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Sports Park - USA Amendment 98-03 Certified Final EIRO 4 GILROY SPORTS PARK AND URBAN SERVICE AREA AMENDMENT (USA 98 -03) CERTIFIED FINAL ENVIRONMENTAL IMPACT REPORT City of Gilroy June 7, 1999 Gilroy Sports Park and Urban Service Area Amendment (USA 98 -03) ¢, Certified Final Environmental Impact Report SCH # 98102079 1 Planning Commission Hearing: May 6,1999 City Council Hearing: May 17,1999 Certified by the Gilroy City Council: June 7,1999 The Draft EIR and Final EIR Addendum together make up the Certified Final EIR. Prepared for: City of Gilroy 7351 Rosanna Street Gilroy, California 95020 (408) 846 -0440 y Mr. William A. Headley, Jr. Facilities and Parks Development Manager June 7, 1999 it Prepared j�/1 Group Inc. 99 Pacific Street, Suite 155F Monterey, California 93940 Phone: (831) 649 -1799 Fax: (831) 649 -8399 E -Mail: emcgroup@emcplanning.com - ' GILROY SPORTS PARK AND URBAN SERVICE AREA AMENDMENT (USA 98 -01) �I if FINAL ENVIRONMENTAL IMPACT REPORT ADDENDUM City of Gilroy April 1999 i Gilroy Sports Park and Urban Service Area Amendment Final Environmental Impact Report Addendum SCH # 98102079 Prepared for: City of Gilroy 7351 Rosanna Street Gilroy, California 95020 (408) 846 -0440 Mr. William A. Headley, Jr. Facilities and Parks Development Manager April 1999 Prepared by: Orl- %� Planning E jrl C Group Ina 99 Pacific Street, Suite 155F Monterey, California 93940 Phone: (831) 649 -1799 Fax: (831) 649 -8399 E -Mail: emcgroup@emcplanning.com Table of Contents 1.0 Introduction ................................................ ............................1 -1 AddendumOverview .............................................................. ............................1 -1 2.0 Response to Comments .............................. ............................2 -1 3.0 Revised Summary ....................................... ............................3 -1 ` Proposed Project ....................................................................... ............................3 -1 Summaryof Impacts and Mitigation Measures .............. ............................3 -2 Summary of Other CEQA Considerations ........................ ............................3 -2 Summary of Alternatives Analysis ' ..................................... ............................3 -4 4.0 Changes to the Draft EIR Text ................ ............................... 4 -1 Appendix A - Mitigation Monitoring Program List of Tables Table A Response to Comments Summary by Topic ......... ............................2 -2 - Table S -1 Summary of Impacts and Mitigation Measures .. ............................3 -6 iJ 1.0 Introduction The City of Gilroy, acting as lead agency, has determined that the proposed addition of 133.2 acres to its Urban Service Area, approval of a Park Master Plan and phased development of a sports park and related off -site improvements (hereinafter "proposed project ") may result in significant adverse environmental effects, as defined by the California Environmental Quality Act (CEQA) Guidelines section 15064. Therefore the City of Gilroy has determined that an environmental impact report (EIR) be prepared to evaluate the potentially significant adverse environmental impacts of the proposed project. A Draft EIR was prepared, and circulated for public review on February 17,1999. The public review period ended on April 2,1999. CEQA Guidelines section 15200 indicates that the purposes of the public review process include sharing expertise, disclosing agency analysis, checking for accuracy, detecting omissions, discovering public concerns and soliciting counter proposals. The Gilroy Sports Park and USA Amendment EIR Final Addendum (hereinafter "addendum ") has been prepared to address comments received during the public review period and, together with the Draft EIR, constitutes the Gilroy Sports Park and USA Amendment Final EIR (Final EIR). Addendum Overview The following is a brief overview of the organization of this addendum. It is intended to inform the reader how this document was prepared and presented, and to identify the general contents within. • Section 1 contains an introduction to the Final EIR well as this addendum overview. • Section 2 contains written comments on the Draft EIR, as well as the responses to those comments. No oral comments were submitted. • Section 3 contains a revised summary of the Draft EIR, identifying the changes in the impacts and mitigation measures resulting from comments on the Draft EIR. • Section 4 contains the revisions to the text of the Draft EIR resulting from comments on the Draft EIR. EMC Plannit:g Group Inc. 1 -1 Introduction Park and USA Amendment Final EIR Addendum This side intentionally left blank 1_2 EMC Planning Group Inc. 1 - EMC Planning Group Inc. 2 -1 2.0 Response to Comments _ CEQA Guidelines section 15132(c) requires that the Final EIR contain a list of persons, organizations, and public agencies who have commented on the Draft EIR. A list of the correspondence received during the public review period is presented below. CEQA Guidelines section 15132(b) and 15132(d) requires that the Final EIR contain the comments that raise significant environmental points in the review and consultation process, and written response to those comments. A copy of each correspondence received during the public review period is presented on the following pages.. Numbers along the left -hand side of the letter identify each comment. A response to each comment that raises a significant environmental point is located immediately following the letter. Where required, revisions have been made to the text of the Draft EIR based on the responses to comments, and these are included in Section 4, Changes to the Draft EIR Text. ` The following correspondence was received during the 45 -day public review period, -` b which ended on April 2,1999. 1. County of Santa Clara Roads and Airports Department 2. California Regional Water Quality Control Board 3. Santa Clara Valley Water District 4. U.S. Army Corps of Engineers " . 5. Greenbelt Alliance 6. California Department of Transportation 7. California Department of Conservation - - 8. Streams for Tomorrow ;y - 9. Valley Transportation Authority 'I 10. County of Santa Clara Local Agency Formation Commission The following correspondence was received after the close of the 45 -day public review period. d� 11. County of Santa Clara Roads and Airports Department Table A summarizes the significant environmental issues raised in each letter. - EMC Planning Group Inc. 2 -1 Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum TABLE A Response to Comments Summary by Topic Draft EIR Topic Correspondence Number 1 2 3 4 5 6 7 S 9 10 11 No Environmental Comment X X Project Description X Policy Consistency X X Adequacy of Mitigation X X EIR Uses Agricultural Considerations X X Geology Hydrology X X X Public Services Biology X X X Transportation X X Air Quality Noise Archaeology Aesthetics JX]j Cumulative Impacts X Alternatives X X Source: EMC Planning Group Inc. 2_2 EMC Planning Group Inc. 1 County of Santa Clara Roads and Airports Department Land Development Services 101 Skyport Drive San Jose, California 95110 March 8, 1999 Mr. Bryan Stice Engineering Division City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 RK,Ei ED MR. 11 1999 Gilroy Pianning Div. Subject: USA 98 -03 — Gilroy Sport Park Draft Environmental Impact Report Dear Mr. Stice: Your Draft Environmental Impact Report dated February 11, 1999 for the subject project has been reviewed. We have the following comments. Please submit the Traffic Impact Report (TIR) reference mentioned on Pages 2-47 L and 2 -48. 2 r2. The project needs to analyze Level of Service (LOS) at the intersections of Thomas L Road/Santa Teresa Blvd. and Miller Avenue /Santa Teresa Blvd. 3. Table 9, Page 2 -64 lists the Level of Service (LOS) as "F" for Saturday peak for 3 Phase V., but on Page 2 -76 under "Significant Impact" the LOS is listed as "E ". Please let us know which one is right. 4. The LOS for Phase VI and VII is listed "F', but no analysis is performed. 4 The delay under Phase V is 45 seconds and it is mitigated by a proposed signal. The delay for Phase VI and VII is 117 seconds. Is any mitigation proposed for these two Phases. Board of Supervisors: Donald F. Gage, Blanca Alvarado, Pete McHugh, James T. Beall, Jr., S. Joseph Simitian County Executive: Richard Wittenberg ell 1 �d a_r��99 1 Mr. Bryan Stice Page 2 March 8, 1999 Thank you for the opportunity to review and comment on this project. Please call me at 573 -2464 if you have any questions. Sincer ly III Ral ca Nitescu Project Engineer RN:rtj cc: S. Kandah File Gilroy Sports Park and USA Amendment. Final EIR Addendum Response to Comments Response to Letter 1 County of Santa Clara Roads and Airports Department Raluca Nitescu, Project Engineer. March 8,1999 1. A copy of the transportation impact analysis has been forwarded to the County of Santa Clara Roads and Airports Department. 2. In its response to the Notice of Preparation, the County of Santa Clara Roads and Airport Department requested that two additional intersections be included in the transportation impact analysis. These were the intersection of Thomas Road /Luchessa Avenue and Church Street and the intersection of Thomas Road and Santa Teresa Boulevard. The City of Gilroy Engineering Division directed the addition of the intersection of Thomas Road /Luchessa Avenue and Church Street to the transportation impact analysis, and further analysis was performed and included in the Draft EIR. The City of Gilroy Engineering Division determined that an analysis of the Thomas Road and Santa Teresa Boulevard intersection was not necessary in the transportation impact analysis. The geometry of this intersection will be improved and signal lights added prior to completion of the first phase of the sports park. These improvements will be built with funding from the City of Gilroy and the developer of the Eagle Ridge residential development. The improvements to this intersection are expected to maintain an acceptable level of service at the intersection with the addition of traffic from the projects included in the cumulative traffic analysis for the sports park. The intersection of Santa Teresa Boulevard and Miller Avenue was not identified as an intersection of concern in the County of Santa Clara Roads and Airport Department response to the Notice of Preparation. The City of Gilroy Engineering Division has determined that analysis of this intersection is not necessary because the intersection has a low existing traffic volume and only 25 percent of traffic from the sports park will utilize the intersection. The Engineering Division estimates that fewer than 70 northbound and fewer than 70 southbound trips would be added to this intersection during the weekday PM peak hour, and that fewer than 100 southbound trips and fewer than 100 northbound trips would be added to this intersection during the Saturday peak hour at project build -out. The Engineering Division finds that an obvious capacity exists at this intersection, and that there would be no benefit in including the intersection in the transportation impact analysis. 3. Based on the page references and figures cited, comment 3 refers to the intersection of Monterey Road and Monterey Frontage Road. LOS F as shown in Table 9 on page 2 -64 of the Draft EIR is correct. The reference to EMC Planning Group Inc. 2 -5 Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum LOS E on page 2 -76 of the Draft EIR has been corrected. Without mitigation, the intersection of Monterey Road and Monterey Frontage Road would incur average delays of 45.6 seconds -and operate at LOS F during the Saturday peak hour after the completion of Phase V. 4. Based on the average delay figures cited, comment 4 refers to the intersection of Monterey Road and Monterey Frontage Road. The average delay and LOS figures included in Table 9 are calculated without the implementation of any mitigation measures. With the implementation of mitigation measures proposed to be implemented prior to the completion of Phase IV, (geometry improvements and signalization), the intersection of Monterey Road and Monterey Frontage Road will operate at LOS C or better under project build - out and cumulative conditions. Without mitigation, the intersection of Monterey Road and Monterey Frontage Road will operate at LOS F during the Saturday peak hour after the completion of Phase V. The intersection will continue to operate at LOS F during the Saturday peak hour after the completion of Phases VI and VII, with average delays increasing from 45.6 seconds after completion of Phase V to 117.1 seconds after completion of Phases VI and VII. With implementation of Mitigation Measure 20 in the Draft EIR, the intersection of Monterey Road and Monterey Frontage Road will operate at LOS C during the Saturday peak hour with an average delay of 18.8 seconds under cumulative conditions. Without mitigation, the intersection of Monterey Road and Monterey Frontage Road will operate at LOS D during the weekday PM peak hour after the completion of Phase V. The intersection will operate at LOS F during the weekday PM peak hour after the completion of Phases VI and VII, with average delays increasing from 28.4 seconds after completion of Phase V to 60.0 seconds after completion of Phases VI and VII. With implementation of Mitigation Measure 20 in the Draft EIR, the intersection of Monterey Road and Monterey Frontage Road will operate at LOS C during the weekday PM peak hour with an average delay of 16.7 seconds under cumulative conditions. Implementation of Mitigation Measure 20 in the Draft EIR will maintain LOS C or better at the intersection of Monterey Road and Monterey Frontage Road during both the weekday PM and Saturday peak hours under project build -out and cumulative conditions. 2 -6 EMC Planning Group Inc. I California Regional Water Quality Control Board ; 2 Central Coast Region ;ton H. Hickox Internet Address: http9 /www.swrcb.ca.gov Grav Davis secretary for 81 Higuera Street Suite 200. San Luis Obispo. California 93401 -5427 Governor ".nvvanmentat Phone (805) 549 -3147 • FAX (805) 543 -0397 Protection March 11, 1999 Bryan Stice Planning Department City of Gilroy, Community Development Department 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: �CFIV� IMAR 1 = 1999 Gilro,t Fi12Rrli "5 Div. GILROY SPORTS COMPLEX — DRAFT ENVIRONMENTAL IMPACT REPORT, SANTA CLARA COUNTY Thank you for the opportunity to review and comment on the Draft Environmental Impact Report (DEIR). We understand that the 133.2 -acre project involves construction of a 78.4 -acre multi -use sports park and 54.8 acres of adjacent, undeveloped parcels. Preliminary plan components for the sports park include:. ♦ Recreational play fields (8 softball diamonds and 4 soccer fields) ♦ Premier play fields (one 90 -foot baseball diamond, two little leagues diamonds and one soccer field) ♦ Competition play fields (one softbalUbaseball diamond and one soccer field) ♦ 8.8 -acres of park preserve with volleyball, bocci ball courts, concession/restrooms, family picnic and play area. ♦ Commercial recreation (indoor soccer, roller hockey, community building, and storage) ♦ 1043 parking spaces ♦ Night watch park ranger station ♦ Infrastructure and facilities needed to support the proposed project Uvas Creek is located at the project's western boundary and at a portion of the southern boundary. Aooroximately 1.800 feet of earthen flood control levee protects a portion of the site from Uvas Creek. The levee is set back from the top of the "nantral creek bank" by approximately 50 feet. The project proposes to use a 50 -foot from top of bank habitat buffer along the length of Uvas Creek. DEIR concedes that Storm water run - off... could increase the rate of storm water discharge into Uvas Creek and the Pajaro River drainage However, the DEIR concludes ...during food flow conditions it is likely that the Increase in run -off due to the new impervious surfaces... would be less than significant Thus. the DEIR concludes that, overall, stormwater runoff will have a less than significant impact on the environment. We disagree with that conclusion. California Environmental Protection Agency 0 Recycled Paper Bryan Stice 2 March 11, 1999 Any stormwater runoff increase will allow more water to enter Uvas Creek. Logically, more water in Uvas Creek means that Uvas Creek will more readily flood or contribute to downstream flooding. This is especially significant when cumulative impacts are considered. As you probably know, hydrology and flooding are controversial environmental issues in the Pajaro River Watershed. Flooding of developed areas can result in a myriad of impacts to water quality and likely violate water quality standards contained in our Basin Plan. The DEIR's analysis of stormwater runoff and flooding impacts should acknowledge cumulative impacts and Pajaro River watershed flooding concerns. If cumulative hydrology /flooding impacts are properly considered, we believe the project will exceed the standards of significance and require mitigation. 2 Mitigation measure 2 for surface watcr quality impacts is unclear. The mitigation measure requires the applicant to submit an "NOI" and detailed engineering plans to our agency for each phase of the project. We assume that the NOI will be for coverage under our general statewide stormwater permit for construction activities greater than five acres. Such a mitigation measure will not address impacts associated with post construction urban runoff. 3 rom a water quality perspective, the following alternative project configuration seems more :nvironmentally sound; move the sports park area as far away from Uvas Creek as possible and establish t more natural creek configuration. More open space should be allowed to flood. The following diagram without the depicted levee) describes a typical natural stream profile: T000eraohic Floodolain Land adjacent to the channel including the hydrologic floodplain and other lands up to an elevation based on the elevation reached by a flood of a given frequency (e.g., the 10 -year or 100 -year floodplain) Hvdroloeic Floodolain The land adjacent to the baseflow channel residing below bankfull elevation. It is inundated about two years out of three. i �y y'.•`c�'b Levee �+ rr*� �s " �1• Reduces floodpiain I� Bankfull elevation Baseflow channel Figure I - Hydrologic and Floodplains Flood Elevation the project provides a rare opportunity to restore a creek segment. Creek restoration would alleviate and 3artially mitigate greater flood concerns, improve water quality and provide for a truly functional riparian tabitat. The Regional Board strongly condones a project redesign to allow for a proper stream restoration. - learly, the project's 54.8 acres of undeveloped land provides some flexibility to restore some natural stream functions. An authoritative reference for stream restoration can be found at itto:Fwww.usda.aov /stream restoration California Environmental Protection Agency Recycled Paper qJ I Brvan Stice March 11, 1999 The DEIR states that the Uvas Creek trail 50 -foot riparian - habitat buffer will provide a beneficial impact. That buffer will be planted with native grasses and native shrub and riparian understory vegetation. While the proposed project may be an improvement to existing conditions (dirt road and agricultural lands), it is not necessarily the best practical riparian improvement. "Riparian" is defined' as "of, pertaining to, situated, or dwelling on the bank of a river or other water body ". As shown DEIR Figure 14, the proposed plantings will occur beyond the "top of bank ". The DEIR states that "the general slope of the site is away from Uvas Creek towards Monterey Road." Thus the proposed riparian habitat buffer area appears to drain away from the creek bank. Under a tvpical natural creek configuration, land terraces and drainages slope towards a creek. Considering the above, from a water quality perspective, there appears to be a more environmentally sound project. The final EIR should evaluate our suggested alternative. We hope the above comments help to produce a superior project. If you have any questions, please call Tom Kukol at (805) 549 -3689. //Sincerely, �,/ Roger W. B 'ggs Executive Officer T1KVi:`.CEQA%S- CLARA\EIRIGilroy Sports Park Commcna.doc Tack: 121 -01 Agency File: Gilroy ' The Random House College Dictionary, Revised Edition, 1984 California Environmental Protection Agencv Recycled Paper Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 2 California Regional Water Quality Control Board Roger W. Briggs, Executive Officer March 11, 1999 1. It is commonly accepted that impervious and pervious surfaces have similar run -off rates during 100 -year storm events (because the soil is saturated and there is no percolation occurring). However, during more frequent but less intense storm events there may be a greater difference in the amount of storm water run -off from pervious and impervious surfaces. This is consistent with the analysis contained in the Draft EIR. The Draft EIR does not specifically differentiate between storm water run -off rates during 100 -year storm events compared to storm events of lesser magnitude, but does note that there is less difference in run -off rates from pervious and impervious surfaces under "flood conditions" than under non -flood conditions. At the direction of the project hydrologist, the description of storm water run -off in the Draft EIR has been revised. Two major factors come into play in determining the effects of storm water run -off on down - stream flooding: run -off rate and lag time. Rainfall intensity and the percolation rate of the surface influence the run -off rate. Lag time is the time that elapses between peak rainfall and peak flow in a channel. This is influenced by distance, terrain and flow interruptions such as dams. The percolation rate is the rate at which water is absorbed into the ground. Each type of ground surface has a characteristic percolation rate. When the ground becomes saturated, no more percolation occurs and any excess water drains on the surface. During periods of heavy rainfall, it is common for the ground to become saturated. When ground with a pervious surface becomes saturated and there is no percolation occurring, run -off rates equal those of impervious surfaces. Therefore during periods of major rainfall the run -off rate is essentially the same for any type of surface. Vegetation can influence the percolation rate by "detaining" water before it drains down onto the soil. Vegetation can also impede the flow of water across the surface after the soil becomes saturated. Lag time is a measure of the delay between the time of peak rainfall, and therefore peak run -off, and the time of peak flow in the channel at a specific location. It represents the travel time for the flow down the channel system to a specific location. Due to the location of the project site within the Uvas Creek watershed, the peak flow in Uvas Creek at the project site occurs hours after the peak rainfall. Therefore, the site soils would be saturated and the surface storage would be filled by prior rainfall at the time of the peak flows in Uvas Creek. The minimum infiltration capacity for typical soils in the Gilroy area range 2 -10 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments from 0.05 inches per hour for heavy clays to 0.20 cubic inches per hour for loams. For the proposed project, this represents approximately a 1.0 cubic feet per second difference in runoff, assuming five acres of impervious area and an infiltration rate of 0.20 inches per hour. On a cumulative basis, the proposed and approved projects include sites in hillside areas with shallow clay soils that would have even lower minimum infiltration capacities than the project site. The potential cumulative impact would be an estimated increase of 10 to 15 cubic feet per second in the peak flood flow. This assumes that there is rainfall in the local area at the time that the peak flood flows occurs in Uvas Creek. This represents less than 0.3 percent increase in the 10 -year flood flow of 5,500 cubic feet per second, which does not overflow the channel, and an increase of 0.1 percent in the 100 -year flow of 14,000 cubic feet per second. This would not be a significant increase in the flood flows or flood elevations for Uvas Creek. For downstream areas, including Pajaro River, the potential increases would be even smaller due to the larger existing flows and the extensive flood plain storage in the Soap Lake area downstream of Monterey Road near the Llagas Creek confluence. 2. Mitigation Measure 2 requires the City to submit a Notice of Intent and detailed engineering plans to the Central Coast Water Quality Control Board. This is for the purpose of obtaining a General Construction Permit under the National Pollution Discharge Elimination System Program. Such a permit requires development and implementation of a Storm Water Pollution Prevention Plan. The Storm Water Pollution Prevention Plan will use 'Best Management Practices" to prevent storm water run -off both during and after construction. It is common that urban pollutants such as coliform bacteria, sediment, organic chemicals, nutrients and pesticides from landscaping and athletic fields, and fuel constituents, heavy metals, oil and grease from automobiles, roads and parking areas enter watercourses through storm or irrigation run- off. A drainage plan for the proposed sports park is being developed by beals group inc. The plan includes a sedimentation basin that will settle out heavy contaminates such as silt before the run -off water is discharged into Uvas Creek. The plan may also include grease separation devices to filter out oil - based contaminants before water is discharged into Uvas Creek. A mitigation measure has been incorporated into the Final EIR to address this issue. 3. CEQA Guidelines section 15126 requires that alternatives be chosen that will minimize any of the significant impacts associated with the proposed project. Water quality impacts would not be reduced or eliminated if the proposed project were redesigned on the site. The range of alternatives studied in the Draft EIR is adequate under CEQA. The alternative project proposed in this letter would alter the naturally occurring conditions at the project site. Uvas Creek in the project reach and downstream for a mile or more is a perched channel. This means that the overbank area slopes away from the EMC Planning Group Inc. 2 -11 Response to Comu:ents Gilroy Sports Park and USA Amendment Final EIR Addendum channel toward Llagas Creek to the east. The channel bank at the northwest corner of the site is approximately eight feet higher than Monterey Road to the east. This is common in California on historic alluvial fans. The silt from channel overflows builds up near the channel until the banks are higher than the overbank areas. Over a long period of time, a perched channel may erode a new more efficient channel along a new route. For a valley channel section (as shown in the Water Quality Board's figure 1), it may be possible to build on the flood plain fringe, property by property, to create the equivalent of s FEMA floodway. This would leave the flood plain area adjacent to the channel to convey flood flows. However, for a perched channel, restricting the flood flow to the overbank area was the original reason for the flood flowage easement on the project site. The upstream flood control levee increased the depth of flooding on the project site. A further levee downstream of the existing flood control levee was considered in the Corps of Engineers' design studies. The longer flood control project was not justified by the potential flood control benefits. Any flood control project for the reach would move the potential flood problem downstream, unless the levee extended downstream of U.S, Highway 101 to Llagas Creek. Redesigning the proposed project to allow more flooding and a "more natural creek configuration" would not be consistent with the natural circumstances of the project site. The existing creek configuration is the natural creek configuration for the project site. The existing riparian corridor is estimated to be approximately 25 feet wide on each side of the creek and is contained within the banks of the creek. The area beyond the top of the bank, such as where the habitat buffer is proposed, is not a riparian habitat but a transitional habitat between the riparian area and the surrounding uplands. This uplands area only occasionally floods. It would not be practical to re -grade the buffer area to drain toward the creek. Any change in the existing channel capacity or channel bank would affect downstream flood conditions. The proposed project does not include any creek restoration component. The existing stream has not been improved or modified through the project site. The existing channel is in its natural condition. The proposed project has been designed to preserve the existing natural channel. The habitat buffer will be a minimum of 50 feet wide and in many places it will be wider. It will be planted with native grasses and forbs, native shrubs and riparian understory, consistent with the naturally occurring vegetation for the area in which it is proposed. The habitat buffer is not intended to be restored riparian habitat, but a buffer between the proposed sports park and the existing undisturbed riparian habitat. Please refer to the response to the second comment in Letter 8 from Streams for Tomorrow for further discussion of the habitat buffer and the beneficial impact of the habitat buffer. 2_12 EMC Planning Group Inc. 3 Santa Uara Valley Water District 5750 ALMADEN EXPRESSWAY SAN JOSE, CA 95118 -3686 TELEPHONE (408) 265 -2600 FACSIMILE (408) 266 -0271 —� www.scvwa.dst.ca.us 1 March 12, 1999 AN cOUAL GP 0C9 7UNITY EMPLOYER ' M r 1. Mr. Bryan Stice Community Development Department 'jiIfGNil City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: Subject: Draft Environmental Impact Report (DEIR) for Gilroy Sports Park—USA 98 -03 2 Thank you for the opportunity to review the subject document sent to us with your letter dated February 11, 1999. The document adequately addresses development of the Gilroy Sports Park adjacent to Uvas Creek with respect to Santa Clara Valley Water District (District) concerns. The hydrology report, identified as amitigation measure for on -site flood flowage (page 2 -17), is currently being prepared. The City of Gilroy's consultant has contacted District staff and we have discussed preliminary results of the study with no significant concerns to date. While not of direct concern to this project, the District offers the following comments on the analysis and conclusions discussed under the paragraph, "Less than Significant Impact —Storm Water Runoff' on page 2 -17. The DEIR states that, during a flood event, site runoff quantities for pervious and impervious surfaces are similar;. and, therefore, the increased runoff created from additional impervious surfaces has a less than significant impact. While this contention is commonly accepted for a major event such as a 1 percent flood, the distinction is less clear during more frequent events. Flood plain analyses and flood maps have been prepared for 100 -year or 1 percent flood events. Maps have not been prepared for other flooding events, yet we know that flooding occurs in many locations more frequently. During these more frequent events, increases in site runoff from impervious surfaces affect flooding depths and areal coverage. Hence, the DEIR comment should be qualified and recognition should be given to the increased frequ--r,�y a; sienificance offlooding in areas subjectto flooding from events other (more frequent) than the 1 percent flood. As aside tiote, it is this condition that contributes to increased high flows on a more regular basis and subsequent erosion in many of our streams. I can be reached at (408) 265 -2607, extension 2253. - Sincerely, r ' / Sue A. Tippets, P.E. Supervising Engineer Community Projects Review Unit 4PW ILa recyciea paper Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 3 Santa Clara Valley Water District Sue A. Tippets, P.E. March 12,1999 The comment regarding the present preparation of the hydrology report is noted. The hydrology report will address the flood constraints on the project site and the potential changes to the sheetflow across the project site during overflows from Uvas Creek. In order to avoid potential adverse impacts, the project site grading will maintain existing overflow elevations from the creek, maintain existing flow paths across the project site and limit increased flood elevations on the project site. These measures will avoid potential adverse impacts for off -site locations. 2. Please refer to the response to the first comment in Letter 2 from the California Regional Water Quality Control Board. At the direction of the project hydrologist, the description of storm water run -off in the Draft EIR has been revised. 2 -14 EMC Planning Group Inc. '1 DEPARTMENT OF THE ARMY 4, SAN FRANCISCO DISTRICT, CORPS OF ENGINEERS 333 MARKET STREET SAN FRANCISCO, CALIFORNIA 941OS-2197 D REPLY TO A CwAq ATTENTION OF: Regulatory Branch f SUBJECT: File No. 24283S RECEIVED MAR 2 2 1999 Mr. Bryan Stice City of Gilroy Community Development Department 7351 Rosanna Street Gilroy, California 95020 Dear Mr. Stice: Gilroy Planning Div. Your request for comments on the Draft Environmental Impact Report concerning the Gilroy Sports Park in Gilroy, Santa Clara County, California was received on March 3, 1999 by your notice dated February 11, 1999. All proposed discharges of dredged or fill material into waters of the United States must be authorized by the Corps of Engineers pursuant to Section 404 of the Clean Water Act (CWA) (33 U.S.C. 1344). Waters of the United States generally include tidal waters, lakes, ponds, rivers, streams (including intermittent streams), and wetlands. Your proposed work for the pedestrian/bicycle bridge over Uvas Creek appears to be vithin.our jurisdiction and a permit may be required. Application for Corps authorization hould be made to this office using the ,application form in the enclosed pamphlet. To avoid lelays it is essential that you enter the file number at the top of this letter into Item No. 1. Fhe application must include plans showing the location, extent and character of the proposed ictivity, prepared in accordance with the requirements contained in this pamphlet. You hould note, in planning your work, that upon receipt of a properly completed application and clans, it may be necessary to advertise the proposed work by issuing a public notice for a ieriod of 30 days. If an individual permit is required, it will be necessary for you to demonstrate to the Corps that your proposed fill is necessary because there are no practicable alternatives, as outlined in the U.S. Environmental Protection Agency's Section 404(b)(1) Guidelines. A copy is enclosed to aid you in preparation of this alternative analysis. 2 4 If you have any questions, please call Mr. Clyde Davis at telephone 415- 977 -8449. Please address correspondence to Regulatory Branch, and refer to the file number at the head of this letter. Sincerely, � .�A,WV6L Calvin C. Fong Chief, Regulatory Branch Enclosure Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments Response to Letter 4 U.S. Army Corps of Engineers Calvin C. Fong, Chief, Regulatory Branch received March 22, 1999 Any project that might have an adverse impact on federally protected wetlands as defined by Section 404 of the Clean Water Act requires a permit from the U.S. Army Corps of Engineers. Construction of a bicycle and pedestrian bridge over Uvas Creek is proposed as part of the sports park development, and may result in a discharge of soil or other materials into the creek. The Draft EIR anticipates that a Section 404 permit may be required for the bridge construction. Mitigation Measure 9 requires that the City contact the U.S. Army Corps of Engineers to ascertain whether Uvas Creek qualifies as a federally protected wetland. If Uvas Creek is a federally protected wetland, as suggested in the Corps' comment letter and therefore under their jurisdiction, then the City will be required to obtain a Section 404 permit in compliance with the Clean Water Act. EMC Planning Group Inc. 2 -17 P E O P L E %00% F O R O P E N S P A C E April 1, 1999 Bryan Stice 1 ?qqg City of Gilroy Community Development Department Planning Division lil�fQl' i�afinlq� i,. 7351 Rosanna Street - Gilroy, CA 95020 RE: USA 98 -03 - Gilroy Sports Park Draft Environmental Impact Report Dear Mr. Stice: Greenbelt Alliance appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) on the proposed Gilroy Sports Park (Planning File USA 98 -03). Greenbelt Alliance strongly supports Gilroy's desire to provide adequate recreational and athletic opportunities for its children and other residents. However, we do have some concerns with the adequacy of the environmental document as well as the potential impacts of the project as proposed. We are particularly concerned with potential adverse impacts related to conversion of prime agricultural land. I The Project Description is Unclear and Inadequate for the Purposes of CEOA 1 As an initial matter, both review of the DEIR and analysis of the potential impacts of the proposed project are significantly complicated by the document's lack of consistency in terms of what constitutes "the project" for the purposes of environmental review under the California Environmental Quality Act (CEQA). Page S -1 of the DEIR describes "the project" as a 133.2 acre urban service area (USA) amendment. However, a subsequent sentence appears to attempt to limit "the project" to a 78.4 acre portion of the aforementioned 133.2 acres: 'The sports park is the only project proposed for development at this time within the Urban Service Area amendment request." For the purposes of environmental analysis, the DEIR seems to treat "the project" as solely the 78.4 acre Sports Park. With the exception of a brief mention of eventual conversion of prime agricultural land on the entire 133.2 acres, the discussion of environmental impacts and mitigation measures provided in the DEIR are generally limited to the Sports Park component. \LAIN OFFICE • 530 Bush Street Suite 303. San Francisco CA 94108 • (415) 398 -3730 • Fax (415) 398-6530 SOUTH BAY OFFICE • 1922 The Alameda Suite 213. San Jose CA 95126 • (408) 983-0539 • Fax (408) 983 -1001 NORTH BAY OFFICE • 520 Mendocino Avenue Suite 225. Santa Rosa CA 95401 . (707) 575 -3661 • Fax ( 707) 5754275 EAST BAY OFFICE • 1372 North Main Street Suite 203. Walnut Creek CA 94596 • (510) 932-7776 • Fax (510) 932 -1970 email: greenbeltn'igc.apc.org • web site: mm.greenbeit.org r - Comment Letter - Gilroy Sports Park DEIR April 1, 1999 5 Page 2 CEQA Guidelines Section 15124 require that a DEIR include a project description and California case law makes clear that an agency cannot provide multiple conflicting project descriptions in different areas of a document. See County of Inyo v. City of Los Angeles (1977) 71 Ca1.App.3d 185; County of Inyo v. Yorty (1973) 32 Cal App. 3d 795; Santiago County Water District v. County of Orange (1981) 118 Ca1.App.3d 818. Shifting project descriptions.are . not allowed because they are confusing and interfere with the public ability to understand and participate in the CEQA process; in the words of the County of Inyo Court, an "unstable project description draws a red herring across the path of public input" 71 Ca1.App.3d at 197 -198. The court in Santiago specifically addressed the situation where certain elements of the full project were not discussed in the EIR: 'Because of this omission, some important ramifications of the proposed project remain hidden from view at the time the project was being discussed and approved. This frustrates one of the core goals of CEQA ". Santiago County Water District v. County of Orange (1981) 118 Ca1.App.3d,818, 830. The Gilroy Sports Park DEIR should be revised to ensure a clear and 2 consistent project description. If the project is a 133.2 acre urban service area expansion, then the document should identify, analyze, and provide mitigation for, the potential impacts associated with buildout of this entire area. Otherwise, the City of Gilroy should limit its USA expansion request to the 78.4 acres necessary for the currently proposed project - the Sports Park. II The DEIR Should be Revised to Include Full Discussion and Analysis of the Impacts of a 133.2 acre USA Expansion. Although the City of Gilroy's immediate goal is to build a Sport Park on a portion of the site, the City cannot ignore or defer analysis of the environmental consequences of bringing an additional 55 acres into its Urban Service Area. It is settled case law that CEQA requires environmental documents to address reasonably foreseeable future phases of a project. Laurel Heights Improvement Association of San Francisco v. Regents of the University of California (1988) 47 Cal. 3d376, 396. Nor can the City avoid analyzing the impacts of the full USA expansion simply by stating that the additional 55 acres are not proposed for development at this time. DEIR at 1 -9. Under State law, a city's USA reflects the area beyond the existing boundary that is expected to receive urban services within the next five years. Gov't Code Sect. 56080. Including an additional 133.2 acres within Gilroy's USA, would, without question, increase development pressure on the entire 133.2 acres and not merely the 78.4 acres Comment Letter - Gilroy Sports Park DEIR April 1, 1999 Page 3 for which the City currently has a specific plan. The DEIR should be revised (and recirculated for additional public comment) to address the full range of potential impacts associated with the 133.2 acre USA expansion including, but not limited to, traffic impacts, biological impacts, air and water quality impacts, growth inducing impacts, etc... III $ The USA Expansion Request Should Be Limited to the 78.4 Acres Needed for the Proposed Sports Park. Alternatively, the City could revise its project description to clearly indicate that the proposed project is a 78.4 acre USA expansion for the purpose of building a Sports Park. As support for its request to annex 55 acres over and above the 78.4 acres proposed for the Sports Park, the DEIR states: "in an effort not to create an 'island', the city has included the adjacent parcels to the north and east in the Urban Service Area amendment request." DEIR at 1 -9. The City's reluctance to allow the additional 55 acres to remain outside of the USA appears to be loosely premised on LAFCo and Santa Clara County policies generally favoring compact and contiguous forms of development. However, these policies are designed to protect open space and prime agricultural land and promote sound land use planning and should not be applied, as here, to justify unnecessarily converting prime agricultural land.. The DEIR should be revised to include a full discussion and analysis of the necessity and rationale for including the additional 55 acres rather than simply relying on a brief conclusory statement about avoiding an "island ". Because the proposed use of the 78.4 acres is not a high intensity urban development but instead a very low intensity recreational facility, the proposed Sports Park could be compatible with continued agricultural production on the adjacent 55 acres. Limiting the USA expansion request to the land that is actually needed for the Sports Park would significantly lessen the project's adverse impact on prime agricultural soils; reducing the loss of prime farmland by 40 %. It is particularly important to eliminate unnecessary conversion of agricultural land in this project because, as the DEIR acknowledges, the farmland that would be converted contains soil that is "considered to be the most productive soil in the Santa Clara Valley..." DEIR at 2 -2 (emphasis added). At the very least, the DEIR should be revised to include a project alternative that is limited to a 78.4 acres USA expansion to allow consideration of this option. Comment Letter - Gilroy Sports Park DEIR April 1, 1999 5 Page 4 IV The DEIR Should be Revised to Identify the Project's Inconsistencv with LAFCo and 4 Santa Clara Countyy Land Use Policies, 5 0 Section 1.5 of the Gilroy Sports Park DEIR addresses Consistency with Local and Regional Plans. Unfortunately, this Section repeatedly confuses economic feasibility and the comparative merit of alternative sites with assessment of the environmental impacts of the proposed project. As a result, the DEIR does not include an accurate description of the project's potential impacts as required by CEQA. The DEIR makes clear the reason for the proposed location - the fact that it is located within an area subject to a flood flowage easement made it financially feasible for the City to acquire this site. Ultimately, fiscal realities may trump other site selection criteria when this project gets to the decisionmaking stage, however, financial preferability does not confer consistency with agency land use policies. State law requires that the DEIR fully disclose the environmental impacts of the proposed project to allow the public an opportunity for meaningful comment. The DEIR should thus be revised to identify the project's inconsistency with several LAFCo and Santa Clara County General Plan policies. Under Santa Clara County Growth and Development Policy C -GD 6, prime agricultural soils "shall not be considered suitable for urban development". The Gilroy Sports Park DEIR acknowledges that the proposed project would convert 133.2 acres of prime agricultural land to non - agricultural uses, but determines that the project is consistent with C -GD 6 because there are no project alternatives that would not affect agricultural soils. This conclusion cannot be supported. The fact that all of the proposed alternatives would be inconsistent with C -GD 6 may be relevant to a decisionmaker forced to assess the relative merit of various options but it does not somehow confer consistency upon the proposed project. The DEIR language should be revised I5anta Clara County Growth and Development Policies C -GD 7 and C -GD 8 address the issue of premature conversion of land. The DEIR states that the Troject is consistent with these provisions because alternative land is not available within existing boundaries. According to the DEIR, "Land within Gilroy's Urban Service Area is expected to be substantially developed within five years." DEIR at 1 -38, 1 -41. However, according to data complied in the context of the ongoing Gilroy General Plan Update, only 48% of the land within the City's existing boundaries is currently developed. The same data suggests that Gilroy will not reach residential buildout for an estimated 22 -47 years, commercial buildout for 25 -27 years, or industrial buildout for 60 -107 7 Comment Letter - Gilroy Sports Park DEIR April 1, 1999 Page 5 years.' It is therefore not accurate to state that the City will be "substantially built out in the next five years ". The DEIR should be revised to eliminate this Santa Clara County Growth and Development Policy C -GD 9 addresses the jobs /housing balance and range of housing opportunities issues. The DEIR concludes that because the Sports Center will not affect housing and it is not known what use will ultimately be made of the additional 55 acres, the project is consistent with this policy. However, the absence of information about what eventual use will be made of the additional 55 acres cannot justify a conclusion that it will not have a future impact. The DEIR should be $ [LACo F Urban Service Area Amendment Policies 5 , 6 address the issue of fficient and use, and the necessity and timing of USA expansion. See iscussion of C -GD 7 and C -GD 8 above. Finally, to the extent that the City is not able to develop a project that is 9 entirely consistent with existing County and LAFCo land use policies, these inconsistencies could, apparently, be minimized by limiting the USA expansion request to 78.4 acres. The DEIR should be revised to analyze this alternative. 