction
Traffic Control Plan must be prepared in accordance with
both the California Department of Transportation Manual
on Uniform Traffic Control Devices and Work Area Traffic
Control Handbook and must address, at a minimum, the
following issues:
Marin Audubon
Society and
contractors
City of San Rafael
Public Works
Department
Prior to issuance of
construction permits,
during construction,
and at time of contract
specifications
Exhibit A-17
EXHIBIT A
Mitigation Measure
Party Responsible
for Ensuring
Implementation
Party Responsible
for Monitoring
Monitoring
Timing
Compliance Verification
Initial Date
Project/
Comments
• Defining truck haul routes to/from the Project that avoid
residential streets, to the extent feasible.
• Placing temporary signing, lighting, and traffic control
devices if required, including, but not limited to,
appropriate signage along access routes to indicate the
presence of heavy vehicles and construction traffic.
• Provision of construction personnel at driveway on
Spinnaker Point Drive leading to construction staging
area to direct traffic, pedestrians, and bicyclists while
trucks are turning into and out of the driveway.
• Notification of all construction activities with San Rafael
City Schools at least two months in advance, so that it
may make proper accommodations for any possible
limitations to access at Bahia Vista Elementary School.
San Rafael City Schools shall be notified of the timing,
location, and duration of construction activities. The
construction contractor shall be required to ensure that
construction of the Proposed Project does not inhibit
vehicle, bicycle, pedestrian, and/or school bus service
through inclusion of such provisions in the construction
contract.
EXHIBIT 3
3-1
RESOLUTION NO.
RESOLUTION OF THE SAN RAFAEL PLANNING COMMISSION CONDITIONALLY
APPPOVING A USE PERMIT (UP21-001) AND AN ENVIRONMENTAL AND DESIGN
REVIEW PERMIT (ED21-002) FOR THE DEVELOPMENT OF THE TISCORNIA MARSH
RESTORATION PROJECT, EAST CANAL STREET
(CASE NOS. UP21-001, ED21-002)
WHEREAS, the Tiscornia Marsh covers 23 acres of tidal marsh and Baylands, as well as
over 2,000 lineal feet of shoreline levee that are bay ward of Albert J Boro Community Center and
Pickleweed Park. The Tiscornia Marsh is owned by Marin Audubon Society; and
WHEREAS, over the past decades, the Tiscornia Marsh property has experienced
considerable erosion along its bay ward edge, which is attributed to the wave action from the San
Francisco Bay. As a result, approximately three acres of valuable tidal marsh has been lost due
to erosion; and
WHEREAS, in June 2016, the Bay Area counties approved Measure AA, a parcel tax
measure which places a $12.00 per year tax on every parcel in the Bay Area. The purpose of the
Measure AA tax is to generate funds for marsh restoration projects around the San Francisco and
San Pablo Bays. The goal is to improve water quality, restore wildlife habitat, and to protect
communities from increased flooding and sea level rise; and
WHEREAS, in 2018, Marin Audubon Society applied for and successfully secured a
Measure AA grant to fund the design, permitting, and CEQA/environmental review for a
restoration of the Tiscornia Marsh. The Measure AA application was endorsed by the San Rafael
City Council on October 1, 2018 (adoption of City Council Resolution 14592). As part of the
Measure AA application process, the restoration project was expanded to incorporate/include the
City-owned, five-acre, diked marsh located north of the Pickleweed Park playfields; and
WHEREAS, on January 3, 2021, Marin Audubon Society applied for planning applications
(Use Permit, UP21-001 and Environmental and Design Review Permit ED21-002) to seek City
approval of the Tiscornia Marsh Restoration Project. Per the SRMC Title 14 (Zoning), these
applications are required as the project is located within the PD (Planning Development) and WO-
(Wetland Overlay) Districts; and
WHEREAS, pursuant to the provisions of the California Environmental Quality Act (CEQA)
Guidelines, the Tiscornia Marsh Restoration Project is subject to environmental review. It was
determined that the project has the potential to result in potentially significant environmental
effects, and the preparation of an Environmental Impact Report was recommended. Following the
provisions of the CEQA Guidelines, and Environmental Impact Report was prepared to assess
the impacts of the restoration project (Tiscornia Marsh Restoration Project Final Environmental
Impact Report [FEIR]). The Planning Commission has: a) reviewed the FEIR finding it to be
adequate and complete; and b) certified the FEIR by separate resolution; and
WHEREAS, prior to taking action to approve the planning applications for the project, the
CEQA Guidelines require that the findings and recommendations of the FEIR be considered, and
that all FEIR mitigation measures be incorporated into this action. To comply with this
requirement, by separate resolution, the Planning Commission has adopted CEQA Findings of
Fact and adopting a Mitigation Monitoring and Reporting Program (MMRP) to support action on
the planning applications; and
EXHIBIT 3
3-2
WHEREAS, on January 11, 2022, the Planning Commission held a duly noticed public
hearing on the planning applications filed for this project (UP21-001 and ED21-002), accepting all
public testimony and the written report of the Community Development Department staff; and
WHEREAS, the custodian of documents which constitute the record of proceedings upon
which this decision is based, is the Community Development Department.
NOW, THEREFORE, BE IT RESOLVED, that the Planning Commission hereby
conditionally approves Use Permit UP21-001 and Environmental and Design Review Permit
ED21-002 for the Tiscornia Marsh Restoration Project based upon the following findings required
by San Rafael Municipal Code (SRMC) Title 14 - Zoning:
Findings for Use Permit (UP21-001)
1. The proposed Tiscornia Marsh Restoration Project is in accord with the San Rafael General
Plan 2040 (General Plan), the objectives of the Zoning Ordinance and the purposes of the
PD-WO (Planned Development- Wetland Overlay), P/OS-WO (Parks/Open Space – Wetland
Overlay), and P/OS (Parks/Open Space – Canalfront Review Overlay) zoning Districts in
which the project site is located in that:
a. The proposed restoration project would not dramatically change the use of the property,
which is undeveloped tidelands, tidal/seasonal marsh, and upland levee which are
permitted uses in and consistent with the Water, Conservation, and Park, Recreation and
Open Space General Plan land uses designations that are adopted for and applicable to
the project site.
b. As outlined below, under the findings for approval of Environmental and Design Review
Permit ED21-002, the restoration project would maintain and enhance the current
undeveloped tidelands, tidal marsh, and upland levee uses, which would be consistent
with and permitted by the PD-WO, P/OS-WO, and P/OS-C Districts.
c. The proposed restoration project would involve grading, including filling and dredging
within the tidelands and tidal marsh areas, which is required to convert an existing diked
marsh to a tidal marsh, and to raise the shoreline levee. This activity is necessary to
achieve goal of the project, which is to enhance and expand a natural resource and to
improve flood protection. The provisions of the SRMC Title 14 – Wetland Overlay (-WO)
District require the approval of a Use Permit for this activity with required findings that this
activity: 1) will be consistent with the policies of the General Plan; 2) would minimize and
mitigate impacts to wetlands; and 3) would be supported by and following consultation
with the appropriate regulatory agencies. As noted above, the activity would enhance and
expand a natural resource, which would be consistent with the General Plan and the
provisions of the -WO Overlay District. In addition, the Tiscornia Marsh Restoration Project
FEIR has determined that environmental impacts from this activity can be mitigated to
less-than-significant levels. Lastly, the appropriate regulatory agencies (California
Department of Fish & Wildlife and US Fish & Wildlife Service) have been consulted and
are supportive of the restoration project, subject to required permitting and specific
conditions, which are incorporated herein.
2. As proposed and as conditioned, the tidelands, tidal marsh, seasonal marsh and raised levee
that would result from the restoration project will not be detrimental to the public health, safety,
or welfare or materially injurious to properties or improvements in the vicinity. Rather, the
project will enhance and improve the existing condition of the project site, resulting in improved
native habitats and reduced flooding risk to the general area. Further, the project would
EXHIBIT 3
3-3
promote and facilitate the enhancement and expansion of existing natural resources and
would raise and re-align the existing shoreline levee for greater flood protection and
adaptation to projected sea level rise, which is critical to the protection of public safety and
health to the community at large.
3. As proposed and conditioned, the enhanced and expanded tidelands, tidal marsh, seasonal
marsh, and raised and re-aligned shoreline levee uses comply with each of the applicable
provisions of the Zoning Ordinance (SRMC Title 14) in that:
a. SRMC Chapter 14.07 of the Zoning Ordinance sets forth requirements for uses and
development within the PD (Planned Development) District. The provisions set forth in
SRMC Section 14.07.020 state that no use other than an existing use or a temporary
use shall be approved without a development plan that is adopted by ordinance of the
City Council. As the proposed project will not dramatically change but would enhance
the existing land use, no development plan is required. However, as provided in
Section 14.07.020, approval of a Use Permit is required; Use Permit UP21-001
complies with this requirement.
b. SRMC Chapter 14.10 of the Zoning Ordinance sets forth general site and use
regulations that are applicable to the P/OS (Parks/Open Space) District. The City-owned
diked marsh portion of the project area is within the P/OS District. The proposal to
convert this diked marsh to tidal marsh would be defined as a “wildlife preserve or
sanctuary,” which is consistent with and a permitted use within the P/OS District.
c. SRMC Chapter 14.13 of the Zoning Ordinance sets forth general site and use
regulations that are applicable to the -WO (Wetland Overlay) District. The project would
be consistent with the purposes of the -WO District (SRMC Section 14.13.010) in that it
would: 1) preserve and enhance wetlands; 2) contribute to improve water quality for the
general area; 3) enhance wildlife habitat, particularly for rare and endangered species;
and 4) expand public recreational activities (shoreline levee path) that would be
compatible with the wetland habitat. Further, the project is consistent with the provisions
and requirements of SRMC Section 14.13.050 as the planning applications being
considered includes the subject Use Permit and a wetland restoration plan. Lastly, as
conditioned, the project will be subject to a wetland management plan.
d. SRMC Chapter 14.15 of the Zoning Ordinance sets forth general site and use
regulations that are applicable to the -C (Canalfront Review Overlay) District. The project
would be consistent with the purposes of the -C District (Section 14.15.010) in that it
would: 1) improve and enhance public views to the canal front; 2) protect the unique
physical and social characteristics of the canal front area; and 3) would not impair or
block the navigable channel of the San Rafael Canal.
Findings for Environmental and Design Review Permit (ED21-002)
1. As proposed and as conditioned, the Tiscornia Marsh Restoration Project, which includes the
restoration and enhancement of tidelands and tidal marsh, the conversion of a dike marsh to
tidal marsh and the raising and re-alignment of an existing shoreline levee, is in accord with
the San Rafael General Plan 2040 (General Plan) in that:
a. The Land Use Map of the Land Use Element designates the project site area in three land
use categories, Conservation, Water, and Park, Recreation and Open Space. These
General Plan land use designations permit wetland preserves and sanctuaries, as well
public access for recreational uses (shoreline path along levee). As proposed and
conditioned, the project would be consistent with these land use designations.
EXHIBIT 3
3-4
b. As proposed, the project would be consistent with and promote applicable goals and
policies set forth in the Conservation and Climate Change Element. Specifically, the
project would be consistent with Policies C-1.2 (Wetland and Sea Level Rise), C-1.3
(Wetland Protection and Mitigation), C-1.4 (Wetland Creation), C-1.12 (Native or Sensitive
Habitats), and C-1.13 (Special Status Species) in that as designed it: 1) incorporates an
“ecotone” marsh design and a raised and rea-aligned shoreline levee which are elements
for combatting and adapting to projected sea level rise; 2) provides for now only wetland
protection, but an enhancement and enlargement of wetlands; 3) expands the wildlife
corridor; and 4) enhances habitat for wildlife, particularly habitat for rare and endangered
species. Lastly, the project would be Policy PROS-1.17 (Public/Private Partnerships) in
that it would combine contiguous like-sites owned by Marin Audubon Society and the City
of San Rafael in achieving a cohesive and comprehensive restoration plan that would
optimize opportunities for expanded wetland habitat and flood control protection.
c. As proposed, the project would be consistent with and promote applicable goals and
policies set forth in the Neighborhoods Element. Specifically, the project would be
consistent with Policies NH-3.2 (Canal Maintenance), NH-3.6 (Public Access), and NH-
3.8 (Flood Control Improvements) in that as designed, it would: 1) not impair or block the
access channel along the San Rafael Canal for continued navigation and maintenance;
2) serve as a potential receiver site for dredge spoils generated by canal channel
maintenance; 3) continue to provide and would enhance public shoreline access along a
raised and re-aligned levee; and 4) include elements that would improve flood control for
the general area.
d. As proposed and conditioned, the project would be consistent with the applicable goals
and policies set forth in the Noise Element. As determined by the Tiscornia Marsh
Restoration Project FEIR, project construction will result in temporary noise and vibration
impacts. The FEIR recommends mitigation measures to reduce these impacts to a less-
than-significant level. Implementation of the mitigation measures ensures consistency with
Noise Element policies N-1.6 (Traffic Noise) and N-1.11 (Vibration), as well as the
provisions and regulations of the City’s noise ordinance (SRMC Chapter 8.13).
e. As proposed and as conditioned, the project would be consistent with the applicable goals
and policies of the Safety and Resilience Element. Specifically, the project would be
consistent with, among others, Policies S-3.4 (Mitigating Flooding and Sea Level Rise)
and S-3.7 (Shoreline Levees) in that it includes project features such as the raising and
re-alignment of the shoreline levee and the creation of an ecotone (horizontal levee) that
are effective in combatting increased flooding and risk from projected sea level rise.
f. As proposed, the project would be consistent with the applicable goals and policies of the
Community Design and Preservation Element. Specifically, as determined by the findings
of the Tiscornia Marsh Restoration Project FEIR, the project would be consistent with
Policies CPD-1.2 (Natural Features) and CDP-1.5 (Views) in that it would: 1) not result in
any major visual changes to the natural features in the area; 2) not block views of the bay
and other scenic vistas.
2. As proposed and as conditioned, the proposed project is consistent with the objectives and
the provisions of the San Rafael Zoning Ordinance (SRMC Chapter 14). Specifically, the
proposed wetland restoration project is consistent with the processes and site development
regulations in the PD-WO (Planned Development- Wetland Overlay), P/OS-WO (Parks/Open
Space – Wetland Overlay), and P/OS (Parks/Open Space – Canalfront Review Overlay)
zoning Districts, in which the project site is located.
EXHIBIT 3
3-5
3. As proposed and as conditioned, the project design is consistent with all applicable site,
architecture and landscaping design criteria and guidelines set forth in SRMC Chapter 14.25
(Environmental and Design Review Permits) for the site in that:
a. As proposed, the site plan is acceptable for the site and intended use is generally
harmonious with the other neighboring natural resources, as well as the variety of urban
uses and improvements surrounding the project site. The project site plan has been
designed to minimize impacts to adjacent properties, while maximizing opportunities for
habitat enhancement, flood control and sea level rise protection, and public shoreline
access.
b. As proposed and as conditioned, the project presents a competent design which has been
prepared by environmental professionals (hydrologists and biologists) skilled in designing
wetland restoration projects. The competency of the project design has been confirmed
by the findings presented in the Tiscornia Marsh Restoration Project FEIR.
c. To address temporary impacts associated with project construction, as proposed and
conditioned, the project proposes site access and circulation that promotes safe access
for construction vehicles and apparatus without impairing street circulation.
