ATTACHMENT_9_Responses to Western States Regional Council of Cartpenters CEQA Comment Letter
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Atachment 9
Responses to Mitchell Tsai on behalf of Western States Regional Council of Carpenters Comments
The Applicant had a biologist with exper�se in Crotch bumble bees survey the project site. The site has a
low poten�al for Crotch bumble bees because it does not provide good habitat and no bees were
observed. The report is provided as Attachment 7 to the agenda staff report.
Moreover, the cited CDFW document is not a survey protocol, and the opening paragraph states, “This
document should not be interpreted as an order or mandatory protocol for species surveys.” As noted in
the protocol, the survey will be conducted according to the condi�ons, including wind condi�ons. The
atached report of the site survey that was conducted shows it is not a bee habitat, and no bees were
present. The addi�onal survey required by the mi�ga�on measure will either confirm this or if bees are
iden�fied, mi�ga�on will be required.
On the traffic, the mi�ga�on measure requires the project to fully fund the sidewalk improvements. To
implement the sidewalk, the city must condemn the property. Should the city decide there is an actual
safety issue, which may or may not be, then the city can condemn the land, and the funding will be used
to install the sidewalk. It is not deferred mi�ga�on, but rather, we are implemen�ng all feasible mi�ga�on
that can be imposed on the project as the project applicant cannot condemn property as part of the
project.
Per the City Engineer, sidewalks and public improvements within the designated project area will be
funded and constructed concurrently with the overall project development. Per the City Engineer,
sidewalks outside this area will be funded and constructed as associated improvements and developments
occur. All transi�onal areas will be engineered to create a cohesive and integrated network. In instances
where the right-of-way has not been dedicated to the city, the developer shall be required to dedicate the
right-of-way prior to the construc�on of public improvements, including curb, guter, and sidewalk.
Conversely, if the right-of-way has been previously dedicated, the developer shall assume responsibility
for the construc�on of the requisite public street improvements.
On VMT-induced GHG emissions caused by laborers commu�ng, this is already addressed in our EIR that
the full commute distance is analyzed. The vast majority of project VMT is during opera�ons, not during
construc�on. Of the VMT generated during construc�on, worker commu�ng is only a small por�on of the
VMT. Local workers will want to take jobs close to their homes and any requirement for local hire will not
necessarily change human behavior.