10 V The DEIR Should Discuss Mitigation Options for Conversion of Prime Agricultural Land - The Gilroy Sports Park DEIR concludes that the project will result in an unavoidably significant loss of prime agricultural. CEQA Section 21002.1 requires agencies to "mitigate or avoid the significant effects on the environment of project ... whenever it is feasible to do so." Although an agency may ultimately approve a project in spite of unavoidable significant impacts by adopting a statement of overriding considerations, this does not obviate the requirement that impacts be mitigated to the greatest extent feasible. The Sports Park DEIR should be revised to include analysis of minimizing the impacts to prime agricultural soils by reducing the USA expansion request and /or by adopting an agricultural land conversion mitigation program such ' This figure includes the 1979 urban reserves. 5 1.1 Comment Letter - Gilroy Sports Park DEIR April 1, 1999 Page 6 as the City of Davis' Farmland Mitigation Program or the South Livermore Valley Area Plan. These programs require that any conversion of agricultural land to nonagricultural uses be mitigated through permanent protection of agricultural land elsewhere in the region. Such program offer a viable system for effectively mitigating the longterm and cumulative impacts of urbanization in areas of prime farmland. VI The DEIR Should be Revised to Include a More Substantial Riparian Setback. Greenbelt Alliance supports the proposed extension of Uvas Creek Trail to Gavilan Community College. However, development of the trail as well as the creation of a large Sports Park immediately adjacent to Uvas Creek will doubtless increase the amount of human and domestic animal visitation to this section of the riparian corridor. While we appreciate that the proposed project will not result in any loss of habitat and will include a re- vegetation component that should actually improve existing conditions in the area, it remains critical that the Creek is protected by a generous buffer to protect riparian habitat value and wildlife. The DEIR states that the Uvas Creek Trail would be setback at minimum fifty (50) feet from the top of bank. We strongly urge you to increase this setback to one hundred (100) feet to insure adequate protection of this important riparian area. VII Conclusion Thank you for your consideration of these comments. Please do not hesitate to contact me at 983 -0539 if you have any questions. Sincerely, Kaitilin Gaffney South Bay Field Representative Response to Continents Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 5 Greenbelt Alliance Kaitilin Gaffney, South Bay Field Representative April 1, 1999 The proposed project is described in the first three paragraphs of the Draft EIR summary on page S -1 and in the Draft EIR introduction on pages 1 -2 through 1 -20. The project is clearly described as consisting of an urban service amendment request consisting of approximately 133 acres, sports park development (on approximately 78 of the 133 acres) and off -site improvements, including roadway improvements, extension of the Uvas Creek Trail and extension of a recycled water distribution line. The sports park project would include overlaid soccer and softball fields, playgrounds, picnic grounds and a commercial recreation area. The project vicinity map on page 1 -5 of the Draft EIR illustrates the entire project site, as well as the sports park portion of the project site. The majority of the project site is currently designated as OPEN SPACE in the City of Gilroy General Plan, with the exception of a small area that is designated PARK /PUBLIC FACILITY. The environmental impact analysis in the Draft EIR is generally limited to the sports park development and development of related off -site improvements because other portions of the project site are proposed to retain the existing OPEN SPACE land use designation. 2. An EIR is not required to analyze those impacts that are purely speculative (CEQA Guidelines section 15145). In Laurel Heights Improvement Association v. Regents of the University of California the court noted that where future development is unspecified and uncertain, no purpose could be served by requiring an EIR to engage in sheer speculation as to future environmental consequences. With a current general plan designation of OPEN SPACE, and without any proposals to change that, the only foreseeable impact of bringing the additional land into the Urban Service Area is the loss of prime agricultural land, based on an eventual loss at an unknown time in the future. It is impossible to provide a meaningful evaluation of potential environmental impacts at that portion of the site without any information on which to base an analysis. The Draft EIR includes the eventual loss of prime agricultural land as a significant and unavoidable impact both on the sports park site where current development plans exist, and on the remaining parcels where no development plans exist, because any type of urban development would result in this impact. The project site is located within the City of Gilroy's existing 20 -year growth boundary and it can be expected that the land will be developed at some point in the future. 2 -24 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment Final EIR Addendum Response to Comments CEQA requires environmental analysis of all reasonably foreseeable future phases of a project. Existing agricultural uses are expected to continue indefinitely on all but the sports park site, and the sports park site itself is expected to be developed over a 20 -year timeframe with much of the sports park site remaining in agricultural use for many years. The Draft EIR addresses all phases of the sports park development through its anticipated completion in approximately 20 years. The continuation of agriculture will have no environmental impacts beyond the existing or "no project" conditions. To predict the type or extent of potential impacts related to public services, transportation, air quality, noise, or aesthetics from future development on land designated OPEN SPACE would be extremely speculative and result in a meaningless environmental document. CEQA Guidelines section 15145 does not require analysis of impacts that are too speculative for evaluation. Urban development on the parcels in question would require a general plan amendment and zoning change and therefore additional environmental review, as stated on page S -1 of the Draft EIR. This additional environmental review will rely on proposed general plan amendments and /or development plans and will yield meaningful information for the public and the decision - makers. If the proposed project included a general plan amendment for the subject parcels (such as residential, commercial, industrial or public facility), build out of the parcels could be evaluated in the environmental document. 3. An alternatives analysis of a project that includes only the sports park site in the Urban Service Area amendment request, would be meaningless as an alternative because it would provide no additional analysis beyond that already contained in the Draft EIR. Except for the extent of the loss of agricultural land, all impacts associated with this alternative would be the same as for the proposed project studied in the Draft EIR. Analyzing this alternative would provide no new information to the public or to the decision - makers. However, should the decision makers choose to limit the Urban Service Area amendment to the sports park site only, this EIR would be a_ dequate for the environmental review necessary to make that decision. 4. The Draft EIR fully discusses all environmental impacts of the proposed project and the alternative sites. The City's choice of the project site for its proposed sports park is an economically based decision that also makes sensible use of an area prone to flooding. While the City purchased the project site for use as a sports park largely because the land's location in a flood plain reduced its market value, this was not a factor in the environmental analysis of the project. The environmental analysis in the EIR is based upon the environmental factors at the project site and the alternative sites. All of the alternative sites identified would result in the loss of prime agricultural land. Although two of the alternative sites would result in a EMC Planning Gronp Inc. 2 -25 Response to Connsnents Gilroy Sports Park and USA Amendment Final EIR Addendum smaller loss of agricultural land than the proposed project, these two sites would also result in greater traffic impacts. The third alternative site would result in a loss of agricultural land that was determined to be approximately equal in impact to the proposed project. Consistency of the proposed project with several of the LAFCO and Santa Clara County policies has been revisited. Please refer to the responses to Letter 10 from the Santa Clara County Local Agency Formation Commission. Please refer to the response to the fourth, fifth and sixth comments in Letter 10 from the Santa Clara County Local Agency Formation Commission regarding Santa Clara County Growth and Development Policies C -GD6, C -GD7 and C -GD8. 6. The two sets of figures are not comparable. The Draft EIR refers to the amount of land remaining to be developed within the City's Urban Service Area. The comment refers to the amount of undeveloped land contained within the General Plan planning area. The Urban Service Area is an officially established area that is expected to receive urban services within an approximate 5 -year time frame. The General Plan planning area is not an officially adopted area, but rather an area surrounding the City for which the City wishes to formulate long term policies. The City's Urban Service Area is much smaller than the General Plan planning area, and the additional land is almost entirely undeveloped. Therefore citing a figure for remaining developable land that refers to this much larger area and comparing it to figures for the Urban Service Area is not valid. Santa Clara County Growth and Development Policy C -GD9 is intended to assure that an adequate housing supply is available within a city that is adding land to its Urban Service Area for the purpose of expanding employment. The addition of the proposed project to Gilroy's Urban Service Area is not for the purpose of expanding employment. The only project proposed for development is the sports park, and this project will result in only a small number of jobs. The remaining land will remain in agricultural use for an indefinite period of time. The purpose of this Urban Service Area amendment request is not to expand employment within the City. Comments on LAFCO Urban Service Area Amendment Policy 5 are addressed in the response to comments on Santa Clara County Growth and Development policies C -GD6, C -GD7 and C -GD8 in the response to the letter from the Santa Clara County Local Agency Formation Commission. 8. Please refer to the response to the second comment in Letter 10 from the Santa Clara County Local Agency Formation Commission. 9. Please refer to the response to the third comment in this letter. 10. Please refer to the response to Letter,7 from the California Department of Conservation. 2 -26 EMC Planning Gilroy Sports Park and LISA Amendment Final EIR Addendum Response to Comments 11. Please refer to the response to the second comment in Letter 8 from Streams for Tomorrow. EMC Planning Group Inc. 2 -27 STATE OF CALIFORNIA - BUSINESS TRANSPORTATION AND HOUSING AGENCY GRAY DAVIS, Govemor w DEPARTMENT OF TRANSPORTATION _ P. O. BOX 23660 OAKLAND, CALIFORNIA 94623.0660 TELEPHONE (510) 286 -4444 FAX (510) 286 -5513 March 30,1999 Mr. Bryan Stice City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: r IVEE. 2 7sss Gilroy , anning Div. SCL- 101 -5.26 SCL101599 SCH #98102079 Gilroy Sports Park and Urban Service Area Amendment: Draft Environmental Impact Report (DEIR). Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for this project. We have examined the above - mentioned DEIR and would like to offer the following comment: 1 All maps should be to scale and should contain sufficient detail so that the State right - of -way can be identified and potential impacts assessed.- In trying to ascertain the possible effects of the project in terms of hydrology issues, we did not have adequately detailed information. Although we eventually obtained a map that enabled us to conduct a thorough review, it was not included in the document. We appreciate the opportunity to be involved in this project. If you have and questions or concerns, please contact Abbe Hoenscheid of my staff at (510)622 -1643. Sincerely, HARRY Y. YAHATA District Director JEAN C.R. FINNEY District Branch Chief IGR /CEQA Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments Response to Letter 6 California Department of Transportation Harry A. Yahata, District Director March 30,1999 1. The comment is noted. The comment does not raise any environmental issues and no response is necessary. EMC Planning Group Inc. 2-29 State of California MEMORANDUM AP9. + 1999 The Resources Agency To: Project Coordinator ,��rOV / P}4nnjn DN. Date: April 1, 1999 Resources Agency V Mr. Bryan Stice City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 From: Department of Conservation Office of Governmental and Environmental Relations Subject: Draft Environmental Impact Report (DEIR) for Gilroy Sports Park and Urban Service Area Amendment (USA 98 -01) SCH # 98102079 The Department of Conservation's Division of Land Resource Protection (Division) has reviewed the above referenced DEIR. The Division maps and monitors farmland conversion on a statewide basis, and administers the California Land Conservation (Williamson) Act and Agricultural Land Conservation Program. We commented on the Notice of Preparation for this project in a letter of November 20, 1998. We offer the following additional comments for your further consideration. The DEIR provides a thorough discussion of the agricultural impacts, the project's setting, and alternative project locations. Additionally, the DEIR discusses the establishment of the Gilroy Agricultural Lands Area as partial mitigation for the agricultural land conversion impact of the project. However, the statement of overriding considerations is not supported by a finding that the city considered a reasonable range of feasible mitigation measures or alternatives to avoid or reduce to less than significant this impact [Public Resources Code Section 21081(a)(3)]. If additional measures or alternatives were considered, the finding should include information on why they were not considered feasible. In particular, the DEIR should at least consider the use of agricultural land conservation easements, or Williamson Act or Farm Security Zone contracts, for protecting other viable agricultural lands threatened by urbanization. In a.1997 unpublished decision, the court directed the lead agency to consider conservation easements as a legitimate means of mitigation of land conversion impacts (El Toro Land Use Planning Authority, at al v. County of Orange; et al, San Diego Superior Court #710123, October 28, 1997). Thank you for the opportunity to review the DEIR. If you have questions on the above comments, or need information or technical assistance, please contact the Division at 801 K Street, MS 13 -71, Sacramento, CA 95814; phone (916) 324 -0850. 7 Project Coordinator and Mr. Bryan Stice April 1, 1999 Page 2 We would be glad -to assist you with examples of agricultural land conservation easement agreements, as well as with information on nearly 30 agricultural land conservation tools used by other local jurisdictions. Hssisiant uirector cc: John Amodio, Chief Division of Land Resource Protection Loma Prieta RCD 8010 Wayland Lane, Suite 1 D Gilroy, CA 95020 Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 7 California Department of Conservation Jason Marshall, Assistant Director April 1, 1999 The City generally agrees with the concept of agricultural conservation measures and is receptive to conservation plans. The City may enter into conservation agreements for land that it owns, or it may negotiate with private landowners, typically as mitigation for environmental impacts of proposed projects or as conditions of approval of proposed projects for the greater public benefit. The City recently negotiated an 1,800 -acre conservation easement in the area west of Santa Teresa Boulevard in conjunction with approval of the Eagle Ridge Subdivision. The City will implement such measures when the City Council establishes that as a priority. The City could consider the use of agricultural land conservation easements, Williamson Act contracts or Farm Security Zone Contracts for mitigation of the loss of agricultural land at the project site. In order for the City to implement one of these conservation strategies for the proposed project, the City would have to purchase an appropriate amount of land on which to implement the conservation plan. This may not be an economically and /or socially feasible approach. 2 -32 EMC Planning Group Inc. SANTA CLA RA COUNTY STREWS FOR TOMORROW Post Off ice Box1409 San Martin, California 95046 April 1, 1999 Mr. Bryan Stice Planning Division City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: Draft Environmental Impact Report Gilroy Sports Park and Urban Service Area Amendment (USA 98 -01); Dated February 1999 We have the following comments and recommendations for your consideration regarding subject Draft Environmental Impact Report (DEIR). I. The DEIR is legally inadequate because it does not adequately discuss - alternatives to the proposed project. Every DEIR must describe a range of reasonable, feasible alternatives to the project, or to the location of the project, which would feasibly attain the project's basic objectives with reduced environmental impact, and must evaluate the comparative merits of each alternative. (Pub.Res.Code Sections 21002,.21100(a)(4); CEQA Guidelines Section 15126.6(a)).. A proper analysis of alternatives ensures the City's compliance with CEQA's mandate to avoid or substantially lessen significant environmental damage where feasible. (Pub.Res.Code Section 21002; CEQA Guidelines Sections 15002(a)(3), 15021(a)(2), 15126.6(b). An alternative is a form of mitigation. The flaw in the DEIR's alternatives analysis is its failure to identify and consider a reasonable range of potentially feasible alternatives, as CEQA requires. (CEQA Guidelines Section 15126.6(a)). A feasible alternative is one which can be accomplished in a successful manner within a reasonable period of time, taking into account economic, legal, social and technological factors. Citizens of Goleta Valley v. Board of Supervisors, (1990) 52 Cal. 3d at 574. Among the factors that may be taken into account when determining the feasibility of an alternative is "whether the proponent can reasonably acquire, control or otherwise have access to the alternative site." (CEQA Guidelines Section 15126.6(f)(1)). Since the City concludes that "Alternative sites were not available at a price affordable to the City" (DEIR, page 3 -2), the off -site alternatives described in the DEIR are infeasible as a matter of law. Therefore, the DEIR is fundamentally flawed because it fails to'analyze a range of feasible alternatives, as CEQA mandates. • 21 Mr. Bryan Stice -2- - April 1, 1999 Nor does the DEIR identify any on -site alternatives despite the fact that significant effects of the project on biological resources could be substantially lessened by alternative project designs, setbacks, and siting of facilities. Alternatives need not be identical no= even substantially similar to the project as originally described as long as they would attain the project's basic objectives with reduced environmental impact. The DEIR should be revised to include an analysis of a range of feasible alternatives -- preferably both off -site and on -site alternatives -- pursuant to CSQA Guidelines Section 15126.6(c). It is our opinion the alternatives analysis as presented in the DEIR would not survive judicial review. II. The DEIR is legally inadequate because it does not adequately disclose nor analyze some significant environmental impacts, nor does it discuss sufficient mitigation measures. 1. As an independent action, establishing the proposed Uvas Creek riparian buffer would be a beneficial impact. However, in the context of analyzing and mitigating project impacts, the buffer constitutes partial mitigation to reduce direct and indirect human - induced adverse impacts to wildlife caused by the public use of the Sports Park. Use of these facilities will adversely iisturb and dislocate sensitive wildlife species in the adjacent riparian :orridor. The buffer will provide partial mitigation for this long -term siavoidable impact. Lt is misleading and erroneous to refer to this mitigation measure as a 'Beneficial Impact ", particularly when the Department of Fish and Game -- the Trustee Agency for wildlife resources -- states "We do not consider the 50 -foot buffer mentioned in the NOP to be adequate to protect this riparian orridor." (November 17, 1998 letter of response to NOP). Che DEIR fails to adequately evaluate the long -term impacts of Sports Park ise on the general assemblage of riparian corridor wildlife species. CEQA requires that an EIR must not only identify probable project impacts, but also provide "information about how adverse the impacts will be." Santiago :ounty Water District v. County of Orange (1981) 118 Cal.3d.818,831. The revised DEIR must correct this deficiency by evaluating such impacts and Ldentifying mitigations (which should include the proposed buffer). 3ecause both construction and public use of the Park facilities will adversely impact riparian wildlife, it is imperative that any buffer be established in Phase I of the Project to maximize the mitigative benefits of the buffer. Che revised DEIR should reflect this need. 3 2. Construction of a pedestrian bridge over Uvas Creek is identified as a potential significant impact. However, Mitigation Measure Number 8 defers the identification of mitigation to a future Streambed Alteration Agreement between the City and Department of Fish and Game. Any proposed mitigation measures to avoid or reduce significant adverse impacts that a project may have on the environment must be made available Mr. Bryan Stice -3- April 1, 1999 for public review at the time the DEIR is circulated for public review and comment. Mitigation measures cannot be left to be formulated in the future. (Gentry v. City of Murrieta, (1995) 36 Cal.App.4th at 1397). Relying upon the presumed success of future mitigations in the form of regulatory agency conditions of approval that have not been formulated at the time the DEIR is circulated for public comment constitutes illegal deferral of mitigation identification. (Sundstrcm v. County of Mendocino, (1988) 202 Cal.App.3d 296, 306 -314). The revised DEIR must identify specific mitigation measures to avoid or reduce impacts on Uvas Creek aquatic habitats and biological resources. For example, the DEIR could identify that (1) all in- channel work shall occur only between June 1 and October 15; (2) Streamflow, shall be diverted around the work site and discharged in a non - erosive manner; (3) Construction and removal of water diversion facilities, as well as other construction activities, shall be conducted without increasing stream turbidity more than 50 Nephelcmetric Turbidity Units above background levels; and (4) Equipment shall not be operated in the live stream. III. Conclusion Given that analysis and mitigation of environmental impacts are at the heart of CQQA, the project will not comply with CEQA until the deficiencies described above are remedied. Therefore, the DEIR must be revised to (1) provide a proper alternatives analysis; (2) evaluate the long -term impacts of Sports Park use on riparian wildlife species, with identification of appropriate mitigation; and (3) provide specific mitigation measures to avoid or minimize the impacts of bridge construction on Uvas Creek. The DEIR should not be certified until the deficiencies discussed above have been fully addressed and corrected in a revised DEIR. Please send us a copy of your Response to Comments document, revised DEIR, and notices of public hearings. When they becune available, please also send us the mitigation monitoring and reporting program required per Pub.Res.Code Section 21081.6 and the City's draft mandatory CDQA findings document. Thank you for the opportunity to provide comments on subject DEIR. If you have questions about our comments and recommendations, please contact me at the letterhead address or telephone (408) 683 -4330 (voice and fax). Sincerely, Keith R. Anderson cc: Mr. Jeffrey Lawson Environmental Advocate Attorney at Law Reed, Elliott, Creech & Roth SCCSFT Reading File A Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 8 Streams for Tomorrow Keith R. Anderson, Environmental Advocate April 1, 1999 1. The commentor has paraphrased CEQA Guidelines section 15126.6(a). The actual text of this section of the guidelines is presented here to assist with responding to this comment. This section states, "An EIR shall describe a range of reasonable alternatives to the project, or to 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, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives that are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason." - CEQA Guidelines section 15126.6(0(1) further discusses the feasibility of alternatives. This section states "Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent). No one of these factors establishes a fixed limit on the scope of reasonable alternatives." Therefore, while a number of factors are presented for consideration in determining the feasibility of an alternative, the alternative need not meet all of the stated criteria to be considered feasible. In determining the "reasonable range of potential feasible alternatives ", City staff and the EIR consultant focused on those alternatives that would "avoid or substantially lessen the significant effects of the project ". All of the significant impacts identified in the Draft EIR can be reduced to a less than significant level with the exception of the loss of prime agricultural land. Therefore, the selection of alternatives was focused on alternative locations that would avoid or lessen the impacts on agricultural land. A redesign of the project at the proposed site would not reduce the impacts associated with the proposed project, as mitigated. 2 -36 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment Final EIR Addendum Response to Comments City staff in consultation with the EIR consultant identified the alternative locations. These locations were identified because they are entirely or partially, located within the City's existing Urban Service Area and are therefore, already anticipated for development in the foreseeable future. This was the City's attempt to select alternatives that would substantially lessen the significant effect regarding the loss of prime agricultural land. Each of the alternative locations identified could "feasibly attain most of the basic objectives of the project", as well as "substantially lessen" the impacts associated with the loss of prime agricultural land. The City of Gilroy purchased the project site because it is located in a flood plain where many other uses are not possible based on conditions of the Army Corps of Engineers levee contract. Therefore, the land was available for a lower price than equivalent land elsewhere in or near the City. The City took advantage of this opportunity and wants to establish a sports park. While the alternative sites could command a considerably higher price than the project site due to their suitability for other urban uses, the City Council could allocate sufficient funds to purchase one of these sites if this were determined to be a necessary expenditure and the economic and social consequences were deemed acceptable. Therefore, the alternative sites selected and analyzed are considered reasonable and would "feasibly attain most of the basic objectives of the project" and therefore, are adequate under CEQA. The EIR does not state that "the City concludes that alternative sites were not available at a price affordable to the City." There are no "conclusions" with respect to the EIR as far as the City of Gilroy is concerned, until the Gilroy City Council certifies the EIR as adequate and makes the appropriate statement of overriding considerations. The EIR does however, state on page 3 -1 and 3 -2 that "the City of Gilroy is expected (emphasis added) to make the following findings regarding the loss of prime farmland prior to approving the project... Alternative sites were not available at a price affordable to the City." If the City Council makes the finding that alternative sites, which may be environmentally superior, are not available at a price affordable to the City, this decision would not render other reasonable alternative sites, infeasible for purposes of evaluation in an EIR. It would be a policy decision based upon the City Council's authority to allocate money for capital expenditures. Even though the City of Gilroy currently owns the project site, and may not be willing to purchase land already within the existing Urban Service Area, failure to evaluate alternative sites would be contrary to the CEQA statutes and guidelines. The alternatives analysis is adequate. 2. The project site is currently in agricultural use. A dirt farm road separates the cultivated fields from the top of the bank of Uvas Creek in most parts of the project site. In the northern part of the project site the dirt road is on top of a Santa Clara Valley Water District levee and is located a greater distance from the top of the bank. The presence of the farm road and levee provides access to the creek and existing riparian corridor, as is evidenced by trash and the EMC Planning Group Inc. 2 -37 Response to Comments Gilroy Sports Park and USA Amendment Final EIRAddendum dumping of large objects (i.e., sofas) observed on the bank of Uvas Creek during site investigations conducted during preparation of the environmental document. The narrow width of the existing riparian corridor, and the lack of vegetation between the farm road and creek in some areas, provides direct access to the creek and riparian area. The existing riparian corridor is estimated to be approximately 25 feet wide on each side of the creek, with some portions of the creek lacking riparian vegetation. Uvas Creek has very steep banks, with the elevation of the creek bed being far below the elevation of the surrounding uplands. At the project site, a 10 -year flood flow will stay within the creek banks, and the surrounding uplands only occasionally flood. Riparian vegetation depends upon soil moisture from a nearby freshwater source. The steepness of the banks and depth of the channel limit the amount of soil moisture that is available to adjacent vegetation and, therefore, contributes to the narrow width of the existing riparian corridor. Further, the narrowness of the existing corridor and its proximity to active agricultural operations does not provide a dense, secluded wildlife habitat. The proposed project includes a minimum 50 -foot wide "habitat buffer', not specifically a riparian buffer, because the most distant portion of the buffer will not receive significant soil moisture from Uvas Creek. The habitat buffer area will transition from native grasses near the proposed pedestrian trail (farthest from Uvas Creek), to native shrubs and riparian understory vegetation near Uvas Creek where riparian vegetation can be supported. Given the existing topography of the site (i.e., gradual slope away from Uvas Creek), it would be impractical to establish a 50 -foot buffer consisting entirely of riparian species. Instead, the goal of the proposed habitat buffer is to restore native vegetation to the area adjacent to Uvas Creek, and promote riparian vegetation in those areas adjacent to Uvas Creek that can support riparian species. Restoration and enhancement of native vegetation along Uvas Creek and expansion of the habitat buffer area along Uvas Creek will increase the value of the riparian habitat for wildlife. In several places the habitat buffer will be much wider than the minimum 50 feet. (Also refer to the response to the third comment in Letter 2 from the Regional Water Quality Control Board regarding the natural slope away from the creek.) Development of the sports park and the Uvas Creek pedestrian trail will introduce more people to the area than the existing farm road. However, the design of the habitat buffer, which includes native shrubs and riparian understory vegetation between the pedestrian trail and the riparian corridor and creek, will create a vegetative barrier between the pedestrian trail and creek. This vegetative barrier will discourage people from entering the habitat buffer, especially if the native vegetation planted in the habitat buffer includes spiny plants (i.e., gooseberry, California rose) or irritant plants (i.e., poison oak, stinging nettle). The slope of the creek bank is very steep and would be difficult to climb in most places. As directed by Mitigation Measure 19 in the Draft EIR, signage will be placed along the pedestrian trail to discourage entry of people and their pets. Also, the vast majority of park 2 -38 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments users will be engaged in sports activities and will not be wandering into the habitat buffer area. The project as designed and mitigated, including the pedestrian trail and habitat buffer, will not result in significant impacts to the riparian corridor. The minimum 50 -foot habitat buffer included in project plans is sufficient to protect the riparian corridor and to enhance the wildlife values of the riparian habitat and, therefore, is a beneficial impact. 3. Three mitigation measures are proposed for the mitigation of the potentially significant environmental impacts of constructing a bicycle and pedestrian bridge across Uvas Creek. The first of these mitigation measures requires the City to obtain the Section 1603 Streambed Alteration Agreement from Fish and Game. Two additional mitigation measures require the City to contact the Army Corps of Engineers to determine if a Section 404 permit is required for discharge into the waters of the United States, and to install siltation fencing or other erosion control measures to prevent erosion during construction. The Section 1603 Streambed Alteration Agreement is an appropriate mitigation measure. While CEQA prohibits deferral of the formulation of mitigation measures to a later time, it specifically allows mitigation measures to specify performance standards that would reduce the significant adverse environmental effects of the project to a less than significant level (CEQA Guidelines section 15126.4 (13)). The Section 1603 Streambed Alteration Agreement sets appropriate standards for the mitigation of the potential biological resources impacts that are identified for the construction of the bicycle and pedestrian bridge over Uvas Creek. Two performance standards are included in the mitigation measure. These include a stipulation that all construction work take place when the creek is either dry or the creek flow very low, and that if any water is flowing, that the flow be diverted into an open gravel -lined bypass channel for the duration of the work. Additional requirements of the Section 1603 Streambed Alteration Agreement will be determined by the California Department of Fish and Game. The mitigation measure requiring a Section 1603 Streambed Alteration Agreement and setting forth these performance standards is appropriate under CEQA. EMC Planning Group Inc. 2 -39 April 2, 1999 S A " T A C l A Y A Valley Transportation Authority City of Gilroy Department of Community Development 7351 Rosanna Street Gilroy, CA 95020 -6141- Attention: Bryan Stice, Planner I RECEIVEro APR 6 1999 Gilroy Planning Div. Subject: Gilroy Sports Park Draft Environmental Impact Report Dear Mr. Stice: Santa Clara Valley Transportation Authority (VTA) staff have reviewed the Draft Environmental Impact Report (DEIR) for the development of a sports park to accommodate a variety of activities at the southwest corner of Thomas Road and Highway 101. VTA comments follow, and are separated into Transit Service and Congestion Management Program issues to reflect our dual role in reviewing the project. Transit Service On Page 2 -51, the DEIR states that a "sidewalk is provided along the north side of Thomas Road- Luchessa Avenue between Monterey Street and Princevalle Street to the north of the project." To allow patrons of the project to safely and conveniently access existing and future transit services in the area, VTA staff recommend that the City also consider providing a sidewalk along the south side of Thomas Road. 2 As noted in WA's November 20, 1998 letter regarding the Notice of Preparation of a DEIR for this project, VTA staff are still considering the possibility of bringing bus service to the sports park. Please continue to forward information about this project to VTA for review and comment. C'I'A staff will work with City and project staffs on this possibility. Congestion Management Program 3 The Transportation Impact Analysis (TLA) section of the DEIR conforms to the Congestion Management Program's guidelines. WVe appreciate the opportunity to review this project. If you have any questions, please call Lauren Bobadilla of my staff at (408) 321 -5776. Sic r 127 � 9 Lomas Rountree Environmental Program Ilana.aer TDR:LGB:kh 3331 North First Street - San lose. CA 95134 -1906 - Administration 408.321.5555 - Customer Service 408.321.2300 E ll Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments Response to Letter 9 Valley Transportation Authority Thomas Rountree, Environmental Program Manager April 2,1999 1. The comment is noted. At some time in the future the City may consider the necessity of adding a sidewalk on the south side of Thomas Road /Luchessa Avenue. The sports park is expected to take 20 years to complete, however, and at this time it does not appear that a sidewalk on the south side of Thomas Road would provide any benefit not already provided by existing and /or planned pedestrian paths. 2. The comment is noted. The comment does not raise any environmental issues, however, and no response is necessary. 3. The comment is noted. The comment does not raise any environmental issues, however, and no response is necessary. EMC Planning Group Inc. 2 -41 County of Santa Clara Local Agency Formation Commission County Government Center. East Wing 70 West Hedding Street. 