4. As determined by the Tiscornia Marsh Restoration Project FEIR and as conditioned herein,
the project design and improvements would not result in adverse environmental impacts in
that:
a. Technical supportive studies prepared by qualified technical experts were prepared in
environmental topic areas of, among others, biological resources, hydrology and water
quality, historic resources, archaeological resources, geology/soils, hazards and
hazardous materials, traffic/circulation, to assess the potential environmental impacts of
the project.
d. Consistent with the California Environmental Quality Act (CEQA) Guidelines, the
supportive technical studies were used in the preparation of an Tiscornia Marsh
Restoration Project FEIR. This FEIR has concluded that all potentially significant
environmental impacts of the project can be mitigated to a less-than-significant level.
e. Mitigation measures recommended in the FEIR, and supportive Mitigation Monitoring and
Reporting Program (MMRP) have been incorporated as conditions of approval in this
Environmental and Design Review Permit.
5. As proposed and as conditioned, the restoration project will not be detrimental to the public
health, safety, or welfare or materially injurious to properties or improvements in the vicinity.
Rather, the project will enhance and improve the existing condition of the project site, resulting
in improved native habitats and reduced flooding risk to the general area. Further, the project
would promote and facilitate the enhancement and expansion of existing natural resources
and would raise and re-align the existing shoreline levee for greater flood protection and
adaptation to projected sea level rise, which is critical to the protection of public safety and
health to the community at large.
BE IT FURTHER RESOLVED that the Planning Commission hereby approves Use Permit
UP21-001 and Environmental and Design Review Permit ED21-002 subject to the following
conditions:
Conditions for Use Permit UP21-001
EXHIBIT 3
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1. This Use Permit (UP21-001) approves the Tiscornia Marsh Restoration Project for the 28-
acre project site, which includes the following properties, uses, and activities:
a. The 23 acres of submerged tidelands, tidal marsh and levee owned by the Marin
Audubon Society, located within the PD-WO (Planned Development – Wetland Overlay)
District.
b. The five (5) acres of diked marsh owned by the City of San Rafael (Pickelweed Park
marsh), located within the P/OS (Parks/Open Space) District. The area is approved to be
restored to tidal action for a tidal marsh, and a new shoreline raised levee is approved
for construction along the inland edges of the to be restored approved tidal marsh.
c. The approval of fill, dredging and general grading of submerged tidelands, tidal marsh,
and diked marsh areas, which are defined as wetlands designated by US Army Corps of
Engineers jurisdiction. This activity authorized through approval of this Use Permit
pursuant to SRMC Section 14.13.050 (-WO Overlay District).
d. A new shoreline levee extending along the bay front. For the shoreline levee, this Use
Permit approves public access for recreation use and maintenance. As required by
Environmental and Design Review Permit ED21-002 conditions of approval, a public
access easement over the privately-owned portion of the new shoreline levee shall be
offered for dedication to the City of San Rafael.
2. This Use Permit (UP21-001) shall be valid for two (2) years from the date of Planning
Commission approval or January 11, 2024 and shall become null and void unless a grading
permit is issued, or a time extension has been granted.
3. The Zoning Administrator may review and approve minor amendments to the Use Permit.
4. The approved use and wetland restoration is subject to the provisions of SRMC Chapter
14.13, the Wetland Overlay (-WO) zoning district. SRMC Section 14.13.090 requires that a
wetland management plan be prepared and implemented for all wetland creation and
restoration. This requirement is addressed in Environmental and Design Review Permit
ED21-002, condition 10, below. Following completion of the project, the created wetland
may be subject to periodic review and monitoring by the City to ensure that it successfully
achieves the goals and objectives outlined in the approved wetland management plan.
Conditions for Environmental and Design Review Permit ED21-002
General Conditions
1. This Environmental and Design Review Permit ED21-002 shall be valid for two (2) years
from the date of Planning Commission approval or January 11, 2024 and shall become null
and void unless a grading permit is issued, or a time extension has been granted.
2. The construction of the Tiscornia Marsh Restoration project shall be in substantial
conformance with the preliminary plans prepared by Environmental Science Associates, Inc,
( date stamped approved January 11, 2022) approved with Design Review Permit ED21-
002. Plan modifications deemed not to be minor by the Community Development Director
may require review by the Planning Commission.
3. Formal approval and authorization to incorporate the City-owned Pickleweed Park diked
marsh into the Tiscornia Marsh Restoration project shall be granted by the City Council. This
authorization shall be in a form acceptable to the City Attorney.
EXHIBIT 3
3-7
4. All activity is subject to a City Grading Permit filed with and issued by the Department of
Public Works. A Tidelands Permit may be required, as determined by the City Engineer. Any
and all above ground improvements or structures proposed in the final construction plans
may be subject to the approval and issuance of a Building Permit, as determined by the
Chief Building Official.
5. Unless addressed as a separate condition of approval, the project sponsor shall be
responsible for implementing all mitigation measures presented in the Tiscornia Marsh
Restoration Project Final Environmental Impact Report (FEIR, 2021) and the approved
Mitigation Monitoring and Reporting Program (MMRP), on file with the Department of
Community Development. Consistent with the City-adopted development fees, the project
sponsor is required to pay a Mitigation Monitoring Fee, which shall be charged and collected
through implementation of the MMRP.
Prior to the Issuance of a Grading Permit and/or Tidelands Permit
Community Development Department
6. Plans submitted for a grading permit shall include a plan sheet, which incorporates the list of
these ED21-002 conditions of approval.
7. The project sponsor shall secure all required approvals and/or permits from other regulatory
agencies including, but not limited to the Bay Conservation and Development Commission
(BCDC), US Army Corps of Engineers, Regional Water Quality Control Board (RWQCB), US
Fish and Wildlife Service. Proof of permit issuance of approval shall be submitted to the City.
8. A final landscape and irrigation plan shall be submitted to Community Development
Department for review and approval. This final plan shall be prepared to demonstrate:
a. Compliance with the Marin Water (MMWD) water conservation ordinance (MMWD
Ordinance 430). The final plan shall be reviewed and approved by Marin Water staff
prior to submittal to the City. Marin Water approval can be in the form of a letter and/or
plan approval stamp.
b. Compliance with the San Rafael Shoreline Park Master Plan, October 1989 and
Shoreline Enhancement Plan, August 1991. Consistent with the recommendations of
these Plans, the final plans shall include and incorporate the following:
1) Wildlife interpretive signs informing the public and visitors as to the purpose of the
marsh restoration.
2) Wayfinding signage guiding public access and use.
3) Installation of viewing benches and trash receptacles with the number and location
determined by the Public Works and Library and Parks Departments; and
4) Installation of a four-foot-high vinyl clad chain link fence installed on the outboard
slope of the new shoreline levee (placed above the mean high tide line). The
purpose of this fence is to prohibit access to the marsh by dogs, similar animals,
and humans.
5) Installation of an all-weather asphalt path along the top of the new shoreline levee.
The asphalt surface shall be ten feet (10’) in width. A one-foot (1’) wide strip of
decomposed granite shall be installed on both sides of the asphalt path.
6) Use of Blue-rock rip rap for the new shoreline levee for the outboard slope banks.
Use of broken, recycled concrete with exposed rebar is not permitted for slope bank
reinforcement.
EXHIBIT 3
3-8
9. Per SRMC Section 14.13.090, preparation of a final wetland management plan is required.
A wetland management plan shall be prepared by a wetland specialist and submitted to the
Community Development Department for approval. The wetland management plan shall
include the required components outlined in SRMC Section 14.13.090 such as but not
limited to: goals and objectives; restoration techniques and standards; planting plan; site
preparation specifications; and a monitoring plan. Some of these components are required
by other conditions included herein.
Department of Public Works
10. A survey of the project site shall be prepared by a licensed surveyor. The survey shall
accurately determine and plot the boundary lines and elevations of all parcels comprising the
project site area.
11. A detailed grading and drainage plan shall be prepared and submitted with the application for
a grading permit. The plan shall be prepared by a registered civil engineer or hydrology
engineer. The final grading and drainage plan shall be subject to review and approval by the
City Engineer.
12. An engineered site plan shall be prepared by a licensed civil engineer based on the property
survey required above. This engineered site plan shall include the following details and
information:
a. The new and re-aligned shoreline levee designed with a minimum crest elevation of 13
feet based on the NAVD88 datum.
b. The future levee trail between the Pickleweed Park playfields and the current diked marsh
area (to be breached for new tidal marsh) shall allow for a 20-foot-wide buffer from the
edge of the playfield (soccer field) and the inboard toe of the levee slope.
13. No mass grading shall occur between October 15 and April 15, unless approved by the City
Engineer.
14. A public access easement is required to be offered for dedication along the private portions
of the new shoreline levee. The public access easement for shoreline levee shall be prepared
and recorded with the County of Marin in a form acceptable to the City Attorney and City
Engineer.
15. A detailed geotechnical investigation shall be submitted with the grading permit application.
The final plans prepared for issuance of a grading permit shall comply with and address the
recommendations presented in the detailed geotechnical investigation.
16. The construction staging area site shall be approved by the Department of Public Works and
the Library and Parks Department. A site plan of the approved construction staging area shall
be prepared and submitted to the Department of Public Works for approval. The plan shall
include perimeter security fencing and a single-access gate.
17. A construction management plan shall be prepared to demonstrate that the project will
comply with the following measures:
a. Compliance with the authorized construction hours per SRMC Chapter 8.13 (Noise).
Authorized construction hours are specified below in a separate condition.
b. An approved construction staging area A construction staging plan is required (see
condition 17, above)
c. Construction noise attenuation measures.
EXHIBIT 3
3-9
d. Areas of material storage and stockpiling.
e. Signs to be posted at the entrance to the staging and construction areas providing
information about construction, the names and contact information of the contractor and
the City of San Rafael staff.
f. A construction vehicle route, traffic management plan, and construction logistics
approved by the City Engineer.
18. The project sponsor shall prepare and submit a construction management plan to implement
the following dust control measures during project construction:
a. Water all active construction areas as necessary.
b. Cover all trucks hauling soil, sand, and other loose materials or require all trucks to
maintain at least two feet of freeboard.
c. Sweep daily (with water sweepers) all paved access roads, parking areas and staging
areas at construction sites.
d. Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent
public streets.
e. Install sandbags or other erosion control measures to prevent silt runoff to public
roadways.
f. Replant vegetation in disturbed areas as quickly as possible
g. Install wheel washers for all exiting trucks or wash off the tires or tracks of all trucks and
equipment leaving the site.
h. Install wind breaks, or plant trees/vegetative wind breaks at windward side(s) of
construction areas.
19. The project proposes over 5,000 square feet of impervious surface coverage. A storm water
control/erosion control plan shall be prepared in compliance with the MCSTOPPP
requirements. The plan shall be submitted with the application for a grading permit and shall
include written documentation and standard specifications that are provided by the County
of Marin. The standard specifications can be accessed at the County of Marin website:
Http://www.marincounty.org/depts/pw/divisions/mcstoppp/development/new-and-
redevelopment-project
20. Plans submitted to for a grading permit shall include a specification sheet addressing
pollution prevention. A standard specification sheet entitled, “Pollution Prevention – It’s Part
of the Plan” is available for this purpose and can be accessed at www.cityofsanrafael.org.
21. The project includes work within the City of San Rafael public right-of-way. The plans
submitted with the grading permit shall show the location and type of utilities within the right-
of-way and the ‘tie-in” locations for utility service to the site. Prior to any work within the City
right-of-way, an encroachment permit shall be secured from the Public Works Department.
22. The construction contractor shall prepare and submit a Construction Traffic Control Plan to
the Public Works Department for approval. The Construction Traffic Control Plan must be
prepared in accordance with both the California Department of Transportation Manual on
Uniform Traffic Control Devices and Work Area Traffic Control Handbook and must address,
at a minimum, the following issues:
a. Placing temporary signing, lighting, and traffic control devices if required, including, but
not limited to, appropriate signage along access routes to indicate the presence of heavy
vehicles and construction traffic.
EXHIBIT 3
3-10
b. Provision of construction personnel at driveway on Spinnaker Point Drive leading to
construction staging area to direct traffic, pedestrians, and bicyclists while trucks are
turning into and out of the driveway.
c. Notification of all construction activities with San Rafael City Schools at least two months
in advance, so that it may make proper accommodations for any possible limitations to
access at Bahia Vista Elementary School. San Rafael City Schools shall be notified of
the timing, location, and duration of construction activities. The construction contractor
shall be required to ensure that construction of the Proposed Project does not inhibit
vehicle, bicycle, pedestrian, and/or school bus service through inclusion of such
provisions in the construction contract.
(FEIR Mitigation Measure TRAN-1)
23. A copy of the executed construction contract shall be submitted to the City Engineer. The
contract shall include a written list of instructions to be carried out by the construction
manager specifying measures to minimize emissions generated by heavy construction
equipment.
Prior to Commencement of Construction
24. To ensure protection of special status plant species, prior to commencement of construction,
the following measures shall be completed and implemented:
a. A qualified biologist shall conduct a properly timed specialstatus plant survey for Marin
knotweed (Polygonum marinense), Suisun Marsh aster (Symphyotrichum lentum),
Congested-headed hayfield tarplant (Hemizonia congesta subsp. congesta), and Point
Reyes bird's-beak (Chloropyron maritimum ssp. palustre) within the species’ suitable
habitat within the Project work limits. The survey shall follow the CDFW Protocols for
Surveying and Evaluating Impacts on Special Status Native Plant Populations and
Sensitive Natural Communities (CDFW 2018). If special-status plant species are identified
within the Project work limits, then the biologist shall establish an appropriate buffer area
for each plant population to exclude activities that directly remove or alter the habitat of,
or result in indirect adverse impacts on, the special-status plant species. A qualified
biologist shall oversee installation of a temporary, mesh-type construction fence (Tensor
Polygrid or equivalent) at least 4 feet (1.2 meters) tall around any established buffer areas
to prevent encroachment by construction vehicles and personnel. The qualified biologist
shall determine the exact location of the fencing. The fencing shall be strung tightly on
posts set at maximum intervals of 10 feet (3 meters) and shall be checked and maintained
weekly until all construction is complete. The buffer zone established by the fencing shall
be marked by a sign stating: “This is habitat of [list rare plant(s)] and must not be disturbed.
This species is protected by [the ESA of 1973, as amended/CESA/California Native Plant
Protection Act].”
b. If direct impacts cannot be avoided, the City shall require the project sponsor to prepare
a plan for minimizing the impacts by one or more of the following methods: (1) salvage
and replant plants at the same location following construction; (2) salvage and relocate
the plants to a suitable off-site location with long-term assurance of site protection; (3)
collect seeds or other propagules for reintroduction at the site or elsewhere; or (4) payment
of fees in lieu of preservation of individual plants, to be used for conservation efforts
elsewhere. The City shall review and approve the plan.
c. The success criterion for any seeded, planted, and/or relocated plants shall be full
replacement at a 1:1 ratio after 5 years. Monitoring surveys of the seeded, planted, or
transplanted individuals shall be conducted for a minimum of 5 years, to ensure that the
success criterion can be achieved at year 5. If it appears the success criterion would not
EXHIBIT 3
3-11
be met after 5 years, contingency measures may be applied. Such measures shall include,
but not be limited to additional seeding and planting, altering, or implementing weed
management activities, or introducing or altering other management activities.
d. Any special-status plant species observed during surveys shall be reported to the CDFW
and submitted to the CNDDB and reported to USFWS, if federally listed.