1 Oth Floor San Jose. California 951 10 (408) 2932424 FAX 295-1613 Autumn Arias. Executive Director April 2, 1999 Bryan Stice, Planner Community Development Department City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 RECEIVED APR 7 1999 Gilroy Planning Div. Re: USA 98 -01 Gilroy Sports Park Draft Environmental Impact Report is c. CL-- Dear Mr. Stice. COUNT 1 l ETA C\ , Thank you for the opportunity to review the Gilroy Sports Park and Urban Service Area Amendment Draft Environmental Impact Report. The Santa Clara County Local Agency Formation Commission ( LAFCO) has the following comments regarding the DEIR. While the document generally does a good job of discussing the environmental issues, including a good analysis of the alternative sites to the proposed project, there are some incorrect conclusions regarding the consistency of the project with the following LAFCO and County. plans and policies: • Page 1-40, Consistency with LAFCO Urban Service Area Amendment Policy 4: Urban Service Area Amendment Policy 4: LAFCO will consider factors such as the following to determine the local and regional impacts of a proposed Urban Service Area amendment: e. Whether the conversion of agricultural and other open space lands is J(J� premature, or if there are other areas into which to channel growth; The document discusses each section of the policy and states, "The proposed project is consistent with this policy." Policy 4-e is discussed as follows: "The proposed project would result in the conversion from agricultural use of the proposed 78.4 -acre sports park site. The remaining parcels would remain in agriculture at this time. The alternate sites are currently in agricultural use and they would be removed from agricultural use if they were developed for a sports park." While the proposed project is consistent with most of Policy 4, it is not consistent with Policy 4 -e. The sports park site would be removed from agricultural production, and the additional 54.8 acres would become vulnerable to development pressure. Furthermore, alternative sites exist within the urban service area. Whether or not the alternative sites would also convert prime agricultural land is not relevant to consistency with this policy. In particular, inclusion of the I ladditional acreage into the urban service area is premature as there is no planned development at this time. 21 Page 1-42, Consistency with LAFCO Urban Service Area Amendment Policy 6: [he Commission will discourage Urban Service Area expansions which include agricultural or other )pen space land unless the city has accomplished one of the following: a. Demonstrated to LAFCO that effective measures have been adopted for protecting the open space status of the land. Such measures may include, but not be limited to, establishment of agricultural preserves pursuant to the California Land Conservation Act; adoption of City /County use agreements or applicable specific plans; implementation of clustering or transfer -of- development -rights policies; evidence of public acquisition; or b. Demonstrated to LAFCO that conversion of such lands to other than open space uses is necessary to promote the planned, orderly efficient development of the city. I'he document states: "The sports -park land has been acquired by the City of Gilroy for public open >pace use. The existing open space designation of the remaining parcels would not change at this time. When those parcels are developed, development would be orderly, and compatible with surrounding urban uses. The Study of the South County Agricultural Preserve was a joint effort of Santa Clara County, the City of Gilroy and Santa Clara County LAFCO. The study established an area of approximately 15,800 acres to the east and south of Gilroy as an agricultural preserve. The proposed project is located outside of the agricultural preserve on land that is within the City of Gilroy's 20 -year ,growth area. The proposed project is consistent with this policy." The project is only partially consistent with this policy. The proposal consists of 133.2 acres of prime agricultural land. While it is true that the proposed urban service expansion area lies outside of the "Gilroy Agricultural Lands Area," the City is requesting that 133.2 acres be added to the urban service area, rather than just the 78.4 acre area needed for the sports park. Inclusion of the additional 54.8 acres into the urban services area is not needed in order to make the sports park contiguous to the existing urban service area. If there is an assumption that the adjacent parcels would not be developed in the short term, they should not be included in the urban service area. Even if it is felt that more contiguity to the urban service area is desirable than just the width of a roadway (which would be the case if only the sports park parcels are taken into the USA), the option exists to include substantially less than 54.8 acres of additional land. The low- intensity land use of a sports park would be highly compatible with continued surrounding agricultural uses. _Inclusion of additional land into the urban service area for which no project is planned at this time is not necessary to promote the planned, orderly efficient development of the City. • Page 1 -35, Consistency with Growth and Development Policy C -GD 1: $ Growth and Development Policy C -GD 1: Most of the future urban growth of Santa Clara County should be accommodated within the existing urban areas, through infill development, rather than expansion of the urbanized area into hillsides and resource areas. The document states: "The proposed project would expand growth into an area that contains prime farmland, a valuable resource. However, the land is contiguous with developed portions of the City of W 1® Gilroy, and is adjacent on two sides to developed land. The - propos 10� _proposed project is consistent with this policy." This proposal is not consistent with this policy. It is not within the existing Urban Service Area (USA) or the existing city limits, and therefore cannot be considered as infill development. 4 Page 1 -37, Consistency with Growth and Development Policy C -GD 6: Growth and Development Policy C -GD 6: Hazard and resource areas with the following characteristics shall be considered unsuited for urban development: e. prime agricultural soils. The document discusses each section of the policy and states: "The proposed project would convert prime farmland to nonagricultural uses over a projected development period of 20 years. No alternative site was identified that would not result in the conversion of prime agricultural land. The proposed project is consistent with this policy." The proposed project is not consistent with this Policy C -GD 6 e. The proposed project would convert 133.2 acres of prime farmland to an urban use. Whether or not the alternative sites would also convert prime agricultural land is not relevant to consistency with this policy. Furthermore, the alternative sites are already totally or partially within the urban service area. ilr • Page 1 -37, Consistency with Growth and Development Policy C -GD 7: $ Growth and Development Policy C -GD 7: Urban expansion should be planned on a staged, orderly basis, consistent with applicable plans (e.g. city, County, countywide plans) and the availability of needed urban services and facilities. The discouragement of expansion of cities' Urban Service Areas should be recommended to the LAFCO." The document states, "The project site is currently within the City of Gilroy planning area and is within the city's 20 -year development boundary. The proposed sports park is expected to be built in a staged and orderly basis in phases over a 20 -year period. The proposed project is consistent with this Policy." The proposed project is not consistent with this policy. There are areas that are currently inside the urban service area of the city of Gilroy large enough to accommodate this proposal. In particular, the inclusion of 54.8 acres of additional land into the urban service area that is not needed for the sports park cannot be considered to be orderly development. o Page 1- 37,1 -38, Consistency with Growth and Development Policy C -GD 8: 6 Growth and Development Policy C -GD 8: Proposals to annex land or expand a city's urban ' service area boundaries shall be approved only if: b. the existing supply of land within the city's USA accommodates no more than five years of planned growth; The documents discusses each policy section and states: "The proposed project is generally consistent with this policy." Policy C -GD b. is discussed as follows: "Land within Gilroy's We Urban Service Area is expected to be substantially developed within five years. Most of the land remaining within the Urban Service Area is designated for residential and commercial use. Suitable sites for the sports park use are very limited. Two of the studied alternate locations are located within the Urban Service Area, and one alternate location is partially within the Urban Service Area. F Land within Gilroy's existing Urban Service Area is expected to be substantially built within five years. The proposed project requires a large amount of land. Though three alternative sites were found within (or partially within) the existing Urban Service Area, these were considered to be less suitable than the project site. Because the project site is located in a flood zone, the City was able to purchase the land at cost that makes the proposed project feasible. The alternative sites are not located in a flood zone and do not have the economic advantage that the project site has. The alternative sites were not as contiguous to developed land as the project site and two of the alternative sites were likely to have significant traffic impacts. Refer to Section 3.5 Alternatives." The proposal is consistent with portions a. and c. of this policy and is not consistent with Policy C -GD b. Lands within the urban service area are not likely to be developed within a five year time frame, especially lands that are suitable for the proposed sports park. • In closing, it is important to comment on potential changes to the Gilroy General 7 Plan as they relate to this proposal. The Gilroy General Plan update process is still underway and will be finalized close to the time of LAFCO's consideration of this project. If elements of the new General Plan change to the extent that they are relevant to this proposal, LAFCO will require additional information in order to adequately review the proposal. At that time, it will need to be determined if supplemental environmental documentation and review will be necessary, or if supplemental information to the commission will suffice. This has been previously discussed with Gilroy staff, who preferred this option over waiting until the General Plan update was adopted before beginning environmental work on this proposal. Of particular interest to LAFCO will be whether the land use designations of the j 133.2 acre project site and the alternative sites will change under the new General Plan, and whether the eastern growth boundary delineating the "Gilroy Agricultural Lands Area" east and south of Gilroy will be upheld. Again, thank you for the opportunity to comment on the Gilroy Sports Park and Urban Service Area Amendment Draft Environmental Impact Report. I can be reached at (408) 299 -3800 x7027 if you have any questions regarding these comments. Sincerely, Autumn H. Arias Executive Director Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Letter 10 County of Santa Clara Local Agency Formation Commission Autumn Arias, Executive Director April 2,1999. LAFCO Urban Service Area Amendment Policy 4e states that LAFCO should consider "whether the conversion of agricultural and other open space lands is premature, or if there are other areas into which to channel growth. Three alternative sites identified in the Draft EIR were determined to be adequate to accommodate the sports park project. Two of these alternative sites would result in reduced agricultural impacts if the proposed project were built there instead of at the project site. None of the alternative sites identified would eliminate the agricultural impacts altogether. However the loss of agricultural land could be reduced from approximately 133 acres to approximately 80 acres through the use of the alternative sites. Excluding the additional project site parcels (those outside the sports park site) from the project would have the same effect. Since there are other sites of adequate size, and notwithstanding the other environmental impacts associated with those sites, there are other areas in which to channel the proposed "growth ". Additionally the proposed project could be reduced in size to achieve this same goal. Therefore, it is acknowledged that the proposed project is inconsistent with LAFCO Urban Service Area Amendment Policy 4e and the text of the EIR has been amended to reflect this. 2. The 54.8 acres of non - sports park land are proposed to retain their existing land use designation of OPEN SPACE. Although the City assumes that these parcels would not be developed in the short term, including them in the Urban Service Area provides for a more contiguous Urban Service Area. The City acknowledges the possibility that once in the Urban Service Area, development pressures on these parcels may increase. The City also acknowledges that the option exists to bring less than 54.8 acres of additional land into the Urban Service Area. 3. Santa Clara County Growth and Development Policy C -GD 1 specifically states that "Most (emphasis added) of the future urban growth of Santa Clara County should be accommodated within the existing urban areas... "While the proposed project is located adjacent to urban development on two sides, it is acknowledged that the proposed project cannot be considered to be an in -fill project. Although the proposed sports park could be loosely defined as an "urban" development, the nature of a sports park is significantly lower in intensity that that of most residential, commercial, and industrial projects. The proposed project is considered to be consistent with this policy. 2 -46 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment Final EIR Addendum Response to Comments 4. Santa Clara County Growth and Development Policy C -GD 6e states that areas of prime agricultural soils are unsuitable for urban growth. Although all of the alternative sites identified in the Draft EIR would also result in development on prime agricultural soils, it is acknowledged that this fact does not lessen the significance of the loss of prime agricultural soils that would occur on the project site with development of the proposed project. It appears that any development on prime agricultural soils would be inconsistent with this policy. Therefore, it is acknowledged that the proposed project is inconsistent with Santa Clara County Growth and Development Policy C -GD 6e, and the text of the EIR has been amended to reflect this. 5. Santa Clara County Growth and Development Policy C -GD 7 requires urban expansion to be planned in a staged, orderly basis and consistent with applicable plans and the availability of urban services and facilities. The policy discourages the expansion of urban service areas. The proposed project will result in the orderly development of the City of Gilroy. The proposed project is located closer to substantial utility infrastructure and is more contiguous with existing development than the alternative sites that were identified. The project site is also closer to existing major transportation nodes. Therefore the proposed project is consistent with the first part of this policy. The City acknowledges that the proposed project is inconsistent with the second part of this policy. The discouragement of expansion of the City's Urban Service Area is not recommended because the City planning staff believes that the project site is superior to alternative sites in terms of proximity to existing development, utility infrastructure, transportation facilities and lodging facilities. The sports park is expected to generate a substantial amount of traffic, and a location near major transportation facilities is considered very important. The nearby location of lodging facilities will decrease the number of trips somewhat during regional events since out -of -town participants staying at the lodgings will be able to easily reach the facility on foot. The project site is adjacent to development on two sides. None of the alternative sites have this proximity to existing development. This policy was challenging to interpret and initially, it appeared that the consistency analysis was adequate. On second review, it would appear that the proposed project is only consistent with the first part of the policy. Therefore, the proposed project would be consistent with the first part of Santa Clara County Growth and Development Policy C -GD 7 but it is �- acknowledged that the proposed project would be inconsistent with the second part of the policy. The text of the EIR has been amended to reflect this. 6. The City of Gilroy expects that most of the land within its existing Urban Service Area will be substantially developed within an approximate 5 -year 9 timeframe. The three alternative sites that were studied in the Draft EIR are EMC Planning Group Inc. 2-47 Response to Comments Gilroy Sports Park and LISA Amendment Final EIR Addendum located within or partially within the Urban Service Area. However, these sites were found to be less suitable than the project site for the proposed sports park. The sites, though within the existing Urban Service Area, are less contiguous to existing development than the project site. The utility and transportation infrastructure at these alternative sites is not as good as at the project site. The City believes that the project site is superior to the alternative sites within the existing Urban Service Area. While it is true that these sites might not be developed within the next five years, the City believes that no equally suitable site for the proposed project exists within the current Urban Service Area. Therefore, given the constraints of the of the proposed project's land requirements, the proposed project is consistent with this policy. 7. CEQA Guidelines require an EIR to discuss consistency with applicable plans. CEQA Guidelines section 15125 (d) requires an EIR to "discuss any inconsistencies between the proposed project and applicable general plans and regional plans." This section includes a list of the types of plans and policies typically included in the analysis. CEQA Guidelines section 15125 (e) requires that "where a proposed project is compared with an adopted plan, the analysis shall examine the existing physical conditions at the time the notice of intent is published" as well as "the potential future conditions discussed in the plan." The Environmental Checklist Form (CEQA Guidelines Appendix G) asks whether the project would "conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect." CEQA makes no requirement that a project be analyzed for consistency with future plans that have not yet been formulated. The City of Gilroy General Plan update is still in the hands of the working committee and no official proposals have been put forth. The update has not yet been released for public review, much less adopted by the City. Any analysis of the upcoming General Plan update would be highly speculative and not required by CEQA. EMC Planning Group Inc. County of Santa Clara Roads and Airports Department Land Development Services 101 Skyport Drive Imo- San Jose, California 95110 April 6, 1999 J ✓Mr. Bryan Stice Community development Department City of Gilroy 7351 Rosanna Street Gilroy, California 95020 RECEIVE® APR 1 ?• 1.999 Gilroy banning Div. Subject: Draft Environmental Impact Report (EIR) Traffic Impact Analysis Gilroy Sports Park Dear Mr. Stice: GG UIyT� 9�TA C, In response to Item (2) of our November 23, 1998 letter, the City furnished us the Traffic Impact Analysis (TIA) dated January 1999 concerning the subject project. We have reviewed the TIA and our comments are as follows: According to figure 6 of the TIA, 30% of the project traffic is directed to Santa Teresa Blvd./Thomas Road intersection. r In the December 15, 1998 letter by Kristi A. Abrams, P.E., Traffic Engineer, City of Gilroy, it is stated as follows: "The Thomas Road/Santa Teresa Expressway intersection will be geometrically improved and signalized prior to the first phase of the Gilroy Sports Park. Funded in part by the Eagle Ridge developer and part by the City of Gilroy, these improvements are anticipated to be completed as early as summer of 1999 and no -~ latter than summer 2000. The first phase of the Gilroy Sports Complex will not open until summer 2002. Therefore, this intersection was not included in the analysis. The Thomas Road/Church intersection will be added to the analysis." Board of Supervisors: Donald F. Gage, Blanca Alvarado, Pete McHugh, James T. Beall, Jr., S. Joseph Simitian Countv Executive: Richard Wittenberg ,m, Mr, Bryan Stice Page 2 April 6, 1999 This is acceptable. A County encroachment permit should be obtained prior to the beginning of any work in the County jurisdiction. We thank you for the opportunity to review this matter. Please call me at (408) 573 -2462 if you have questions. Sincerely, A>N' i ok Vy as Project Engineer AAV:rtj cc: DEC MA JME File 11 n Gilroy Sports Park and USA Amendment Final EIR Addendum Response to Comments Response to Letter 11 County of Santa Clara Roads and Airports Department Ashok Vyas, Project Engineer April 4,1999 1. The comment is noted. The comment does not raise any environmental issues, however, and no response is necessary. EMC Planning Group Inc. 2 -51 Response to Comments Gilroy Sports Park and USA Amendment Final EIR Addendum This side intentionally left blank 2 -52 EMC Planning Group Inc. 3.0 Revised Summary Proposed Project The proposed project consists of three primary components: an Urban Service Area amendment request to Santa Clara County Local Agency Formation Commission (LAFCO) and annexation to the City of Gilroy; approval of a Park Master Plan and development of the Gilroy Sports Park and commercial recreation building; and construction of off -site improvements including the extension of the Uvas Creek Trail from Thomas Road — Luchessa Avenue south to Gavilan Community College (including a pedestrian /bicycle bridge over Uvas Creek), extension of the City's recycled water distribution line to the sports park, and roadway improvements. The project site is located on the south end of Gilroy at the southwest corner of Monterey Street and Thomas Road — Luchessa Avenue. It is bordered by Thomas Road — Luchessa Avenue to the north, Uvas Creek and Farman Lane to the south, Monterey Street and Monterey Frontage Road to the east, and Uvas Creek to the ' west. Surrounding land uses are residential (single- family and rural), commercial (hotels under construction), and agricultural (row crops and greenhouses). U.S. Highway 101 is located to the east of the project site. The entire 133.2 -acre project site is proposed for inclusion into the City's Urban Service Area, and annexation to the City. This would include the 78.4 -acre sports park site and 54.8 acres of adjacent parcels to the east and north. The sports park is the only project proposed for development at this time within the Urban Service Area amendment request. The adjacent parcels are not proposed for development. This EIR assumes these parcels will remain in open space. Any proposed _y development on these parcels will require further environmental review. Preliminary plans for the proposed sports park include the following components: recreational play fields (eight softball diamonds and four soccer fields and concession/ restrooms); premier play fields (one 90 -foot baseball diamond, two Little League diamonds and one soccer field and concession /restrooms); competition play fields (one softball /baseball diamond and one soccer field and concessions and restrooms); 8.8 acres of park preserve with family picnic, concessions and restrooms, volleyball and bocci ball courts, horseshoe pits and play area; commercial recreation building (indoor soccer, roller hockey, community building, storage); corporation yard; parking (1,043 spaces); and a night watch park ranger station. Soccer fields overlay baseball /softball fields. Football may also be played on the soccer fields. The athletic fields would have lighting for night games, a public address system and seating. The sports park and related off -site improvements would be constructed in phases over a 20 -year period. EMC Planning Group Inc. 3-1 Revised Summary Gilroy Sports Park and LISA Amendment Final EIR Addendum Summary of Impacts and Mitigation Measures Pursuant to CEQA Guidelines section 15063 an initial study was prepared to determine the potentially significant effects of the proposed project. The initial study determined that certain issues would have a potentially significant impact on the environment. These issues concerned agricultural considerations, geology, hydrology, public services and service systems, biological resources, transportation/ circulation, air quality, noise, archaeological resources, and aesthetics. The initial study determined that there would be a less than significant impact concerning population and housing and energy. Those issues determined to have a potentially significant environmental impact were studied in greater depth in this EIR. Environmental impacts and proposed mitigation measures for the proposed project are presented in Table S -1. Summary of Other CEQA Considerations Unavoidable Significant Adverse Environmental Impacts An unavoidable significant adverse environmental impact is a significant adverse impact that cannot be reduced to a less than significant level through the implementation of mitigation measures. CEQA Guidelines section 15093 requires that a lead agency make findings of overriding considerations for unavoidable significant adverse environmental impacts before approving a proposed project. The loss of prime farmland is generally considered a significant and unavoidable adverse environmental impact. The proposed project would result in the loss of the 133.2 acres of prime farmland (though some of this land is used for commercial and residential farm - related uses). The establishment of the Gilroy Agricultural Lands Area by both the City of Gilroy and the County of Santa Clara serves as a regional mitigation for losses of prime farmland in southern Santa Clara County, outside of the agricultural lands area. Although this regional mitigation has been implemented, it does not reduce the loss of prime farmland to a less than significant level and the proposed project would still be considered to have a significant and unavoidable impact on prime farmland. Cumulative Impacts Cumulative impacts are those environmental impacts resulting from the cumulative effects of approved but not yet built projects and probable projects in the area of the proposed project. Cumulative impacts were based on projects in the southern part of Gilroy. Cumulative impacts were identified concerning agricultural considerations, hydrology, transportation/ circulation and air quality. 3 -2 EMC Planning Group Inc. r_ I Gilroy Sports Park and USAAmendinent Final EIR Addendum Revised Summary Agricultural Considerations The proposed project would add 133.2 acres of prime farmland to the City of Gilroy Urban Service Area. Land within the Urban Service Area is generally expected to be developed within an approximate five -year timeframe. Prime farmland is a non- replaceable resource. Each cumulative project that involves the conversion of prime farmland to non - agricultural uses contributes to the depletion of this resource. Hydrology Development of previously undeveloped land results in the covering of permeable soil with impermeable pavement and structures. The proposed project along with other proposed development will result in an increase in the amount of currently permeable land that is covered by impermeable surfaces. Under certain weather conditions increases in the amount of area covered in impervious materials can result in increased rates of storm water run -off into streams. The increased rate of storm water run -off can result in higher flows in streams, in a more rapid rise in streams' water levels and can potentially result in local or widespread flooding in areas adjacent to the stream. However, during flood conditions it is likely that the increase in run -off would be less than significant because under these conditions run -off from pervious surfaces is typically high also. than 0.3 percent increase in the 10 -Year flood flow of 5,500 cubic feet per second, which does not overflow the channel and an increase of 0.1 percent in the 100 -year flow of 14,000 cubic feet per second This would not be a significant increase in the flood flows or flood elevations for Uvas Creek. For downstream areas including Pajaro River, the potential increases would be even smaller due to the larger existing flows and the extensive flood plain storage in the Soap Lake area downstream of Monterey Road near the Llagas Creek confluence. Transportation /Circulation A traffic impact assessment prepared for the proposed project determined that the increase in traffic associated with the proposed project and other proposed or existing development would result in traffic congestion at one intersection. The cumulative conditions level of service at the intersection of Monterey Street and Monterey Frontage Road would be below the standards prescribed by the City of Gilroy General Plan. A mitigation measure in Section 2.6 Transportation/ Circulation would require the installation of a signal light at this intersection prior to completion of Phase IV of the proposed sports park. With implementation of this mitigation measure the proposed project would not result in a significant cumulative traffic impact. EMC Planning Gronp Bu. 3 -3 Revised Summary Gilroy Sports Park and USA Amendment Final EIR Addendum Air Quality The San Francisco Bay Area is designated by the U.S. EPA as a non - attainment area for the national ozone standard. The region has had recent violations of the national ambient air quality standard for ozone. The State Implementation Plan (SIP), a compilation of plans and regulations that govern how the region complies with the Federal Clean Air requirements is being revised. The 1999 SIP will identify how the region will attain the national air quality standard for ozone in the future. The addition of the vehicular trips and associated emissions from the proposed project and other proposed and existing development in the area would contribute to cumulative air quality impacts in a non - attainment area. Significant Irreversible Environmental Changes The proposed project would result in the permanent loss of prime agricultural land. While this loss is mitigated in part by the establishment of the Gilroy Agricultural Lands Area, the prime agricultural land lost to the proposed project is not replaceable. The loss of prime agricultural land would be a significant irreversible change. Growth Inducing Impacts Growth inducement generally refers to the likelihood that a proposed project will foster growth in the surrounding area, either directly or indirectly. The most common factor in fostering growth is the removal of obstacles to population or economic growth. The proposed project would require the extension of a recycled water distribution /�, line. Recycled water is used primarily for irrigation of large park or open space +, areas, and extension of this line would not be likely to induce concentrated urban growth. All other infrastructure is currently available near the project site. The project site is currently within the City of Gilroy 20 -year development area. The proposed project would transfer the project site into the Urban Service Area. Development within Urban Service Areas is generally expected to occur within an approximate five -year timeframe. Development of those parcels that are not part of the proposed sports park could be hastened by the development of the sports park. The proposed project could have growth inducing impacts on the project site and possibly on adjacent areas. Summary of Alternatives Analysis Four alternatives to the proposed project were analyzed to determine if they would achieve project objectives while minimizing environmental impacts. The " No " 3 -4 EMC Planning Gronp Inc. Gilroy Sports Park and USA Amendment Final EIR Addendum Revised Summary Project' alternative would maintain the area in its current use and no Urban Service Amendment, annexation or sports park and related development would take place. Three alternative locations were also studied: Santa Teresa Boulevard at State Highway 152; Santa Teresa Boulevard and Miller Avenue; and Monterey Road at Bolsa Road. The 'No Project" alternative is the environmentally superior alternative, because it eliminates the unavoidable significant impact of loss of prime farmland. However, the 'No Project" alternative does not achieve project objectives of providing the community with additional athletic fields and parkland. The proposed project has beneficial biological impacts that would not be achieved with the 'No Project" alternative. The remaining alternatives and the proposed project are all approximately equal in terms of their environmental impacts, and the selection of one alternative as the environmentally superior is based on very fine shades of interpretation. Though very close to the other remaining alternatives and the proposed project in terms of its environmental effects, the Santa Teresa Boulevard and Miller Avenue alternative is the environmentally superior alternative among the remaining alternatives. The principal factor that favors this alternative is its reduced impact on prime farmland compared to the other alternative locations. However, this alternative may result in traffic impacts that could be difficult to mitigate. EMC Planning Group Inc. 3 -5 TABLE S -1 Summary of Impacts and Mitigation Measures Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Agricultural Loss of Prime Farmland. Unavoidable N/A The establishment of the Gilroy Unavoidable Considerations Development of the sports park Significant Agricultural Lands Area by both the City Significant would result in the loss of 78.4 of Gilroy and the County of Santa Clara acres of prime farmland serves as a regional mitigation for losses identified in the Farmland of prime farmland in southern Santa Mapping and Monitoring Program Clara County outside of the agricultural over the 20 -year build -out of the lands area. Although this regional proposed sports park. mitigation has been implemented, it does not reduce the loss of prime farmland to a Lass of Prime Farmland less than significant level and the Approval of the Urban Service proposed project would still be considered Area amendment and to have a significant and unavoidable development of parcels adjacent impact on prime farmland. to the sports park site could ultimately result in the loss of the remaining 54.8 acres of designated farmland within the project site. Agricultural Conflict With Williamson Act No N/A None No Considerations Contract. Four of the parcels on Impact Required Impact the project site were under Williamson Act contract. Notices of non - renewal were filed and the contracts expired January 1, 1999. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Agricultural Effect on Adjacent Agricultural No N/A None No Considerations Uses. Implementation of the Impact Required Impact proposed project would not affect agricultural operations off the project site. Geology Seismic Hazards. The proposed- Less Than N/A None Less Than project exposes people or structures Significant Required Significant to a small risk of potential substantial adverse effects involving seismic hazards. Hydrology Storm Water Run -off. Storm Less Than N/A None Less Than water run -off from access roads, Significant Required Significant parking lots and pathways could increase the rate of storm water discharge into Uvas Creek and the Pajaro River drainage during some weather conditions. Hydrology On -Site Flood Flowage. SCVWD Potentially 1 The City shall have a hydrology report Less Than holds a flood flowage easement Significant prepared for the project by a qualified Significant that restricts land use and hydrologist or engineer, to address development on a large portion of hydrology - related design requirements the project site. Inappropriate for the project site and buildings. development within this easement could put structures at risk of damage and people at risk of injury or death from storm - related flooding. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Hydrology Surface Water Quality. During Significant 2 The City shall submit a Notice of Intent Less than construction, grading will expose and detailed engineering designs to the Significant sediments to rain or wind erosion Central Coast Regional Water Quality and subsequent transportation of Control Board, and implement a Storm sediments to the Uvas Creek, Water Pollution Prevention Plan that uses Pajaro River and Monterey Bay. storm water 'Best Management Practices" Materials used and wastes to control runoff, erosion and generated during construction sedimentation from the site. would degrade water quality also. Development of the project 3 The City shall submit plans for review would generate non -point source by, and obtain an approved permit from pollutants from newly the Santa Clara Valley Water District. established urban activity at the project site. Hydrology Surface Water Quality. Potentially 1 a Project plans, subject to the review and Less Than approval of the City of Gilroy Planning, Significant ,Operation of the Gilroy Sports Significant Park will introduce new urban Division, shall include a sedimentation pollutants to the project site. basin adequate for filtering out heavy These contaminants could be storm water contaminants such as silt, and transported to the drainage grease traps suitable for filtering out other urban pollutants to the extent system, polluting downstream water systems. feasible. The sedimentation basin and grease trap shall be designed subject to the review and approval of the City of Gilroy Engineering Division and shall be installed at the time that the storm water out -fall is constructed. o > o Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Public Services Construction of New Less Than N/A None Less Than and Service Infrastructure. The proposed Significant Required Significant Systems project does not require substantial extensions or upgrades to the existing potable water supply, wastewater or storm drain infrastructure. Public Services Water Supply. The proposed No N/A None No and Service project would result in a minimal Impact Required Impact Systems increase in demand for potable water. The proposed project would increase demand for recycled water for irrigation. Public Services Police and Fire Services. The No N/A None No and Service proposed project does not result in Impact Required Impact Systems the need for additional facilities for the provision of police or fire services. Biological Loss of Habitat. Due to continuous No N/A None No Resources human interaction, agricultural Impact Required Impact fields typically provide little habitat for wildlife and do not represent a significant biological resource. Biological Riparian Buffer. The proposed Beneficial N/A None Beneficial Resources 50 -foot habitat buffer will Required substantially increase the amount of native habitat along Uvas Creek. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Biological Invasive Plant Species. The Significant 4 Project plans shall include a habitat Less Than Resources riparian habitat along Uvas buffer designed to include appropriate Significant Creek could be affected by the native plant species and shall not include presence of non - native, invasive plantings of non - native, invasive plant plant species. species. Wherever possible, the east side of the trail shall be planted with native grasses or other native species to provide additional native habitat. Biological Loss of Significant Trees. Some of Potentially 5 A field survey shall be conducted to Less Than Resources the trees along the north side of Significant determine the number type, size and Significant Thomas Road — Luchessa Avenue, location of any potentially significant along the north side of Mesa tree to be removed. Road, and through the riparian habitat leading to and from the 6 The protected zone (one to 1.5 times the proposed pedestrian bridge may distance from the trunk to the dripline, be considered "significant" trees depending on the tree species) of any trees that might be removed or injured or groups of trees to be retained shall be during construction activities. fenced to prevent injury to the trees during construction. Biological Riparian Habitat. Construction Potentially 7 A Habitat Mitigation Plan shall be Less Than Resources of the pedestrian bridge over Significant prepared to identify the exact amount and Significant Uvas Creek could disturb riparian location of impacted and replacement woodland habitat. habitat, and shall specify replacement specifications for any removed habitat. low Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Biological Riparian Habitat. Construction Significant 8 A Section 1603 Streambed Alteration Less Than Resources of the pedestrian bridge over Agreement shall be obtained from the Significant Uvas Creek could introduce fill California Department of Fish and Game. material into the creek and /or Construction activities in or adjacent to increase turbidity in the creek and Uvas Creek to occur when the creek is dry interfere substantially with the or has a very low flow (generally June movement of steelhead as well as through October 15). other fish and aquatic wildlife. 9 The City shall contact the U.S. Army Corps of Engineers to determine who has jurisdiction over the bridge construction activities and if a permit is required for bridge construction. 10 Erosion control measures shall be installed along portions of Uvas Creek to prevent sediment from filling the creek. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Biological Burrowing Owls. Construction Potentially 11 Field surveys shall be conducted to Less Than Resources activity along the slope of the Significant determine if burrowing owls are present in Significant levee in the northwest corner of the construction zone or within 250 feet of the project site could result in the the construction zone if any construction direct loss of burrowing owl nests, would occur during the nesting and /or including eggs and young, or the breeding season of burrowing owls abandonment of an active nest by potentially nesting in the area (February the adults. 1 through August 31) and /or during the winter residency period (December 1 and January 31). If active nests are found, a burrowing owl habitat mitigation plan shall be prepared. 12 The City shall arrange for a biologist to inform workers of the potential presence of special- status wildlife and measures to be implemented to avoid loss of these wildlife during construction activities. F Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Biological Raptors. Construction activities Potentially 12 See above. Less Than Resources in or near the riparian woodland Significant Significant habitat found along Uvas Creek 13 A field survey shall be conducted by a could result in the direct loss of qualified biologist to determine if active white - tailed kite, northern raptor nests are present in the construction harrier, Cooper's hawk, and zone or within 250 feet of the construction short -eared owl nests, including zone if any construction would occur during eggs and young, or the the nesting and /or breeding season of abandonment of an active nest by raptors potentially nesting in the areas the adults. -proposed for development (generally March 1 through August 1). If active nests are found, at the discretion of the biologist, clearing and construction within 250 feet shall be postponed or halted until the nests are vacated and juveniles have fledged and there is no evidence of a second attempt at nesting. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Biological Amphibians. Construction Potentially 8 See above. Less Than Resources activity in or near the riparian Significant Significant woodland habitat found along 10 See above. Uvas Creek could result in the direct and indirect loss of 12 See above. California red - legged frog, foothill yellow - legged frog, 14 A biologist shall monitor the project site western spadefoot toad, during construction activities within 100 California tiger salamander, and feet of Uvas Creek. If California red - western pond turtle. legged frog, foothill yellow - legged frog, Use of the sports park may result western spadefoot toad, California tiger in death or harassment of salamander, and /or western pond turtle wildlife by pets and people, turtles are observed at the site, consumption by predators construction activities shall be halted attracted to the project site, or and the United States Fish and Wildlife death or injury from pesticides. Service shall be contacted for further assistance. 15 All food - related trash items shall be enclosed in sealed containers and regularly removed from the project area to deter attraction of potential predators Pets shall not be allowed on the construction site. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Biological Habitat Disturbance During Potentially 2 See above. Less Than Resources Construction. Accidental spills of Significant Significant contaminants or other harmful 3 See above. materials, such as diesel fuel or oil, from construction vehicles 16 A plan shall be prepared to allow prompt could spread into the riparian response to any accidental spills, and woodland habitat and Uvas inform workers of the importance of Creek and harm or kill wildlife. preventing spills and of the appropriate During use of the sports park, measures to take in case of a spill. Uvas Creek could be contaminated by pesticides, fertilizers, and Guidelines shall be established for the similar substances. 17 prevention of contamination of the creek by pesticides and fertilizers from maintenance of the athletic fields. Biological Habitat Disturbance During Potentially 10 See above. Less Than Resources Recycled Water Line Significant Significant Construction. Construction 16 See above. activity could produce erosion or accidental spills of contaminants that could decrease habitat quality and interfere with the movement or well -being of wildlife. Biological Effects of Nighttime Lighting on Potentially 18 A lighting plan for the sports park shall Less Than Resources Wildlife. Nighttime lighting of Significant be developed requiring all lighting in the Significant the sports park play fields could western portion of the sports park to be spill over into the riparian directed away from the riparian habitat, woodland habitat and disturb prohibiting lighting along the Uvas wildlife, restrict the movement or Creek Trail; and generally restricting activity of wildlife, or facilitate lighting after 11:00 PM. increased predation of wildlife. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Biological Domestic Activities. People and Potentially 19 A signage plan for the sports park shall Less Than Resources unleashed pets wandering off the Significant be prepared to outline the language, Significant Uvas Creek Trail could restrict number and location of signs to dissuade the movement or activity of people from straying off the Uvas Creek and /or disturb or kill wildlife Trail and to prohibit unleashed dogs on the Uvas Creek trail. Transportation LOS Below City Standards. Significant 20 Prior to completion of Phase IV of the Less Than Circulation With completion of Phase V of proposed sports park the City of Gilroy Significant the proposed sports park the shall install a traffic signal and make intersection of Monterey Street lane improvements to at the intersection and Monterey Frontage Road of Monterey Street and Monterey Frontage would be congested. Road. Transportation State Highway Traffic. The Less Than N/A None Less Than Circulation proposed sports park would not Significant Required Significant cause congestion on nearby freeway segments. Transportation Bicyclist and Pedestrian Safety. Significant 21 The Uvas Creek Trail extension shall Less Than Circulation The proposed design of the connect by direct route to Thomas Significant temporary alignment of the Uvas Road — Luchessa Avenue at Princevalle Creek Trail crossing of Thomas Street via a built -up earth ramp on the Road— Luchessa Avenue would levee's north embankment. result in a potential safety hazard to users of the trail. Transportation Bicyclist and Pedestrian Safety. Significant 22 Cross walks shall be installed across Less Than Circulation The temporary alignment of the Thomas Road — Luchessa Avenue at Significant Uvas Creek Trail crossing of Princevalle Street and stop signs shall be Thomas Road — Luchessa Avenue installed on Thomas Road — Luchessa would expose trail users to high Avenue at Princevalle Street. speed cross traffic. J '- Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Transportation Bicycle Access. The project plans Significant 23 The City shall construct a Class 1 path on Less Than Circulation do not indicate a bicycle route the west side or Class II bicycle lanes on Significant connection between Monterey both sides of Monterey Frontage Road as a Street, a designated bicycle route part of the design and construction of and the proposed sports park improvements to Monterey Frontage Road access road. between Monterey Street and the sports ark access road. Transportation Pedestrian Access. Sports park- Significant 24 Prior to completion of Phase IV of the Less Than Circulation related traffic increases along proposed project the City of Gilroy shall Significant Monterey Street and Monterey construct a minimum 6 -foot wide sidewalk Frontage Road will present along the west side of Monterey Frontage hazardous conditions to Road and a minimum 10 -foot wide pedestrians accessing the sidewalk along Monterey Street between proposed sports park. Thomas Road — Luchessa Avenue and the sports park access road. Transportation Parking Supply. The proposed Significant 25 The City of Gilroy shall include in project Less Than Circulation sports park would have a plans, 180 parking spaces from a later Significant shortage of 180 parking spaces at phase to be built prior to completion of the completion of Phase V. Phase V. Transportation Internal Circulation. The No N/A None No Circulation transportation impact assessment Impact Required Impact made recommendations for improvements to internal vehicular circulation at the proposed sports park. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Air Quality Sports Park Operations. The Less Than N/A None Less Than proposed sports park would result Significant Required Significant in the emission of various pollutants into the atmosphere. These emissions would be below the thresholds established by the BAAQMD. Air Quality Project Construction. Construction Potentially 26 Dust control measures shall be Less Than activities at the project site could Significant incorporated into all permits for any Significant result in a significant adverse air phase of the project. The measures shall quality impact from dust. be implemented as necessary to adequately control dust. Noise Noise from Park Activities. Less Than N/A None Less Than Activities at the proposed sports Significant Required Significant park, including athletic events and traffic entering and exiting the project site would generate noise. Noise Construction Noise. Construction Significant 27 Construction activities shall be limited to Less Than activities at the project site could specified hours. Significant result in high levels of noise. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Archaeological Currently unidentified buried Potentially 28 The city shall contract with a qualified Less Than Resources cultural resources may be found Significant archaeologist to arrange a schedule for Significant during construction on the project monitoring the project site during grading site. and excavation activities. 29 If archaeological resources or human remains are discovered during construction, work shall be halted at a minimum of 200 feet from the find and the area shall be staked off. The project developer shall notify a qualified professional archaeologist. If the find is determined to be significant, appropriate mitigation measures shall be formulated and implemented. 30 If human remains are found during construction there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the coroner of Santa Clara County is contacted to determine that no investigation of the cause of death is required. If the coroner determines the remains to be Native American the coroner shall contact the Native American Heritage Commission within 24 hours. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Aesthetics Change in Rural Character. Less, Than N/A None Less Than Development of the project site Significant Required Significant would permanently alter the existing rural character of the area. Aesthetics Nighttime Lighting. The Less Than N/A None Less Than proposed sports park would Significant Required Significant introduce a major new source of light to the local area. Note: Impacts and Mitigation Measures are summarized in this table. Refer to the text of the Environmental Impact Report for the complete text of the impacts and mitigation measures associated with each area of concern. Source: EMC Planning Group Inc. 4.0 Changes to the Draft EIR Text Changes to the text of the EIR resulting from comments received during the public review period, or to correct errors found in the Draft EIR are presented in this section. Deletions to the text are shown with strike through type and additions to the text are shown with underline type. An incorrect policy number was included in the Draft EIR. The following change is made to page 1 -29 of the Draft EIR: Natural Environment Policy 11-23: In preference to the construction of expensive flood prevention facilities, floodways will be left open for agricultural and recreational use in areas of particular risk and where protection is minimal. Based on comments received during the public review period the following changes are made - to page 1 -37 of the Draft EIR: Growth and Development Policy C -GD 6: Hazard and resource areas with the following characteristics shall be considered unsuited for urban development: e. prime agricultural soils. Consistency: The proposed project would convert prime farmland to non- agricultural uses over a projected development period of 20 years. NE) a'� Mer e The proposed project is inconsistent with this policy. Growth and Development Policy C -GD 7: Urban expansion should be planned on a staged, orderly basis, consistent with applicable plans (e.g. city, County, countywide plans) and the availability of needed urban services and facilities. The discouragement of expansion of cities' Urban Service Areas should be recommended to the LAFCO. Consistency: The project site is currently within the City of Gilroy planning area and is within the city's 20 -year development boundary. The proposed sports park is expected to be built in a staged and orderly basis in phases over a 20 -year period. contiguous with existing development than the alternative sites that were identified. EMC Planning Group Inc. 4-1 Changes to the Draft EIR Text Gilroy Sports Park and USA Amendment Final EIR Addendum The project site is also closer to existing major transportation nodes. Therefore the proposed project is consistent with the first part of this policy. expected to generate a substantial amount of traffic, and a location near major facility on foot. The project site is adjacent to development on two sides. None of the alternative sites have this proximity to existing development. Therefore, the proposed project would be consistent with the first part of Santa Clara County Growth and Development Policy C-GD 7 but inconsistent with the second part of the policy. Based on comments received during the public review period the following changes are made to page 1 -40 of the Draft EIR: Urban Service Area Amendment Policy 4: LAFCO will consider factors such as the following to determine the local and regional impacts of a proposed Urban Service Area amendment: a. The ratio of lands planned for residential use to land planned for employment - producing use; b. The existence of adequate regional and local transportation capabilities to support the planned city growth; c. Ability of the city to provide urban services to the growth areas without detracting from current service levels; d. The ability of school districts to provide school facilities; e. Whether the conversion of agricultural and other open space lands is premature, or if there are other areas into which to channel growth; f. The role of special districts in providing services; g. Environmental considerations which may apply; h. The impacts of proposed city expansion upon the County as a provider of services; L Fiscal impacts on other agencies. 4 -2 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final RTE Addendum Changes to the Draft EIR Text Consistency: Each of these factors is discussed below: a. There are three existing houses that would remain, at least in the short term, on the project site. A residence would be provided for a caretaker for the sports park. An unknown number of employees would work at the project site, but it would be a fairly small number. Many of the jobs at the project site would be low -paid seasonal jobs. b. The proposed project is served by U'S. Highway 101, Monterey Street and other local streets, and the extension of the Uvas Creek Trail, which is proposed as a part of this project. c. The City of Gilroy would extend domestic and recycled water supply lines and sewer and storm drain lines to the project site. The City of Gilroy police and fire departments would provide public safety services to the project site. This extension of services would not reduce the level of service available to other areas of the city. d. The proposed project will not affect school enrollment. This factor is not relevant to the proposed project. e. The proposed project would result in the conversion from agricultural use of the proposed 78.4 -acre sports park site. The remaining parcels would remain in agriculture at this time. g4te alternate sites are ent4y in f. The City of Gilroy would provide water, sewer, storm drainage, police and fire services to the site. g. The amendment is subject to the analysis of this EIR. The proposed project would result in the conversion of prime agricultural land to non - agricultural uses. This would be a significant and unavoidable impact. Other potential impacts have been identified in this EIR and mitigation measures are presented to reduce those impacts to a less than significant level. h. The proposed project would not increase the demand on services provided by Santa Clara County. Services currently provided by the county would be provided by the City of Gilroy if the proposed project is approved. L A fiscal analysis is currently under preparation for the proposed project. The proposed project is consistent with items a —d and f —i of this policy, but inconsistent with item e of this policy. EMC Planning Group Inc. 4-3 Changes to the Draft EIR Text Gilroy Sports Park and USA Amendment Final EIR Addendum Based on comments received during the public review period and at the direction of the project hydrologist, the fallowing changes are made to page 2 -17 of the Draft EIR: Storm Water Run -off The sports park site is currently undeveloped farmland. A large proportion of the rainfall that lands on the project site soaks into the soil. The general slope of the site is away from Uvas Creek towards Monterey Road. Much of the water that runs off the project site drains to Monterey Road and via a storm drain into Uvas Creek. The proposed project would include turf areas, access roads, parking lots, pathways and structures. Star-in . atef . off F_,.... these ,_c.. ees eould, under some I.. R2� the rainfall has the greatest potential loss top surface storage and infiltration into the soil. For individual sites, the peak run -off may also be increased by the construction of a storm drain system, which reduces the time for flow to discharge to the creek or stream. occurs hours after the peak rainfall. storm events would not occur. For larger flood events, greater than the 10- Based on comments received during the public review period and at the direction of the project hydrologist the following changes are made to page 2 -16: 4 -4 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final RIE Addendum Changes to the Draft EIR Text Storm Water Quality A variety of contaminants are common to urban area storm water and irrigation run -off. These contaminants include coliform bacteria, sediment, organic chemicals, nutrients and pesticides from landscaping and athletic fields, and fuel constituents, heavy metals, oil and grease from automobiles, roads and parking areas. These contaminants could be transported to the drainage system, polluting downstream water systems. The potential for contamination exists during both the construction and operation of the proposed project. Water quality degradation is regulated by the Federal National Pollution Discharge Elimination System (NPDES) Program, which was established by the Clean Water Act. The NPDES controls and reduces pollutants to water bodies from point and non -point discharges. In California, the California Regional Water Quality Control Boards (RWQCB) administer the NPDES Program. The Central Coast RWQCB issues and enforces NPDES permits for discharges to water bodies in the portion of Santa Clara County that drains to the Monterey Bay. Projects disturbing more than five acres of land during construction are required to file a notice of intent to be covered under the State NPDES General Construction Permit for discharges of storm water associated with construction activities. The applicant must propose control measures that are consistent with the State NPDES General Construction Permit and consistent with recommendations and policies of the local agency and the RWQCB. The State NPDES General Construction Permit requires development and implementation of a Storm Water Pollution Prevention Plan ( SWPPP) that uses storm water "Best Management Practices" to control runoff, erosion and sedimentation from the site both during and after construction. The SWPPP has two major objectives: (1) to help identify the sources of sediments and other pollutants that affect the quality of storm water discharges; and (2) to describe and ensure the implementation of practices to reduce sediment and other pollutants in storm water discharges. The SCVWD also requires a project review and permit for any construction that takes place within 50 feet of any watercourse within its boundaries. Because of the flood flowage easement, SCVWD will review project plans to assure that the project will not have any detrimental effects on watercourses, habitat or animals. Portions of the proposed project would involve grading and paving near the top of the Uvas Creek levee. A SCVWD permit may be required for all or some of the construction work at the sports park site. Project plans include the installation of a sedimentation basin near the storm drain out -fall into Uvas Creek. A grease trap may also be employ Based on comments received during the public review period the following impact statement is added to page 2 -18 of the Draft EIR: EMC Planning Group Inc. 4 -5 Changes to the Draft EIR Text Gilroy Sports Park and USA Amendment Final EIR Addendum Potentially Significant Impact— Surface Water Quality. A variety of contaminants are common to urban area storm water and irrigation run -off. These potentially result in the pollution of Uvas Creek and the Pajaro River. These 4 -6 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final RIEAddendum Changes to the Draft EIR Text Based on comments received during the public review period the following Mitigation Measure is added to page 2 -18 of the Draft EIR: out heavy storm water contaminants such as silt and grease traps suitable for filtering out other urban pollutants to the extent feasible. The sedimentation Based on comments received during the public review period the following change is made to page 2 -76 of the Draft EIR: Significant Impact —LOS Below City Standards. With completion of Phase V of the proposed project, the level of service at he intersection of Monterey Street and Monterey Frontage Road would be LOS D during the weekday PM peak hour and LOS E F during the Saturday peak hour. This level of service does not meet the standards for roadway operation as contained in the City of Gilroy General Plan. This is a significant adverse environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Based on comments received during the public review period the following impact statement is added to page 2 -76 of the Draft EIR: during the Saturday12eak hour after the completion of Phases VI ana Vu, witn With implementation of Mitigation Measure 20 in the Draft EIR, the intersection of conditions. With completion of Phase V the intersection of Monterey Road and Monterev Frontage Road will operate at LOS D during the weekday PM peak hour. The intersection will operate at LOS F during the weekday PM peak hour after the With implementation of Mitigation Measure 20 in the Draft EIR, the intersection of Monterey Road and Monterey Frontage Road will operate at LOS C during the weekday PM peak hour with an average delay of 16.7 seconds under cumulative conditions. EMC Planning Group Inc. 4-7 Changes to the Draft EIR Text Gilrou Snorts Park and USA Amendment Final EIR Addendum Implementation of Mitigation Measure 20 in the Draft EIR will be adequate to maintain LOS C or better at the intersection of Monterey Road and Monterey Frontage Road during both the weekday PM and Saturday peak hours under project build -out and cumulative conditions. No further mitigation measures are required Based on comments received during the public review period the following changes are made to pages 3 -1 and 3 -2 of the Draft EIR: The City of Gilroy is expected to make the following findings regarding the loss of prime farmland prior to approving the project: • The Gilroy Agricultural Lands Area is, at least partial mitigation for the loss of the 133.2 acres of prime farmland. • The project site is adjacent to urban uses to the north (residential) and east (commercial), and is easily accessed from U.S. Highway 101. • The sports park is a social benefit highly desired by the City of Gilroy and its citizens. • There are no alternative sites for the sports park that would not result in the conversion of prime farmland. • The project site is in a flood zone, which makes it undesirable for intensive .urban development and therefore, was available at a price the City of Gilroy could afford. Alternative sites were not available at a price affordable to the Qty-. The City could allocate sufficient funds to purchase one of the alternate sites if this were determined to be a necessary expenditure and the economic and social consequences were deemed acceptable. Based on comments received during the public review period and at the direction of the project hydrologist the following changes are made to page 3 -4 and page 3 -7 of the Draft EIR: Hydrology Urban development in the Pajaro River watershed has resulted in the covering of many acres of permeable land with impermeable surfaces such as pavement and structures. Essentially none of the rainfall that hits impervious surfaces is absorbed into the surfaces on which it falls. When rainfall lands on these impermeable surfaces, it drains on the surface and eventually into a drainage pipe or watercourse. Storm water in the Pajaro River watershed that is not absorbed into the soil or retained in reservoirs eventually makes its way into the Pajaro River. Under certain storm conditions increases in the amount of area covered in impervious materials results in increased rates of run -off into streams. The increased rate of storm water run -off can result in higher flows in streams and in a more rapid rise in streams' water levels. Increased flows in streams often result in local or widespread flooding in areas adjacent to the stream. Two major floods have EMC Planning Group Inc. Gilroy Sports Park and USA Amendment Final RIE Addendum Changes to the Draft EIR Text occurred in the lower reaches of the Pajaro River in the past several years, resulting in extensive property damage and displacement of residents. Howeverg 49fa pervious surfaces is ,.,.,ka4y hig- also. due to the location of the project site infiltration rate of 0.20 inches per hour. assumes that there is rainfall in the local area at the time that the peak flood flow occurs in Uvas Creek This represents less than 0.3 percent increase in the 10 -year flood flow of 5,500 cubic feet per second which does not overflow the channel, and an increase of 0.1 percent in the 100 -year flow of 14,000 cubic feet per second. This would not be a significant increase in the flood flows or flood elevations for Uvas Creek. For downstream areas including Pajaro River, the potential increases would be even EMC Planning Group Inc. 4-9 Changes to the Draft EIR Text Gilroy Sports Park and USA Amendment Final EIR Addendum This side intentionally left blank 4 -10 EMC Planning Group Inc. Appendix A Mitigation Monitoring Program Gilroy Sports Park and USA Amendment EIR Mitigation Monitoring Program Introduction On January 1, 1989, the California State Legislature passed into law Assembly Bill 3180. This bill requires public agencies to adopt reporting or monitoring programs when they approve projects subject to an environmental impact report or a negative declaration that includes mitigation measures to avoid significant adverse environmental effects. The reporting or monitoring program is to be designed to ensure compliance with conditions of project approval during project implementation in order to avoid significant adverse environmental effects. The law was passed in response to historic non - implementation of mitigation measures presented in environmental documents and subsequently adopted as conditions of project approval. In addition, monitoring ensures that mitigation measures are implemented and thereby provides a mechanism to evaluate the effectiveness of the mitigation measures. A definitive set of project conditions would include enough detailed information and enforcement procedures to ensure the measure's compliance. This monitoring program is designed to provide a mechanism to ensure that mitigation measures and subsequent conditions of project approval are implemented. Monitoring Program The basis for this monitoring program is the mitigation measures included in the environmental impact report. These mitigation measures are designed to eliminate or reduce significant adverse environmental effects to less than significant levels. These mitigation measures become conditions of project approval, which the project proponent is required to complete during and after implementation of the project. The measures are arranged in order according to the stage in the project in which implementation must occur. In some cases, different parts of a single mitigation measure will be implemented at different stages; in this case the measure is listed under the stage at which initial implementation occurs, and implementation times of other parts of the measure are noted. The attached checklist is proposed for monitoring the implementation of the mitigation measures. This monitoring checklist contains all appropriate mitigation measures in the environmental impact report. Gilroy Sports Park Mitigation Monitoring Program 1 Monitoring Program Procedures It is required that the City of Gilroy uses the attached monitoring checklist for the project. The monitoring program should be implemented as follows: 1. The city community development director should be responsible for coordination of the monitoring program, including the monitoring checklist. The community development director should be responsible for completing the monitoring checklist and distributing the checklist to the responsible individuals or agencies for their use in monitoring the mitigation measures. 2. Each responsible individual or agency will then be responsible for determining whether the mitigation measures contained in the monitoring checklist have been complied with. Once all mitigation measures have been complied with, the responsible individual or agency should submit a copy of -the monitoring checklist to the community development director to be placed in the project file. If the mitigation measure has not been complied with, the monitoring checklist should not be returned to the community development director. Prior to issuance of a certificate of occupancy, the community development director should review the checklist to ensure that all mitigation measures and additional conditions of project approval included in the monitoring checklist have been complied with. A certificate of occupancy should not be issued until all mitigation measures and additional conditions of project approval included in the monitoring checklist have been complied with. 4. If a responsible individual or agency determines that a non - compliance has occurred, a written notice should be delivered by certified mail to the project proponent within 10 days, with a copy to the community development director, describing the non - compliance and requiring compliance within a specified period of time. The City of Gilroy may take all actions provided in its municipal code in regards to such violations. Gilroy Sports Park Mitigation Monitoring Program 2 N Mitigation Monitoring Checklist The following table summarizes the project stages for which mitigation measures must be implemented: Implementation Stage .• MXfigahon Measures npiemented Included on project plans as appropriate la, 4,18,19, 25 Included in the final improvement plan for the Uvas Creek Trail 4,18,19, 21, 22 Prior to issuance of any permits for any phase 26, 27, 29, 30 Prior to issuance of a grading permit 1, 2, 3, 26, 27, 28, 29, 30 From 45 to 20 days prior to commencing grading activities 11 From 45 to 20 days prior to any clearing; grading construction in or adjacent to riparian habitat 11,13 Prior to removal of any significant tree(s): 5 Prior to commencement of construction activities 6,12,16,17 Prior to commencement of trail construction activities 6, 7,12,16,17 Prior to commencement of bridge construction activities 6, 8, 9,10, 12,16,17 During construction activities 14,15 Concurrent with improvements to Monterey Frontage Road 6,12,14,15,16,17, 23 Prior to completion of Phase IV of the sports park 20,24 Gilroy Sports Park Mitigation Monitoring Program 3 The following mitigation measures shall be included on project plans as appropriate: Mitt s1�Tatnre of Mtfigatian Pazjy Paxlp- gAtion Responsible for =iesponsible� Measure "� �Iuiplementatrox} £or ° Number ;f;G Monrtoringi .r.. la Project plans, subject to the review and approval of the City of City of Gilroy City of Gilroy Gilroy Planning Division shall include a sedimentation basin Engineering adequate for filtering out heavy storm water contaminants such Division and as silt, and grease traps suitable for filtering out other urban City of Gilroy pollutants to the extent feasible. The sedimentation basin and Engineering grease trap shall be designed subject to the review and approval Division of the City of Gilroy Engineering Division and shall be installed at the time that the storm water out -fall is constructed. 4 Project plans, subject to the review and approval of the City of City of Gilroy City of Gilroy Gilroy Planning Division, shall include a habitat buffer Planning designed to include appropriate native plant species and shall Division not include plantings of non - native, invasive plant species. The currently unvegetated portion of the 50foot (minimum) buffer area west of the trail shall be planted with locally - obtained native grass, shrub and riparian understory species. Wherever possible, the east side of the trail shall be planted with native grasses or other native species to provide additional native habitat before giving rise to the turf athletic fields. 18 Prior to final project approval subject to the review and City of Gilroy City of Gilroy approval of the City of Gilroy Planning Division, a lighting plan Planning for the sports park shall be developed. This lighting plan shall Division include at least the following elements: • All lighting in the western portion of the sports park will be directed away from the riparian habitat; • No lighting will be installed along the Uvas Creek Trail; and • No lighting will generally be allowed after 11:00 PM. 19 Prior to final project approval, a signage plan for the sports park City of Gilroy City of Gilroy shall be prepared to outline the language, number and location Planning of signs to dissuade people from straying off the Uvas Creek Division Trail and to prohibit unleashed dogs on the Uvas Creek trail, subject to approval by the City of Gilroy Planning Division. 25 The City of Gilroy shall include in project plans, subject to City of Gilroy City of Gilroy review and approval of the City of Gilroy Planning Division, an Planning additional 180 parking spaces to be built prior to completion of Division Phase V. Gilroy Sports Park Mitigation Monitoring Program 4 The following mitigation measures shall be included in the final improvement plan for the Uvas Creek Trail: -113iti :gation ,Measure Nurriber Nature of Mitigation e Party �, Responsible fore Implementation, ' Party fiI?esponsible. foi Momttiring; 21 The final improvement plan for the Uvas Creek Trail extension, City of Gilroy City of Gilroy subject to the review and approval of the City of Gilroy Engineering Engineering Division, shall include a connection to Thomas Division Road — Luchessa Avenue that leaves the top of the levee at a point east of Princevalle Street and connects to Thomas Road— Luchessa Avenue at the intersection of Princevalle Street via a built -up earth ramp on the levee's north embankment. 22 The final improvement plan for the Uvas Creek Trail extension, City of Gilroy City of Gilroy subject to the review and approval of the City of Gilroy Engineering Engineering Division, shall include cross walks across Thomas Division Road — Luchessa Avenue at Princevalle Street and stop signs on Thomas Road — Luchessa Avenue at Princevalle Street. Gilroy Sports Park Mitigation Monitoring Program 5 The following mitigation measures shall be implemented prior to issuance of any permits for any phase: Mitr gation illeasure Number Nature of;Mtrgafion .° _ `; 'i Party Responsrble for Irnplementatzon 'Party, , Responsible.: for Monrtoriig 26 The following dust control measures shall be incorporated into City of Gilroy City of Gilroy all permits for any phase of the project. The measures shall be Planning implemented as necessary to adequately control dust subject to Division the review and approval of the City of Gilroy Planning Division. • Water all active construction areas at least twice daily; • Cover all trucks hauling, soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard; • Pave, apply water three times daily, or apply (non- toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites; • Sweep daily (with water sweepers) all paved access roads, parking areas and staging areas at construction sites; • Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets; • Hydroseed or apply (non- toxic) soil stabilizers to inactive construction areas (previously graded areas inactive for ten days or more); • Enclose, cover, water twice daily or apply (non- toxic) soil binders to exposed stockpiles (dirt, sand, etc.); • Limit traffic speeds on unpaved roads to 15 mph; • Install sandbags or other erosion control measures to prevent silt runoff to public roadways; • Replant vegetation in disturbed areas as quickly as possible; • Install wheel washers for all existing trucks, or wash off the tires or tracks of all trucks and equipment leaving the site; • Install wind breaks, or plant trees/ vegetative wind breaks at windward side(s) of construction areas; • Suspend excavation and grading activity when winds (instantaneous gusts) exceed 25 miles per hour; • Limit the area subject to excavation, grading and other construction activity at any one time. Gilroy Sports Park Mitigation Monitoring Program 6 27 The following language shall be included on any permits issued for the sports park, subject to the review and approval of the City of Gilroy Engineering Division. "All noise generating construction activities shall be limited to weekdays between 7:00 AM and 7:00 PM, and to Saturdays and City holidays between 9:00 AM and 7:00 PM. No construction is allowed on Sundays. In addition, temporary berms or noise attenuation barriers shall be utilized when necessary." City of Gilroy City of Gilroy Engineering Division 29 Due to the possibility that significant buried cultural resources City of Gilroy City of Gilroy might be found during construction the following language Planning shall be included any permits issued for the project site, Division including, but not limited to building permits for future development, subject to the review and approval of the Gilroy Planning Division: If archaeological resources or human remains are discovered during construction, work shall be halted at a minimum of 200 feet from the find and the area shall be staked off. The project developer shall notify a qualified professional archaeologist. If the find is determined to be significant, appropriate mitigation measures shall be formulated and implemented. 30 In the event of an accidental discovery or recognition of any City of Gilroy City of Gilroy human remains in any location other than a dedicated Planning cemetery, the City shall ensure that this language is included Division in all permits in accordance with CEQA Guidelines section 15064.5(e): If human remains are found during construction there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie - adjacent human remains until the coroner of Santa Clara County is contacted to determine that no investigation of the cause of death is required. If the coroner determines the remains to be Native American the coroner shall contact the Native American Heritage Commission within 24 hours. The Native American Heritage Commission shall identify the person or persons it believes to be the most likely descendent from the deceased Native American. The most likely descendent may then make recommendations to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and associated grave goods as provided in Public Resources Code Section 5097.98. Gilroy Sports Park Mitigation Monitoring Program 7 The following mitigation measures shall be implemented prior to issuance of a grading permit (this may be required at each phase for mitigation measures 2,3 and 28): M�ti The landowner or his authorized representative shall Party Party° gation_ rebury the Native American human remains and Responsible fvr ;Lesponsrblee a Measure associated grave goods with appropriate dignity on Cmplemeatation for Number the property in a location not subject to further ; °Mortrtorrng;" 1 disturbance if: a) the Native American Heritage City of Gilroy City of Gilroy Commission is unable to identify a most likely Engineering descendent or the most likely descendent failed to Division and make a recommendation within 24 hours after being SCV WD notified by the commission; b) the descendent identified fails to make a recommendation; or c) the landowner or his authorized representative rejects the 2 recommendation of the descendent, and the mediation City of Gilroy City of Gilroy by the Native American Heritage Commission fails to Engineering provide measures acceptable to the landowner. Division and The following mitigation measures shall be implemented prior to issuance of a grading permit (this may be required at each phase for mitigation measures 2,3 and 28): M�ti Natre of Nlingation Party Party° gation_ : _ ", Responsible fvr ;Lesponsrblee a Measure - Cmplemeatation for Number ; °Mortrtorrng;" 1 The City shall have a hydrology report prepared for the project City of Gilroy City of Gilroy by a qualified hydrologist or engineer, to address hydrology- Engineering related design requirements for the site and buildings, subject Division and to the review and approval of the City of Gilroy Engineering SCV WD Division and SCVWD prior to issuance of a grading permit. All grading, design or other recommendations of this report shall be incorporated into project plans. 2 The City shall, for each phase of the project, submit a Notice of City of Gilroy City of Gilroy Intent (NOI) and detailed engineering designs to the Central Engineering Coast RWQCB. This permit shall require development and Division and implementation of a SWPPP that uses storm water 'Best RWQCB Management Practices" to control runoff, erosion and sedimentation from the site. The SWPPP must include Best Management Practices that address source reduction and, if necessary, shall include practices that require treatment. The SWPPP shall be submitted to the City of Gilroy Engineering Division for review and approval prior to approval of a grading permit for each phase of the project. 3 The City shall submit plans for review by, and obtain an City of Gilroy SCVWD approved permit from the Santa Clara Valley Water District ( SCVWD) prior to approval of a grading permit for each phase of the project. 