(FEIR Mitigation Measures 3.4-5)
25. To ensure protection of fish and marine mammals during pile driving phases of construction,
prior to the commencement of pile driving, the Project sponsor shall prepare a NOAA- and
CDFW-approved sound attenuation monitoring plan to protect fish and marine mammals, and
the approved plan shall be implemented during construction. This plan shall provide detail on
the sound attenuation system, detail methods used to monitor and verify sound levels during
pile driving activities (if required based on projected in-water noise levels) and describe
methods to reduce impact pile-driving in the aquatic environment to an intensity level less
than 120 dB (RMS) continuous noise level for marine mammals at a distance of 1,640 feet.
The plan shall incorporate, but not be limited to, the following elements:
a. All in-water construction shall be conducted within the established environmental work
window between June 1 and November 30, designed to avoid potential impacts on fish
species.
b. To the extent feasible, vibratory pile drivers shall be used for the installation of all support
piles. Vibratory pile driving shall be conducted following the USACE “Proposed
Procedures for Permitting Projects that will Not Adversely Affect Selected Listed Species
in California.” The USFWS and NMFS completed Section 7 consultation on this document,
which establishes general procedures for minimizing impacts on natural resources
associated with projects in or adjacent to jurisdictional waters.
c. If NOAA sound level criteria for marine mammals are exceeded during vibratory hammer
pile installation, a NOAA-approved biological monitor shall be available to conduct surveys
before and during pile driving to inspect the work zone and adjacent waters for marine
mammals. The monitor shall be present as specified by NMFS during impact pile driving
and ensure that:
1) The safety zones established in the sound monitoring plan for the protection of marine
mammals are maintained.
2) Work activities are halted when a marine mammal enters a safety zone and resumed
only after the animal has left the area or has not been observed for a minimum of 15
minutes.
(FEIR Mitigation Measure 3.4-6)
26. A qualified archaeologist, defined as an archaeologist meeting the U.S. Secretary of the
Interior’s Professional Qualification Standards for Archeology, shall conduct a training
program for all construction and field workers involved in site disturbance. On-site personnel
shall attend a mandatory pre-Project training that shall outline the general archaeological
sensitivity of the area and the procedures to follow in the event an archaeological resource
and/or human remains are inadvertently discovered.
(FEIR Mitigation Measure CUL-1)
During Construction
EXHIBIT 3
3-12
27. Contractor Contact Information Posting: Prior to the commencement of construction, the
project site shall be posted with the name and contact number of the lead contractor in a
location visible from the public street.
28. Construction Hours: Construction hours shall be limited as specified by Municipal Code
Section 8.13.050.A which are 7:00 a.m. to 6:00 p.m., Monday through Friday and Saturday
from 9:00 a.m. to 6:00 p.m. Construction shall not be permitted on Sundays or City-
observed holidays. Construction activities shall include delivery of materials, arrival of
construction workers, start-up of construction equipment engines, playing of radios and
other noises caused by equipment and/or construction workers arriving at or on the site.
29. To mitigate potential impacts to pre-contact or historic-era archaeological resources
encountered during project construction, the following measures shall be implemented:
a. All construction activities within 100 feet shall halt, and a qualified archaeologist shall
inspect the find within 24 hours of discovery and notify the City of the initial assessment.
Precontact archaeological materials might include obsidian and chert flaked-stone tools
(e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil
(“midden”) containing heataffected rocks, artifacts, or shellfish remains; stone milling
equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone
tools, such as hammerstones and pitted stones. Historic-era materials might include
building or structure footings and walls, and deposits of metal, glass, and/or ceramic
refuse.
b. If the City determines, based on recommendations from a qualified archaeologist and a
Native American representative (if the resource is pre-contact indigenous related), that
the resource may qualify as a historical resource or unique archaeological resource (as
defined in CEQA Guidelines Section 15064.5) or a tribal cultural resource (as defined in
Public Resources Code [PRC] Section 21080.3), the resource shall be avoided if
feasible. Consistent with Section 15126.4(b)(3), this may be accomplished through
planning construction to avoid the resource, incorporating the resource within open
space, capping, and covering the resource, or deeding the site into a permanent
conservation easement.
c. If avoidance is not feasible, the City shall consult with appropriate Native American tribes
(if the resource is pre-contact indigenous related), and other appropriate interested
parties to determine treatment measures to avoid, minimize, or mitigate any potential
impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines
Section 15126.4. This shall include documentation of the resource and may include data
recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions
such as treating the resource with culturally appropriate dignity and protecting the
cultural character and integrity of the resource (according to PRC Section 21084.3).
(FEIR Mitigation Measure CUL-1)
30. If potential human remains are encountered during construction, all work shall halt within
100 feet of the find and the City shall be contacted by on-site construction crews. The City
shall contact the Marin County coroner in accordance with PRC Section 5097.98 and Health
and Safety Code Section 7050.5. If the coroner determines that the remains are Native
American, the coroner shall contact the NAHC. As provided in PRC Section 5097.98, the
NAHC shall identify the person or persons believed to be the Most Likely Descendant
(MLD). The MLD shall make recommendations for the means of treating, with appropriate
dignity, the human remains and any associated grave goods, as provided in PRC Section
5097.98.(FEIR Mitigation Measures CUL-2)
EXHIBIT 3
3-13
31. The following measures are required to ensure grading and site disturbance complies with
the SRMC Chapter 11.12 (Trees), which addresses tree removal and protection:
a. Any tree-related work (removal, planting, or pruning) shall adhere to the City of San
Rafael Municipal Code Section 11.12. Specifically, written permit must be issued to cut,
prune, break, injure, or remove any living tree in, upon, or along any public street,
sidewalk, or walkway in the city or cut, disturb, or interfere in any way with the roots of
any tree in, upon, or along any street, sidewalk, or walkway, or spray with any chemical
or insecticide any tree in, upon, or along any public street, sidewalk, or walkway, or
place any sign, poster, or other fixture on any tree or tree guard, or injure, misuse, or
remove any device placed to protect any tree in, upon, or along any public street,
sidewalk, or walkway in the city. Whenever any tree shall be cut down or removed in or
from any sidewalk area, its butt and roots shall be dug up and removed, or cut level with
the ground, as directed by the public works department.
b. In the erection or repair of any building or structure, guards shall be placed around all
nearby trees in, upon, or along the public streets, sidewalks, and walkways within the
city as shall prevent injury to them.
(FEIR Mitigation Measure 2.4-7)
32. The Project applicant and/or its construction contractors shall comply with the following
applicable BAAQMD Basic Construction Mitigation Measures: BAAQMD Basic Construction
Measures:
a. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and
unpaved access roads) shall be watered two times per day.
b. All haul trucks and railcars transporting soil, sand, or other loose material off-site shall be
covered.
c. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet
power vacuum street sweepers at least once per day. The use of dry power sweeping is
prohibited.
d. All vehicle speeds on unpaved roads shall be limited to 15 mph.
e. All roadways, driveways, and sidewalks to be paved shall be completed as soon as
possible. Building pads shall be laid as soon as possible after grading unless seeding or
soil binders are used.
f. Idling times shall be minimized either by shutting equipment off when not in use or
reducing the maximum idling time to five minutes (as required by the California airborne
toxics control measure Title 13, Section 2485 of the California Code of Regulations
[CCR]). Clear signage shall be provided for construction workers at all access points.
g. All construction equipment shall be maintained and properly tuned in accordance with
manufacturer’s specifications. All equipment shall be checked by a certified visible
emissions evaluator.
h. Post a publicly visible sign with the telephone number and person to contact at the City
of San Rafael regarding dust complaints. This person shall respond and take corrective
action within 48 hours. BAAQMD’s phone number shall also be visible to ensure
compliance with applicable regulations.
(FEIR Mitigation Measure 3.3-1)
33. The Project applicant and/or its construction contractors shall be required to use off-road
diesel construction equipment compliant with EPA Tier 4 nonroad engine standards. Before
construction activities begin, the construction contractor and/or the Project applicant shall
prepare an equipment list that identifies each piece of off-road equipment to be operated at
the Project site by its equipment identification number and demonstrates that each piece of
EXHIBIT 3
3-14
equipment meets EPA Tier 4 nonroad engine standards. The list shall be made available at
the construction site and shall be updated when new or replacement construction equipment
is brought to the site.
(FEIR Mitigation Measure 3.3-2)
34. During construction, the following measures shall be implemented:
a. A qualified biologist (4-year college degree in biology or related field and demonstrated
experience with the species of concern) shall provide Worker Environmental Awareness
Training (WEAT) to field management and construction personnel. Communication
efforts and training shall take place during pre-construction meetings so that construction
personnel are aware of their responsibilities and the importance of compliance. WEAT
shall identify the types of sensitive resources located in the study area and the measures
required to avoid impacts on these resources. Materials covered in the training program
shall include environmental rules and regulations for the specific Project and
requirements for limiting activities to the construction right-of-way and avoiding
demarcated sensitive resource areas.
b. If new construction personnel are added to the Project, the contractor shall ensure the
new personnel receive WEAT before starting work. A sign-in sheet of those contractor
individuals who have received the training shall be maintained by the Project proponent.
A representative shall be appointed during the WEAT to be the contact for any employee
or contractor who might inadvertently kill or injure a listed species or who finds a dead,
injured, or entrapped individual.
c. All vehicle operators shall limit speed to 15 miles per hour (mph) within the Project site.
d. No erosion control materials shall contain any plastic or monofilament netting.
e. To avoid attracting predators, all food-related trash items shall be bagged and removed
daily.
(FEIR Mitigation Measure 3.4-1)
35. During construction, the following measures are required to minimize and/or avoid impacts
to California Black Rail and California Ridgeway’s Rail:
a. To minimize or avoid the loss of individual California black rail and California Ridgway’s
rail, construction activities, including vegetation management activities requiring heavy
equipment, adjacent to the tidal marsh areas (within 500 feet [150 meters] or a distance
determined in coordination with the USFWS or CDFW based on site specific conditions,
shall be avoided during the breeding season from February 1 through August 31.
b. If areas within or adjacent to rail habitat cannot be avoided during the breeding season,
protocol-level surveys shall be conducted to determine rail nesting locations. The
surveys shall focus on potential habitat that could be disturbed by construction activities
during the breeding season to ensure that rails are not breeding in these locations.
c. Survey methods for rails shall follow the Site-Specific Protocol for Monitoring Marsh
Birds, which was developed for use by USFWS and partners to improve bay-wide
monitoring accuracy by standardizing surveys and increasing the ability to share data
(Wood et al. 2017). Surveys are concentrated during the approximate period of peak
detectability, January 15 to March 25, and are structured to efficiently sample an area in
three rounds of surveys by broadcasting calls of target species during specific periods of
each survey round. Call broadcasts increase the probability of detection compared to
passive surveys when no call broadcasting is employed. This protocol has since been
adopted by the Invasive Spartina Project (ISP) and Point Blue Conservation Science to
survey California Ridgway’s rails at sites throughout San Francisco Bay Estuary
EXHIBIT 3
3-15
including at Tiscornia Marsh. The survey results and protocols from the ISP shall be
used, or a survey protocol developed in coordination with CDFW and USFWS
incorporating both species simultaneously and with the same level of effort as protocols
currently in use by ISP shall be used. The survey protocol for California Ridgway’s rail is
summarized as follows:
1) Previously used survey locations (points) should be used when available to maintain
consistency with past survey results. Adjacent points should be at least 200 meters
apart along transects in or adjacent to areas representative of the marsh. Points
should be located to minimize disturbances to marsh vegetation. Up to eight points
can be located on a transect.
2) At each transect, three surveys (rounds) are to be conducted, with the first round of
surveys initiated between January 15 and February 6, the second round performed
February 7 to February 28, and the third round March 1 to March 25. Surveys should
be spaced at least 1 week apart, and the period between March 25 to April 15 can be
used to complete surveys delayed by logistical or weather issues. A FESA Section
10(a)(1)(A) permit is required to conduct active surveys.
3) Each point on a transect shall be surveyed for 10 minutes each round. A recording of
calls available from the USFWS is broadcast at each point. The recording consists of
5 minutes of silence, followed by a 30-second recording of California Ridgway’s rail
vocalizations, followed by 30 seconds of silence, followed by a 30-second recording
of California black rail, followed by 3.5 minutes of silence
d. If no breeding California black rail or California Ridgway’s rail are detected during
surveys, or if their breeding territories can be avoided by 500 feet (150 meters) or a
distance determined in coordination with the USFWS ad CDFW based on site specific
conditions, then Project activities may proceed at that location.
e. If protocol surveys determine that breeding California black rail and/or California
Ridgway’s rail are present in the project area, the following measures would apply to
Project activities conducted during their breeding season (February 1- August 31):
1) Construction activities would not occur within 500 feet of a detected Ridgway’s rail or
black rail call center.
2) A USFWS- and CDFW-approved biologist shall be on site during construction
activities occurring within 50 feet of any other suitable rail breeding habitat.
3) All other biologists that may need to access the tidal marsh outside of the active
construction period or be on site during construction for activities beyond 500 feet
from suitable rail breeding habitat, shall be trained in black rail and Ridgway’s rail
biology, identification, and vocalizations, and shall be familiar with both species of rail
and their nests.
4) The qualified biologist/biological monitor shall have the authority to stop all work if a
Ridgway’s rail or black rail enters or is discovered within 50 feet of the active work
zone. All nearby work shall halt and not continue until the Ridgway’s rail or black rail
leaves the area on its own accord or until approving agencies have been consulted.
The no work zone shall be large enough as determined by the qualified
biologist/biological monitor in order to avoid impacts to all special-status species. If a
California black rail or California Ridgway’s rail vocalizes or flushes, it is possible that
a nest or young are nearby. If an alarmed bird or nest is detected, work shall be
stopped, and workers shall leave the immediate area carefully and quickly. An
alternate route shall be selected that avoids this area, and the location of the sighting
shall be recorded to inform future activities in the area.
5) All construction crews working in the marsh during rail breeding season shall be
trained and supervised by a USFWS- and CDFW-approved rail biologist
EXHIBIT 3
3-16
6) If any activities shall be conducted during the rail breeding season in California black
rail or California Ridgway’s rail-occupied marshes, biologists shall have maps or
global positioning system (GPS) locations of the most current occurrences on the
site.
(FEIR Mitigation Measure 3.4-2)
36. To avoid and minimize impacts to nesting birds, during construction, the following measures
shall be followed and implemented:
a. Removal of trees and scrub vegetation shall occur outside the bird nesting season
(February 1 to August 31), to the extent feasible.
b. If removal of trees and vegetation cannot be fully accomplished outside of the nesting
season, a qualified biologist shall conduct pre-construction nesting surveys within 7 days
prior to the start of such activities or after any construction breaks of 10 days or more.
Surveys shall be performed for the study area and suitable habitat within 250 feet of the
Project site to locate any active raptor (birds of prey) nests or rookeries.
c. If active nests are located during the pre-construction bird nesting survey, the qualified
biologist shall evaluate if the schedule of construction activities could affect the active
nests and the following measures shall be implemented based on their determination:
1) If construction is not likely to affect the active nest, it may proceed without restriction;
however, a biologist shall regularly monitor the nest to confirm there is no adverse
effect and may revise their determination at any time during the nesting season. In
this case, the following measure would apply.
2) If construction may affect the active nest, the biologist shall establish a no-disturbance
buffer in coordination with CDFW. Typically, these buffer distances are 100 feet for
passerines and 250 feet for raptors. These distances may be adjusted depending on
the level of surrounding ambient activity (e.g., if the Project site is adjacent to a road
or active trail) and if an obstruction, such as a building, is within line‐of‐sight between
the nest and construction. For bird species that are federally and/or state‐listed
sensitive species (i.e., fully protected, endangered, threatened, species of special
concern), a City representative or qualified biologist shall coordinate with the USFWS
and/or CDFW regarding modifications to nest buffers, prohibiting construction within
the buffer, modifying construction, or removing or relocating active nests that are
found on the site.
3) Any birds that begin nesting within the Project area and survey buffers amid
construction activities are assumed to be habituated to construction-related or similar
noise and disturbance levels. A qualified biologist shall coordinate with the USFWS
and/or CDFW and determine if no work exclusion zones shall be established around
active nests in these cases.
(FEIR Mitigation Measure 3.4-3)
37. To avoid and minimize impacts to the Salt Marsh Harvest Mouse and the Salt Marsh
Wandering Shrew, during construction, the following measures shall be followed and
implemented:
a. Ground disturbance to suitable salt marsh harvest mouse habitat (including, but not
limited to pickleweed, and emergent salt marsh vegetation) shall be avoided to the
extent feasible. Where salt marsh harvest mouse habitat cannot be avoided (such as for
channel excavation, access routes and grading, or anywhere else that vegetation could
be trampled or crushed by work activities), vegetation shall be removed to ground level
from the ground disturbance work area plus a 5-foot buffer around the area, as well as
EXHIBIT 3
3-17
any access routes within salt marsh harvest mouse habitat, utilizing mechanized hand
tools or by another method approved by the USFWS and CDFW. Vegetation height shall
be maintained at or below 5 inches above ground. Vegetation removal in salt marsh
harvest mouse habitat shall be conducted under the supervision of the USFWS- and
CDFW-approved biologist. The number of biologists needed to effectively inspect
vegetational removal for the presence of mice and nests depends on the site
characteristics and vegetation removal methods and may be determined in coordination
with approving agencies.
b. To protect salt marsh harvest mouse from construction-related traffic, access roads, haul
routes, and staging areas within 50 feet of salt marsh harvest mouse habitat shall be
bordered by temporary exclusion fencing; or other wildlife exclusion fencing as specified
in federal or state permits. The fence should be made of a material that does not allow
salt marsh harvest mouse to climb or pass through, of a minimum above-ground height
of 30 inches, and the bottom should be buried to a depth of at least 6 inches so that
mice cannot crawl under the fence. Any supports for the salt marsh harvest mouse
exclusion fencing (e.g., t-posts) shall be placed on the inside of the Project site. The last
5 feet of the fence shall be angled away from the road to direct wildlife away from the
road. A USFWS- and CDFW-approved biologist with previous salt marsh harvest mouse
experience shall be on site during fence installation and shall check the fence alignment
prior to vegetation clearing and fence installation to ensure that no salt marsh harvest
mice are present.
c. Salt marsh harvest mouse marsh habitat that must be accessed by mini-excavators or
other vehicles to complete Project construction (e.g., excavating smaller channels) shall
be protected through use of low ground pressure (LGP) equipment, wooden or PVC
marsh mats, or other method approved by the USFWS and CDFW following vegetation
removal (see 2nd bullet, above).
d. Construction activities related to restoration and infrastructure shall be scheduled to
avoid extreme high tides when there is potential for salt marsh harvest mouse to move to
higher, drier grounds, such as ruderal and grassland habitats. No Project activities shall
be conducted within 50 feet of suitable tidal marsh or other salt marsh harvest mouse
habitat within 2 hours before and after an extreme high tide event (6.5 feet or higher
measured at the Golden Gate Bridge and adjusted to the timing of local high tides) or
when the adjacent marsh is flooded unless wildlife exclusion fencing has been installed
around the work area.
e. All construction equipment and materials shall be staged on existing roadways and away
from suitable salt marsh harvest mouse habitat when not in use. All construction
equipment shall be visually inspected prior to work activities each day for signs of salt
marsh harvest mouse or any other wildlife.
f. Vegetation shall be removed from all non-marsh areas of disturbance (driving roads,
grading, and stockpiling areas) to discourage the presence of salt marsh harvest mouse.
g. A USFWS- and CDFW-approved biologist with previous salt marsh harvest mouse
monitoring and/or surveying experience shall be on site during construction activities
occurring in suitable habitat. The USFWS- and CDFW-approved biologist has the
authority to stop Project activities if any of the requirements associated with these
measures are not being fulfilled. If a harvest mouse is observed in the work area,
construction activities shall cease in the immediate vicinity of the potential salt marsh
harvest mouse. The individual shall be allowed to leave the area before work is
resumed. If the individual does not move on its own volition, the USFWS-approved
biologist would contact USFWS (and CDFW if appropriate) for further guidance on how
to proceed.
EXHIBIT 3
3-18
h. If the USFWS- and CDFW-approved biologist has requested work stoppage because of
take of any of the listed species, or if a dead or injured salt marsh harvest mouse is
observed, the USFWS and CDFW shall be notified within 1 day by email or telephone.
(FEIR Mitigation Measure 3.4-4)
38. During construction, the construction contractor shall be required to implement the following:
a. The security fence shall be maintained around the construction staging area to screen
views of the equipment, materials/stockpiles, vehicles, and debris. The security fence
shall be removed when construction is completed.
b. Dumpsters shall be emptied regularly.
c. The construction staging area shall be keep clear or trash, weeds, and construction
debris.
a. Hydro-seed or apply non-toxic soil stabilizers to inactive construction areas.
b. Enclose, cover, water twice daily, or apply non-toxic soil binders to exposed stockpiles
(dirt, sand, etc.).
c. Limit vehicle traffic speeds on unpaved roads to 15 mph.
d. Replant vegetation in disturbed areas as quickly as possible.
e. Install sandbags or other erosion control measures to prevent silt runoff from public
roadways.
Compliance with this condition is subject to periodic inspections by City staff.
Prior to Completion of Final Restoration Construction
39. All landscaping and irrigation must be approved by MMWD prior to City approval.
Verification of MMWD approval shall be submitted to the City.
Post Construction Monitoring
40. See Use Permit UP21-001 condition wetland management plan condition #4 for periodic post
construction monitoring.
The foregoing resolution was at the regular City of San Rafael Planning Commission meeting held
on the 11th day of January 2022.
Moved by Commissioner _____________ and seconded by Commissioner ______________.
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST: ______________________________ ______________________________
Leslie Mendez, Secretary Shingi Samudzi, Chair
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-1
LAND USE ELEMENT
.
Land Use Classifications.
Conservation.
This designation denotes land which is to remain
undeveloped due to high environmental sensitivity,
exceptional visual resource value, or hazards such as
wildfire, slope instability, and flooding, including
inundation related to sea level rise. Areas with this
designation include a combination of privately owned
properties and areas owned by utilities and
conservation groups. On private properties, this
designation is generally applied to the portion of the
site that has been determined to be undevelopable
due to the factors listed above. The primary
objectives in Conservation areas are to manage and
restore natural resources, protect plant and animal
habitat, and minimize environmental hazards and
associated threats to life and property. Where
appropriate, compatible activities such as agriculture
and recreation may be considered.
Water.
This designation applies to the navigable waters of
San Francisco and San Pablo Bays, the San Rafael
Canal, and associated marinas along the San Rafael
shoreline. The designation provides an opportunity
for a limited number of water dependent uses which
require water access as a central element of their
function and which contribute to the maritime
character of the area. Liveaboards and other types of
floating homes are allowed in this category, subject to
permitting and water quality requirements
Consistent.
The western portion of the Tiscornia Marsh property is designated for Conservation use. The
restoration project would retain and improve its current wetland use, which would be consistent
with this designation.
Consistent.
The eastern portion of the Tiscornia Marsh property is designated for Water use. This area
contains submerged tidelands. A portion of the submerged tidelands would be converted to
marshland. The marsh use would be consistent with this designation.
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-2
Parks, Recreation and Open Space.
This designation denotes land dedicated as parks,
recreation, and open space (PROS), including City
parks, County and State Parks, common open space
within private development, cemeteries, and areas
acquired for resource conservation, hazard reduction,
and passive recreation such as hiking. Permitted
uses include athletic fields, sports facilities, civic
buildings with a primarily recreational or social
function, and leisure-oriented uses such as picnic
areas, boat slips, and tot lots. Land with this
designation is further classified in the PROS Element
of the General Plan as “improved” or “natural.” Park,
Recreation, and Open Space areas provide important
habitat for plant and animal life and should be
managed to reduce the potential for conflicts between
people and wildlife.
Consistent.
The portion of the project area that is owned by the City of San Rafael is designated for Park,
Recreation and Open Space use. This area contains diked marshland. The restoration plan
proposes to return this diked marshland to tidal action creating new seasonal marsh. The
proposed seasonal marsh use would be consistent with this designation.
LU-1.15. Planned Development Zoning.
Encourage the use of Planned Development (PD)
zoning for development on parcels greater than five
acres when the application of traditional zoning
standards would make it more difficult to achieve
General Plan goals. The PD zoning designation
allows flexible design standards that are more
responsive to site conditions as well as the transfer of
allowable General Plan and zoning density between
contiguous sites under common ownership.
Consistent.
The Tiscornia Marsh portion of the project area that is owned by Marin Audubon Society is within
the Planned Development (PD) District. The PD District requires the approval of a development
plan. Essentially, the marsh restoration proposal is development plan for this property. As the
project proposes no changes in the approved land use (marsh, submerged tidelands, and upland
levee/path), and ordinance action is not required to establish the land uses. Per SRMC Title 14
(Zoning) a Use Permit may be required to establish use regulations. A Use Permit application
has been filed and is included in the planning applications for action by the City.
LU-2.1. Land Use Map and Categories.
Use the General Plan Map as the framework for
future land use decisions (see Figure 3-1). The Map
displays the distribution of different land use
categories in the San Rafael Planning Area. Each
category is associated with a particular set of uses
and densities/ intensity standards. All proposed
projects must meet these standards, as well as other
applicable standards established by the City’s zoning
Consistent.
As noted above, the wetland restoration project and use are consistent with the three land use
categories that are adopted for the project area. While the proposed use is permitted, a Use
Permit application is required to comply with the PD District and the Wetland Overlay (WO-)
District set forth in SRMC Title 14 (Zoning).
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-3
regulations. Some uses in each category are
“conditional,” meaning they are allowed only in limited
areas or may be subject to specific conditions.
NEIGHBORHOODS ELEMENT
NH-3.2. Canal Maintenance.
Ensure the long-term maintenance of the Canal as a
navigable waterway, including regular dredging.
Encourage the maintenance of docks, along with litter
removal and water quality improvements.
Consistent.
The proposed project is adjacent to and outside the navigable channel of the San Rafael Creek
(Canal). The project would have no direct impact from any future dredging activity along the
creek. Should the planned timing of future dredging be in sync with the timing of the marsh
restoration construction, the proposed project would benefit from the use of the local spoils for
creation of the marsh area.
NH-3.5: Waterfront Design.
Require new buildings along the Canal waterfront to
provide public views of the water and accommodate
public access to the shoreline. Design factors
important in reviewing specific development
proposals include pedestrian access, waterfront
setbacks, view protection and enhancement, habitat
protection, architectural design quality, and
landscaping.
Consistent.
The project includes the raising and realignment of the shoreline levee that is within the project
area. The levee is proposed to be raised to a higher finished elevation to address projected sea
level rise. As determined by the Tiscornia Marsh Restoration Project EIR (2021), the raising of
the levee would no impair public views along the waterfront.
NH-3.6. Public Access.
Increase and improve public access to the Canal
through the creation of waterfront promenades, a
potential new pedestrian bridge east of Grand
Avenue, additional access points within new
development, and waterside access for boats.
Consistent.
The project includes the raising and realignment of the shoreline levee that is within the project
area. The new levee top with be developed with a new pedestrian/bicycle path, which will be
accessible to the public. The path would improve public access.
NH-3.8. Flood Control Improvements.
Coordinate development and redevelopment of uses
along the Canal with a comprehensive strategy to
reduce flood hazards, adapt to sea level rise and
create a more resilient shoreline. This should include
improvements to levees and sea walls, pump
Consistent.
The project includes the raising and realignment of the shoreline levee that is within the project
area, along with the creation of new marshland in areas that are currently submerged tidelands
and diked marshland. As determined by the Tiscornia Marsh EIR, these improvements will
improve flood control for an area that is prone to flood risk.
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-4
stations, and storm drainage infrastructure.
COMMUNITY DESIGN & PRESERVATION ELEMENT
CDP-1.2. Natural Features.
Recognize and protect the key natural features that
shape San Rafael’s identity, including the Bay, local
hills and ridgelines, creeks and wetlands, tree cover,
and views of Mt. Tamalpais and other natural
landmarks. Height limits and other building standards
should respect San Rafael’s natural topography and
reinforce its sense of place, including the character
and boundaries of individual neighborhoods.
Consistent.
The project will not result in any major changes to the natural features of the area. Rather, the
restoration project will improve the natural features by returning portions of the site that were
diked and filled to its original marshland condition.
CDP-1.4: Waterfront Identity.
Strengthen San Rafael’s identity as a waterfront city,
providing improved visual and physical access to San
Pablo Bay, San Rafael Bay, and the San Rafael
Canal.
Consistent.
As noted above, the project includes the raising and realignment of the shoreline levee that is
within the project area. The new levee top with be developed with a new pedestrian/bicycle path,
which will be accessible to the public. The path would improve public access.
CDP-1.5. Views.
Respect and enhance to the greatest extent possible,
views to the Bay and its islands; wetlands, marinas,
and canal waterfront; hillsides and ridgelines; Mt.
Tamalpais; Marin Civic Center; and St. Raphael’s bell
tower; as seen from streets, parks, and public
pathways.
Consistent.
As noted above, the project includes the raising and realignment of the shoreline levee that is
within the project area. The levee is proposed to be raised to a higher finished elevation to
address projected sea level rise. As determined by the Tiscornia Marsh EIR, the raising of the
levee would not impair public views along the waterfront.
CONSERVATION AND CLIMATE CHANGE ELEMENT
C-1.1. Wetland Preservation.
Require appropriate public and private wetlands
preservation, restoration and/or rehabilitation through
the regulatory process. Support and promote
Consistent.
The project would result in enhanced and preserved wetlands. The current diked marshland and
portions of the submerged tidelands are conditions that have developed on the site over time
through natural and manmade actions. The project would restore this area to its natural
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-5
acquisition of fee title and/or easements from willing
property owners.
condition.
C-1.2. Wetlands and Sea Level Rise.
Optimize the role of wetlands in buffering the San
Rafael shoreline against the future impacts of sea
level rise.
Consistent.
As a whole, the project is designed to enhance and restore wetlands to their natural condition.
The project features include raising the shoreline levee and creating an “ecotone” (outboard,
horizontal levee), which are key to combating and adapting to sea level rise.
C-1.3. Wetland Protection and Mitigation.
In order to protect and preserve valued wetlands,
loss of wetlands due to filling shall be avoided.
Compensatory mitigation for the loss of wetlands
shall be required in the event that preservation is not
possible or practical due to conditions such as the
location, configuration, and size of the wetland.
Consistent.
The project would not result in the loss of wetlands but would enhance wetlands that are
currently protected. Although the development of an “ecotone” in an area of submerged tidelands
and diked marsh will require some filling of the bay, this filling would be offset by the removal of
fill in the diked marsh area.
C-1.4. Wetland Creation.
Require that any wetlands created to mitigate losses
as described in Policy C-1.3 are similar in habitat
type and at least equal in functional quality to the
wetlands being filled.
Consistent.
As noted above, the project would not result in the loss of wetlands but would enhance wetlands
that are currently protected. Although the development of an “ecotone” in an area of submerged
tidelands and diked marsh will require some filling of the bay, this filling would be offset by the
removal of fill in the diked marsh area.
C-1.11. Wildlife Corridors.