28 The City shall contract with a qualified archaeologist to City of Gilroy City of Gilroy arrange a schedule for monitoring during grading and Planning excavation activities due to the project site's creek -side location Division and proximity to recorded historic and prehistoric sites. Gilroy Sports Park Mitigation Monitoring Program 8 The following mitigation measure shall be implemented from 45 to 20 days prior to commencing grading activities: Mitr a- gatron lYleasure _ 1Vumber - Nature,dfi.Mitigakitrnr "" Party , Responsible fora Iinplernentatior Perky Responsible•' fob Iyloniforiag` 11 Subject to the review of the City of Gilroy Planning Division, City of Gilroy City of Gilroy no earlier than 45 days and no later than 20 days prior to Planning commencement of grading or construction on or adjacent to Division the slope of the levee, field surveys shall be conducted at least four consecutive evenings by a qualified biologist to determine if burrowing owls are present in the construction zone or within 250 feet of the construction zone. These surveys shall be required only if any construction would occur during the nesting and /or breeding season of burrowing owls potentially nesting in the area (February 1 through August 31) and /or during the winter residency period (December 1 and January 31). Pre - construction survey results shall be submitted to the California Department of Fish and Game for review and approval. If active nests are found in within the survey area, a burrowing owl habitat mitigation plan shall be submitted to the California Department of Fish and Game for review and approval. The burrowing owl habitat mitigation plan shall contain mitigation measures contained in the California Department of Fish and Game Staff Report on Burrowing Owl Mitigation (California Department of Fish and Game 1995). Compliance with this mitigation measure may include, but not be limited to, the following: • Avoidance of occupied burrows during the nesting season (February 1 through August 31); • Acquisition, protection and funding for long -term management and monitoring of foraging habitat adjacent to occupied habitat; • Enhancement of existing burrows and /or creation of new burrows; • Passive relocation of burrowing owls. Sports Park Mitigation Monitoring Program The following mitigation measure shall be implemented from 45 to 20 days prior to any clearing, grading construction in or adjacent to riparian habitat: MI :gation `Measure Number. Nature 'of Mitigation "� at Responsible for Implementation Responsi)}le'r Monrtosing:; 13 Subject to the review of the City of Gilroy Planning Division, City of Gilroy City of Gilroy no earlier than 45 days and no later than 20 days prior to Planning commencement of clearing, grading or construction in or Division adjacent to any riparian habitat, a field survey shall be conducted by a qualified biologist to determine if active raptor nests are present in the construction zone or within 250 feet of the construction zone. These surveys shall be required only if any construction would occur during the nesting and /or breeding season of raptors potentially nesting in the areas proposed for development (generally March 1 through August 1). If active nests are found within the survey area, at the discretion of the biologist, clearing and construction within 250 feet shall be postponed or halted until the nests are vacated and juveniles have fledged and there is no evidence of a second attempt at nesting. The following mitigation measure shall be implemented prior to removal of any significant tree(s): lVlifr L gafinn Measure Number ° Nature of Mitrgatton"e: ", } Party eposble fo fi Impleinentahon Paxtya. ible: , fork N "Monitoring.;, 5 Prior to the removal of any significant tree(s), a field survey City of Gilroy City of Gilroy shall be conducted by a certified arborist to determine the Planning number and location of each significant tree to be removed, the Division type and approximate size of each significant tree, and the reason for removal. These findings shall be included in a written report that contains specifications for replacing significant trees to be removed. The written report shall be prepared prior to the commencement of grading activities that take place along the north side of Thomas Road— Luchessa Avenue, along the north side of Mesa Road, and through the riparian habitat leading to and from the proposed pedestrian bridge, subject to approval by the City of Gilroy Planning Division. Gilroy Sports Park Mitigation Monitoring Program 10 The following mitigation measures shall be implemented prior to commencement of construction activities (Additional mitigation measures also apply to particular phases of construction): Mitr Nature » "ofMrtigatron Party Party gatron Responstble fan ox Respousible', , Wasure Implementatr for Number, MoWtonng 6 Prior to the commencement of construction activities, the City of Gilroy City of Gilroy protected zone (one to 1.5 times the distance from the trunk to Planning the dripline, depending on the tree species) of any trees or Division groups of trees to be retained shall be fenced to prevent injury to the trees during construction. Soil compaction, parking of vehicles or heavy equipment, stockpiling of construction materials, and /or dumping of materials shall not be allowed within the protected zone. The fencing shall remain in place until all construction activities are complete. The trees or groups of trees to be fenced shall be indicated in a written report prepared subject to approval by the City of Gilroy Planning Division. 12 Prior to commencement of construction activities, the city shall City of Gilroy City of Gilroy arrange for a qualified biologist to inform workers of the Planning potential presence of the all special - status species, their Division protected status, work boundaries, and measures to be implemented to avoid loss of these species during construction activities. 16 Prior to the commencement of construction activities, a plan City of Gilroy City of Gilroy shall be prepared to allow a prompt and effective response to Engineering any accidental spills, and all workers shall be informed of the Division importance of preventing spills and of the appropriate measures to take should a spill occur, subject to approval by the City of Gilroy Engineering Division. This plan shall specify that all staging areas and all fueling and maintenance of vehicles and other equipment shall occur at least 100 feet from the riparian habitat and Uvas Creek. 17 Prior to approval of construction plans, guidelines shall be City of Gilroy City of Gilroy established for the prevention of contamination of the creek by Engineering pesticides, herbicides, fungicides, and fertilizers from Division maintenance of the athletic fields, subject to the review and approval of the City of Gilroy Engineering Division. The guidelines shall include a requirement for oil /grease separators to be installed in on -site storm drain systems and sweeping ro rams to be implemented for parking lots. Gilroy Sports Park Mitigation Monitoring Program 11 The following mitigation measure shall be implemented prior to commencement of trail construction activities: �Mitx ga tion' Measure Number Nature "of, Mitigation" - j ParEp Responsible for uiplementatxon ' , Paftp ; e Ropbnsible` - ,lVloriitorit g, 7 Prior to commencement of trail construction activities the City City of Gilroy City of Gilroy of Gilroy Planning Division shall have a qualified biologist Planning prepare a Habitat Mitigation Plan for approval by the City of Division Gilroy and the California Department of Fish and Game. The Habitat Mitigation Plan shall identify the exact amount and location of impacted and replacement habitat, and shall specify the use of locally - obtained native riparian species. Any loss of riparian woodland vegetation resulting from Uvas Creek trail construction activities shall be mitigated on -site within the 50- foot (minimum) habitat buffer at a minimum 3:1 replacement ratio. The following mitigation measures shall be implemented prior to commencement of bridge construction activities: lYIih gatian Measure :Number Nature of 14Itigatxon':' ' Party es R onsible fnr P. °Ixriplexrientatxon , Party „tes`ons�ble` P Monxtorxng`q 8 Prior to the commencement of bridge construction activities, a City of Gilroy CA Dept. of Section 1603 Streambed Alteration Agreement shall be Fish and obtained from the California Department of Fish and Game. Game Compliance with this mitigation measure may include, but not be limited to, the following: • Bridge construction work shall be initiated and completed during the summer and fall months when this portion of the creek is dry, or at least has a very low flow. Typically, no construction work shall be allowed in the creek between October 15 and early June. • From June to October 15, when construction is allowed, if any water is flowing in the creek, the flow shall be diverted into an open, gravel -lined bypass channel for the duration of the bridge construction work. Gilroy Sports Park Mitigation Monitoring Program 12 9 Prior to commencement of bridge construction activities the City of Gilroy U.S. Army 14 City shall contact the U.S. Army Corps of Engineers to City of Gilroy Corps of determine who has jurisdiction over the bridge construction Engineers activities and if a permit is required for bridge construction. Division 10 Prior to commencement of construction activities, siltation City of Gilroy City of Gilroy fencing or hay bales shall be installed along portions of Uvas Engineering Creek within 100 feet of construction and /or staging areas, or Division other erosion control measures shall be implemented to prevent sediment from filling the creek, subject to approval by 15 the City of Gilroy Engineering Division. City of Gilroy City of Gilroy The following mitigation measures shall be implemented during construction activities: ?lt3itt gation ": Wasure, Number s Nature of ,Mzhgattgn * k `' y l` • .." r' Party Responsrble# fora Implementation. m _ '' Party ' Responsible for M'0 t'oring 14 Subject to the review of the City of Gilroy Planning Division, a City of Gilroy City of Gilroy qualified biologist shall monitor the project site during Planning construction activities within 100 feet of Uvas Creek. If Division California red - legged frog, foothill yellow - legged frog, western spadefoot toad, California tiger salamander, and /or western pond turtle turtles are observed at the site, construction activities shall be halted and the USFWS shall be contacted for further assistance. 15 Alf food - related trash items shall be enclosed in sealed City of Gilroy City of Gilroy containers and regularly removed from the project area to Community deter attraction of potential predators of the California red- Development legged frog, foothill yellow - legged frog, western spadefoot Department toad, California tiger salamander, and western pond turtle. Pets shall not be allowed on the construction site. The proper location of the trash containers shall be subject to the review and approval of the City of Gilroy Community Development Department. Gilroy Sports Park Mitigation Monitoring Program 13 The following mitigation measures shall be implemented concurrent with improvements to Monterey Frontage Road: Mti= gation ' . Measure Number Nature of Mitigation "* Party '. Responsible for., Implementation Party, ; Responsible' for ' Monitoring ; 23 The City of Gilroy shall include a Class 1 path on the west side City of Gilroy City of Gilroy or Class H bicycle lanes on both sides of Monterey Frontage Engineering Road as a part of the design and construction of improvements Division to Monterey Frontage Road between Monterey Street and the sports park access road. The path or bicycle lanes shall be constructed at the same time as other planned improvements to these roads are made, subject to the review and approval of the City of Gilroy Engineering Division. The following mitigation measures shall be implemented prior to completion of Phase IV of the sports park: Miti- gation" Measure Number. 'Nature of Mitigation _ n Party Responsible "for Implementation° Party., Responsible` . for Monitoring,' 20 Prior to completion of Phase IV of the proposed project the City of Gilroy City of Gilroy City of Gilroy shall install a traffic signal at the intersection of Engineering Monterey Street and Monterey Frontage Road. The minimum Division lane configuration shall be: • Southbound Approach - one left -tum lane, one through lane, one shared through /right -turn lane; • Westbound Approach - one shared lane for all movements; • Northbound Approach - one left -turn lane, one through lane, one shared through /right -turn lane; • Eastbound Approach - one shared lane, one left -turn lane for all movements. Protected left -tum phasing shall be provided for the northbound and southbound approach, while a single signal phase shall be provided to serve the eastbound and westbound approaches. 24 Prior to completion of Phase IV of the proposed project the City of Gilroy City of Gilroy City of Gilroy shall construct a minimum 6 -foot wide sidewalk Engineering along the west side of Monterey Frontage Road and a Division minimum 10 -foot wide sidewalk along Monterey Street between Thomas Road— Luchessa Avenue and the sports park access road. Gilroy Sports Park Mitigation Monitoring Program 14 GILROY SPORTS PARK AND URBAN SERVICE AREA AMENDMENT (USA 98 -01) DRAFT ENVIRONMENTAL IMPACT REPORT City of Gilroy February 1999 Gilroy Sports Park and Urban Service Area Amendment Draft Environmental Impact Report SCH # 98102079 Prepared for: City of Gilroy 7351 Rosanna Street Gilroy, California 95020 (408) 846 -0440 Mr. William A. Headley, Jr. Facilities and Parks Development Manager February 1999 Prepared by: 99 Pacific Street, Suite 155F Monterey, California 93940 Phone: (831) 649 -1799 Fax: (831) 649 -8399 E -Mail: emcgroup@emcplanning.com Table of Contents Summary............................................................ ............................... S -1 ProposedProject ......................................................................... ............................S -1 Summaryof Impacts and Mitigation Measures ................... ............................5 -2 iSummary of Other CEQA Considerations ............................ ............................5 -2 Summaryof Alternatives Analysis ......................................... ............................5 -4 1.0 Ini 1.1 1.2 1.3 1.4 1.5 r. 1.6 roduction................................................. ............................1 -1 Authorizationand Purpose ............................................. ............................1 -1 ProjectLocation .................................................................. ............................1 -2 ProjectDescription ............................................................ ............................1 -2 ProjectObjectives .............................. ............................... ...........................1 -20 Consistency With Local and Regional Plans ............... ...........................1 -25 EIRUses ............................................................................. ...........................1 -44 2.0 Environmental Setting, Impacts and Mitigation Measures...... 2 -1 2.1 Agricultural Considerations ........................................................................2- 2.2 Geology ............................................................................... ............................2 -9 2.3 Hydrology .......................................................................... ...........................2 -10 2.4 Public Services and Service Systems ............................ ...........................2 -18 2.5 Biological Resources ......................... ............................... ...........................2 -25 2.6 Transportation / Circulation ............................................. ...........................2 -47 2.7 Air Quality ......................................................................... ...........................2 -79 2.8 Noise ................................................................................... ...........................2 -84 2.9 Archaeological Resources ............................................... ...........................2 -91 2.10 Aesthetics ............................................ ............................... ...........................2 -94 2.11 Issues Determined to Have Less Than Significant Impacts .............2 -100 3.0 Related Environmental Issues 3.1 Unavoidable Significant Adverse Environmental Impacts ..................3 -1 3.2 Cumulative Impacts .......................................................... ............................3 -2 3.3 Significant Irreversible Environmental Changes ....... ............................3 -9 3.4 Growth Inducing Impacts ................................................ ............................3 -9 3.5 Alternatives ......................................................................... -9 ............................3 4.0 Bibliography and Project Team .................... ............................4 -1 4.1 Persons Contacted ............................................................. ............................4 , -1 4.2 Literature Cited .................................................................. -1 ............................4 4.3 Project Team ....................................................................... ............................4 -3 Technical composite is available under a separate cover. List of Figures n Figure1 Regional Location ........................................................... ............................1 -3 Figure 2 Project Vicinity ............................................................... ............................1 -5 Figure3 Site Photos ....................................................................... ............................1 -7 Figure 4 Existing Land Uses ........................................................ ...........................1 -11 Figure5 General Plan Designations .......................................... ...........................1 -13 Figure 6 Project Site and Relation to Existing Urban Service Area ................1 -15 Figure7 Preliminary Master Plan .............................................. ...........................1 -17 Figure 8 Gilroy Sports Park Phasing Plan ................................ ...........................1 -21 Figure 9 Uvas Creek Trail Extension ......................................... ...........................1 -23 Figure 10. Farmland Designations ................................................. ............................2 -3 a I • Figure 11 Flood Zone Designations ............................................. ...........................2 -13 Figure 12 Recycled Water Distribution Line .............................. ...........................2 -21 Figure13 Habitat Types ................................................................. ...........................2 -27 Figure 14 Current Conditions Along Uvas Creek ..................... ...........................2 -37 Figure 15 Proposed Conditions Along Uvas Creek .................. ...........................2 -39 Figure 16 Existing Transportation Network ............................... ...........................2 -49 Figure 17 Existing Weekday PM and Saturday Peak Traffic Volumes ...........2 -53 Figure 18 Existing Intersection Lane Configurations ............... ...........................2 -55 Figure19 Background Traffic Volumes ...................................... ...........................2 -59 Figure 20 Trip Distribution Patterns ........................................... ...........................2 -67 Figure 21 Peak Hour Project - Related Trips ................................ ...........................2 -69 Figure 22 Project Conditions Traffic Volumes .......................... ...........................2 -71 Figure23 Noise Exposure Study Locations ................................ ...........................2 -89 Figure 24 Existing Character of Project Site ............................... ...........................2 -97 Figure25 Cumulative Projects ....................................................... ............................3 -5 Figure 26 Alternative Site Locations ............................................ ...........................3 -11 List of Tables Table S -1 Summary of Impacts and Mitigation Measures ....... ............................S -6 Table 1 Assessor's Parcels in Amendment Request .............. ...........................1 -10 Table 2 Gilroy Sports Park Proposed Phasing Plan .............. ...........................1 -19 Table 3 Potential Special - Status Species ................................. ...........................2 -30 Table 4 Two -Way Stop - Controlled Intersection Level of Service Definitions Using Average Total Vehicular Delay Estimates ......... 2-52 Table5 Exisitng Intersection Levels of Service ..................... ...........................2 -57 Table 6 Approved Developments in the Vicinity of the Project Site ........... 2-57 Table 11 Parking Demand and Supply ..................................... ...........................2 -75 Table 12 Projected Sports Park Air Quality Impacts — URBEMIS7 ModelingResults .......................................................... ...........................2 -81 Table 13 > Athletic Event Noise Exposure ................................... ...........................2 -86 Table 14 Projected Residential Noise Exposure from Athletic Events ........... 2 -88 Table 15 Approved Developments in the Vicinity of the Project Site .............3 -4 Table 16 Cumulative Conditions Intersection Levels of Service ......................3 -8 Table 17 Summary of Environmental Effects of Proposed Project and Alternatives...................................... ............................... ...........................3 -26 Table 18 Comparison of Environmental Effects of Alternatives to .,.' Proposed Project ............................................................ ...........................3 -27 Table 7 Background Intersection Levels of Service .............. ...........................2 -58 Table8 Trip Generation Estimates ........................................... ...........................2 -62 Table 9 Background Plus Sports Park Intersection Levels of Service .......... 2 -64 Table 10 Background Plus. Sports Park Freeway Segment Analysis ..............2 -65 i! Table 11 Parking Demand and Supply ..................................... ...........................2 -75 Table 12 Projected Sports Park Air Quality Impacts — URBEMIS7 ModelingResults .......................................................... ...........................2 -81 Table 13 > Athletic Event Noise Exposure ................................... ...........................2 -86 Table 14 Projected Residential Noise Exposure from Athletic Events ........... 2 -88 Table 15 Approved Developments in the Vicinity of the Project Site .............3 -4 Table 16 Cumulative Conditions Intersection Levels of Service ......................3 -8 Table 17 Summary of Environmental Effects of Proposed Project and Alternatives...................................... ............................... ...........................3 -26 Table 18 Comparison of Environmental Effects of Alternatives to .,.' Proposed Project ............................................................ ...........................3 -27 r_ Summary Proposed Project The proposed project consists of three primary components: an Urban Service Area amendment request to Santa Clara County Local Agency Formation Commission (LAFCO) and annexation to the City of Gilroy; approval of a Park Master Plan and development of the Gilroy Sports Park and commercial recreation building; and construction of off -site improvements including the extension of the Uvas Creek Trail from Thomas Road — Luchessa Avenue south to Gavilan Community College (including a pedestrian /bicycle bridge over Uvas Creek), extension of the City's recycled water distribution line to the sports park, and roadway improvements. The project site is located on the south end of Gilroy at the southwest comer of Monterey Street and Thomas Road — Luchessa Avenue. It is bordered by Thomas Road— Luchessa Avenue to the north, Uvas Creek and Farman Lane to the south, Monterey Street and Monterey Frontage Road to the east, and Uvas Creek to the west. Surrounding land uses are residential (single- family and rural), commercial (hotels under construction), and agricultural (row crops and greenhouses). U.S. Highway 101 is located to the east of the project site. The entire 133.2 -acre project site is proposed for inclusion into the City's Urban Service Area, and annexation to the City. This would include the 78.4 -acre sports park site and 54.8 acres of adjacent parcels to the east and north. The sports park is the only project proposed for development at this time within the Urban Service Area amendment request. The adjacent parcels are not proposed for development. This EIR assumes these parcels will remain in open space. Any proposed development on these parcels will require further environmental review. Preliminary plans for the proposed sports park include the following components: recreational play fields (eight softball diamonds and four soccer fields and concession / restrooms); premier play fields (one 90 -foot baseball diamond, two Little League diamonds and one soccer field and concession / restrooms); competition play fields (one softball /baseball diamond and one soccer field and concessions and restrooms); 8.8 acres of park preserve with family picnic, concessions and restrooms, volleyball and bocci ball courts, horseshoe pits and play area; commercial recreation building (indoor soccer, roller hockey, community building, storage); corporation yard; parking (1,043 spaces); and a night watch park ranger station. Soccer fields overlay baseball/ softball fields. Football may also be played on the soccer fields. The athletic fields would have lighting for night games, a public address system and seating. The sports park and related off -site improvements would be constructed in phases over a 20 -year period. EMC Planning Group Inc. S-1 Summary Gilroy Sports Park and USA Amendment EIR Summary of Impacts and Mitigation Measures Pursuant to CEQA Guidelines section 15063 an initial study was prepared to determine the potentially significant effects of the proposed project. The initial study determined that certain issues would have a potentially significant impact on the environment. These issues concerned agricultural considerations, geology, hydrology, public services and service systems, biological resources, transportation/ circulation, air quality, noise, archaeological resources, and aesthetics. The initial study determined that there would be a less than significant impact concerning population and housing and energy. Those issues determined to have a potentially significant environmental impact were studied in greater depth in this EIR. Environmental impacts and proposed mitigation measures for the proposed project are presented in Table S -1. Summary of Other CEQA Considerations Unavoidable Significant Adverse Environmental Impacts An unavoidable significant adverse environmental impact is a significant adverse impact that cannot be reduced to a less than significant level through the - implementation of mitigation measures. CEQA Guidelines section 15093 requires that a lead agency make findings of overriding considerations for unavoidable significant adverse environmental impacts before approving a proposed project. The loss of prime farmland is generally considered a significant and unavoidable adverse environmental impact. The proposed project would result in the loss of the 133.2 acres of prime farmland (though some of this land is used for commercial and residential farm - related uses). The establishment of the Gilroy Agricultural Lands Area by both the City of Gilroy and the County of Santa Clara serves as a regional mitigation for losses of prime farmland in southern Santa Clara County, outside of the agricultural lands area. Although this regional mitigation has been implemented, it does not reduce the loss of prime farmland to a less than significant level and the proposed project would still be considered to have a significant and unavoidable impact on prime farmland. Cumulative Impacts Cumulative impacts are those environmental impacts resulting from the cumulative effects of approved but not yet built projects and probable projects in the area of the proposed project. Cumulative impacts were based on projects in the southern part of Gilroy. Cumulative impacts were identified concerning agricultural considerations, hydrology, transportation/ circulation and air quality. S -z EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Summary Agricultural Considerations - The proposed project would add 133.2 acres of prime farmland to the City of Gilroy Urban Service Area. Land within the Urban Service Area is generally expected to be developed within an approximate five -year timeframe. Prime farmland is a non - replaceable resource. Each cumulative project that involves the conversion of prime farmland to non - agricultural uses contributes to the depletion of this resource. Hydrology Development of previously undeveloped land results in the covering of permeable soil with impermeable pavement and structures. The proposed project along with other proposed development will result in an increase in the amount of currently permeable land that is covered by impermeable surfaces. Under certain weather conditions increases in the amount of area covered in impervious materials can result in increased rates of storm water run -off into streams. The increased rate of _ storm water run -off can result in higher flows in streams, in a more rapid rise in streams' water levels and can potentially result in local or widespread flooding in areas adjacent to the stream. However, during flood conditions it is likely that the increase in run -off would be less than significant because under these conditions run -off from pervious surfaces is typically high also. Transportation/Circulation A traffic impact assessment prepared for the proposed project determined that the increase in traffic associated with the proposed project and other proposed or existing development would result in traffic congestion at one intersection. The cumulative conditions level of service at the intersection of Monterey Street and Monterey Frontage Road would be below the standards prescribed by the City of Gilroy General Plan. A mitigation measure in Section 2.6 Transportation/ Circulation would require the installation of a signal light at this intersection prior to completion of Phase IV of the proposed sports park. With implementation of this mitigation measure the proposed project would not result in a significant cumulative traffic impact. Air Quality The San Francisco Bay Area is designated by the U.S. EPA as a non - attainment area for the national ozone standard. The region has had recent violations of the national ambient air quality standard for ozone. The State Implementation Plan (SIP), a compilation of plans and regulations that govern how the region compiles with the Federal Clean Air requirements is being revised. The 1999 SIP will identify how the region will attain the national air quality standard for ozone in the future. The addition of the vehicular trips and associated emissions from the proposed project and other proposed and existing development in the area would contribute to cumulative air quality impacts in a non - attainment area. r EMC Planning Group Inc. S -3 Summary Gilroy Sports Park and USA Amendment EIR Significant Irreversible Environmental Changes The proposed project would result in the permanent loss of prime agricultural land. While this loss is mitigated in part by the establishment of the Gilroy Agricultural Lands Area, the prime agricultural land lost to the proposed project is not ` replaceable. The loss of prime agricultural land would be a significant irreversible change. Growth Inducing Impacts Growth inducement generally refers to the likelihood that a proposed project will foster growth in the surrounding area, either directly or indirectly. The most common factor in fostering growth is the removal of obstacles to population or economic growth. The proposed project would require the extension of a recycled water distribution line. Recycled water is used primarily for irrigation of large park or open space areas, and extension of this line would not be likely to induce concentrated urban growth. All other infrastructure is currently available near the project site. The project site is currently within the City of Gilroy 20 -year development area. The proposed project would transfer the project site into the Urban Service Area. Development within Urban Service Areas is generally expected to occur within an approximate five -year timeframe. Development of those parcels that are not part of the proposed sports park could be hastened by the development of the sports park. The proposed project could have growth inducing impacts on the project site and possibly on adjacent areas. Summary of Alternatives Analysis Four alternatives to the proposed project were analyzed to determine if they would achieve project objectives while minimizing environmental impacts. The " No Project' alternative would maintain the area in its current use and no Urban Service Amendment, annexation or sports park and related development would take place. Three alternative locations were also studied: Santa Teresa Boulevard at State Highway 152; Santa Teresa Boulevard and Miller Avenue; and Monterey Road at Bolsa Road. The 'No Project" alternative is the environmentally superior alternative, because it J eliminates the unavoidable significant impact of loss of prime farmland. However, the 'No Project" alternative does not achieve project objectives of providing the community with additional athletic fields and parkland. The proposed project has beneficial biological impacts that would not be achieved with the 'No Project" alternative. The remaining alternatives and the proposed project are all S -4 EMC Planning Group Inc. I U 1) Gilrou Svorts Park and USA Amendment EIR Summa approximately equal in terms of their environmental impacts, and the selection of one alternative as the environmentally superior is based on very fine shades of interpretation. Though very close to the other remaining alternatives and the proposed project in terms of its environmental effects, the Santa Teresa Boulevard and Miller Avenue alternative is the environmentally superior alternative among the remaining alternatives. The principal factor that favors this alternative is its reduced impact on prime farmland compared to the other alternative locations. However, this alternative may result in traffic impacts that could be difficult to mitigate. EMC Planning Group Inc. S -5 TABLE S -1 Summary of Impacts and Mitigation Measures Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual I Impact Agricultural Loss of Prime Farmland. Unavoidable N/A The establishment of the Gilroy Unavoidable Considerations Development of the sports park Significant Agricultural Lands Area by both the City Significant would result in the loss of 78.4 of Gilroy and the County of Santa Clara acres of prime farmland serves as a regional mitigation for losses identified in the Farmland of prime farmland in southern Santa Mapping and Monitoring Program Clara County outside of the agricultural over the 20 -year build -out of the lands area. Although this regional proposed sports park. mitigation has been implemented, it does not reduce the loss of prime farmland to a Loss of Prime Farmland less than significant level and the Approval of the Urban Service proposed project would still be considered Area amendment and to have a significant and unavoidable development of parcels adjacent impact on prime farmland. to the sports park site could ultimately result in the loss of the remaining 54.8 acres of designated farmland within the project site. Agricultural Conflict With Williamson Act No N/A None No Considerations Contract. Four of the parcels on Impact Required Impact the project site were under Williamson Act contract. Notices of non - renewal were filed and the contracts expired January 1, 1999. Area of Concern Impact Level of Mitigation Mitigation Measure I Residual Si nificance Number Impact Agricultural Effect on Adjacent Agricultural No N/A None No Considerations Uses. Implementation of the Impact Required Impact proposed project would not affect agricultural operations off the project site. Geology Seismic Hazards. The proposed Less Than N/A None Less Than project exposes people or structures Significant Required Significant to a small risk of potential substantial adverse effects involving seismic hazards. Hydrology Storm Water Run -off. Storm Less Than N/A None Less Than water run -off from access roads, Significant Required Significant parking lots and pathways could increase the rate of storm water discharge into Uvas Creek and the Pajaro River drainage during some weather conditions. Hydrology On -Site Flood Flowage. SCVWD Potentially 1 The City shall have a hydrology report Less Than holds a flood flowage easement Significant prepared for the project by a qualified Significant that restricts land use and hydrologist or engineer, to address development on a large portion of hydrology - related design requirements the project site. Inappropriate for the project site and buildings. development within this easement could put structures at risk of damage and people at risk of injury or death from storm - related flooding. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Hydrology Surface Water Quality. During Significant 2 The City shall submit a Notice of Intent Less than construction, grading will expose and detailed engineering designs to the Significant sediments to rain or wind erosion Central Coast Regional Water Quality and subsequent transportation of Control Board, and implement a Storm sediments to the Uvas Creek, Water Pollution Prevention Plan that uses Pajaro River and Monterey Bay. storm water 'Best Management Practices" Materials used and wastes to control nmoff, erosion and generated during construction sedimentation from the site. would degrade water quality also. Development of the project 3 The City shall submit plans for review would generate non -point source by, and obtain an approved permit from pollutants from newly the Santa Clara Valley Water District. established urban activity at the project site. Public Services Construction of New Less Than N/A None Less Than and Service Infrastructure. The proposed Significant Required Significant Systems project does not require substantial extensions or upgrades to the existing potable water supply, wastewater or storm drain infrastructure. Public Services Water Supply. The proposed No N/A None No and Service project would result in a minimal Impact Required Impact Systems increase in demand for potable water. The proposed project would increase demand for recycled water for irrigation. wo — — - Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Public Services Police and Fire Services. The No N/A None No and Service proposed project does not result in Impact Required Impact Systems the need for additional facilities for the provision of police or fire services. Biological Loss of Habitat. Due to continuous No N/A None No Resources human interaction, agricultural Impact Required Impact fields typically provide little habitat for wildlife and do not represent a significant biological resource. Biological Riparian Buffer. The proposed Beneficial N/A None Beneficial Resources 50 -foot habitat buffer will Required substantially increase the amount of native habitat along Uvas Creek. Biological Invasive Plant Species. The Significant 4 Project plans shall include a habitat Less Than Resources riparian habitat along Uvas buffer designed to include appropriate Significant Creek could be affected by the native plant species and shall not include presence of non - native, invasive plantings of non - native, invasive plant plant species. species. Wherever possible, the east side of the trail shall be planted with native grasses or other native species to provide additional native habitat. E� Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure I Residual I Impact Biological Loss of Significant Trees. Some of Potentially 5 A field survey shall be conducted to Less Than Resources the trees along the north side of Significant determine the number type, size and Significant Thomas Road — Luchessa Avenue, location of any potentially significant along the north side of Mesa tree to be removed. Road, and through the riparian habitat leading to and from the 6 The protected zone (one to 1.5 times the proposed pedestrian bridge may distance from the trunk to the dripline, be considered "significant" trees depending on the tree species) of any trees that might be removed or injured or groups of trees to be retained shall be during construction activities. fenced to prevent injury to the trees during construction. Biological Riparian Habitat. Construction Potentially 7 A Habitat Mitigation Plan shall be Less Than Resources of the pedestrian bridge over Significant prepared to identify the exact amount and Significant Uvas Creek could disturb riparian location of impacted and replacement woodland habitat. habitat, and shall specify replacement specifications for any removed habitat. 10 Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure Residual Impact Biological Riparian Habitat. Construction Significant 8 A Section 1603 Streambed Alteration Less Than Resources of the pedestrian bridge over Agreement shall be obtained from the Significant Uvas Creek could introduce fill California Department of Fish and Game. material into the creek and /or Construction activities in or adjacent to increase turbidity in the creek and Uvas Creek to occur when the creek is dry interfere substantially with the or has a very low flow (generally June movement of steelhead as well as through October 15). other fish and aquatic wildlife. 9 The City shall contact the U.S. Army Corps of Engineers to determine who has jurisdiction over the bridge construction activities and if a permit is required for bridge construction. 10 Erosion control measures shall be installed along portions of Uvas Creek to prevent sediment from filling the creek. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure I Residual I Impact Biological Burrowing Owls. Construction Potentially 11 Field surveys shall be conducted to Less Than Resources activity along the slope of the Significant determine if burrowing owls are present in Significant levee in the northwest corner of the construction zone or within 250 feet of the project site, could result in the the construction zone if any construction direct loss of burrowing owl nests, would occur during the nesting and /or including eggs and young, or the breeding season of burrowing owls abandonment of an active nest by potentially nesting in the area (February the adults. 1 through August 31) and /or during the winter residency period (December 1 and January 31). If active nests are found, a burrowing owl habitat mitigation plan shall be prepared. 12 The City shall arrange for a biologist to inform workers of the potential presence of special- status wildlife and measures to be implemented to avoid loss of these wildlife during construction activities. Area of Concern Impact Level of Si nificance Mitigation Number Mitigation Measure I Residual Impact Biological Raptors. Construction activities Potentially 12 See above. Less Than Resources in or near the riparian woodland Significant Significant habitat found along Uvas Creek 13 A field survey shall be conducted by a could result in the direct loss of qualified biologist to determine if active white - tailed kite, northern raptor nests are present in the construction harrier, Cooper's hawk, and zone or within 250 feet of the construction short -eared owl nests, including zone if any construction would occur during eggs and young, or the the nesting and /or breeding season of abandonment of an active nest by raptors potentially nesting in the areas the adults.. proposed for development (generally March 1 through August 1). If active nests are found, at the discretion of the biologist, clearing and construction within 250 feet shall be postponed or halted until the nests are vacated and juveniles have fledged and there is no evidence of a second attempt at nesting. Area of Concern Impact Level of Significance Mitigation Number Mitigation Measure 1 Residual Impact Biological Amphibians. Construction Potentially 8 See above. Less Than Resources activity in or near the riparian Significant Significant woodland habitat found along 10 See above. Uvas Creek could result in the direct and indirect loss of 12 See above. California red - legged frog, foothill yellow - legged frog, 14 A biologist shall monitor the project site western spadefoot toad, during construction activities within 100 California 'tiger salamander, and feet of Uvas Creek. If California red - western pond turtle. legged frog, foothill yellow - legged frog, Use of the sports park may result western spadefoot toad, California tiger in death or harassment of salamander, and /or western pond turtle wildlife by pets and people, turtles are observed at the site, consumption by predators construction activities -shall be halted attracted to the project site, or and the United States Fish and Wildlife death or injury from pesticides. Service shall be contacted for further assistance. 15 All food - related trash items shall be enclosed in sealed containers and regularly removed from the project area to deter attraction of potential predators Pets shall not be allowed on the construction site. r Area of Concern Impact Level of Mitigation Mitigation Measure I Residual Significant Number Impact Biological Habitat Disturbance During Potentially 2 See above. Less Than Resources Construction. Accidental spills of Significant Significant contaminants or other harmful 3 See above. materials, such as diesel fuel or oil, from construction vehicles 16 A plan shall be prepared to allow prompt could spread into the riparian response to any accidental spills, and woodland habitat and Uvas inform workers of the importance of Creek and harm or kill wildlife. preventing spills and of the appropriate During use of the sports park, measures to take in case of a spill. Uvas Creek could be contaminated by pesticides, fertilizers, and Guidelines shall be established for the similar substances. 