Preserve and protect areas that function as wildlife
corridors, particularly those areas that provide
connections permitting wildlife movement between
larger natural areas.
Consistent.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), as a whole, the project
would result in new and enhanced wetlands that would improve habitat for wildlife use and
movement.
C-1.12: Native or Sensitive Habitats.
Protect habitats that are sensitive, rare, declining,
unique, or represent a valuable biological resource.
Potential impacts to such habitats should be
minimized through compliance with applicable laws
and regulations, including biological resource
surveys, reduction of noise and light impacts,
restricted use of toxic pesticides, pollution and trash
control, and similar measures.
Consistent with Mitigation and Conditions.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), as a whole the built
project would result in improved habitat for native and sensitive species. The EIR determined that
project construction has the potential to disturb, impact or destroy native and sensitive habitats;
however, mitigation measures are recommended to reduce these construction-related impacts to
a less-than-significant level. To preclude (or minimize) access into the habitat area by dogs and
humans, the project should be conditioned to require the installation of a 4-foot-high vinyl clad
link fence on the bayside slope bank of the raised levee.
C-1.13. Special Status Species. Consistent with Mitigation and Conditions.
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-6
Conserve and protect special status plants and
animals, including those listed by State or federal
agencies as threatened and/or endangered, those
considered to be candidate species for listing by state
and federal agencies, and other species that have
been assigned special status by the California Native
Plant Society and the California Fish and Game
Code. Avoidance of impacts, accompanied by habitat
restoration, is the preferred approach to
conservation, but mitigation measures may be
considered when avoidance is not possible.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), as a whole the built
project would result in improved habitat for known special status species. The EIR determined
that project construction has the potential to disturb, impact or destroy special status species;
however, mitigation measures are recommended to reduce these construction-related impacts to
a less-than-significant level. To preclude (or minimize) access into the habitat area by dogs and
humans, the project should be conditioned to require the installation of a 4-foot-high vinyl clad
link fence on the bayside slope bank of the raised levee.
C-3.2. Reduce Pollution from Urban Runoff.
Require Best Management Practices (BMPs) to
reduce pollutants discharged to storm drains and
waterways. Typical BMPs include reducing
impervious surface coverage, requiring site plans that
minimize grading and disturbance of creeks and
natural drainage patterns, and using vegetation and
bioswales to absorb and filter runoff.
Consistent with Mitigation.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), as a whole the built
project would result in new wetlands that would further filter urban runoff, and thus further reduce
pollution. The EIR determined that project construction has the potential to introduce or increase
pollutants; however, mitigation measures are recommended to reduce these construction-related
impacts to a less-than-significant level.
C-5.2. Consider Climate Change Impacts.
Ensure that decisions regarding future development,
capital projects, and resource management are
consistent with San Rafael’s CCAP and other climate
goals, including greenhouse gas reduction and
adaptation.
Consistent.
As designed, the project would address anticipated increased flooding and projected sea level
rise. The project included elements such as a raised levee and creation of an outboard
“ecotone,” which are key measures for combating projected sea level rise.
C-5.5: Carbon Sequestration.
Enhance the ability of the city’s natural and built
environment to sequester (absorb and store) carbon
emissions.
Consistent.
The project would result in the enhancement of and the creation of new wetlands that would
promote aquatic plants, which are known for absorbing carbon emissions.
PARKS, RECREATION AND OPEN SPACE ELEMENT
PROS-1.8. Linear Parks and Trails.
Encourage linear parks and trails along the Bay
Consistent.
The project would result in an improved and increased linear park and trails system for the
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-7
shoreline, the San Rafael Canal, local creeks, and
transportation corridors such as the SMART right-of-
way. Where feasible, spur trails should connect linear
parks to nearby neighborhoods, parks, and open
spaces.
Southeast San Rafael neighborhood. The proposal to raise and shift the alignment of the
shoreline levee will not only mitigate increased flooding and combat projected sea level rise, but
it would also provide for a more protected and improved public trail that is well used by the
community.
PROS-1.9. Role of Open Space.
Recognize San Rafael’s open space network as an
essential component of the park system, including its
potential to provide for hiking, picnicking, wildlife
observation, environmental education, and enjoyment
of nature. Passive recreational activities such as
hiking, birdwatching, and picnicking, should be
encouraged in these areas where consistent with
habitat protection and hazard reduction goals.
Consistent with Conditions.
The project would result in an improved public shoreline path system, which would increase
opportunities for wildlife observation, environmental education, and the enjoyment of nature. To
further enhance this opportunity, project approvals should be conditioned to require that wildlife
interpretive signs be installed at points along the shoreline path to educate visitors about the
purpose, goal, and benefits about the project. To preclude (or minimize) access into the habitat
area by dogs and humans, the project should be conditioned to require the installation of a 4-
foot-high vinyl clad link fence on the bayside slope bank of the raised levee.
PROS-1.17. Public/Private Partnerships.
Consider the use of public-private partnerships to
rehabilitate, activate, and expand parks and
community facility space. Where appropriate and
consistent with the community’s vision, this could
include more intensive and varied uses of parkland,
provided that the integrity of the open space is
retained.
Consistent.
The project is a partnership of Marin Audubon Society and the City of San Rafael.
PROS-3.1. Open Space Frame.
Retain and protect San Rafael’s open space frame,
including open space on the city’s perimeter and the
network of open spaces that define and connect the
city’s neighborhoods. Open space should be
recognized as essential to wildlife, environmental and
human health, psychological well-being, and as a
natural means of separating communities, preventing
sprawl, and providing visual relief.
Consistent.
As a whole, the project would enhance and further protect existing, secured open space along
the shoreline.
PROS-3.2: Balancing the Uses of Open Space.
Protect and preserve the natural resource value of
open space while permitting compatible recreational
Consistent with Conditions.
The project would provide a balance of natural resource enhancement and protection with public
access for recreational and educational uses.
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-8
and educational uses. Open space areas should be
maintained in a natural state and regarded as a
resource for enjoyment by all residents of San
Rafael. Recreational and educational uses, where
permitted, should be limited to activities with minimal
impacts on the environment and locations where
such activities will not create hazards or have
adverse effects on sensitive natural resources.
PROS-3.3. Open Space Management.
Maintain and manage City-owned open space lands
to reduce natural hazards and wildfire risks, enhance
recreational opportunities, maximize ecological value,
support climate resilience, and preserve aesthetics.
Work with other public open space owners to support
similar objectives on their properties within the San
Rafael Planning Area. It is recognized that these
objectives may conflict as management decisions are
made; solutions should strive for balance and reflect
objective data, wildfire science, and community input.
Consistent.
The project area includes the City-owned diked marshland that is north of the Albert J. Boro
Community Center and Pickleweed Park. As present, this diked marshland is not maintained and
is vulnerable risks such as wildfire and flooding. As proposed, the restoration project would return
this diked marshland to tidal action and restore it to its original wetland condition. Being part of
the greater Tiscornia Marsh Restoration Project, this City-owned property would be better
managed than under current conditions.
PROS-3.8. Trails.
Encourage the development and maintenance of
trails within and between open space areas. Trails
should be designed and maintained in an
environmentally sensitive manner and should provide
safe and secure routes for a variety of users.
Consistent.
As noted above, the project would result in an improved and increased linear park and trails
system for the Southeast San Rafael neighborhood. The proposal to raise and shift the alignment
of the shoreline levee will not only mitigate increased flooding and combat projected sea level
rise but would provide for a more protected and improved public trail that is well used by the
community.
PROS-3.10. Public Education.
Provide education programs to residents about the
importance of open space to wildlife, wildfire
prevention, watershed protection and water quality,
climate resilience and carbon sequestration, habitat
conservation, and human well-being.
Consistent with Conditions.
The project would result in an improved public shoreline path system, which would increase
opportunities for wildlife observation, environmental education, and the enjoyment of nature. To
further enhance this opportunity, project approvals should be conditioned to require that wildlife
interpretive signs be installed at points along the shoreline path to educate visitors about the
purpose, goal, and benefits about the project.
SAFETY AND RESILIENCE ELEMENT
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-9
S-3.4. Mitigating Flooding and Sea Level Rise.
Consider and address increased flooding and sea
level rise impacts in vulnerable areas (see Figure 8-
3) in development and capital projects, including
resiliency planning for transportation and
infrastructure systems.
Consistent.
As noted above, the project features include raising the shoreline levee and creating an
“ecotone” (outboard, horizontal levee), which are key to mitigating increased flooding, as well as
combating and adapting to projected sea level rise.
S-3.6. Resilience to Tidal Flooding.
Improve San Rafael’s resilience to coastal flooding
and sea level rise through a combination of structural
measures and adaptation strategies.
Consistent.
As noted above, the project features include raising the shoreline levee and creating an
“ecotone” (outboard, horizontal levee), which are key to mitigating increased flooding, as well as
combating and adapting to projected sea level rise.
S-3.7. Shoreline Levees.
Improve and expand San Rafael’s shoreline levee
system. When private properties are developed or
redeveloped, require levee upgrading as appropriate,
based on anticipated high tide and flood conditions.
Consistent.
As noted above, the project would raise and realign the existing shoreline levee, which would
reduce flooding assist in adapting the area to projected sea level rise.
S-3.8. Storm Drainage Improvements.
Require new development to mitigate potential
increases in runoff through a combination of
measures, including improvement of local storm
drainage facilities. Other measures, such as the use
of porous pavement, bioswales, and “green
infrastructure” should be encouraged.
Consistent.
As noted above the project includes the raising and realignment of the shoreline levee that is
within the project area, along with the creation of new marshland in areas that are currently
submerged tidelands and diked marshland. As determined by the Tiscornia Marsh EIR, these
improvements will improve flood control for an area that is prone to flood risk.
NOISE ELEMENT
N-1.6. Traffic Noise.
Minimize traffic noise through land use policies, law
enforcement, street design and improvements, and
site planning and landscaping.
Consistent with Mitigation.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), project construction will
result in a temporary increase in vehicle traffic in the adjacent neighborhood. Albeit a short-term
impact, it is potentially significant. The EIR recommends mitigation measures to reduce this
construction-related impact to less-than-significant levels.
N-1.11. Vibration.
Ensure that the potential for vibration is addressed
Consistent with Mitigation.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), project construction will
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-10
when transportation, construction, and nonresidential
projects are proposed, and that measures are taken
to mitigate potential impacts.
result in a temporary increase in vibration that would be experienced in the adjacent
neighborhood. Albeit a short-term impact, it is potentially significant. The EIR recommends
mitigation measures to reduce this construction-related impact to less-than-significant levels.
MOBILITY ELEMENT
M-2.5. Traffic Level of Service.
Maintain traffic Level of Service (LOS) standards that
ensure an efficient roadway network and provide a
consistent basis for evaluating the transportation
effects of proposed development projects on local
roadways. These standards shall generally be based
on the performance of signalized intersections during
the AM and PM peak hours. Arterial LOS standards
may be used in lieu of (or in addition to) intersection
LOS standards in cases where intersection spacing,
and road design characteristics make arterial LOS a
more reliable and effective tool for predicting future
impacts.
Consistent. With Mitigation.
As determined by the Tiscornia Marsh Restoration Project EIR (2021), project construction will
result in a temporary increase in vehicle traffic in the adjacent neighborhood. Albeit a short-term
impact, it is potentially significant. The EIR recommends mitigation measures to reduce this
construction-related impact to less-than-significant levels.
M-6.3. Connectivity.
Develop pedestrian and bicycle networks that
connect residents and visitors to major activity and
shopping centers, existing and planned transit,
schools, and other neighborhoods. Work to close
gaps between existing facilities. Funding and
prioritization for projects should consider relative
costs and benefits, including such factors as safety,
number of potential users, and impacts on parking.
Consistent.
As noted above, the project would result in an improved and increased linear park and trails
system for the Southeast San Rafael neighborhood. The proposal to raise and shift the alignment
of the shoreline levee will not only mitigate increased flooding and combat projected sea level
rise, but it would also provide for a more protected and improved public trail that is well used by
the community.
M-6.4. Urban Trails Network.
Identify, renovate, improve, and maintain an urban
trails network to encourage walking and appreciation
of historical and new pathways.
Consistent.
As noted above, the project would result in an improved and increased linear park and trails
system for the Southeast San Rafael neighborhood. The proposal to raise and shift the alignment
of the shoreline levee will not only mitigate increased flooding and combat projected sea level
rise, but it would also provide for a more protected and improved public trail that is well used by
the community.
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-11
COMMUNITY SERVICES AND INFRASTRUCTUURE ELEMENT
CSI-4.6. Climate Change Impacts.
Incorporate sea level rise and increased storm
intensity forecasts in the planning and design of local
infrastructure projects.
Consistent.
As noted above, the project features include raising the shoreline levee and creating an
“ecotone” (outboard, horizontal levee), which are key to mitigating increased flooding, as well as
combating and adapting to projected sea level rise.
CSI-4.10: Storm Drainage Facilities.
Continue to monitor and pursue improvements to the
storm drainage system, including programs to reduce
flooding, improve water quality, remove trash, and
respond to climate-related changes. Evaluate the
potential for restoration of the natural hydrologic
function of creeks and drainageways where possible.
Consistent.
As noted above the project includes the raising and realignment of the shoreline levee that is
within the project area, along with the creation of new marshland in areas that are currently
submerged tidelands and diked marshland. As determined by the Tiscornia Marsh EIR, these
improvements will improve flood control for an area that is prone to flood risk.
CSI-4.11. Canal Dredging.
Periodically dredge the San Rafael Canal to reduce
flood risks, maintain environmental health, and keep
the canal viable as a commercial and recreational
waterway. Dredge spoils should be disposed in an
environmentally sensitive manner.
Consistent.
The proposed project is adjacent to and outside the navigable channel of the San Rafael Creek
(Canal). The project would have no direct impact from any future dredging activity along the
creek. Should the planned timing of future dredging be in sync with the timing of the marsh
restoration construction, the proposed project would benefit from the use of the local spoils for
creation of the marsh area.
EQUITY, DIVERSITY, AND INCLUSION ELEMENT
EDI-1.2. Broad-Based Involvement.
Partner with community-based organizations to
engage populations whose voices have been
underrepresented in public processes because of
language, mobility, age, citizenship, economic, and
other barriers. Engagement should support self-
determination and empowerment, as well as input on
projects and plans.
Consistent.
The surrounding neighborhood and the community have been involved in the evolution of the
Tiscornia Marsh Restoration Project through the various planning stages. Three community
meetings were hosted by Marin Audubon Society over the past several years, which has resulted
in input to and changes to the scope and design of the project.
EDI-2.1. Neighborhood Design for Active Living.
Improve the design of San Rafael’s neighborhoods to
promote physical activity for all residents, including
Consistent.
As noted above, the project would result in an improved and increased linear park and trails
system for the Southeast San Rafael neighborhood. The proposal to raise and shift the alignment
EXHIBIT 5
TISCORNIA MARSH RESTORATION PROJECT – EAST CANAL STREET
ANALYSIS OF PROJECT CONSISTENCY WITH SAN RAFAEL GENERAL PLAN 2040
File #: ED21-002, UP21-001, IS21-001
PAGE: 4-12
opportunities for safe walking and cycling, and
walkable access to goods and services.
of the shoreline levee will not only mitigate increased flooding and combat projected sea level
rise, but it would also provide for a more protected and improved public trail that is well used by
the community.
EDI-2.2: Safe Space for Physical Activity. Provide
safe physical spaces for children and families to play
and be physically active in all neighborhoods,
particularly in the Canal area and other
neighborhoods where many homes lack outdoor
living space.
Consistent.
As noted above, the project would result in an improved and increased linear park and trails
system for the Southeast San Rafael neighborhood. The proposal to raise and shift the alignment
of the shoreline levee will not only mitigate increased flooding and combat projected sea level
rise, but it would also provide for a more protected and improved public trail that is well used by
the community.
EDI-2.10. Resiliency Planning.
Improve resiliency planning for climate change, public
health emergencies, and other community stressors
among non-English speaking and lower-income
populations. Increase awareness of sea level rise
and flooding risks in the Canal area and in other
vulnerable areas, as well as the importance of
adaptation measures.
Consistent.
As noted above, the surrounding neighborhood and the community have been involved in the
evolution of the Tiscornia Marsh Restoration Project through the various planning stages. Three
community meetings were hosted by Marin Audubon Society over the past several years, which
has resulted in input to and changes to the scope and design of the project.
175 N. Redwood Dr., Ste. 135, San Rafael, CA 94903 | 415.485.6257 |
mcl@marinconservationleague.org
Marin Conservation League was founded in 1934 to preserve, protect and enhance the
natural assets of Marin County.
Page 1 of 1
January 5th, 2022
City of San Rafael
Planning Commission
1400 Fifth Avenue
San Rafael, CA 94901
Via email: leslie.mendez@cityofsanrafael.org
Re: Tiscornia Marsh Habitat Restoration and Sea Level Rise Adaptation Project
Dear Planning Commissioners:
The Marin Conservation League has reviewed the Tiscornia Marsh proposal and urges you to
approve the project. There are still many steps before the project is ready to begin construction, but
the need is there now. This project will not only increase the protection of the area for near-term
sea level rise, but also will be a demonstration project for other jurisdictions with similar issues.
The Final Environmental Impact Report (EIR) addresses the issues raised by California Department
Fish and Wildlife. Most of the comments submitted were supportive of the project, not necessarily
addressing the merits of the EIR document.
The project is well designed. MCL supports its construction.
Thank you for this opportunity to comment.
Yours truly,
Robert Miller Susan Stompe
President Chair, Land Use, Water and
Transportation Committee
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CONSERVATION
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Community Development Department – Planning
Division
Meeting Date: January 11, 2022
Agenda Item:
3
Case Numbers:
ZC21-001, UP21-007, ED21-
024, TS21-002, IS21-002 &
DA21-001
Project Planner:
Tricia Stevens
(916) 698-4592
REPORT TO PLANNING COMMISSION
SUBJECT: Northgate Mall Redevelopment Project (5800 Northgate Drive) – Scoping meeting for the
Notice of Preparation of an Environmental Impact Report (EIR) for a Rezone to the Planned Development
(PD) zone, a Use Permit, an Environmental and Design Review Permit, and a Tentative Map to allow the
comprehensive redevelopment of the existing Mall into a new, phased mixed-use development with retail
and approximately 1,443 residences on a 44.76-acre site. APNs: 175-060-12, -40, -59, -61, -66 &-67;
General Commercial (GC) District; MeloneGeier Partners, owner/applicant; File Nos: ZC21-001, UP21-
007, ED21-024, TS21-002, IS21-002 & DA21-001
EXECUTIVE SUMMARY
The proposed project, also known as the Northgate Town Square, would result in the redevelopment of
the existing mall through demolition, renovation, and new construction with a mix of commercial and
residential land uses. The proposed project would be developed in two phases, and at full buildout is
currently proposed to include a total of approximately 225,100 square feet of commercial uses and up to
1,443 residential units, of which seven percent would be restricted to low-income households. The
remainder of the ten percent affordable housing requirement will be provided off-site or with other options
allowed by Zoning Ordinance Section 14.16.030. Project applications include the following:
• A Zoning Map and Zoning Text Amendment to the Planned Development (PD) Overlay Zone that
outlines allowable land uses, development standards, and a development plan for the proposed
project;
• A Development Agreement that sets forth the terms and requirements of the City and the public
benefits provided by the developer;
• A Tentative Vesting Parcel Map that will subdivide the property into 11 parcels;
• A Master Use Permit as required by the PD Overlay Zone to address standards for specific uses;
and
• An Environmental and Design Review Permit to address the site plan, architecture, landscaping,
building design and other site improvements.
Consistent with the California Environmental Quality Act (CEQA), the issuance of a Notice of Preparation
(NOP) is required when the lead agency has determined that an EIR will be prepared. An NOP was issued
on December 9, 2021, and transmitted to the State Clearinghouse, responsible and trustee agencies and
interested parties, to announce the initiation of the EIR process. The purpose of the scoping meeting is to
afford the Planning Commission, other agencies, and the public an opportunity to provide oral comments
on the Initial Study and the scope of issues and alternatives to be addressed in the EIR. Following the
close of the 30-day NOP comment period, City staff will review comments received and consider revisions
to the Initial Study and/or the scope of the Draft EIR, in accordance with CEQA Guidelines.
REPORT TO PLANNING COMMISSION - Case Nos: ZC21-001, UP21-007,
ED21-024, TS21-002, IS21-002 & DA21-001
Page 2
RECOMMENDATION
It is recommended that the Planning Commission take the following action:
1. Accept public comment on the Notice of Preparation and the scope of issues to be addressed in
the EIR; and
2. Direct staff to prepare a Draft Environmental Impact Report (DEIR), taking into consideration verbal
and written comments received during the scoping period.
BACKGROUND
The project sponsor, Merlone Geier Partners, LLC, submitted an application for the proposed project on
March 10, 2021. The City of San Rafael Planning Commission (PC) and Design Review Board (DRB) held
a joint study session on September 14, 2021. In addition to feedback and input from the PC and DRB, the
public was given the opportunity to provide initial comments on the project at this meeting.
Site Description/Setting: The project site is located west of US Highway 101 (US 101), in the City of San
Rafael, Marin County. The approximately 44.76-acre project site consists of the Northgate Mall, which is
located within the San Rafael Town Center in the northern portion of the city. The project site is generally
surrounded by a mix of uses, including commercial, residential, open space, and institutional. The project
site is bordered by Las Gallinas Avenue to the north and east and Northgate Drive to the south and west.
The project site is designated as Community Commercial Mixed Use on the City’s General Plan Land Use
Map and is within the General Commercial zoning district. The mall, which originally opened in 1965, is
generally oriented on a north-south axis, with the main building located in the center of the project site
surrounded by surface parking and standalone buildings and structures. Current major tenants within the
mall include Century Theatre, Macy’s, Kohl’s, Rite Aid, and HomeGoods. A total of 2,908 parking spaces
are provided on the project site.
PROJECT DESCRIPTION
The proposed project would result in the redevelopment of the existing mall through demolition, renovation,
and new construction with a mix of commercial and residential land uses. As shown in Table 1, the
proposed project would be developed in two phases, and at full buildout is currently proposed to include a
total of approximately 225,100 square feet of commercial uses and up to 1,443 residential units, of which
seven percent would be restricted to a minimum of low-income households. The remainder of the ten
percent affordable housing requirement will be provided off-site or with other options allowed by Zoning
Ordinance Section 14.16.030.
It should be noted that proposed square footages, residential unit mix, and other elements of the project
may be subject to continued refinement after publication of this NOP and prior to consideration of project
approval. The analysis in the EIR will evaluate the maximum development potential for the proposed
project.
REPORT TO PLANNING COMMISSION - Case Nos: ZC21-001, UP21-007,
ED21-024, TS21-002, IS21-002 & DA21-001
Page 3
Table 1: Proposed Project Buildout Summary
Phase
Existing
Commercial
(square feet)
Demolished
Commercial
(square feet)
Existing
Commercial
to Remain
(square feet)
New
Commercial
(square feet)
Total
Commercial
(square feet)
Residential
Units
Phase 1 766,507 305,446 461,061 44,100 505,161 1,013
Phase 2a 505,161 339,861 165,300 59,800 225,100 1,443
Source: Merlone Geier Partners LLC (2021).
a: Phase 2 represents the proposed project at full buildout, and therefore includes development from Phase 1.
As shown on Figure 1, Phase I consists of the following main elements:
I. Demolition of the Sears anchor, HomeGoods pad, and approximately 140,932 square feet of the
Mall structure.
II. New construction and renovation of retail and residential uses, corresponding to letters on Figure
1. Residential density is 20.5 units per acre and commercial floor area ration (FAR) is .27.
A. Remodel of the current multi-screen cinema with IMAX theatre (65,000 square feet), and the
addition of small shops and restaurants in the front of the cinema.
B. Construction of new retail on the east end, targeting a specialty grocery (Major 3), with housing
units above.
C. Renovation of a portion of the existing Mall structure west of Macys with a Major 2 store, and
retention of the existing Macy’s. The landscaping and parking in the north area (north of Macy’s)
would largely remain as is.
D. Retention of the existing Kohl’s and adjacent small shops and restaurants.
E. Addition of a 26,000 square foot plaza in the vicinity of the Kohl’s building, and preservation of
a portion of the Mall pavilion as a focal point and new parking and landscaping in the central
portion.
F. Addition of new restaurant pads on the north end of the site adjacent to Las Galinas Avenue.
G. Retention of the existing parking garage.
H. Phased construction of up to 1,013 housing units in six apartment-style buildings not exceeding
five stories in height, located on the southern, eastern, and western perimeters of the Project
property. Parking for the residential units would be both structured and surface parking.
I. Construction of Affordable housing on Parcel 1 consisting of 96 units
REPORT TO PLANNING COMMISSION - Case Nos: ZC21-001, UP21-007,
ED21-024, TS21-002, IS21-002 & DA21-001
Page 4
Figure 1: 2025 Phase I Plan
As shown on Figure 2, Phase II consists of the following main elements:
I. Demolition of the remaining Macy's and Kohl's anchors and the demolition and reconstruction of the
"Shops 1" structure adjacent to the Kohl's anchor.
II. New retail and residential uses, corresponding to letters on Figure 2. Residential density is 29.5
dwelling units per acre and floor area ration (FAR) is .13.
A. Addition of a 35,000 square foot town square plaza in the central portion of the project.
B. Construction of new retail including Major 1, with housing above, to replace the Kohl’s anchor
and existing shops.
C. Construction of up to an additional 430 housing units.
D. Construction of additional standalone restaurant pads along Las Gallinas Avenue.
E. Construction new retail shops including Major 4, with housing above, to replace the Macy’s
building.
REPORT TO PLANNING COMMISSION - Case Nos: ZC21-001, UP21-007,
ED21-024, TS21-002, IS21-002 & DA21-001
Page 5
Figure 2: 2040 Phase II Plan
ENVIRONMENTAL ANALYSIS AND REVIEW
Notice of Preparation
A Notice of Preparation (NOP) was published on December 9, 2021, to announce the commencement of
the EIR process and to solicit comments concerning the scope of issues to be addressed in the EIR. A 30-
day public review period is underway and written public comments will be accepted until Friday, January
14, 2022. (Note: an extra week was provided to account for holiday closures). The purpose of the scoping
meeting is to afford the Planning Commission, other agencies, and the public an opportunity to provide
oral comments on the scope of issues and alternatives to be addressed in the EIR. Following the close of
the NOP comment period, City staff will review comments received and consider revisions to the scope of
the Draft EIR, in accordance with CEQA Guidelines.
Probable Environmental Effects
The EIR will address the proposed project’s potential impacts to the following environmental topics as
required by CEQA.
• Aesthetics
• Agricultural and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
REPORT TO PLANNING COMMISSION - Case Nos: ZC21-001, UP21-007,
ED21-024, TS21-002, IS21-002 & DA21-001
Page 6
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
Project Alternatives
The EIR will provide conclusions on the significance level of each impact. Based on this analysis,
alternatives to the proposed project will be identified and analyzed to reduce identified impacts. Section
15126.6(e) of the CEQA Guidelines requires the evaluation of a No Project Alternative. Other alternatives
may be considered during preparation of the EIR and will comply with the CEQA Guidelines, which call for
a range of reasonable alternatives to the project, or the location of the project, which would feasibly attain
most of the basic objectives of the project but would avoid or substantially lessen any of the significant
effects of the project.
NEXT STEPS
EIR Process
Following the close of the NOP comment period, a draft EIR will be prepared that will consider all NOP
comments. In accordance with CEQA Guidelines Section 15105(a), the draft EIR will be released for public
review and comment for a required minimum 45-day review period. Following the close of the 45-day public
review period, the City will prepare a final EIR, which will include responses to all substantive comments
received on the draft EIR. The draft EIR and final EIR will be considered by the Planning Commission and
City Council in making the decision to certify the EIR and approve or deny the project.
Project Revisions
The applicant has indicated that revisions to the project will be made in response to Planning Commission,
Design Review Board, city staff, and general public comments. It is anticipated that such revisions will be
consistent with the scope of the EIR and would not create greater impacts than those studied in the
document. If such revisions do expand the scope of the EIR, then the scope of the EIR will be reassessed.
CORRESPONDENCE
As of the date and publication of this staff report, the City has received one comment letter on the NOP
from the Native American Heritage Commission. Correspondence received before the Planning
Commission meeting will be forwarded to Commission members under separate cover.
EXHIBITS
1. NOP for the Northgate Project, December 2021 (online link).
2. NOP comment received from the Native American Heritage Commission
Plans/documents and provided on website: Northgate Town Square - San Rafael (cityofsanrafael.org)
CHAIRPERSON
Laura Miranda
Luisefio
VICE CHAIRPERSON
Reginald Pagaling
Chumash
PARLIAMENTARIAN
Russell Attebery
Karuk
COMMISSIONER
William Mungary
Paiute/White Mountain
Apache
COMMISSIONER
Isaac Bojorquez
Ohfone-Costanoan
COMMISSIONER
Sara Dutschke
Miwok
COMMISSIONER
Buffy McQulllen
Yokayo Pomo, Yuki,
Nomfaki
COMMISSIONER
Wayne Nelson
Luisefio
COMMISSIONER
Stanley Rodriguez
Kumeyaay
EXECUTIVE SECRETARY
Christina Snider
Pomo
NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 95691
(916) 373-3 7 I 0
n o hc@nohc.co.gov
NAHC .ca.gov
STATE OF CALIFORNIA Gavia Newsom Governor
NATIVE AMERICAN HERITAGE COMMISSl ~e=---e:==--==-=-==-=-==-=-i
~~©~~\YI~~
December 16, 2021
Tricia Stevens, Consulting Planner
City of San Rafael
1400 Fifth Street
San Rafael, CA 94901
Re: 2021120187, Northgate Mall Redevelopment Project, Marin County
Dear Ms. Stevens:
lffij JAN O 3 znn jw
COMMUNllY DEVELO PMEN T DEPARTMENT
CllY OF SAN RAFAEL
The Native American Heritage Commission (NAHC) has received the Notice of Preparation
(NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project
referenced above. The California Environmental Quality Act (CEQA) (Pub . Resources Code
§21000 et seq.), specifically Public Resources Code §21084. l, states that a project that may
cause a substantial adverse change in the significance of a historical resource, is a project that
may have a significant effect on the environment. (Pub . Resources Code§ 21084. l; Cal. Code
Regs., tit.14, § 15064.5 (b) (CEQA Guidelines § 15064.5 (b)). If there is substantial evidence, in
light of the whole record before a lead agency, that a project may have a significant effect on
the environmerit, an Environmental Impact Report (EIR) shall be prepared. (Pub . Resources
Code §21080 (d); Cal. Code Regs., tit. 14 , § 5064 subd.(a)(l) (CEQA Guidelines§ 15064 (a)(l)).