17 prevention of contamination of the creek by pesticides and fertilizers from maintenance of the athletic fields. Biological Habitat Disturbance During Potentially 10 See above. Less Than Resources Recycled Water Line Significant Significant Construction. Construction 16 See above. activity could produce erosion or accidental spills of contaminants that could decrease habitat quality and interfere with the movement or well-being of wildlife. Biological Effects of Nighttime Lighting on Potentially 18 A lighting plan for the sports park shall Less Than Resources Wildlife. Nighttime lighting of Significant be developed requiring all lighting in the Significant the sports park play fields could western portion of the sports park to be spill over into the riparian directed away from the riparian habitat, woodland habitat and disturb prohibiting lighting along the Uvas wildlife, restrict the movement or Creek Trail; and generally restricting activity of wildlife, or facilitate lighting after 11:00 PM. increased predation of wildlife. Area of Concern Impact Level of Mitigation Mitigation Measure I Residual I Significance Number Impact Biological Domestic Activities. People and Potentially 19 A signage plan for the sports park shall Less Than Resources unleashed pets wandering off the Significant be prepared to outline the language, Significant Uvas Creek Trail could restrict number and location of signs to dissuade the movement or activity of people from straying off the Uvas Creek, and /or disturb or kill wildlife Trail and to prohibit unleashed dogs on the Uvas Creek trail. Transportation LOS Below City Standards. Significant 20 Prior to completion of Phase IV of the Less Than Circulation With completion of Phase V of proposed sports park the City of Gilroy Significant the proposed sports park the shall install a traffic signal and make intersection of Monterey Street lane improvements to at the intersection and Monterey Frontage Road of Monterey Street and Monterey Frontage would be congested. Road. Transportation State Highway Traffic. The Less Than N/A None Less Than Circulation proposed sports park would not Significant Required Significant cause congestion on nearby freeway segments. Transportation Bicyclist and Pedestrian Safety. Significant 21 The Uvas Creek Trail extension shall Less Than Circulation The proposed design of the connect by direct route to Thomas Significant temporary alignment of the Uvas Road — Luchessa Avenue at Princevalle Creek Trail crossing of Thomas Street via a built -up earth ramp on the Road— Luchessa Avenue would levee's north embankment. result in a potential safety hazard to users of the trail. Transportation Bicyclist and Pedestrian Safety. Significant 22 Cross walks shall be installed across Less Than Circulation The temporary alignment of the Thomas Road — Luchessa Avenue at Significant. Uvas Creek Trail crossing of Princevalle Street and stop signs shall be Thomas Road — Luchessa Avenue installed on Thomas Road — Luchessa would expose trail users to high Avenue at Princevalle Street. speed cross traffic. Area of Concern Impact FsiLgrE vel of Mitigation Mitigation Measure Ii idual ance Number pact Transportation Bicycle Access. The project plans Significant 23 The City shall construct a Class 1 path on Less Than Circulation do not indicate a bicycle route the west side or Class I1 bicycle lanes on Significant connection between Monterey both sides of Monterey Frontage Road as a Street, a designated bicycle route part of the design and construction of and the proposed sports park improvements to Monterey Frontage Road access road. between Monterey Street and the sports ark access road. Transportation Pedestrian Access. Sports park- Significant 24 Prior to completion of Phase IV of the Less Than Circulation related traffic increases along proposed project the City of Gilroy shall Significant Monterey Street and Monterey construct a minimum 6 -foot wide sidewalk Frontage Road will present along the west side of Monterey Frontage hazardous conditions to Road and a minimum 10 -foot wide pedestrians accessing the sidewalk along Monterey Street between proposed sports park. Thomas Road - Luchessa Avenue and the sports park access road. Transportation Parking Supply. The proposed Significant 25 The City of Gilroy shall include in project Less Than Circulation sports park would have a plans, 180 parking spaces from a later Significant shortage of 180 parking spaces at phase to be built prior to completion of the completion of Phase V. Phase V. Transportation Internal Circulation. The No N/A None No Circulation transportation impact assessment Impact Required Impact made recommendations for improvements to internal vehicular circulation at the proposed sports park. Area of Concern Impact Level of Mitigation Mitigation Measure Residual Significance Number Impact Air Quality Sports Park Operations. The Less Than N/A None Less Than proposed sports park would result Significant Required Significant in the emission of various pollutants into the atmosphere. These emissions would be below the thresholds established by the BAAQMD. Air Quality Project Construction. Construction Potentially 26 Dust control measures shall be Less Than activities at the project site could Significant incorporated into all permits for any Significant result in a significant adverse air phase of the project. The measures shall quality impact from dust. be implemented as necessary to adequately control dust. Noise Noise from Park Activities. Less Than N/A None Less Than Activities at the proposed sports Significant Required Significant park, including athletic events and traffic entering and exiting the project site would generate noise. Noise Construction Noise. Construction Significant 27 Construction activities shall be limited to Less Than activities at the project site could specified hours. Significant result in high levels of noise. Area of Concern Impact Level of Significance Mitigation Number I Mitigation Measure I Residual Impact Archaeological Currently unidentified buried Potentially 28 The city shall contract with a qualified Less Than Resources cultural resources may be found Significant archaeologist to arrange a schedule for Significant during construction on the project monitoring the project site during grading site. and excavation activities. 29 If archaeological resources or human remains are discovered during construction, work shall be halted at a minimum of 200 feet from the find and the area shall be staked off. The project developer shall notify a qualified professional archaeologist. If the find is determined to be significant, appropriate mitigation measures shall be formulated and implemented. 30 If human remains are found during construction there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the coroner of Santa Clara County is contacted to determine that no investigation of the cause of death is required. If the coroner determines the remains to be Native American the coroner shall contact the Native American Heritage Commission within 24 hours. Area of Concern Impact Level of Si nificance Mitigation Number Mitigation Measure Residual I Impact Aesthetics Change in Rural Character. Less Than N/A None Less Than Development of the project site Significant Required Significant would permanently alter the existing rural character of the area. Aesthetics Nighttime Lighting. The Less Than N/A None Less Than proposed sports park would Significant Required Significant introduce a major new source of light to the local area. Note: Impacts and Mitigation Measures are summarized in this table. Refer to the text of the Environmental Impact Report for the complete text of the impacts and mitigation measures associated with each area of concern. Source: EMC Planning Group Inc. r/ Introduction 1.1 Authorization and Purpose This environmental impact report (EIR) has been prepared by EMC Planning Group Inc. (hereinafter "consultant ") under contract to the City of Gilroy as the lead agency in accordance with the California Environmental Quality Act (CEQA) and implementing guidelines. This EIR has been prepared using available information from private and public sources noted herein, as well as information generated by the consultant through field investigation. This EIR will be used to inform public decision - makers and their constituents of the environmental impacts of the proposed project. In accordance with CEQA guidelines, this report describes both beneficial and adverse impacts generated by the proposed project and suggests measures for mitigating significant adverse environmental impacts resulting from the proposed project. Based upon the decision to prepare an EIR, the city prepared and distributed a notice of preparation (NOP), in accordance with CEQA Guidelines section 15082. CEQA Guidelines section 15375 defines an NOP as: ...a brief notice sent by the lead agency to notify the responsible agencies, trustee agencies, and involved federal agencies that the lead agency plans to prepare an EIR for the project. The purpose of the notice is to solicit guidance from those agencies as to the scope and content of the environmental information to be included in the EIR. The NOP and responses to the NOP received from responsible agencies are contained in Appendix A. This EIR describes and evaluates the existing environmental setting of the project site and surrounding areas, discusses the characteristics of the proposed project, identifies environmental impacts associated with the proposed project, and provides feasible mitigation measures that can be implemented to reduce or avoid identified adverse environmental impacts. This EIR also evaluates reasonable alternatives to the proposed project. Where an EIR identifies a significant adverse impact, the lead agency may not approve the project unless it finds that changes to the project or mitigation measures have been required of the project to reduce the impact's significance or that changes are infeasible for specified social, economic, and /or other reasons (Public Resources Code section 21081). When a mitigation measure is associated with a project impact that is identified as significant in the EIR, the lead agency may not exclude the mitigation measure from the project conditions without making specific findings regarding the omission. EMC Planning Group Inc. 1 -1 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This EIR is a factual, objective public disclosure document that takes no position on the merits of the proposed project. Thus, the findings of this EIR do not advocate a position "for" or "against" the proposed project. Instead, this EIR provides information on which decisions about the proposed project can be based. The EIR has been prepared according to the professional standards and practices of the EIR participants' individual disciplines and in conformance with the legal requirements and informational expectations of CEQA and its implementing guidelines. 1.2 Project Location The project site is located immediately south of the City of Gilroy in unincorporated Santa Clara County, approximately 35 miles south of San Jose, 10 miles south of Morgan Hill, and 30 miles northeast of Salinas. Figure 1 illustrates the regional location. The project site is located at the south end of Gilroy at the southwest corner of Monterey Street and Thomas Road — Luchessa Avenue. It is bordered by Thomas Road — Luchessa Avenue to the north, Uvas Creek and Farman Lane to the south, Monterey Street and Monterey Frontage Road to the east, and Uvas Creek to the west. Surrounding land uses are residential (single- family), commercial (hotels under construction), and agricultural (row crops and greenhouses). U.S. Highway 101 is located to the east of the project site, approximately 300 feet from the south end of the site and approximately 1,100 feet from the north end of the site. Figure 2 illustrates the project vicinity. 1.3 Project Description Existing Uses and Improvements The project site is 133.2 acres, located in unincorporated Santa Clara County, immediately south of both the city limits of Gilroy and the Urban Service Area limits. The site is currently in agricultural row -crop production. Four rural residences are located along the site's eastern boundary on Monterey Street and Monterey Frontage Road. A propane gas facility is located at the corner of Monterey Street and Thomas Road — Luchessa Avenue. Uvas Creek is located at the western boundary and a portion of the southern boundary. An earthen flood - control levee was constructed on a portion of the site. It extends from a point approximately 1,100 feet (on -site) south of Thomas Road — Luchessa Avenue to 4,500 feet upstream (and off -site) to Miller Avenue. Approximately 1,800 feet of the levee is on the project site. The levee is set back from the top of the natural creek bank by approximately 50 feet. Photographs of the project site are presented in Figure 3. 1 -2 EMC Planning Group Inc. I Source: California State Automobile Association and EMC Planning Group Inc. No Scale A Land Use Planning and Design Firm Gilroy Sports Park and USA Amendment EIR Regional Location Figure 1 Section 1: Introduction This side intentionally left blank. Park and USA Amendment EIR EMC Planning Group Inc. ;I i Gilroy Golf Course m 0 o� y� T �o GI rye Sports Park Site Project O Additional SIte USA Amendment Area Caltrain Station Gavilan mesa noau College o� 9 _,_ \7 ado• Source: California Automobile Association and EMC Planning Group Inc. Scale: 1" = 2,200' Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Project Vicinity 2 and Design Firm Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This side was intentionally left blank. 1_6 EMC Planning Group Inc. a� �l �a Thomas Road - Luchessa Avenue The view east from Uvas Creek. Thomas Road — Luchessa Avenue and Uvas Creek Levee, looking east. Source: EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR AALLan Land Use Planning Site Photos and Design Firm Figure 3 Section 1: Introduction This side intentionally left blank. Park and USA Amendment EIR 1 -8 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment EIR Section 1: Introduction The City of Gilroy General Plan land use designation for the project site is OPEN SPACE and PARK /PUBLIC FACILITY. General Plan land use designations surrounding the site include RESIDENTIAL, COMMERCIAL - GENERAL SERVICES, COMMERCIAL - VISITOR SERVING, AND OPEN SPACE. Figure 4 shows existing land uses and Figure 5 shows General Plan designations for the project site and vicinity. Proposed Improvements The proposed project consists of three primary components: an Urban Service Area amendment request to Santa Clara County Local Agency Formation Commission (LAFCO) and annexation to the City; approval of a Park Master Plan and development of the Gilroy Sports Park and commercial recreation building; and construction of off -site improvements including the extension of the Uvas Creek Trail from Thomas Road — Luchessa Avenue south to Gavilan Community College (including a pedestrian /bicycle bridge over Uvas Creek), extension of the city's recycled water distribution line to the sports park, and roadway improvements. References in this EIR to the "project site' and "proposed project' refer to the entire Urban Service Area amendment proposal. Specific references are made in this EIR to the "proposed sports park" and "sports park site" and the "proposed trail extension" and "trail extension site." Urban Service Area Amendment Request The entire 133.2 -acre project site is proposed for inclusion into the city's Urban Service Area, and annexation to the city. This would include the 78.4 -acre sports park site and 54.8 acres of adjacent parcels on the east and north. Figure 6 identifies the project site and it's relation to the existing Urban Service Area. Table 1 provides a list of parcels included in the proposal. The sports park is the only project proposed for development at this time within the Urban Service Area amendment request. A small portion of the sports park site is located adjacent to the existing Urban Service Area boundary along Monterey Frontage Road. However, in an effort to not create an "island ", the city has included the adjacent parcels to the north and east in the Urban Service Area amendment request. The adjacent parcels' General Plan land use designation of OPEN SPACE will not be modified at this time. It is unknown what type of development would take place on those parcels or when it would occur. City of Gilroy General Plan and Santa Clara County General Plan policies require that the parcels be annexed to the city prior to development. The City of Gilroy would annex the project site following approval of the Urban Service Area amendment by LAFCO. Planning Group Inc. Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Gilroy Sports Park j J The proposed sports park's preliminary master plan map is presented in Figure 7. The Gilroy Sports Complex Draft Master Plan, prepared by the beals group inc. in May 1998 is available for public review at the City of Gilroy Community Development Department. Preliminary plan components include the following: recreational play fields (eight softball diamonds and four soccer fields and concession /restrooms); premier play fields (one 90 -foot baseball diamond, two Little League diamonds and one soccer field and concession/ restrooms); competition play fields (one softball /baseball diamond and one soccer field and concessions and restrooms); 8.8 i acres of park preserve with family picnic, concessions and restrooms, volleyball and bocce ball courts, horseshoe pits and play area; commercial recreation building (indoor soccer, roller hockey, community center, storage); corporation yard; parking (1,043 spaces); and a park ranger station. Soccer fields overlay baseball/ softball fields. Football may also be played on the soccer fields. The athletic fields would have lighting for night games, a public address system and seating. The commercial recreation building is proposed to be a mostly open tent -like structure. TABLE 1 Assessor's Parcels in Amendment Request Project Component Assessor's Parcel Number Acres Sports Park Area 808 -21 -030 26.26 808 -21 -028 31.53 808 -21 -026 20.56 Additional Area 808 -21 -021 7.00 808 -21 -018 0.87 808 -21 -016 26.05 808 -21 -008 0.10 808 -21 -009 0.70 808 -21 -031 7.42 808 -21 -029 4.70 808 -21 -027 6.20 808 -21 -013 4.51 808 -21 -014 1.35 808 -21 -015 32.95 Total 133.20 Source: City of Gilroy w� �1 1 -10 EMC Planning Group Inc. u� Tenth Street Medium Densitu Industrial Yard General Industrial. General Services Commercial Source: California Automobile Association and EMC Planning Group Inc. Scale: 1 = 1,00 Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Existing Land Uses 4 and Design Firm Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This side was intentionally left blank. 1_12 EMC Planning Group Inc. A, P PF V11 LEGEND 0. ­ 0 "V6 C o °00 00 0 01 O -n0 o 0o.0 0( 0 00 -- ---- — ----- 0 00 t 00C 0 00 00 0 0 0 ( 000 0 0 0 00 1 00 rl 00, N, - ... ... . ... 00. 0 a ......... . _ VS C'. I Le C C COMMERCIAL - GENERAL SERVICES VS COMMERCIAL - VISITOR SERVING L RESIDENTIAL - LOW DENSITY M RESIDENTIAL - MEDIUM DENSITY I INDUSTRIAL - GENERAL INDUSTRIAL OS OPEN SPACE P/PF PARK/PUBLIC FACILITY Source: City of Gilroy Scale: 1" 1,000• Gilroy Sports Park and USA Amendment EIR Figure A Land U and Desigse Planning General Plan Designations 5 n Firrn I I Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This side was intentionally left blank. 1 -14 EMC Planning Group Inc. 11L"I 1 1 LIEU 'r6, i EXISTIN U R B A N .HaNlbome SI. .Foxglove Cl. -- - -- i ati E \� USA REQUEST kr�' -ice (Parcel N's as Of '98-'99) I I File USA 98 -03 i i Sports Park Area: 308 -21 -030 '^m 808 -21 -028 i - / 808 -21 -026 i Additional Area 808.21 -021 /// 11 o 808 -21 -018 1 _ - / 808 -21 -016 " \ 308 -21 -008 808 -21 -009 j' �• 808 -21 -031 i c'c�/ /d 308 -21 -029 808 -21 -027 \: "� "'✓ C \ 1 308 -21 -013 ♦ 308 -21 -013 Source: City of Gilroy 308 -21 -015 No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Project Site and Relation and Design Firm to Existing Urban Service Area 6 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This side was intentionally left blank. 0 j i i EMC Planning Group Inc. Y1 aai R Source: the beals group inc. - - - - - - - - - - 91 Gilroy Sports Park and USA Amendment EIR A Land Use Planning and Design Firm Preliminary Master Plan `R No Scale Figure 7 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR 1 This side was intentionally left blank. 1 1 1_18 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction The preliminary master plan also includes the following: a 50 -foot from top of bank habitat buffer along Uvas Creek to be enhanced with native plantings; walking /bicycle paths throughout the site; a portion of the Uvas Creek Trail; a six -foot high perimeter fence; and entry gates and an entry building at the Monterey Frontage entrance. The sports park would be developed in nine phases. The proposed phasing plan is summarized in Table 2 and illustrated in Figure 8. Phases are being proposed in sequence of construction from the entrance to the west end of the site for Phases One through Seven. Phases Eight and Nine can occur at any time, and have been separated based on their ability to be constructed independently of the other phases. Based on the experience of other cities of similar size constructing similar projects, the City of Gilroy expects full development of the proposed sports park to take approximately 20 years. TABLE 2 Gilroy Sports Park Proposed Phasing Plan Phase Number Description of Work Preliminary Projected Cost I Utility infrastructure; entrance; corporation yard; Uvas Creek Trail rough grade. $ 1,814,405 II Premier Little League area and parking; Uvas Creek Trail extension to Thomas Road. $ 3,992,025 III Commercial recreation building infrastructure; multi -use ball field. $ 1,984,013 IV North multi -use field area and parking. $ 3,962,695 V South multi -use field area and parking. $ 3,036,954 VI Premier softball /baseball field area and parking. $ 1,837,605 VII. Park preserve picnic areas and recreation facilities. $ 1,557,725 VIII Monterey Frontage Road improvements. $ 636,875 IX Uvas Creek Trail extension to Gavilan Community College. $ 885,000 Total $19,450,279 Notes: Projected cost is based on 1998 dollars. All hard and soft costs are included. The commercial recreation building has not been included in the cost. The expected timeframe for full development is 20 years. Phases are presented in the order they are anticipated to be built, except that Phases VIII and IX may be built at any time during the overall park development. Source: the beals group inc. EMC Planning Group Inc. 1 -19 I Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Development of the sports park would be funded through the city's park development fund, grants and donations. Various user fees and revenue from the commercial recreational facilities are expected to cover a portion of the operating costs. Off -Site Improvements Off -site improvements include the extension of the Uvas Creek Trail from Thomas Road— Luchessa Avenue south to Gavilan Community College; extension of the city's recycled water distribution line to the sports park; and roadway improvements. Uvas Creek Trail Extension. The proposed Uvas Creek Trail extension is illustrated in Figure 9. The existing portion of the Uvas Creek Trail runs from the corner of Uvas Park Drive and Laurel Drive to Thomas Road — Luchessa Avenue. The project's internal trail system would connect to a southward extension of the existing trail. The trail would be further extended to the Gavilan Community College area. A bridge crossing over Uvas Creek would be required and is proposed for the central, southern portion of the project site. The trail would then continue south to Mesa Road where it would turn east to reach the Gavilan Community College campus. Recycled Water Distribution Line. The city would extend a recycled water distribution line to serve the landscape needs of the sports park. Two routes are under consideration: along the median of Monterey Street, or along the east side of the Uvas Creek levee. Roadway Improvements. To enable pedestrian traffic, a sidewalk crossing at the intersection of Thomas Road — Luchessa Avenue and Monterey Street, with a ten - foot wide sidewalk continuing southward down to the Monterey Frontage Road has been proposed. There would also be a six-foot wide crosswalk at the Monterey Frontage Road, with appropriate project signs and introduction to the sports park. The crosswalk and intersection of Monterey Street and Monterey Frontage Road would be signalized in the future. This improvement would be based on a demand and use level with traffic /circulation for the sports park. The sidewalk would then continue down the Monterey Frontage Road and into the park itself. The sidewalk would be buffered from the road with shade trees and accent planting. i 1.4 Project Objectives The project is intended to meet the community's existing impacted needs and future growth demand for sports facilities for youth and adult baseball, softball, soccer and football. Several of the fields would be suitable for regional tournament play. Additionally, the sports park would provide informal parkland for picnicking and play, a location for commercial indoor recreation facilities and a community hall. 1 -20 EMC Planning Group Inc. THOMX5 ROAD RI PH ASE FMASE AREA WISTINGIME L I UFUT( INFRASTRUCTURE. ENTRANCE. CORPCQXTION YAROAND WAS MEEK TRIAL EXTENSION ROUGH MARINO WAS CREW TRAIL EXTENSION TO P1061AS ROAD III COMMERCIAL RECREATION AND MULnUSE aAU- MEW V SOUTH MULTVUSEFIV.DAREAANOPARKING PARKING VU INFCRMALRECREATIONAREA "it MONTEREY FRONTAGE ROAD INFIKOVEMEhffS N., If, IF r Source: the beats group inc.. Gilroy Sports Park and USA Amendment EIR A Land Use Planning and Design Firm and Sports Park Phasing Plan IMPROVEMENTS TO THOMAS ROM v • Vill No Scale Figure 8 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR t i This side was intentionally left blank. ;I 1 J q } 1_22 EMC Planning Group Inc. Source: the beals group inc. A Land Use Planning and Design Firm n�oru ■onu \\\ ncwiu pow n�wo�o �'•cq� \ �uomcs tnora \ ww•uve Uvas Levee Trail System Extension to Thomas Road Bridg Yr' 0 Uvas Levee Trail System Extension to Gavilan College Gilroy Sports Park and USA Amendment EIR Uvas Creek Trail Extension Figure 9 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR This side was intentionally left blank. i �I I t ' 4 F I J 1 -24 EMC Planning Group Inc. _ } Park and USA Amendment EIR Section 1: Introduction A segment of the Uvas Creek Trail would pass through the site. This trail would eventually provide a non - motorized transportation corridor through the southern portions of Gilroy, including connections to the sports park and Gavilan Community College. The project site is not currently within the Urban Service Area. The portion of the project site, which would be developed as the sports park, is contiguous with the existing Urban Service Area only for a very short distance where the proposed sport park access road meets Monterey Frontage Road. The adjacent parcels to the north and east of the sports park site have been included in the Urban Service Area amendment request because the addition of the sports park parcels alone would result in a virtual "island" of Urban Service Area. The adjacent parcels' General Plan land use designation of OPEN SPACE will not be modified at this time. 1.5 Consistency With Local and Regional Plans In accordance with CEQA Guidelines section 15125(d), this section of the EIR evaluates the consistency of the proposed project with applicable local and regional plans. These plans include the City of Gilroy General Plan, the City of Gilroy Zoning Ordinance, the Santa Clara County General Plan, applicable LAFCO policies, and the Bay Area Air Quality Management District (BAAQMD) Clean Air Plan. City of Gilroy General Plan The City of Gilroy General Plan was first adopted by the Gilroy city council on November 5,1979. The latest revisions were adopted by the Gilroy city council on June 3, 1996. A major update to the General Plan is currently underway, and is expected to conclude in the summer of 1999. This section analyzes those policies of the current City of Gilroy General Plan that are relevant to the proposed project. Urban Growth and Community Design Policy 2a: Hazardous areas, such as flood -prone areas and earthquake fault zones, are not suitable for intensive urban development. Consistency: The proposed project would utilize the flood -prone portions of the project site for sports fields, parkland and open space. This is not an intensive form of urban development. Therefore the proposed project is consistent with this policy. Urban Growth and Community Design Policy 2c: Extensive areas of Class I and II, agricultural land should be retained for agricultural production until the absence of alternative sites requires the conversion of agricultural land to urban uses. EMC Planning Group Inc. 1 -25 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Consistency: The proposed project would convert approximately 78 acres of Class I agricultural land to sports fields, parkland and open space. The sports park would be developed in phases over an approximate 20 -year time span, during which undeveloped portions of the site could remain in agricultural use. The remaining parcels on the project site could remain in agricultural use at this time. Three alternative sites for the proposed project have been identified. Refer to Section 3.5, Alternatives. All of these are currently in agricultural use. All three contain prime agricultural land and would require the conversion of that land to non - agricultural uses. No suitable sites were identified that would not involve the conversion of ; agricultural land. The proposed project is consistent with this policy. Urban Growth and Community Design Policy 3: Urban development will only occur within the incorporated portion of the Planning Area. Land will therefore be annexed to the City before final development approval is given. I Consistency: The project site is outside the city limits of the City of Gilroy, but lies within its Planning Area. The sports park site would be required to be annexed to the city prior to final approval of the proposed project by the city. As part of the proposed project, the city is submitting an Urban Service Area amendment request to LAPCO to add the project site to the Urban Service Area. Approval of this amendment would also include annexation of the sports park site into the city. The other parcels are not currently proposed for development. The proposed project is consistent with this policy. Urban Growth and Community Design Policy 4: The City will phase development in an orderly, contiguous manner in order to maintain a ' compact development pattern to avoid premature investment for the extension of public facilities and services. New urban development will occur in areas where municipal services are available and capacity exists prior to the approval of development in areas which would require major new facility expansion. Consistency: The project site is contiguous to developed areas of the city located north and east of the project site. The proposed project is consistent with this policy. Urban Growth and Community Design Policy 5: The City will establish a phasing plan for guiding future growth in the Planning Area. As of the date of this document, [June 3, 1996] urban development for the next five years will occur within the Urban Service Area. Urban development in the 6 -20 year period will occur within the "20 -year area." 1_26 EMC Planning Group Inc. ,- t Gilroy Sports Park and USA Amendment EIR Section 1: Introduction Urban zoning, development approvals and building permits will only be granted to property within the Urban Service Area. The City will not accept development proposals on land outside the Urban Service Area. Land located outside the Urban Service Area will be considered an "Urban Reserve." Agriculture will be encouraged as an interim use within the Urban Reserve. Consistency: The project site is outside the Urban Service Area and within the 20 -year area, as shown on the City of Gilroy General Plan land use map. As part of the proposed project, the city is submitting an Urban Service Area amendment request to LAFCO, to add the project site to the Urban Service Area. The project site would be annexed to the city. With approval of the USA Amendment, the proposed project is consistent with this policy. Urban Growth and Community Design Policy 9: New development will pay for all of the incremental public service costs which it generates. Consistency: The proposed project is a public facility sponsored by the City of Gilroy. The city would provide the necessary services to the proposed project. Park user fees and revenue from commercial recreational facilities would cover some of the costs of operation of the facility. Urban Growth and Community Design Policy 14: Historic and architecturally significant buildings, archaeological sites and other landmarks that give residents a tie with the past should be preserved. Private preservation efforts will be encouraged. Consistency: The project site is located in an area considered to be archaeologically sensitive. A mitigation measure is included in Section 2.8, Archaeological Resources, which would require monitoring of the site during construction and adherence to standard archaeological procedures in the event that archaeologically significant artifacts are discovered on the project site. With implementation of this mitigation measure, the proposed project is consistent with this policy. Urban Growth and Community Design Policy 26: The City recognizes bicycling as a major transportation mode which can significantly reduce the demand for energy needed for transportation. Bicycling will be actively encouraged as a safe, convenient, and attractive alternative to the automobile by identifying and mitigating disincentives which may exist, such as hot, un- shaded streets, dangerous traffic conditions, and physical barriers preventing safe or convenient access. EMC Planning Group Inc. 1 -27 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Consistency: The proposed project includes internal bicycle pathways and a connection to the Uvas Creek Trail, a major bicycle facility that would serve most of southern Gilroy. Monterey Street, south of Thomas Road — Luchessa Avenue is a city- designated bicycle route. The project plans do not indicate a bicycle route connection between the sports park entrance and Monterey Street. A mitigation measure presented in Section 2.6 Transportation/ Circulation would require the inclusion of a bicycle path or bicycle lanes on or along Monterey Frontage Road. With implementation of this mitigation measure, the proposed project is consistent with this policy. Natural Environment Policy 1: Land will be used for the purpose for which it is most suited by virtue of its inherent natural characteristics, as modified by its locational relationships, whether that use be urban development or natural resource preservation. Consistency: This policy requires the comparison of the relative merits of conservation of the natural attributes of the land, and the land's value for development, especially considering its location relative to other land uses and features. The project site borders Uvas Creek, which is considered a valuable natural resource to the city (refer to Natural Environment Policy 2 and 3, following). The project site is located in a flood zone, and is not appropriate for intensive development. The current land use is agricultural. This use provides open space and a buffer to Uvas Creek. The proposed project would maintain the land as open space, and provide a. minimum 50 -foot setback from Uvas Creek. The proposed project is located on land that is adjacent to developed land on two sides, and easily accessed from U.S. Highway 101, most of the City of Gilroy, and the Uvas Creek Trail. The proposed project would be an appropriate use of the project site. Both agricultural use and the proposed use are appropriate to the project site. The proposed project is consistent with this policy. Natural Environment Policy 2: The City will preserve natural resource and wildlife habitat areas, reduce risk in hazardous areas and provide recreational opportunities by preserving the following areas in open space: Natural resources — such as the Uvas Creek and Llagas Creek riparian communities, the heavily vegetated portions of the Santa Cruz mountains, and several stands of trees along Miller Avenue and trees bordering Hecker Pass. Hazardous areas — such as fault zones and floodways. 1 -28 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction • Recreational land — community, neighborhood and linear parks, expanded linear parks along Uvas and Llagas Creek, and the gold course. Consistency: The proposed project preserves the natural resources along its frontage with Uvas Creek. The proposed project maintains a hazardous floodway in open space. The proposed project includes a link in the Uvas Creek Trail, and extends the reach of the linear park along Uvas Creek. The proposed project is consistent with this policy. Natural Environment Policy 3: The ecologic, aesthetic and recreational values of the creeks, which flow through the Gilroy Planning Area, will be protected from urban encroachment and degradation. New development will preserve the function of natural drainages, including small canyons and seasonal creeks. The easements and setbacks adjacent to these creeks will be maintained in open space. Consistency: The proposed project would maintain the area near Uvas Creek as open space and enhance the natural buffer along the creek banks. There are no small drainages on the project site. The proposed project is consistent with this policy. Natural Environment Policy 11: The potential seismic, geologic, and flooding hazards to life and property will be reduced to an acceptable level of risk [reference to City of Gilroy General Plan Appendix Cj. Consistency: The project site is at a moderate to high risk of flooding. Appendix C of the City of Gilroy General Plan lists parks and other open space uses as appropriate for areas at moderate to high risk from natural hazards. The proposed project is consistent with this policy. Natural Environment Policy 11: In preference to the construction of expensive flood prevention facilities, floodways will be left open for agricultural and recreational use in areas of particular risk and where protection is minimal. Consistency: The proposed project would place recreational facilities in a flood zone. The proposed project is consistent with this policy. Natural Environment Policy 29: To minimize absorption losses and storm runoff increases, the City will encourage removal of pavement not directly needed for traffic or parking needs, maintenance of EMC Planning Group Inc. 1 -29 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR unpaved parkways between sidewalks and streets, use of permeable paving, and a break -up of large paved areas with landscaped strips, and islands. Consistency: The proposed project includes paved access roads, parking areas and pathways. Mitigation measures presented in Section 2.3 Hydrology require the preparation of a hydrology report and drainage plans. With implementation of these mitigation measures the proposed project is consistent with this policy. Natural Environment Policy 41: Areas subject to natural hazards such as major flooding or soils with a high water table will be encouraged to remain in long -term agricultural production where such use exists. Consistency: The intent of this policy is to protect people and structures from potential injury or damage as the result of flooding. The proposed project would convert land in agricultural use within a flood zone to sports fields and parkland. While these are urban uses, they are appropriate uses of a flood zone and do not impose any undue risks from flooding. The proposed project is consistent with this policy. Public Services and Facilities Policy 2: The City will provide a full range of necessary public facilities and services that are convenient to users, economical, and that reinforce City and community identity. Consistency: The proposed project would fulfill a need for a large multi-use sports facility for City of Gilroy residents. The proposed project is consistent with this policy. Public Services and Facilities Policy 5: Parks and recreation facilities of varying sizes, function and location will be provided to serve Gilroy's entire population. Consistency: The proposed project would provide a large sports facility currently not available to Gilroy residents. The southern part of Gilroy has very few park facilities; the proposed sports park would be the southern -most park facility in Gilroy. The proposed project is consistent with this policy. Public Services and Facilities Policy 15: The City should attempt to acquire the rights to use public and quasi - public utility and drainage channel corridors as linear parks to provide the network for a system of pedestrian and bicycle paths. Whenever feasible, recreational open spaces and linear parks should be linked to each other and to those planned by the Santa Clara County Parks and Recreation Department. 1 -30 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction Where interruption of the open space network is unavoidable, connecting foot and bicycle paths should be marked and made as safe as possible. Consistency: The proposed project would be linked to other areas of the city by the Uvas Creek Trail and would include extensions of the Uvas Creek Trail. The Uvas Creek Trail currently traverses Uvas Creek Park Preserve and has a close connection to Christmas Hill Park. The proposed project would link the trail with the proposed sports park and facilities at Gavilan Community College. The proposed project is consistent with this policy. Public Services and Facilities Policy 36: Proposed expressway, arterial collector street and bicycle path alignments will be planned and reserved in advance of development in areas in which increased traffic will be generated. Development will be set back along the entire right -of -way (ROW) with sufficient width to accommodate anticipated future traffic requirements. Consistency: The proposed project includes plans for the ultimate extension of the Uvas Creek Trail south from the project site to Gavilan Community College. The proposed project is consistent with this policy. Public Services and Facilities Policy 46: The City will correct deficiencies and expand the existing facilities and provide for the design of safe, convenient and attractive bicycle and pedestrian facilities whenever possible. Consistency: The proposed project would extend the existing Uvas Creek Trail south to the proposed sports park and Gavilan Community College. The proposed project is consistent with this policy. Public Services and Facilities Policy 47: Proposed expressway, arterial and collector streets on the City's Bikeway Plan will be planned to accommodate bike traffic by appropriate bikeway improvements, including bike paths separated from the roadway whenever possible. Bicycle and pedestrian paths will be provided along greenbelts, linear parks, public easements and drainages in public open space. Consistency: The proposed project would extend the existing Uvas Creek Trail south to the proposed sports park and Gavilan Community College. The proposed project is consistent with this policy. EMC Planning Group Inc. Section 1: Introduction Gilroy Sports Park and LISA Amendment EIR Public Services and Facilities Policy 48: Street crossings shall be designed to provide for the safety needs of bicyclists and pedestrians. River and other crossings by bridges shall be designed to accommodate bike lanes or paths physically separated from the roadway. Bridges for the exclusive use of pedestrians and bicycles should be provided whenever barriers exist which impede convenient and safe access. Consistency: The proposed project would include a bicycle and pedestrian bridge over Uvas Creek in order to continue the Uvas Creek Trail to Gavilan Community College. The Uvas Creek Trail would temporarily utilize an at -grade crossing of Thomas Road — Luchessa Avenue. Site distances at the proposed crossing are good. Crossing of Thomas Road — Luchessa Avenue might be attempted west of the intended crossing due to the proposed design of the path. A mitigation measure presented in Section 2.6 Transportation /Circulation would require a revised design of the path near Thomas Road — Luchessa Avenue. With implementation of this mitigation measure the proposed project is consistent with this policy. Public Services and Facilities Policy 55: Emphasize non -auto travel modes of transportation. Consistency: The proposed project includes access features exclusively for bicycle and pedestrian use. The entry roads and parking lots are designed to accommodate busses. The proposed project is consistent with this policy. Circulation and Air Quality Supporting Policy 9: The City will strive to maintain traffic conditions at Level of Service (LOS) C (corresponding to no more than 80 percent of theoretical capacity utilization) at Gilroy intersections and roadways. Exceptions to this standard will be allowed only where the City Council determines that improvements needed to maintain LOS C at specific locations are infeasible. Consistency: At full build -out, the proposed project would cause the level of service at the intersection of Monterey Street and Monterey Frontage Road to drop below LOS C. A mitigation measure presented in Section 2.6 Transportation/ Circulation would require the signalization of this intersection to return operation of the intersection to LOS C or better. With implementation of this mitigation measure, the proposed project is consistent with this policy. City of Gilroy General Plan Update The City of Gilroy is currently updating its General Plan. The updated General Plan is expected to be available for review in the summer of 1999. Since the update is in process and no final determinations have been made, no analysis of its provisions is included in this EIR. 1 -32 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction City, of Gilroy Zoning Ordinance The City of Gilroy Zoning Ordinance was adopted by the Gilroy City Council on August 15,1983. This analysis was prepared based on amendments adopted by the Gilroy City Council through February 2,1998. The proposed project would consist of the sports park, which would be zoned "PF Park /Public Facilities," and the remaining land, which would be zoned "OS Open Space ". The following discussion analyzes those provisions of the zoning code that are especially relevant to the proposed project. Section 24 OS Open Space District. The Open Space district permits agricultural uses, botanical conservatories, outdoor nature laboratories, native wildlife sanctuaries and similar uses. Conditional uses in this district include communication and public utility facilities; educational, charitable, research and philanthropic institutions in conjunction with permitted uses; guest ranches; recreational uses, such as riding academies, stables, country clubs and golf courses; and similar uses as determined by the planning director. The maximum building height allowed in the district is two stories or 30 feet. Land designated as Open Space may have to remain in that designation for a minimum period of time, to be determined by the city council at the time of approval of the designation. Roads and trails built in the Open Space district require the approval of the planning director. Consistency: There are currently no development plans for the parcels that would be designated Open Space. The Uvas Creek Trail extension would require approval from the planning director on those parcels that are designated Open Space. The proposed project is consistent with the provisions of this section of the zoning ordinance. Section 25 PF ParklPublic Facilities District: The Park /Public Facilities district permits all facilities owned or leased, and operated or used by any government agency; public or private colleges and universities and their related facilities; hospitals; and cemeteries, mausoleums, or crematories. Conditional uses include the facilities of entities under the jurisdiction of the Federal Communications Commission or the Interstate Commerce Commission; and, on property owned by a governmental agency and leased for any of these uses: private educational facilities, day -care centers, community centers, residential care facilities, business or trade schools, outdoor recreation service, neighborhood recreation center, art dance gymnastic, exercise or music studio or class, or special education class. The maximum allowable building height in the district is 30 feet. Consistency: The proposed project would include three parcels designated Park /Public Facility, on which the proposed sports park would be built. The sports park would be owned and operated by the City of Gilroy, with some facilities EMC Planning Group Inc. 1 -33 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR potentially operated by other entities under lease agreements with the city. The proposed project is consistent with the provisions of this section of the zoning ordinance. Santa Clara County General Plan The project site is currently under the jurisdiction of Santa Clara County. The Santa Clara County General Plan was adopted by the Santa Clara County Board of Supervisors on December 20, 1994. The General Plan land use designation for the project site is Open Space Reserve (OSR). The following Santa Clara County General Plan policies apply to lands designated OSR. Land Use Policy R -LU 45: Open Space Reserve (OSR) lands include rural unincorporated areas contiguous to a city Urban Service Area (USA) for which no permanent land use designation was applied pending future joint studies by affected jurisdictions of desired long -term land use patterns. Consistency: This policy defines the county's current land use designation for the project site. The long -term land use for the project site has not been determined by the county. The City of Gilroy, County of Santa Clara and Santa Clara County LAFCO participated in a study of agricultural lands near Gilroy that resulted in the designation of the Gilroy Agricultural Lands Area. The project site is outside of those areas considered for inclusion in the study area. The purpose of the Gilroy Agricultural Lands Area is to protect the economic viability of agriculture and to direct urban growth in a sustainable pattern elsewhere in the vicinity of Gilroy. The project site is outside the Gilroy Agricultural Lands Area boundaries. The project site is designated as OPEN SPACE and PARK /PUBLIC FACILITY in the General Plan. The sports park site would be developed consistent with this designation and the remaining parcels would retain their OPEN SPACE designation. The proposed project is consistent with this policy. Land Use Policy R -LU 49: For lands within the vicinity of the City of Gilroy designated OSR, joint studies should be conducted to resolve and define: a. areas to be reserved for future urban growth; b. areas to be reserved for long -term agricultural use; and c. other planning objectives identified within the South County Joint Area Plan deemed appropriate to the OSR areas. 1 -34 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction Consistency: The Study of the South County Agricultural Preserve was a joint effort of Santa Clara County, the City of Gilroy and Santa Clara County LAFCO. The study established the Gilroy Agricultural Lands Area, an area of approximately 15,800 acres of agricultural land to the east and south of Gilroy that will not be developed in the near future. The proposed project is located outside of the Gilroy Agricultural Lands Area on land that is within the City of Gilroy's 20 -year area. The 20 -year area is designated on the City of Gilroy General Plan as land that is expected to be developed over the next 20 years. The proposed project is consistent with this policy. The following policies from the Santa Clara County General Plan concern urban growth and expansion of Urban Service Areas. Growth and Development Policy C -GD 1: Most of the future urban growth of Santa Clara County should be accommodated within the existing urban areas, through infill development, rather than expansion of the urbanized area into hillsides and resource areas. Consistency: The proposed project would expand growth into an area that contains prime farmland, a valuable resource. However, the land is contiguous with developed portions of the City of Gilroy, and is adjacent on two sides to developed land. The proposed project is consistent with this policy. Growth and Development Policy C -GD 2: Urban development shall occur only within cities' urban service areas (USAs) and under city Jurisdiction. The County shall not allow urban development on unincorporated lands outside cities' urban service areas. Consistency: Part of the proposed project includes the addition of the project site to the City of Gilroy Urban Service Area, as well as annexation of the land by the city. The proposed project is consistent with this policy. Growth and Development Policy C -GD 3: Urban service areas should generally include only those areas suited for urban development. Development of such areas should be: a. reasonably serviceable with public facilities and services; b. relatively free from risks associate with natural hazards; c. without substantial adverse environmental impact; d. not likely to create severe off -site impacts on surrounding areas; and e. without cumulative adverse impacts on the county's water supply watersheds or any other natural resources. EMC Planning Group Inc. 1 -35 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Consistency: Each of these factors is considered below: a. The proposed project is located close to existing public services. b. The project site is located within a flood zone. However, the proposed sports park use would not result in the exposure of life or property to the risks associated with flooding and is an appropriate use of such a site. c. The proposed project would convert prime farmland to non - agricultural uses over a projected development period of 20 years. This is considered a significant unavoidable impact. No alternative site was identified that would not result in the conversion of prime agricultural land. The project site is located outside of the Gilroy Agricultural Lands Area and within the city's 20 -year growth area. d. The proposed project would not create severe off -site impacts on surrounding areas. Because the project site is close to major transportation corridors traffic to and from the proposed project will not have a significant impact on local streets, nor will it have a significant impact on traffic on U.S. Highway 101. Mitigation measures presented in the EIR would mitigate other potential off -site impacts to a less than significant level. The proposed project would have beneficial impacts on the adjacent riparian areas by widening the existing buffer area. e. The proposed project would not result in cumulative adverse impacts on the county's water supply watersheds or other natural resources. The proposed project is consistent with this policy, with the exception of item c. The proposed project would have unavoidable significant impacts in regard to the loss of prime agricultural land. Growth and Development Policy C -GD 5: Lands generally unsuitable for urban development may be allowed to annex to cities or be included in urban service areas only if the land is preserved as a non -urban open space use. Consistency: The project site is located in a flood zone as shown on the National Flood Insurance Program maps. Most of the project site is located in Zone B in which urban development is permitted with appropriate design considerations. The portion of the project site that is susceptible to more severe flooding is proposed for use as athletic fields and parkland. The proposed project is consistent with this policy. Growth and Development Policy C -GD 6: Hazard and resource areas with the following characteristics shall be considered unsuited for urban development: 1 -36 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction a. flood potential, including areas designated as floodways, tidal zones, coastal high hazard areas and federal flood insurance rate zones by the National Flood Insurance Program. Consistency: The project site is located in a flood zone as shown on the National Flood Insurance Program maps. Much of the project site is located in Zone X in which urban development is permitted with appropriate design considerations. The portions of the project site that are susceptible to more severe flooding are proposed for use as athletic fields, parkland and open space. The proposed project is consistent with this policy. Growth and Development Policy C -GD 6: Hazard and resource areas with the following characteristics shall be considered unsuited for urban development: e. prime agricultural soils. Consistency: The proposed project would convert prime farmland to non- agricultural uses over a projected development period of 20 years. No alternative site was identified that would not result in the conversion of prime agricultural land. The proposed project is consistent with this policy. Growth and Development Policy C -GD 7: Urban expansion should be planned on a staged, orderly basis, consistent with applicable plans (e.g. city, County, countywide plans) and the availability of needed urban services and facilities. The discouragement of expansion of cities' Urban Service Areas should be recommended to the LAFCO. Consistency: The project site is currently within the City of Gilroy planning area and is within the city's 20 -year development boundary. The proposed sports park is expected to be built in a staged and orderly basis in phases over a 20 -year period. The proposed project is consistent with this policy. Growth and Development Policy C -GD 8: Proposals to annex land or expand a city's urban service area boundaries shall be approved only if: a. the city, special districts and affected school districts have the ability to provide all needed public services and facilities to the area within five years and without lessening existing levels of service; b. the existing supply of land within the city's USA accommodates no more than five years of planned growth; c. the area proposed for urban development is contiguous to existing urban areas. EMC Planning Group Inc. Section 1: Introduction Gilroy Sports Park and USA Amendment EIR Consistency: Each of these factors is considered below: a. The City of Gilroy will provide all services to the project site as needed. The city has adequate potable water and will extend a recycled water line to the site for irrigation. The city has adequate wastewater treatment capacity to accommodate the proposed project. The proposed project would be served by the city police and fire departments without the need for new facilities or personnel. The proposed project would not result in additional students and so there would be no impact on school districts. b. Land within Gilroy's Urban Service Area is expected to be substantially developed within five years. Most of the land remaining within the Urban Service Area is designated for residential and commercial use. Suitable sites for the sports park use are very limited. Two of the studied alternate locations are located within the Urban Service Area, and one alternate location is partially within the Urban Service Area. c. The project site is contiguous with urban development on the north and east. The alternate sites are less contiguous with other urban development than the project site. Land within Gilroy's existing Urban Service Area is expected to be substantially built within five years. The proposed_ project requires a large amount of land. Though three alternative sites were found within (or partially within) the existing Urban Service Area, these were considered to be less suitable than the project site. Because the project site is located in a flood zone, the City was able to purchase the land at cost that makes the proposed project feasible. The alternative sites are not located in a flood zone and do not have the economic advantage that the project site has. The alternative sites were not as contiguous to developed land as the project site and two of the alternative sites were likely to have significant traffic impacts. Refer to Section 3.5 Alternatives. The proposed project is generally consistent with this policy. Growth and Development Policy C -GD 9: Proposals to annex land or expand the USA of a city for the purpose of adding lands for employment should be approved only if: a. lands planned for employment overall do not exceed the capacity of the city's planned housing supply; or b. the city's housing element of its General Plan can document that the housing needs of all segments of the community population are being met as stipulated by state law. 1 -38 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction Consistency: The proposed project includes the development of a sports park, which is not an employment -based use. The remaining parcels on the project site are not proposed for development at this time and it is not known what type of development will ultimately take place on those parcels. The proposed project is consistent with this policy. Santa Clara County Local Agency Formation Commission Policies The local agency formation commissions were created by the Knox- Nisbet Act passed by the State legislature in 1963 to govern changes in the boundaries and organization of cities and special districts in California. This act was supplemented by the District Reorganization Act of 1965 and the Municipal Organization Act of 1977. These three laws were consolidated under the Cortese -Knox Local Government Reorganization Act of 1985 (Government Code section 56000 et seq.). Urban Service Area Amendment Policy 1: LAFCO will review /amend a city's Urban Service Area once a year, if such review is desired by the city and initiated by city resolution and application. Until a city's application has been heard and acted upon by the Commission, no further Urban Service Area amendments will be accepted for filing from that city. LAFCO may make an exception to the "once a year' limitation upon Urban Service amendment requests where amendment is needed to carry out some special institutional development or activity that is in the public interest. Such exception shall not normally be extended in connection with proposed residential, commercial, or industrial development. Consistency: This amendment request is expected to be made in August 1999. The previous amendment request was filed in October 1997. The proposed project is consistent with this policy. Urban Service Area Amendment Policy 2: LAFCO will require application of an appropriate General Plan designation to territory proposed for inclusion in an Urban Service Area. Consistency: The parcels comprising the sports park would be designated PARK /PUBLIC FACILITY, which is consistent with their proposed use. The remaining parcels would retain the current OPEN SPACE designation, consistent with the current land use on those parcels. The proposed project is consistent with this policy. EMC Planning Group Inc. 1 -39 Section 1: Introduction Gilrou Sports Park and USA Amendment EIR Urban Service Area Amendment Policy 3: LAFCO encourages contractual agreements and /or plans between the cities and the County which define: a. Growth at the urban fringe; and b. Potential, new growth areas. Consistency: The Study of the South County Agricultural Preserve was a joint effort of Santa Clara County, the City of Gilroy and Santa Clara County LAFCO. The study established an area of approximately 15,800 acres to the east and south of Gilroy as the Gilroy Agricultural Lands Area. The proposed project is located outside of the agricultural lands area on land that is within the City of Gilroy's 20 -year growth area. The proposed project is consistent with this policy. Urban Service Area Amendment Policy 4: LAFCO will consider factors such as the following to determine the local and regional impacts of a proposed Urban Service Area amendment: a. The ratio of lands planned for residential use to land planned for employment - producing use; b. The existence of adequate regional and local transportation capabilities to support the planned city growth; c. Ability of the city to provide urban services to the growth areas without detracting from current service levels; d. The ability of school districts to provide school facilities; e. Whether the conversion of agricultural and other open space lands is premature, or if there are other areas into which to channel growth; f. The role of special districts in providing services; g. Environmental considerations which may apply; h. The impacts of proposed city expansion upon the County as a provider of services; i. Fiscal impacts on other agencies. Consistency: Each of these factors is discussed below: a. There are three existing houses that would remain, at least in the short term, on the project site. A residence would be provided for a caretaker for the sports park. An unknown number of employees would work at the project site, but it would be a fairly small number. Many of the jobs at the project site would be low -paid seasonal jobs. 1 -40 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction b. The proposed project is served by U.S. Highway 101, Monterey Street and other local streets, and the extension of the Uvas Creek Trail, which is proposed as a part of this project. c. The City of Gilroy would extend domestic and recycled water supply lines and sewer and storm drain lines to the project site. The City of Gilroy police and fire departments would provide public safety services to the project site. This extension of services would not reduce the level of service available to other areas of the city. d. The proposed project will not affect school enrollment. This factor is not relevant to the proposed project. e. The proposed project would result in the conversion from agricultural use of the proposed 78.4 -acre sports park site. The remaining parcels would remain in agriculture at this time. The alternate sites are currently in agricultural use and they would be removed from agricultural use if they were developed for a sports park. f. The City of Gilroy would provide water, sewer, storm drainage, police and fire services to the site. g. The amendment is subject to the analysis of this EIR. The proposed project would result in the conversion of prime agricultural land to non - agricultural uses: This would be a significant and unavoidable impact. Other potential impacts have been identified in this EIR and mitigation measures are presented to reduce those impacts to a less than significant level. h. The proposed project would not increase the demand on services provided by Santa Clara County. Services currently provided by the county would be provided by the City of Gilroy if the proposed project is approved. i. A fiscal analysis is currently under preparation for the proposed project. The proposed project is consistent with this policy. Urban Service Area Amendment Policy 5: When a city with a substantial supply of vacant land within its Urban Service Area applies for an Urban Service Area expansion, LAFCO will require an explanation of why the expansion is necessary, and how an orderly, efficient growth pattern, consistent with LAFCO mandates, will be maintained. Consistency: The city has evaluated all available vacant land in the city. Land within Gilroy's existing Urban Service Area is expected to be substantially built EMC Planning Group Inc. 1 -41 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR within five years. One location that is within the city limits has been considered as an alternative. An additional alternative location that is within the Urban Service Area and one that is partially within the Urban Service Area were also considered. Though several alternative sites were found within the existing Urban Service Area, these were considered to be less suitable than the project site. Because the project site is located in a flood zone, the City was able to purchase the land at cost that makes the proposed project feasible. The alternative sites are not located in a flood zone and do not have the economic advantage that the project site has. The alternative sites were not as contiguous to developed land as the project site and two of the alternative sites were likely to have significant traffic impacts. Refer to Section 3.5 Alternatives. The city prefers the project site due to its proximity to U.S. Highway 101 and the Uvas Creek Trail, and because the land is within a flood zone and therefore more affordable. The project site is adjacent to developed land on two sides. The proposed project is generally consistent with this policy. Urban Service Area Amendment Policy 6: The Commission will discourage Urban Service Area expansions which include agricultural or other open space land unless the city has accomplished one of the following: Demonstrated to LAFCO that effective measures have been adopted for protecting the open space status of the land. Such measures may include, but not be limited to, establishment of agricultural preserves pursuant to the California Land Conservation Act; adoption of City /County use agreements or applicable specific plans; implementation of clustering or transfer -of- development- rights policies; evidence of public acquisition; or b. Demonstrated to LAFCO that conversion of such lands to other than open space uses is necessary to promote the planned, orderly, efficient development of the city. Consistency: The sports -park land has been acquired by the City of Gilroy for public open space use. The existing open space designation of the remaining parcels would not change at this time. When those parcels are developed, development would be orderly, and compatible with surrounding urban uses. The Study of the South County Agricultural Preserve was a joint effort of Santa Clara County, the City of Gilroy and Santa Clara County LAFCO. The study established an area of approximately 15,800 acres to the east and south of Gilroy as an agricultural preserve. The proposed project is located outside of the agricultural preserve on land that is within the City of Gilroy's 20 -year growth area. The proposed project is consistent with this policy. 1 -42 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction Urban Service Area Amendment Policy 7: The Commission will consider whether an Urban Service Area amendment, leading to the conversion of agricultural or other open space land, will adversely affect the open space resources of the County. Factors to be studied include, but are not limited to: The agricultural significance of the amendment area relative to other agricultural lands in the region (soil, climate, water - related problems, parcel size, current land use, crop value, Williamson Act contracts, etc.); b. The economic viability of use of the land for agriculture; c. Whether public facilities, such as roads, would be extended through or adjacent to other agricultural lands in order to provide services to anticipated development in the amendment area; d. Whether the amendment area is adjacent to or surrounded by existing urban or residential development. r` Consistency: The proposed project's consistency with this policy is analyzed separately for each factor: I a. The project site is adjacent to the urbanized area of Gilroy and included within the city's 20 -year growth area. The Gilroy Agricultural Lands Area has been established on 15,800 acres east and south of the city to maintain the agricultural viability of that area. Four of the parcels on the project site were previously under Williamson Act contracts, but those have expired. The project site land is classified as Prime Farmland. The sports park site was most recently planted in corn. Based on the 1997 Santa Clara County crops report, agricultural production on the sports park site is estimated to have been worth $174,000. The sports park site represents a relatively small part of the County's agriculture. b. The project site is surrounded by urban development on the north and east sides. Land which is largely surrounded by urban land is generally less viable economically for agricultural use compared to lands which are in wholly agricultural areas (Crawford, Multari and Starr 1995). c. No new roads or other infrastructure would be built through other agricultural lands to serve the proposed project. Farman Lane, a dirt farm road would be paved. d. The project site is adjacent to developed areas on its north and east sides. This would be considered a favorable factor towards approval of the Urban Service Area amendment. EMC Planning Group Inc. 1 -43 Section 1: Introduction Gilroy Sports Park and USA Amendment EIR The project site is adjacent to urbanized land on two sides and is within the city's 20- year urban growth boundary. Although the proposed project would convert prime farmland to other uses, because of the project site's proximity to urban development, its relatively small contribution to agricultural production and its proposed park use, the proposed project would not have an adverse effect on the County's open space resources. The proposed project is generally consistent with this policy. Urban Service Area Amendment Policy 7: Where appropriate, LAFCO will consider adopted policies advocating maintenance of greenbelts or other open space around cities in reviewing Urban Service Area amendments. Consistency: The Study of the South County Agricultural Preserve was a joint effort of Santa Clara County, the City of Gilroy and Santa Clara County LAFCO. The study established an area of approximately 15,800 acres to the east and south of Gilroy as an agricultural preserve. The proposed project is located outside of the agricultural preserve on land that is within the City of Gilroy's 20 -year growth area. The proposed project is consistent with this policy. Bay Area Air Quality Management District 1997 Clean Air Plan The 1997 Clean Air Plan was adopted by the BAAQMD on December 17,1997. The plan is an update to the 1991 and 1994 Clean Air Plans, enacted pursuant to the California Clean Air Act of 1988, as amended. The Clean Air Act requires air - districts that exceed State ozone standards to reduce pollutant emissions by five percent per year, or take all feasible measures to achieve emissions reductions. The principal strategies for ozone reduction that are relevant to the proposed project are the reduction of automobile trips and traffic congestion, the provision of transit and encouragement of bicycle and pedestrian travel. Consistency: The proposed project would be accessible by automobile from U.S. Highway 101 and major local streets, by public bus service planned to serve the entry gate area of the project, and by non - motorized means through the entry gate and through the Uvas Creek Trail. URBEMIS7 modeling was performed by EMC Planning Group Inc. in December 1998. Project- associated automobile emissions were projected to be within thresholds established by the BAAQMD. The proposed project is consistent with this plan. 1.6 EIR Uses As mandated by CEQA Guidelines section 15124(d), this section contains a list of agencies that are expected to use the EIR in their decision - making, and a list of the approvals for which the EIR will be used. These lists include information that is known to the lead agency. 1 -44 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 1: Introduction List of Agencies and Approvals Lead Agency City of Gilroy • Urban Service Area Amendment (Entire Project Site) • Annexation (Entire Project Site) • Pre - zoning (Sports Park Site Only) ' , • Sports Park Master Plan • Construction (Sports Park Site Only) Regional Agencies Santa Clara County Local Agency Formation Commission • Urban Service Area Amendment (Entire Project Site) Santa Clara Valley Water District • Development Permit for construction within 50 feet of a waterway. State Agencies Californid State Department of Water Resources • General Development Storm Water Discharge Permit California Department of Fish and Game • California Department of Fish and Game Code Section 1603 Stream or Lake Alteration Agreement (Creek Crossing of Uvas Creek Trail Extension) Federal Agencies U.S. Army Corps of Engineers • Clean Water Act Section 404 Permit (Creek Crossing of Uvas Creek Trail Extension) EMC Planning Group Inc. 1 -45 Section 1: Introduction Park and USA Amendment EIR This side was intentionally left blank. 1 -46 EMC Planning Group Inc. 2.0 Environmental Setting, Impacts and Mitigation Measures The proposed project is comprised of an Urban Service Area amendment, annexation, sports park master plan and development and related off -site improvements. Where the setting or impacts are similar for all facets of the proposed project, these are discussed as a whole. Where the setting or impacts are specific to particular aspects of the proposed project, these are discussed ' I individually. Environmental impacts are categorized into five levels of impacts: beneficial; no impact; less than significant; significant (or potentially significant) and significant and unavoidable. 2.1 Agricultural Considerations Environmental Setting Existing Uses The project site comprises 14 parcels with a total land area of 133.2 acres. The majority of the acreage is currently farmed with row crops. Four rural residences and associated farm buildings are located on the project site, near Monterey Street and Monterey Frontage Road. A commercial propane gas facility is located within the project site near the corner of Monterey Street and Thomas Road— Luchessa �s Avenue. Along the western periphery of project site the proposed Urban Service Area amendment boundaries encompass small portions of Uvas Creek. These areas are undeveloped and support riparian vegetation. A levee extends along the eastern bank of Uvas Creek for approximately 1,800 feet to a point approximately 1,100 feet south of Thomas Road. Much of the project site is located in a flood zone, and is not appropriate for intensive development. The sports park site is entirely in agriculture. Approximately 4,000 feet of the proposed Uvas Creek Trail extension is within the project site, primarily on the levee or existing farm roads. The remainder of the proposed trail extension is to the south of Uvas Creek, off the project site on what is currently a dirt access road to surrounding farmland. Surrounding Uses The land north of the project site is an established residential neighborhood of single family houses. To the east of the project site are commercial uses, including hotels I EMC Planning Group Inc. 2-1 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR under construction, automobile dealership and mini- storage. South of the project site is additional agricultural land bordered by Uvas Creek on its west and south, and Monterey Frontage Road on its east. Greenhouses occupy some of this agricultural land and the remainder is farmed with row crops. On the west, the project site borders Uvas Creek, which is designated by the city for open space and preservation of natural resources (City of Gilroy 1996). Two park and open space areas are located along Uvas Creek northwest of the project site. Uvas Creek Preserve surrounds the creek for approximately two miles. A bicycle trail runs most of the length of the preserve. Christmas Hill Park is located on uplands to the southwest of Uvas Creek, adjacent to the Uvas Creek Preserve. Christmas Hill Park is a developed park with softball field and an amphitheater, among other facilities. It is the site of the annual Gilroy Garlic Festival. Gilroy High School athletic fields provide additional open space to the north of Uvas Creek. Most of the land near Uvas Creek to the south of the project site is farmland. Existing uses on the project site and surrounding land are illustrated in Figure 4 in Section 1.3 Project Description. Soils and Farmland Value The soil on the project site is Yolo loam. Yolo loam is a well - drained soil underlain by alluvium from sedimentary rock. The soil has high fertility and a very deep effective rooting depth. The soil is categorized as Agricultural Class I and is considered to be the most productive soil in the Santa Clara Valley (United States Department of Agriculture Soil Conservation Service 1974). Class I soils are those that have few limitations that restrict their use. Approximately 4,140 acres or 0.8 percent of Santa Clara County soils are Yolo loam. In 1974, approximately half of all areas of Yolo loam soil had been used for urban development. The California Department of Conservation maintains the Farmland Mapping and Monitoring Program. This program qualitatively identifies and keeps an inventory of California farmland. Under this program the project site is classified as prime farmland (California Department of Conservation 1996). Figure 10 shows the Farmland Mapping designations in the project vicinity. Prime farmland is defined by the California Department of Conservation as: ...land which has the best combination of physical and chemical characteristics for the production of crops. It has the soil quality, growing season, and moisture supply needed to produce sustained yields of crops when treated and managed, including water management, according to current farming methods. Prime Farmland must have been used for the production of irrigated crops at some time during the two update cycles prior to the mapping date. Prime Farmland does not include publicly owned lands for which there is an adopted policy preventing agricultural use. 2 -2 EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -4 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting In 1996, Santa Clara County had 33,870 acres of prime farmland. Between 1994 and 1996, 304 acres of prime farmland were converted to other uses in Santa Clara County (California Department of Conservation 1996). Between 1990 and 1994 there were 1,613 acres of prime farmland in Santa Clara County converted to other uses (Santa Clara County 1994). Land taken out of agricultural use for urban development is permanently lost from agricultural production. Urban development leads to lowered efficiency and decreased production on remaining farmland (Crawford, Multari and Star 1995). Williamson Act Lands The goal of the California Land Conservation Act of 1965, or Williamson Act, is to retain agricultural land in agricultural use. The act enables local governments to enter into contracts with private landowners to restrict land uses in return for reduced property tax assessments. The program is overseen by the California Department of Conservation. Williamson Act contracts are for ten -year terms, with automatic renewal each year. A contract may be terminated in several ways. Most commonly, a notice of non - renewal is filed, and the contract ends when the remaining nine years have expired. The tax assessment reductions are gradually phased out over the nine -year period. A contract may be cancelled without the nine -year termination period, but this procedure requires the review and approval of the Department of Conservation and the payment of a cancellation fee equal to 12 percent of the full market value of the property. Four of the parcels on the project site (APNs 808 -21 -028, 808 -21 -029, 808 -21 -030 and 808 -21 -031) were previously under Williamson Act contract. These parcels include two of the three parcels that comprise the sports park site and the two parcels between the sports park site and Monterey Frontage Road. Notices of non - renewal were filed for all four parcels and the contracts expired effective January 1, 1999 (Robert Friedrick, personal communication, February 4,1999). Gilroy Agricultural Lands Area The Gilroy Agricultural Lands Area was established through an agreement between the City of Gilroy, Santa Clara County, and Santa Clara County LAFCO, based on the outcome of the Study of the South County Agricultural Preserve. The 15,660 -acre area is designated for long -term agricultural use and aims to prevent the encroachment of urban development. The area covers agricultural land east and south of Gilroy, from Buena Vista Road in the north to the Pajaro River and San Benito County line in the south. All but a very small part of the agricultural lands area is located to the east of U.S. Highway 101. The agricultural lands agreement is meant to support long -term agricultural economic viability and to encourage sustainable future urban development (City of Gilroy et al 1996). The plan directs future growth to areas within a 20 -year growth boundary that is consistent with County and City General Plans and remains IEMC Planning Group Inc. 2-5 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR relatively constant over the long term. Prime farmland is a severely limited and irreplaceable resource. The establishment of the Gilroy Agricultural Lands Area is a partial mitigation for the loss of prime agricultural land in the vicinity of Gilroy. Project Analysis The proposed project would add 133.2 acres of prime farmland to the Urban Service Area of the City of Gilroy. The Urban Service Area consists of land that is expected to be developed for urban uses within a five -year timeframe. The sports park is the only development proposed at the present time. The remaining parcels would retain a land use designation of OPEN SPACE at this time. According to the City of Gilroy General Plan Map the project site is within the City of Gilroy 20 -year area boundary. The 20 -year area is an area that is expected to accommodate development within an approximate 20 -year timeframe. The proposed project is consistent with the policy of the Gilroy Agricultural Lands Area, which directs new development out of the agricultural lands area and into the 20 -year area. Several of the parcels were under Williamson Act contract, but those contracts have now expired. The land proposed for the sports park and trail extension would be remain as open space, and provide a buffer between developed areas and the natural corridor along Uvas Creek. The sports park would be the third in a series of parks that preserve an open space corridor along Uvas Creek. Substantial and contiguous open space adjacent to the creek is beneficial in maintaining the viability of the riparian habitat for wildlife. The sports park would also form a buffer between the residential uses north of the project site, and the existing agricultural uses south of the project site. Much of the sports park site is within the flood zone of Uvas Creek, and uses such as athletic fields are appropriate there, since the potential for flood- related harm to users or structures would be very low. The sports park site would be directly accessed by bicycle trail, which is especially appropriate for a facility that will be used extensively by children. The proposed trail would be an extension of the existing Uvas Creek Trail. Most of the