In order to deterrriine whether a project will cause a substantial adverse change in the
significance of a historical resource, a lead agency will need to determine whether there are
historical resources within the area of potential effect (APE).
CEQA was amended significantly in 2014 . Assembly Bill 52 (Gatto, Chapter 532, Statutes of
2014) (AB 52) amended CEQA to create a separate category of cultural resources, "tribal
cultural resou.rces" (Pub. Resources Code §21074) and provides that a project with an effect
that may cause a substantial adverse change in the significance of a tribal cultural resource is
a project that may have a significant effect on the environment. (Pub . Resources Code
§21084 .2). Public agencies shall , when feasible, avoid damaging effects to any tribal cultural
resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice
of preparation, a notice of negative declaration, or a mitigated negative declaration Is filed on
or after July 1, 2015 .. If your project involves the adoption of or amendment to a general plan or
a specific plan, or the designation or proposed designation of open space, on or after March l,
2005 , it may also be subject to Senate Bill 18 (Burton , Chapter 905 , Statutes of 2004) (SB 18).
Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the
federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal
consultation requirements of Section 106 of the National Historic Preservation Act of 1966 ( 154
U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.
The NAHC recommends consultation with California Native American tribes that are
traditionally and culturally affil iated with the geographic area of your proposed project as early
as possible in order to avoid inadvertent discoveries of Native American human remains and
best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as
well as the NAHC's recommendations for conducting cultural resources assessments.
Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with
any other applicable laws.
Pagel of 5
AB 52
AB 52 has added to CEQA the additional requirements listed below, along with many other requirements :
1. Fourteen Day Period to Provide Notice of Completion of an Application/Decision to Undertake a Project :
Within fourteen ( 14) days of determining that an application for a project is complete or of a decision by a public
agency to undertake a project, a lead agency shall provide formal notification to a designated contact of, or
tribal representative of, traditionally and culturally affiliated California Native American tribes that have
requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.
Resources Code §21080.3. l (d)).
d. A "California Native American tribe" is defined as a Native American tribe located in California that is
on the contact list maintained by the NA HC for the purposes of Chapter 905 of Statutes of 2004 (SB 18).
(Pub. Resources Code §21073).
2. Begin Consultation Within 30 Days of Receiving a Tribe's Request for Consu ltat ion and Before Releasing a
Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report : A lead agency shall
begin the consultation process within 30 days of receiving a request for consultation from a California Native
American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.
(Pub. Resources Code §21080.3. l, subds. (d) and (e)) and prior to the release of a negative declaration,
mitigated negative declaration or Environmental Impact Report. (Pub. Resources Code §21080.3. l (b)).
a. For purposes of AB 52, "consultation shall have the same meaning as provided in Gov. Code §65352.4
(SB 18). (Pub. Resources Code §21080.3. l (b)).
3. Mandatory Topics of Consu ltat ion If Requested by a Tribe : The following topics of consultation, if a tribe
requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
'c. Significant effects. (Pub. Resources Code §21080.3.2 (a)).
4. Discretionary Topics of Consu ltation : The following topics are discretionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project's impacts on tribal cultural resources.
d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe
may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).
5. -Confidentia lity of Informa tion Submitted by a Tribe During the Environmental Review Process: With some
exceptions, any information, including but not limited to, the location, description, and use of tribal cultural
resources submitted by a California Native American tribe during the environmental review process shall not be
included in the environmental document or otherwise disclosed by the lead agency or any other public agency
to the public, consistent with Government Code §6254 (r) and §6254.10. Any information submitted by a
California Native American tribe during the consultation or environmental review process shall be published in a
confidential appendix to the environmental document unless the tribe that provided the information consents, in
writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3 (c) (l )).
6. Discussion of Impacts to Tribal Cultura l Resources in t he Environmental Document: If a project may have a
significant impact on a tribal cultural resource, the lead agency's environmental document shall discuss both ?f
the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource.
b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed
to pursuant to Public Resources Code §21082.3, subdivision (a), avoid or substantially lessen the impact on
the identified tribal cultural resource. (Pub. Resources Code §21082.3 (b)).
Page 2 of 5
7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the
following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on
a tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot
be reached. (Pub. Resources Code §21080.3.2 (b)).
8. Recommending Mitigation Measures Agreed Upon in Consu ltatio n in the Environmenta l Document: Any
mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code §21080.3.2
shall be recommended for inclusion in the environmental document and in an adopted mitigation monitoring
and reporting program, if determined to avoid or lessen the impact pursuant to Public Resources Code §21082.3,
subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §21082.3 (a)).
9. Required Consideration of Feas ible Mitigation : If mitigation measures recommended by the staff of the lead
agency as a result of the consultation process are not included in the environmental document or if there are no
agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if
substantial evidence demonstrates that a project will cause a significant effect to a tribal cultural resource, the
lead agency shall consider feasible mitigation pursuant to Public Resources Code §21084.3 (b). (Pub .'Resources
Code §21082.3 (e)).
10. Examples of Mitigation Measures That, If Feas ible~ May Be Consi d ered to Avoid or Mini mize Significant Adverse
Impacts to Trib a l Cultura l Resources :
a. Avoidance and preservation of the resources in place, including, but not limited to:
i. Planning and constructidn to avoid the resources and protect the cultural and natural
context.
ii. Planning greenspace, parks, or'pther open space, to incorporate the resources with culturally
appropriate protection and management criteria.
b. Treating the resource with culturally bppropriate dignity, taking into account the tribal cultural values
and meaning of the resource, including, but not limited to, the following:
i. Protecting the cultural character and integrity of the resource.
ii. Protecting the traditional use of the resource. ·
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easElments or other interests in real property, with culturally appropriate
management criteria for the purposes of preserving or utilizing the resources or places.
d. Protecting the resource. (Pub. Resource Code §21084.3 (b)).
e. Please note that a federally recognized California Native American tribe or a non-federally
recognized California Native Americqn tribe:that is on the contact list maintained by the NAHC to protect
a California prehistoric, archaeological,. cultural, spiritual, or ceremonial place may acquire and hold
conservation easements if the conservation easement is voluntarily conveyed. (Civ. Code §815.3 ( c)).
f. Please note that it is the policy of the state that Native American remains and associated grave
artifacts shall be repatriated. (Pub. Resources Code §5097.991 ).
11. Prerequisites for Certifying an Environme nt a l Impact Report or Ado pting a Mitiga te d Negative Declaratio n or
Negat ive Declaration with a Significant Impact on a n Identified Tribal Cultural Resource: An Environmental
Impact Report may not be certified, nor may a mitigated negative declaration or a negative declaration be
adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public
Resources Code §2 l 080.3. l and §2 l 080.3.2 and concluded pursuant to Public Resources Code
§21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise
failed to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources
Code §21080.3. l (d) and the tribe failed to request consultation within 30 days. (Pub. Resources Code
§21082.3 (d)).
The NAHC's PowerPoint presentation titled, "Tribal Consultation Under AB 52: Requirements and Best Practices" may
be found on line at: http://nahc.ca .g ov/wp-content/uploods/2015/l 0/A852TriboIConsu ltation Cal EPA PDF.pdf
Page 3 of 5
SB 18
SB 18 applies to local governments and requires local governments to contact, provide notice to, refer plans to, and
consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of
open space. (Gov. Code §65352.3). Local governments should consult the Governor's Office of Planning and
Research's "Tribal Consultation Guidelines," which can be found online at:
https://www.opr.co.gov/docs/09 14 05 Updated Guidelines 922.pdf.
Some of SB 18's provisions include:
1. Triba l Consultation : If a local government considers a proposal to adopt or amend a general plan or a
specific plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC
by requesting a "Tribal Consultation List." If a tribe, once contacted, requests consultation the local government
must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification to
request consultation unless a shorter timeframe has been agreed to by the tribe. (Gov. Code § 65352.3
(a)(2)).
2. No Statutory Time Limit on SB 18 Tribal Consultation . There is no statutory time limit on SB 18 tribal consultation.
3. Confidentiality: Consistent with the guidelines developed and adopted by the Office of Planning and
Research pursuant to Gov. Code §65040.2, the city or county shall protect the confidentiality of the information
concerning the specific identity, location, character, and use of places, features and objects described in Public
Resources Code §5097.9 and §5097.993 that are within the city's or county's jurisdiction. (Gov. Code §65352.3
(b)).
4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures
for preservation or mitigation; or ·
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes
that mutual agreement cannot be reached concerning the appropriate measures of preservation or
mitigation. (Tribal Consultation Guidelines, Governor's Office of Planning and Research (2005) at p. 18).
Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initiating tribal consultation with
tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in AB 52 and
SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and "Sacred Lands
File" searches from the NAHC. The request forms can be found online at: http://nahc.co.gov/resources/forms/.
NAHC Recommendations for Cultural Resources Assessments
To adequately assess the existence and significance of tribal cultural resources and plan for avoidance, preservation
in place, or barring both, mitigation of project-related impacts to tribal cultural resources, the NAHC recommends
the following actions:
1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center
(http://ohp.porks.co.gov/?page id=l068) for an archaeological records search. The records search will
determine:
a. If part or all of the APE has been previously surveyed for cultural resources.
b. If any known cultural resources have already been recorded on or adjacent to the APE.
c. If the probability is low, moderate, or high that cultural resources are located in the APE.
d. If a survey is required to determine whether previously unrecorded cultural resources are present .
2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report
detailing the findings and recommendations of the records search and field survey.
a. The final report containing site forms, site significance, and mitigation measures should be submitted
immediately to the planning department. All information regarding site locations, Native American
human remains, and associated funerary objects should be in a separate confidential addendum and
not be made available for public disclosure.
b. The final written report should be submitted within 3 months after work has been completed to the
appropriate regional CHRIS center.
Page 4 of 5
3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the
Sacred Lands File , nor are they required to do so. A Sacred Lands File search is not a substitute for
consultation with tribes that are traditionally and culturally affiliated with the geographic area of the
project's APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the
project site and to assist in planning for avoidance, preservation in place, or, failing both, mitigation
measures.
4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources)
does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for
the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code
Regs., tit. 14, § 15064.5(f) (CEQA Guidelines § 15064.5(f)). In areas of identified archaeological sensitivity, a
certified archaeologist and a culturally affiliated Native American with knowledge of cultural resources
should monitor all ground-disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the disposition of recovered cultural items that are not burial associated in consultation with culturally
affilic;ited Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the treatment and disposition of inadvertently discovered Native American human remains . Health
and Safety Code §7050.5, Public Resources Code §5097.98, and Cal. Code Regs., tit. 14, § 15064.5,
subdivisiom (d) and (e) (CEQA Guidelines§ 15064.5, subds. (d) and (e)) address the processes to be
followed in the event of an inadvertent discovery of any Native American human remains and
associated .grave goods in a location other than a dedicated cemetery.
If you have any questions or need additional information, please contact me at my email address:
Katy.Sonchez.@nahc.co .gov.
Sincerely ,
Katy Sanchez
Associate Environmental Planner
cc: State Clearinghouse
Page 5 of 5
Community Development Department – Planning Division
Meeting Date: January 11, 2022
Agenda Item:
4
Case Numbers:
P22-01
Project Planner:
Leslie Mendez (415) 485-3095
REPORT TO PLANNING COMMISSION
SUBJECT: Annual Meeting of Planning Commission for 2022 to include: a) election of officers; and
b) review of Planning Commission “Rules and Procedures”; and c) selection of liaisons
to DRB meetings
EXECUTIVE SUMMARY
The Annual Meeting of the Planning Commission is required to elect the Chair and Vice Chair officers for
the calendar year. The Annual Meeting also provides the Commission an opportunity to review and
consider adoption of revisions to the Planning Commission’s “Rules and Procedures.” The Rules and
Procedures were last amended by the Commission at the January 2021 annual meeting. This year, staff
has no suggested edits to the Rules and Procedures, however, the Commissioners may have suggested
edits.
RECOMMENDATION
It is recommended that the Planning Commission take the following action:
a) Elect a new Chair and Vice Chair for 2022; and
b) Consider and accept any proposed changes to the Planning Commission “Rules and
Procedures;” and
c) Select Planning Commission liaisons to the DRB for 2022
BACKGROUND AND ANALYSIS
Election of Officers:
Section II.E of the Planning Commission “Rules and Procedures” requires that the Planning Commission
conduct an annual meeting to select officers (Chair and Vice Chair) for the calendar year. The Annual
Meeting is defined as the “first meeting of the calendar year,” which for this year is January 11, 2021.
The office of the Chair and Vice Chair is rotational, with selection based on seniority or tenure of service.
Per the Rules and Procedures, generally, a Commissioner shall not serve as a Chair more than once in
seven consecutive years. See attached Exhibit 1, which lists the appointment dates and past service as
chair by each of the Commission members.
Chair
Based on the rotation criteria, Commissioner Previtali is next-in-line to serve as Chair, as he
served as Vice Chair for 2021.
Vice Chair
In order to determine the next Vice Chair, the same rules and procedures for Chair apply to Vice
Chair. There are three Commissioners who have not served as Chair or Vice Chair in the past 7
years (Commissioners Saudi, Haveman, and Harris). Commissioner Saudi was appointed in July
REPORT TO PLANNING COMMISSION Page 2
2020; Commissioner Haveman was appointed in May 2021 and Commissioner Harris in June
2021. Therefore, Commissioner Saudi would be the next in line to serve as Vice Chair.
RECOMMENDATION: Based on the rules and procedures, it is recommended that Commissioner
Previtali be elected to serve as Chair and Commissioner Saudi be elected to serve as Vice Chair.
Consideration of Revisions to Planning Commission “Rules and Procedures”:
The Rules and Procedures are reviewed by the Commission. Staff has no new recommended edits to
the Rules and Regulations that were adopted by the Planning Commission last year to include provision
for virtual public hearings. The Planning Commission is asked to review the currently adopted Rules and
Procedures and submit any feedback or suggested changes.
Selection of Commissioners for DRB Liaison:
The annual meeting also provides an opportunity to select Commissioners to serve as a liaison at the
Design Review Board meetings for the calendar year. Commissioners (with the exception of the new
Chair) are requested to serve as liaison in two-month increments, which involves attendance at up to
four, regular DRB meetings during the two selected months of service. However, since the Planning
Commission is currently one member short, staff is looking to have DRB liaison assignments for the first
half of the year and will bring the item back for the second half of year at a later date when the
Commission is fully appointed. Staff is, therefore, requesting that with the exception of the new Chair,
that either (1) half the Commissioners volunteer for a two month period for the first half of the year (the
rest to volunteer for the second half); or (2) each Commissioner select one month (with one volunteering
for two), with each Commissioner to volunteer for a second month the second half of the year (with the
exception of the Commissioner already signed up for two months). A schedule of DRB for January
through June 2022 is included as Exhibit 3.
2022 Planning Commission Meeting Dates:
Provided for your information is a list of scheduled Planning Commission meetings for 2022.
OPTIONS
Regarding the “Rules and Procedures,” the Planning Commission has the following options:
1. Modify the “Rules and Procedures” for review and direct staff to return with revised document for
consideration at a future meeting;
2. Identify additional areas for further study and direct staff to return with recommended revisions to
the “Rules and Procedures” for action at a future meeting;
3. Continue this upcoming year with the current “Rules and Procedures” as adopted on January 12,
2021.
EXHIBITS
1. Table Listing Planning Commissioners, Tenure and Chairpersonship, prepared February 4, 2022
2. Planning Commission “Rules and Procedures” revised January 12, 2021
3. Planning Commission liaison assignment to DRB meetings dates for first half of 2022
4. Planning Commission Meeting Schedule for 2022
T:\CD AGENDA ITEMS\_Agenda Item Approvals for PC\2022-01-11\4. Action Calendar_Annual Meeting
of Planning Commission 2022\Exhibit 1 PC membership.doc
EXHIBIT 1
San Rafael Planning Commission
History of Tenure and Chairpersonship
Prepared January 4, 2022
Commissioner First
Appointed to
Commission
Years Served as
Chairperson
Years Served as
Vice Chair
Aldo Mercado
07/2018 2020 partial 2020 partial
Shingai Samudzi 07/2019
2021 2020 partial
Jon Previtali
07/2020 None 2021
Samina Saude
07/2020
None None
Jon Haveman 05/2021 None None
Camille Harris 06/2021 None None
EXHIBIT 2-1
Exhibit 2
PLANNING COMMISSION RULES AND PROCEDURES
CITY OF SAN RAFAEL
I. Organization and Officers
A. Organization
1. The Planning Commission shall consist of seven regular members
appointed by the Mayor with the approval of the City Council and shall be
organized and exercise such powers as prescribed by the City Charter
and by the San Rafael Municipal Code (City Code).
2. The term of the Commission members is four years with a staggered
expiration schedule.
3. Vacancies on the Commission for other than expiration will be filled by
appointment for the un-expired portion of the term.
4. If any Commissioner should have three consecutive, unexplained
absences from regular meetings of the Planning Commission as shown in
the roll call of the official minutes, the Chair may recommend to the City
Council that the seat be relinquished.
5. If any Commissioner wishes to request a leave of absence for three to six
consecutive meetings, the request shall be made to and approved by the
Chair. A request for a leave of absence for more than six consecutive
meetings shall be made to and approved by the City Council.
B. Officers
1. Selection
a. A Chair and Vice-Chair shall be elected from among the Commission's
membership at the Annual Meeting held the first meeting of the
calendar year, to serve for a one year period. It is intended that the
Chair and Vice-Chair be rotated among the Commissioners based on
tenure, as defined by total years of service. In the event the years of
service are identical, tenure will be determined in alphabetical order. It
is the general rule that a Commissioner shall not serve as Chair more
than once in seven consecutive years. However, in the event that: 1) a
position is vacated; 2) a Commissioner is not interested in serving as
an officer; or 3) there is limited tenure among the other
Commissioners, then a Commissioner can be appointed as an officer
more than once in seven years.
b. The Vice-Chair shall serve as Chair in the following year.
EXHIBIT 2-2
c. The Chair and Vice-Chair may not succeed themselves. However, in
the event that the current Chair or Vice-Chair has served less than a
year, the Commission may choose to re-elect her/him for an additional
term.
d. The Vice-Chair shall succeed the Chair if he/she vacates the office,
and shall serve the un-expired term of the Chair. The Commission
shall elect a new Vice-Chair to serve the un-expired term of that office.
Selection shall be based on seniority.
e. In the absence of the Chair and Vice-Chair, the member of the
Commission with the longest tenure, as defined by total years of
service, shall preside over the meeting. In the event that the years of
service are identical, seniority will be determined by alphabetical order.
2. Responsibilities
The responsibilities and powers of the officers of the Planning
Commission shall be as follows:
a. Chair
- Preside at all meetings of the Commission.
- Call special meetings of the Commission in accordance with legal
requirements and the Rules of Procedure.
- Sign documents of the Commission.
- See that all actions of the Commission are properly taken.
- Assist staff in determining agenda items.
- The Chair shall be an ex officio member of all committees with voice
but not vote.
b. Vice-Chair
During the absence, disability or disqualification of the Chair, the Vice-
Chair shall exercise or perform all the duties and be subject to all the
responsibilities of the Chair.
C. Duties and Powers
1. The Planning Commission shall have the power to recommend to the City
Council, after conducting a public hearing, the adoption, the amendment
or the repeal of a General Plan, a Neighborhood or Specific Plan, the
Zoning Ordinance of the City Code, or a site-specific master plan for a
Planned Development (PD) District, or any part thereof, for the physical
development of the City.
2. The Planning Commission shall exercise such functions with respect to
environmental review, land subdivisions, land use and planning, design
EXHIBIT 2-3
review, and zoning, as may be prescribed by City Code, City resolution,
and State law.
3. The Commission shall advise the City Council on those matters falling
within its charged responsibilities in a manner reflecting concern for the
overall development and environment of the City as a setting for human
activities.
D. Rules of Order
Except as otherwise provided in these Rules of Procedure, "Roberts Rules of
Order, Newly Revised" shall be used as a guide to the conduct of the
meetings of the Planning Commission, provided, however, that a failure of the
Commission to conform to said rules of order shall not, in any instance, be
deemed to invalidate the action taken.
II. Meetings
A. Public Meetings
All meetings shall be held in full compliance with the provisions of state law,
ordinances of the City and these Rules of Procedure.
B. Regular Meetings
1. Regular meetings shall be held on the second and fourth Tuesdays
following the first Monday in each month, at 7:00 p.m. in the Council
Chambers of the City Hall, unless otherwise determined by the
Commission. All regular meetings must be held in the following manner:
a. within the city limits of San Rafael.
b. using a remote virtual meeting format
2. Whenever a regular meeting falls on a public holiday, no regular meeting
shall be held on that day. Such regular meeting may be rescheduled to
another business day, or canceled by motion adopted by the Planning
Commission. All meetings must be held within the city limits of San Rafael.
3. A meeting of the Commission may be canceled by the Chair for lack of a
quorum, no pending business, or any other valid reason. Such
cancellation may be made at any time prior to the scheduled meeting. All
efforts shall be made by the Community Development Department staff to
notify those involved at the earliest possible time. Prior to the scheduled
meeting, the Community Development staff shall post a cancellation
notice on the City of San Rafael public hearing board, the City website and
at the prescribed location of the meeting.
C. Adjourned Meetings
EXHIBIT 2-4
In the event it is the wish of the Planning Commission to adjourn its meeting
to a certain hour on another day, a specified date, time, and place must be
set by a majority vote of the Commissioners present, prior to the regular
motion to adjourn.
D. Special Meetings
Special meetings of the Planning Commission may be held at any time upon
the call of the Chair or by a majority of the voting members of the Commission
or upon request of the City Council following at least 24 hours notice to each
member of the Commission and to the press. The time and place of the
special meeting shall be determined by the convening authority. At least 24
hours prior to the scheduled special meeting, the Community Development
staff shall post a notice of the meeting on the City of San Rafael public
hearing board, the City website and at the prescribed location of the meeting.
E. Annual Meeting
The Annual Meeting of the Planning Commission will be held at the first
meeting of the calendar year. The meeting will be devoted to the election of a
Chair and Vice-Chair for the ensuing year and any other business scheduled
by the Commission.
F. Study Sessions/Workshops/Informational Presentations
1. The Commission may be convened in the same manner as prescribed for
the calling of a special meeting for the purpose of holding a study session,
or for presentations of informational items, provided that no official action
shall be taken.
2. Such meetings shall be open to the public.
G. Notification
Public Hearings and Discussion Items - Notice of the time, place/ items to be
considered and action pending shall be given in accordance with the
requirements of the City Code and State Law.
H. Agenda
1. An agenda for each meeting of the Commission shall be prepared by the
Community Development Director or staff in consultation with the Chair.
2. A staff report shall be prepared for each item and-distributed to the
Planning Commission and made available to the public a minimum of 72
hours prior to a regular meeting.
3. A copy of the agenda shall be posted in City Hall 72 hours before a
regular meeting.
EXHIBIT 2-5
4. Items not appearing on the agenda cannot be acted upon or discussed by
the Commission. However, the Commission may take action under the
following circumstances:
a. If the Commission finds, by majority vote, that an emergency situation
must be addressed. An "emergency situation” is limited to work
stoppages and crippling disasters;
b. If by a two-thirds vote (or a unanimous vote if two-thirds of the
members are not present), there is a need to take immediate action
and the need for action came to the attention of the Commission and
staff after the agenda was posted.
Prior to discussing such items, the Commission shall publicly identify the
item and shall provide the public an opportunity to provide comment on
the item.
5. Members of the public may address the Commission on any agenda item,
and may, at the beginning of the meeting, address the Commission on any
issue that is not listed on the agenda, provided that the issue is within the
jurisdiction and powers of the Planning Commission.
I. Order of Meetings
1. The Order of business shall be as follows:
a. The Chair shall take the chair at the hour appointed for the meeting
and shall immediately call the meeting to order.
b. The Chair shall lead a pledge of allegiance, for in person meeting; the
pledge of allegiance will not occur for virtual meetings
c. Members present and absent shall be recorded by roll call.
d. The order of the agenda shall be approved as submitted or revised by
a majority vote of the Commissioners present.
e. The public shall be advised of the procedures to be followed in the
meeting including the protocol and time frames for public comment.
For virtual meetings, the public will be advised of the different ways to
participate.f. Any member of the audience may comment on any
matter which is not listed on the agenda.
g. The minutes of any preceding meeting shall be submitted for review
and approval by a majority vote of the Commissioners present at that
preceding meeting.
h. The Commission shall then hear and act upon those proposals
scheduled for consideration or public hearing.
i. Director's Report.
j. Commission Communications.
k. Adjournment.
EXHIBIT 2-6
2. Presentation or Hearing of Proposals
The following shall be the order of procedure for hearings/discussion items
concerning planning and zoning matters:
a. The Chair shall announce the subject of the public hearing/discussion
item, as noticed.
b. If a request is made for continuance, a motion may be made and voted
upon to continue the public hearing to a definite time and date (noticing
not required) or a time and date to be determined (re-noticing
required).
c. Order of Speaking.
The order of speaking shall be as follows:
1. The Chair shall call for commissioners to make ex parte disclosures
and potential conflict of interest disclosures with respect to the
proposed project.
2. Staff provides a report on the project and summarizes its
compliance with San Rafael's General Plan, compliance with State
laws and the City Code, the status of environmental review, and the
staff recommendation for action(s) by the Commission.
3. The public hearing is opened.
4. The applicant makes a presentation to the Commission.
5. The public speaks to the Commission.
6. The Commission may ask questions or obtain facts or clarification
from staff, the applicant or the public after each segment of the
agenda.
7. The public hearing is closed.
8. The matter is returned to the Commission for discussion and action.
d. Rules of Testimony
The rules of testimony shall be as follows:
1. Upon opening the public hearing, the Chair shall invite the public to
speak by inviting each speaker (one-at-a-time) to approach the
podium. For virtual meetings, the chair will ask staff to advise the
public on the different options for participating. On large or
controversial projects where many people wish to provide public
testimony, the Chair may request that speaker cards be filled-out
and submitted.
2. Persons presenting testimony to the Commission are requested to
identify themselves by name and place of residence.
EXHIBIT 2-7
3. Persons presenting testimony to the Commission shall be limited to
three (3) minutes for their presentation. An extension of this time
limit may be granted at the Chair’s discretion.
4. If there are numerous people in the audience who wish to
participate on the issue and it is known that all represent the same
opinion, a spokesperson should be selected to speak for the entire
group. At the Chair’s discretion, the spokesperson may be granted
additional time beyond the three (3) minute limit for his or her
presentation.
5. To avoid unnecessary repetitive evidence, the Chair may limit the
number of speakers or the time on a particular issue.
6. Irrelevant, defamatory, or disruptive comments will be ruled out of
order.
7. No person shall address the Commission without first securing the
permission of the Chair.
8. All comments shall be addressed to the Commission. All questions
shall be made or directed through the Chair.
e. Applicant Presentations
Applicant presentations shall comply with the guidelines developed by
the Planning Commission. Applicants shall be limited to a maximum of
ten (10) minutes for their presentation, inclusive of all members of the
applicant’s team (if applicable). An extension of this time limit may be
granted at the Chair’s discretion.
J. Motions
1. A motion to adjourn shall always be in order except during roll call.
2. The Chair of the Commission, or other presiding officer, may make and
second motions and debate from the Chair subject only to such
limitations of debate as are imposed on all members of the
Commission.
K. Voting
1. Voting Requirements
a. A quorum shall consist of four members.
b. The affirmative vote of a majority of the quorum present is
necessary for the Commission to take action on all matters other
than those listed under Section c below.
c. Certain votes of the Commission require a majority vote of the
entire Commission (4 votes) to carry. These are:
Adoption or amendment of a General Plan or any part thereof.
Adoption or amendment to any Neighborhood or Specific Plan
or any part thereof.
EXHIBIT 2-8
Adoption or amendment to the Zoning Ordinance of the City
Code or amendment thereto.
Adoption or amendment to a site-specific master plan for a
Planned Development (PD) District.
Other actions as required under federal or state law. (These will
be dealt with as they arise.)
d. When a member of the Commission abstains from voting on any
matter before it because of a potential conflict of interest, because
the Commissioner does not believe he/she can be objective, or
because the Commissioner was absent at any previous hearing on
an item, said vote shall not constitute nor be considered as either a
vote in favor of or opposition to the matter being considered.
Abstentions shall not be allowed for any other reason.
e. A tie vote shall be recorded as a failure of action to pass. A tie vote
on a motion defeats the motion.
2. Roll Call Vote
Any Commissioner, the applicant or an appellant can request a roll call
vote.
For virtual meetings a roll call vote shall be required.
3. Recording of Votes
The minutes of the Commission's proceedings shall show the vote of
each member, including whether they were absent, abstained from
voting, or failed to vote on a matter considered.
4. Disqualification from Voting
A member shall disqualify himself/herself from voting in accordance
with the State Political Reform Act and other applicable state law.
When a member is disqualified, he/she shall state, prior to the
considerations of such matter by the Commission that the member is
disqualifying himself/herself due to a possible conflict of interest and
shall then leave the voting area.
III. Review and Amendments Procedure
A. These Rules of Procedure shall be reviewed at the Annual Meeting of each
year. On an ad hoc basis, the chair may appoint a subcommittee to review
these rules prior to the meeting. The review subcommittee shall present their
recommendations for amending or not amending these rules. Minor changes
may be brought forward by staff for the Commission's consideration.
B. In addition, these Rules of Procedure may be amended at any meeting of the
Planning Commission by a majority of the membership of the Commission
EXHIBIT 2-9
provided that notice of the proposed amendment is received by each
Commissioner not less than 5 days prior to said meeting.
(Approved May 9, 2000. Revised February 26, 2002, December 14, 2004, May 29, 2007, January 27, 2009, January
9, 2018, February 11, 2020, and January 12, 2021)
Exhibit 3
- DESIGN REVIEW BOARD MEETINGS –
Planning Commission Liaison January – June 2022
Months Commission Liaison
January 4 (cancelled)
January 19 (Wednesday)
February 8
February 23 (Wednesday)
March 8
March 22
April 5
April 19
May 3
May 17
June 7
June 21
Notes:
• Chair does not serve as liaison
• All DRB meetings are the 1st and 3rd Tuesday of each
month, starting with the first full week (a week includes
a Monday).
• All dates above are Tuesday’s except as noted. If there
is a holiday on Monday, the DRB meeting gets pushed
to Wednesday for that week.
Exhibit 4
PLANNING COMMISSION MEETINGS for 2022
January 11
January 25
February 15
March 15
March 29
April 12
April 26
May 10
May 24
June 14
June 28
July 12
July 26
August 9
August 23
September 13
September 27
October 11
October 25
November 15
November 29
December 13
Notes:
• All PC meetings are the 2nd and 4th Tuesday of each month,
starting with the first full week (a week includes a Monday).
• All dates above are Tuesdays unless there is a holiday on
Monday that week, then the PC meeting gets pushed to
Wednesday for that week.