proposed trail extension would be built on existing dirt roads, either on the levee top or adjacent to farmland. One small part of the trail would be built directly on land currently in crops. The trail would be located along the edge of the Uvas Creek natural area. Trails are acceptable uses within and adjacent to habitat protection buffers. The trail extension would create a continuous non - motorized route through southwest Gilroy, connecting two neighborhoods, Gilroy High School, Gavilan Community College, and the sports park. The trail would also connect to Princevalle Street, a designated Class H bicycle route that provides a direct link to central Gilroy. The proposed project is located on land that is adjacent to developed land on the north and east and easily accessed from U.S. Highway 101, most of the City of 2 -6 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Gilroy, and the Uvas Creek Trail. The proposed park uses are compatible with existing surrounding commercial, residential and agricultural uses. The low - intensity nature of the proposed development is appropriate adjacent to the Uvas Creek natural area, and the farmland to the south of the project site. _ No Impact— Conflict With Williamson Act Contract. Four of the parcels on the project site were previously under Williamson Act contract and expired in January 1999. Therefore, because these parcels are no longer in Williamson Act contract, no additional impact results above those identified in the previous two impact statements. No Impact— Effect on Adjacent Agricultural Uses. Implementation of the proposed project would not induce the adjacent farmland to be converted to non - agricultural uses. The parcels adjacent to the project site are outside the City of Gilroy 20 -year planning area and are unlikely to be developed in the near future. EMC Planning Group Inc. 2 -7 Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: ` • convert prime farmland, unique farmland or farmland of statewide importance (as shown on the maps prepared pursuant to the Farmlands Mapping and Monitoring Program of the California Resources Agency) to non - agricultural use; • conflict with existing zoning for agricultural use or a Williamson Act contract; or • involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non - agricultural use. Significant and Unavoidable Impact —Loss of Prime Farmland. Development of the sports park would result in the loss of 78.4 acres of prime farmland identified in the Farmland Mapping and Monitoring Program over the 20 -year build -out of the proposed project. The conversion of prime farmland to non - agricultural uses is considered a significant adverse environmental impact. r. Significant and Unavoidable Impact —Loss of Prime Farmland. Approval of the Urban Service Area amendment and development of parcels adjacent to the sports park site, could ultimately result in the loss of the remaining 54.8 acres of designated prime farmland within the project site. A portion of this 54.8 is currently developed with residential and commercial structures relating to the existing agricultural uses r^ on the project site. Property owners of the parcels adjacent to the sports park (and within the Urban Service Area amendment area) could be induced to seek approval for further development of their property. This would be considered a significant adverse environmental impact. _ No Impact— Conflict With Williamson Act Contract. Four of the parcels on the project site were previously under Williamson Act contract and expired in January 1999. Therefore, because these parcels are no longer in Williamson Act contract, no additional impact results above those identified in the previous two impact statements. No Impact— Effect on Adjacent Agricultural Uses. Implementation of the proposed project would not induce the adjacent farmland to be converted to non - agricultural uses. The parcels adjacent to the project site are outside the City of Gilroy 20 -year planning area and are unlikely to be developed in the near future. EMC Planning Group Inc. 2 -7 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Mitigation Measures The loss of prime farmland is generally considered a significant and unavoidable adverse environmental impact. Although development plans have only been proposed for the sports park site, the remainder of the project site could be developed at some time in the future if the Urban Service Area amendment is approved. The City /County adoption of the Gilroy Agricultural Lands Area serves as regional mitigation for the loss of prime farmland in southern Santa Clara County. Although this regional mitigation has been implemented by both the City of Gilroy and the County of Santa Clara, the loss of 133.2 acres of prime farmland could still be considered significant and unavoidable, unable to be mitigated to a less than significant level. CEQA Guidelines section 15093(a) requires the decision - making agency (City of Gilroy, as well as the Santa Clara County LAFCO) to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable'. Section 15093(b) states that when the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and /or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. The City of Gilroy is expected to make the following findings regarding the loss of prime farmland prior to approving the project: • The Gilroy Agricultural Lands Area is at least partial mitigation for the loss of the 133.2 acres of prime farmland; • The project site is adjacent to urban uses to the north (residential) and east (commercial), and is easily accessed from U.S. Highway 101; • The sports park is a social benefit highly desired by the City of Gilroy and its citizens; • There are no alternative sites for the sports park that would not result in the conversion of prime farmland; and • The project site is in a flood zone, which makes it undesirable for intensive urban development and therefore, was available at a price the City of Gilroy could afford. Alternative sites were not available at a price affordable to the City. 2 -8 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting 2.2 Geology Environmental Setting The project site is located within the seismically- active Santa Clara Valley. The project site is located approximately four miles southwest of the Calaveras fault, three miles northeast of the Sargent fault, and seven miles northeast of the San Andreas fault. These three faults are active and considered capable of producing severe ground shaking events. Most of the project site would be used for at -grade parking and athletic fields. Relatively few structures would be located on the project site. Most structures that would be located on the project site would be small service buildings such as snack vending booths and restrooms that have minimal occupancy loads and are unlikely to suffer substantial damage during an earthquake. The only major building that is included in project plans is the commercial recreation building/ community center. As a condition of the building permit all buildings would be required to be built to the standards of the most current edition of the Uniform Building Code. EMC Planning Group Inc. 2-9 Maximum earthquakes capable of occurring under existing known geologic conditions are 8.5 on the Richter scale for the San Andreas fault, 7.5 for the Calaveras fault, and 7.0 for the Sargent fault. It is estimated that an earthquake of magnitude 8.5 on the San Andreas fault has a recurrence interval of 100 to 1,000 years, although it is unknown when the last magnitude 8.5 earthquake occurred on the San Andreas ` fault. Similarly, a lesser recurrence interval would exist for an earthquake of smaller magnitude. 7.1 The Loma Prieta earthquake, which occurred on October 17,1989, measured on the Richter scale and was centered approximately 18 miles northwest Gilroy. The City Gilroy. earthquake caused moderate to severe damage to structures in the of The west portion of the project site is designated E -1 with moderate potential for liquefaction, and the east section of the project site is designated F -1 with a low potential for liquefaction, according to the Santa Clara County Relative Seismic Stability Map (Santa Clara County 1974). According to the Association of Bay Area i Governments (ABAG) the project site would experience "moderately high" shaking amplification in the event of a major earthquake (ABAG 1995). Project Analysis Based on historic records and on the known seismicity of the area, it is likely that the ' project site will experience an earthquake of magnitude 6.0 or greater within the next 50 years, as well as numerous smaller earthquakes, all generated within 20 miles of the project site. In the event of a strong earthquake centered along any of the nearby faults, ground shaking at the site will likely be moderate to high. Most of the project site would be used for at -grade parking and athletic fields. Relatively few structures would be located on the project site. Most structures that would be located on the project site would be small service buildings such as snack vending booths and restrooms that have minimal occupancy loads and are unlikely to suffer substantial damage during an earthquake. The only major building that is included in project plans is the commercial recreation building/ community center. As a condition of the building permit all buildings would be required to be built to the standards of the most current edition of the Uniform Building Code. EMC Planning Group Inc. 2-9 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: • expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic hazards or landslides. Less Than Significant Impact— Seismic Hazards. The proposed project presents a small risk of exposing people or structures to potential substantial adverse effects involving seismic hazards or landslides. This risk is associated primarily with the commercial recreation/ community center building, the only substantial building proposed for the sports park. Because all structures would be built to the standards of the latest version of the Uniform Building Code, the proposed project would have a less than significant impact in terms of geologic hazards, and no mitigation measures are necessary. 2.3 Hydrology Environmental Setting A hydrology and drainage report was conducted for substantially the same project site in January 1993 by Cregan and D'angelo. Background information on the Uvas Creek watershed is contained in the U.S. Army Corps of Engineers feasibility study of the Uvas Creek levee (U.S. Army Corps of Engineers 1981). This section is based on information contained in those reports. Water supply, water demand and wastewater generation are discussed in Section 2.4 Public Services and Service Systems. Both of these documents are available for review at the City of Gilroy Planning Division office. Storm Water Run -off and Flooding In undeveloped areas, a large proportion of rainfall is absorbed into the soil before storm water begins to run -off into streams. The percentage of storm water that percolates into the soil depends on a number of factors including slope, soil cover (e.g., vegetation) soil type, existing level of saturation and intensity of rainfall. Developed areas contain many surfaces, such as streets and buildings that are impervious to water. When rainfall lands on these surfaces, it drains on the surface and eventually into a drainage pipe or watercourse. Essentially none of the storm water that hits impervious surfaces is absorbed into the surfaces on which it falls. The difference in run -off between pervious and impervious surfaces varies depending on conditions. Those factors noted above that influence percolation into pervious surfaces affect the relative run -off rates between pervious and impervious surfaces. Under low rainfall conditions, or if the soil is not saturated, a very high 2-10 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting proportion of rainfall infiltrates a pervious surface, and there is very little surface run -off. As the soil becomes saturated or the rainfall intensifies, a higher proportion of the water runs off from pervious surfaces and the difference between run -off from pervious and impervious surfaces can become quite small. Water flows are not constant along the length of a stream. Following major rainfall, the water level will peak at some point along the stream and the peak flow will move downstream. Flooding occurs when the flow rate exceeds the capacity of the watercourse. The timing of storm water run -off is critical to the effect it will have on flood levels. Storm water that runs off into a watercourse while flood level flows are passing will contribute to flooding. Water that flows into a watercourse outside of flood stage flows, either before or after flood flows pass, will generally not contribute to the flooding. Regional Setting Uvas Creek is part of the Uvas - Carnadero Creek drainage basin, which includes the major tributaries of Little Uvas Creek, Little Arthur Creek and Bodfish Creek. The drainage encompasses approximately 90 square miles. Uvas Dam, constructed in 1957, is approximately 11 miles upstream of the project site. Little Uvas Creek feeds the Uvas Reservoir, which is impounded behind the dam. A levee on the north and east of Uvas Creek was built in 1991, and extends approximately 5,600 feet, including approximately 1,800 feet on the project site. Downstream of U.S. Highway 101 (and approximately three - quarters of a mile south of the project site) Uvas Creek becomes known as Camadero Creek, until it flows into the Pajaro River. The Pajaro River flows into Monterey Bay near Watsonville. The width of the Uvas Creek channel varies widely, from four feet wide to over 600 feet wide. In the vicinity of the project site the channel is approximately 100 to 150 feet across bank top to bank top, and very deep. Project Site Setting Uvas Creek forms the western and southern boundary of the project site. Most of the project site is within a flood zone (Federal Emergency Management Agency 1998). Areas subject to flooding on the project site can be categorized into three distinct areas: areas that are within a Santa Clara Valley Water District (SCVWD) flood flowage easement, areas outside the flood flowage easement but within the 100 -year flood zone, and areas within the 500 -year flood zone. Approximately 18 acres of land was removed from FEMA's Zone A area and reclassified as Zone X in April 1991, following completion of the Uvas Creek levee. Zone X areas can be developed with permanent structures subject to the review and approval of the City of Gilroy. Approximately half of the sports park site is within Zone A. The southern portions of the sports park site are in Zone C, an area subject only to minimal flooding, and the northern -most parts of the sports park site are in Zone X. EMC Planning Group Inc. 2 -11 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR The project site parcels to the north of the sports park site are located almost entirely in Zone X, while those to the east are primarily Zone A. Flood zone designations on the project site are illustrated in Figure 11. A 100 -year flood or "one- percent flood" is defined as a flood that has a one percent chance of occurring each year, or once on average in 100 years. Areas subject to this level of flooding are classified by the Federal Emergency Management Agency (FEMA) as Zone A. The greatest recorded flood on Uvas Creek occurred in 1986. The estimated peak flow rate for that event was close to FEMA's estimated 100 -year flow rate for Uvas Creek. The flow did not exceed the maximum Uvas Creek levee design flow (Kirk Wheeler, personal communication, January 26, 1999). A 500 -year flood is defined as a flood that has a two- tenths of a percent chance of occurring each year or once an average in 500 years. Areas that are subject to flooding less than one foot in depth by 100 -year floods, or protected by a levee from 100 -year floods, or subject to flooding by a 500 -year flood are classified by FEMA as Zone X Areas. Major creeks subject to flooding in southern Santa Clara County are the Pajaro River, Llagas Creek, Uvas Creek and their tributaries. A one - percent flood in southern Santa Clara County would inundate approximately 14,800 acres (County of Santa Clara 1986). The U.S. Army Corps of Engineers constructed a flood - control levee adjacent to a portion of the project site in 1990. The levee runs along the eastern side of Uvas Creek south from Thomas Road — Luchessa Avenue for approximately 1,800 feet. This levee protects the northern portion of the project site, as well as residential areas to the north of the project site from flooding during 100 -year floods. These areas may be subject to floods that exceed the 100 -year flood level. SCVWD has jurisdiction over Uvas Creek and owns the levee on the east of Uvas Creek. Additionally, SCVWD holds a flood flowage easement that restricts land use and development on a large portion of the sports park site. The flood flowage easement encompasses land that was calculated to suffer induced flooding due to the construction of the Uvas Creek levee, that is, flooding to a greater extent than would have been expected prior to the construction of the levee. Approximately 48.95 acres of the project site are within the flowage easement. Uses within the flowage easement are restricted to open space uses that will not inhibit the flow of floodwaters across the land. The flood flowage easement requires that a park within the flowage easement must be operated and regulated by a public agency. Parking of vehicles left unattended overnight is prohibited within the easement between October 15 and April 15 of every year. No buildings that would interfere with the flow of floodwaters may be constructed within the easement. Portable structures must be removed during the October 15 to April 15 time period. Inappropriate development within this easement.could put structures at risk of damage and people at risk of injury or death from storm- related flooding. Structures within the flood flowage easement could impede the flow of floodwaters and result in additional flooding in adjacent areas. EMC Planning Group Inc. 1 n ;> �1 t '�f �1 1 c� �r 1 ' � JI s" I r h 1 I� IN r r� k r MASSEY THOMAS SUBD. Or RANCH LOT e I. � s la to _____ '3ATo \ ti 11 20.674C. �ET 4u 91 WCNESSA AYE. sue' i. 3 QQW� LLJ 4 i= O 1 101 �Ilr Source: FEMA, City of Gilroy and EMC Planning Group Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Flood Zone Designations 11 and Design Firm Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 14 EMC Planning Group Inc. 1 F� �4 Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Areas outside the flowage easement but within the 100 -year flood zone are subject to restrictions as outlined in the City of Gilroy Floodplain Ordinance. Permanent j structures in these areas must have their lowest floor elevation at least one foot -- above the 100 -year flood elevation as indicated on the FEMA Flood Rate Insurance Maps. Project Analysis Storm Water Run -off The sports park site is currently undeveloped farmland. A large proportion of the rainfall that lands on the project site soaks into the soil. The general slope of the site is away from Uvas Creek towards Monterey Road. Much of the water that runs off the project site drains to Monterey Road and via a storm drain into Uvas Creek. The proposed project would include turf areas, access roads, parking lots, pathways and structures. Storm water run -off from these surfaces could, under some conditions, increase the rate of storm water discharge into Uvas Creek and the Pajaro River drainage. However, during flood conditions it is likely that the increase in run -off due to new impervious surfaces would be less than significant, since under these conditions the run -off rate from pervious surfaces is typically high also. Under some rainfall conditions it is possible that the run -off rate could be lower with the proposed project than with existing conditions. Turf areas may have a lower run -off rate than the existing, agricultural fields, and run -off amounts can vary with the intensity of the storm (Kirk Wheeler, personal communication, January 26, 1999). On -site Flood Water Flowage The SCVWD flood flowage easement imposes use restrictions on most of the sports ,> park site and a very small portion of one of the remaining parcels on the project site. The flood flowage easement would restrict usage of the sports park site during winter months, but would not completely eliminate usage during that period. The - restriction on parking from October 15 to April 15, stated in the flowage easement, would apply only to overnight parking of vehicles and parking during potential flood conditions (William Headley, personal communication, December 1, 1998). Park facilities such as restrooms and backstops would need to be removed from the flowage easement area during the winter or designed by a qualified hydrologist to assure that they do not impede the flow of floodwaters. The commercial recreation building is proposed to be a mostly open tent -like structure through which water could flow with minimal interruption. The sports park use is generally appropriate for the flood zone area, provided that park facility designs take into consideration the requirements of flood flowage across the site during times of major storm events and flooding. EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Storm Water Quality A variety of contaminants are common to urban area storm water and irrigation run -off. These contaminants include coliform bacteria, sediment, organic chemicals, nutrients and pesticides from landscaping and athletic fields, and fuel constituents, heavy metals, oil and grease from automobiles, roads and parking areas. These contaminants could be transported to the drainage system, polluting downstream water systems. The potential for contamination exists during both the construction and operation of the proposed project. Water quality degradation is regulated by the Federal National Pollution Discharge Elimination System (NPDES) Program, which was established by the Clean Water Act. The NPDES controls and reduces pollutants to water bodies from point and non -point discharges. In California, the California Regional Water Quality Control Boards (RWQCB) administer the NPDES Program. The Central Coast RWQCB issues and enforces NPDES permits for discharges to water bodies in the portion of Santa Clara County that drains to the Monterey Bay. Projects disturbing more than five acres of land during construction are required to file a notice of intent to be covered under the State NPDES General Construction Permit for discharges of storm water associated with construction activities. The = applicant must propose control measures that are consistent with the State NPDES General Construction Permit and consistent with recommendations and policies of the local agency and the RWQCB. The State NPDES General Construction Permit requires development and implementation of a Storm Water Pollution Prevention Plan ( SWPPP) that uses , storm water "Best Management Practices" to control runoff, erosion and sedimentation from the site both during and after construction. The SWPPP has two major objectives: (1) to help identify the sources of sediments and other pollutants that affect the quality of storm water discharges; and (2) to describe and ensure the implementation of practices to reduce sediment and other pollutants in storm water discharges. The SCVWD also requires a project review and permit for any construction that takes place within 50 feet of any watercourse within its boundaries. Because of the flood flowage easement, SCVWD will review project plans to assure that the project will not have any detrimental effects on watercourses, habitat or animals. Portions of the proposed project would involve grading and paving near the top of the Uvas Creek levee. A SCVWD permit may be required for all or some of the construction work at the sports park site. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: • violate any water quality standards or waste discharge requirements; 2 -16 EMC Planning Group Inc. IGilroy Sports Park and LISA Amendment EIR Section 2: Environmental Setting • substantially alter the existing drainage pattern of the site or area, including through the alteration of a stream or river; 1 • substantially increase the rate or amount of surface runoff in a manner that would result in flooding on -site or off -site; • create or contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff; or • place within a 100 -year flood hazard area structures that would impede or redirect flood flows. Less Than Significant Impact —Storm Water Run -off. The proposed project would include the construction of access roads, parking lots, pathways and structures, which add new impervious materials to the project site. Storm water run -off from these impervious surfaces could increase the rate of storm water discharge into Uvas Creek.and the Pajaro River drainage. However, during flood conditions it is likely that the increase in run -off due the new impervious surfaces at the project site would be less than significant. Potentially Significant Impact —On -Site Flood Flowage. SCVWD holds a flood flowage easement that restricts land use and development on a large portion of the project site. Inappropriate development within this easement could put structures at risk of damage and people at risk of injury or death from storm- related flooding. Structures within the flood flowage easement could impede the flow of floodwaters and result in additional flooding in adjacent areas. Uses within the flowage easement are restricted to open space uses that will not inhibit the flow of floodwaters across the land. Inappropriate development that would place structures or people at risk during flooding or the impedance of flood waters across the project site would be significant environmental impacts. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure 1. The City shall have a hydrology report prepared for the project by a qualified hydrologist or engineer, to address hydrology - related design requirements for the site and buildings, subject to the review and approval of the City of Gilroy Engineering Division and SCVWD prior to issuance of a grading permit. All grading, design or other recommendations of this report shall be incorporated into project plans. Significant Impact— Surface Water Quality. During construction, grading will expose sediments to rain or wind erosion and subsequent transportation of sediments to the Uvas Creek, Pajaro River and Monterey Bay. The silt load that could be generated could degrade the quality of water in the Uvas Creek, Pajaro EMC Planning Group Inc. 2-17 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR River and Monterey Bay by transporting other pollutants adhered to sediments, obstructing natural flow patterns at the points of sediment deposition, or adversely affecting biological resources. Materials used and wastes generated during construction would degrade water quality also. Wastes generated commonly include wash water from concrete mixers, paints and painting equipment cleaning activities, oil, grease and fuel constituents from vehicle use, storage and maintenance, solid wastes from tree and shrub removal during land clearing, and wood and paper materials from packaging of building products. Development of the sports park would increase the amount of runoff from the site under some weather conditions by adding new impervious surfaces and would generate non -point source pollutants from newly established urban activity at the project site. The runoff would contain pollutants typical of urban activity, such as oil and grease, fuel constituents, heavy metals, organic chemicals, bacteria, and sediments. These pollutants would degrade the quality of the surface waters in Uvas Creek, Pajaro River and Monterey Bay. Introduction of pollutants into a watercourse is a significant environmental impact. With implementation of the following mitigation measures, water quality degradation would be reduced to a less than significant level. Mitigation Measures 2. The City shall, for each phase of the project, submit a Notice of Intent (NOI) and detailed engineering designs to the Central Coast RWQCB. This permit shall require development and implementation of a SWPPP that uses storm water 'Best Management Practices" to control runoff, erosion and sedimentation from the site. The SWPPP must include Best Management Practices that address source reduction and, if necessary, shall include practices that require treatment. The SWPPP shall be submitted to the City of Gilroy Engineering Division for review and approval prior to approval of a grading permit for each phase of the project. 3. The City shall submit plans for review by, and obtain an approved permit from the Santa Clara Valley Water District (SCVWD) prior to approval of a grading permit for each phase of the project. 2.4 Public Services and Service Systems Environmental Setting The project site is located in unincorporated Santa Clara County. Services on the project site are currently provided by agencies other than the City of Gilroy, provided on -site by the property owner, or unavailable. 2 -I8 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Water. Existing water on the project site is from on -site private wells. A municipal water supply line is located beneath Monterey Street, just east of the project site. The existing recycled water supply line originates at the wastewater treatment plant southeast of Gilroy, runs northwesterly until it meets the Princevalle drainage channel, then follows the channel westward through Christmas Hill Park to Santa Teresa Boulevard. Wastewater. Existing residences on the project site are served by individual septic systems. Municipal wastewater trunk lines are located beneath Monterey Street, just east of the project site and beneath Thomas Road — Luchessa Avenue, just north of the project site. Storm Drain. The project site is not currently served by storm drains. All storm water runoff is carried over the surface and /or percolates into the ground. Police Protection. Police protective services at the project site are currently { . ' provided by the Santa Clara County Sheriff's Department. y Fire Protection. Fire protective and emergency medical response services are �1 currently provided by the South Santa Clara County Fire Department ( SSCCFD). SSCCFD stations are located at U.S. Highway 101 and Masten Road, and at State Highway 152 and Burchell Road. The City of Gilroy has an automatic aid agreement with SSCCFD. Under this agreement, the first engine company that is able to reach an emergency responds automatically. The City of Gilroy Fire Department is 1 located 1.5 miles from the project site and would generally be the first fire company to respond to the project site. Project Analysis With the addition of the project site to the Urban Services Area, the City of Gilroy will assume responsibility for the provision of services. At this time the sports park is the only development proposed for the project site. The remaining parcels will remain designated OPEN SPACE and are expected to remain in agriculture at this time. When those parcels are developed in the future there will be additional public services needs. Development of these parcels will require additional environmental review. Specific development plans are available for the proposed sports park and trail extension, and potential alignments are known for the extension of the recycled water distribution line. These are discussed in further detail below. The primary utility corridor into the project site would follow the access road from Monterey Frontage Road. Sports Park Area Water. The sports park would be served by a potable domestic water supply for drinking, bathroom fixtures and general use, and a reclaimed wastewater supply for EMC Planning Group Inc. 2 -19 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR irrigation. The projected annual demands were calculated by the beals group inc. for project build -out conditions. The City of Gilroy would provide potable water from the main located beneath Monterey Street. The sports park is expected to require 26 acre -feet of potable water annually. The City of Gilroy has an adequate supply of potable water available to meet the total potable water demand projected at the sports park. The City of Gilroy would provide recycled water for irrigation of the athletic fields and landscaping. The sports park would require in the range of 184 to 245 acre -feet of irrigation water annually. The City of Gilroy has an adequate supply of recycled water available to meet this demand. The recycled water distribution line does not currently serve the project site. An extension of the distribution line would be built from the existing line along the Princevalle channel. The preferred alignment follows Monterey Street. An alternative alignment follows Uvas Creek, to the east of the levee. The location of the existing recycled water distribution line and possible extensions are shown in Figure 12. Wastewater. The City of Gilroy would provide sanitary sewer services to the project site. The City of Gilroy sanitary sewer system includes a network of trunk sewers (greater than or equal to 10 inches in diameter) that generally flow from west to east and discharge into an interceptor sewer on the west side of Highway 101 that carries flow south to the Gilroy /Morgan Hill Wastewater Treatment Plant (Camp Dresser & McKee Inc. 1993). The project site would connect to the trunk line beneath Monterey Street. The beals group inc. calculates that the proposed sports park would generate approximately 22 acre -feet of wastewater annually at project build -out. The City of Gilroy wastewater treatment plant has adequate capacity to accommodate the additional wastewater. Storm Drain. As part of the construction of the sports park and road improvements, a system of storm drains would be constructed to channel storm water runoff. Storm water is discussed in Section 2.3 Hydrology. Police Protection. The City of Gilroy would provide police protective services to the proposed sports park. The Gilroy Police Department has a staff of 92 people. Of ' these, 57 are sworn officers and 35 are non -sworn personnel (Kathy Sakahara, personal communication, December 3, 1998). The police station is located near the corner of Sixth Street and Rossanna Street, approximately 1.5 miles from the sports park site. The City of Gilroy Police Department is staffed on a per capita basis, so no additional police officers would be required as a result of the development of the sports park. Police would respond to incidents at the sports park on a demand basis. Sports park personnel would provide monitoring of the site during events, and call for police assistance if needed. 2 -20 EMC Planning Group Inc. I C l . c -y a � i a — �m "^t y '� aJ Thrrd Stree f m� I Y G ' 40 q l V� N d dqL m so 4, a. Tenth Street'( tea, Christmas Q Hill Park l , Gilm u High School, M 40 Alternative Alignment Leavesley Road ♦ PYeferred Wastewater Alignment Treatment Plant xs: Sports Park Site Gavilan Additional Cortege USA Amendment Area Mesa Road l' 0 Existing Recycled Water Line i, . 1p 0 viriiiii Potential Extension Alignments Source: California Automobile Association and EMC Planning Group Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Recycled Water 12 and Design Firm Distribution Line Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. r. 0 2_22 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2. Environmental Setting The sports park site would be fenced around most of its periphery and the access road would be gated at sunset, or after the close of nighttime events. A caretaker would live on -site to provide additional security. Emergency access within the site would be provided via the access road, parking lots and pedestrian pathways. The pedestrian pathways would be built to acceptable standards for emergency vehicle use. Secondary emergency ingress to the site would be available from Farman Lane and the Uvas Creek Trail. The proposed project would enlarge the geographic range of coverage for the police department but would not require the addition or enlargement of facilities or the addition of equipment or personnel. The enlarged coverage area is adjacent to existing service areas and police will be able to respond within an acceptable period ` of time. Fire Protection. The City of Gilroy Fire Department would provide fire protective and emergency medical response services to the proposed sports park. The nearest fire station is located at Chestnut Street and Ninth Street, approximately 1.5 miles from the sports park site. Emergency access within the site would be provided via the access road, parking lots and pedestrian pathways. The pedestrian pathways would be built to acceptable standards for emergency vehicle use. Secondary emergency ingress to the site would be available from Farman Lane and the Uvas Creek Trail. The proposed project would enlarge the geographic range of coverage for the fire department but would not require the addition or enlargement of facilities or the addition of equipment or personnel. The enlarged coverage area is adjacent to existing service areas and can be reached from the fire station well within the fire department's emergency response time standard. The City of Gilroy Fire Department is currently the first responding company to the project site, and is reimbursed through an automatic aid agreement with SSCCFD. Uvas Creek Trail Police Protection. The City of Gilroy would provide police protective services to the proposed Uvas Creek Trail extension. The City of Gilroy Police Department is staffed on a per capita basis, so no additional police officers would be hired as a result of the development of the trail. Police would respond to incidents on the trail on a demand basis. No emergency telephones are indicated on project plans, so calls would need to be made from the nearest public telephone or residence. The trail would be built to acceptable standards for emergency vehicle use. Fire Protection. The City of Gilroy Fire Department would provide fire protective and emergency medical response services to the proposed sports park. The nearest fire station is located at Chestnut Street and Ninth Street, approximately 1.5 miles from the sports park site. The trail would be built to acceptable standards for emergency vehicle use. EMC Planning Group Inc. 2 -23 Section 2: Environmental Setting Gilroy Sports Park and LISA Amendment EIR Recycled Water Line The recycled waste water line would be extended to the sports park site by one of two possible routes: the preferred route is beneath Monterey Street and Monterey Frontage Road; the alternatively route is along Uvas Creek, east of the levee. The placement of the recycled water line on the Monterey Street alignment would result in less than significant environmental impacts. The placement of the recycled water line along the Uvas Creek alignment could result in the disturbance of riparian woodland habitat during construction activities. These potential effects are discussed in detail in Section 2.5 Biological Resources. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: result in substantial adverse physical impacts or significant environmental impacts associated with the provision of new or physically altered governmental facilities, in order to maintain acceptable services ratios, response times or other performance objectives for fire protection, police protection, schools, parks or other facilities; • fail to meet wastewater treatment requirements of the applicable Water Quality Control Board; • require or result in the construction of new water or wastewater treatment facilities or storm water drainage facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects; or • result in a substantial depletion of water supply or solid waste disposal capacity. Less Than Significant Impact — Construction of Water, Wastewater and Storm Drain Infrastructure. The proposed project does not require substantial extensions or upgrades to the existing potable water supply, wastewater or storm drain infrastructure. The proposed project would have a less than significant impact on these systems. Mitigation measures are not necessary. Potentially Significant Impact — Recycled Water Distribution Line Construction. Construction activities on the Uvas Creek bank also have the potential to produce erosion or accidental spills of contaminants or other harmful materials which could decrease habitat quality and interfere with the movement or well -being of special- status species potentially occurring in the riparian habitat. This would be a potentially significant impact. Implementation of mitigation measures presented in Section 2.5 Biological Resources would reduce this impact to a less than significant level. These mitigation measures would require siltation fencing, hay bales or other erosion control measures to be installed along the portion of Uvas Creek occurring on the project site to prevent sediment from filling the creek, and the preparation of a spill abatement and clean -up plan. 2 -24 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting No Impact —Water Supply. The proposed project would result in a minimal increase in demand for potable water. The City of Gilroy has adequate water supplies to meet the projected demand for potable water. The proposed project would increase demand for recycled water for irrigation. The City of Gilroy has an adequate supply of recycled water to meet the projected demands. Mitigation measures are not necessary. No Impact — Police and Fire Services. The proposed project does not result in the need for additional facilities for the provision of police or fire services, and would not decrease the level of these services provided to any part of the community. The proposed project would have no physical impact to the environment associated with the provision of police or fire services. Mitigation measures are not necessary. 23 Biological Resources Environmental Setting A reconnaissance -level biological survey was conducted by LSA Associates, Inc. in January 1993 to identify biological resources occurring or potentially occurring on the project site, including vegetation types, significant wildlife habitat features, and the potential for the presence of special - status plant and animal species. The project site was resurveyed by a biologist from EMC Planning Group Inc. in November 1998 to field -check and update the 1993 biological survey. The following discussion includes information contained in the 1993 biological survey and updated information provided by the 1998 survey. Habitats observed in the project site include agricultural land, Uvas Creek and associated riparian woodland habitat, and landscape plants associated with existing and former residences. Figure 13 illustrates the habitat types observed on the project site. The following discussion describes those plant and animal species that were observed during the 1993 and /or 1998 survey, or that would be expected to commonly occur in habitats present on the project site. Agricultural. The majority of the project site is in agricultural row crop production and does not contain naturally- occurring plant species. Due to continuous human interaction, agricultural fields typically provide little habitat for wildlife. No bird species were observed foraging in the agricultural land; however, turkey vulture (Cathartes aura), American crow (Corvus brachyrhynchos), and gulls (Larus spp.) were observed flying over the field. Crows and songbirds may forage in the cultivated fields and small mammals (e.g. pocket gophers, ground squirrels, and black - tailed hares) may also forage and burrow in the fields assuming they are not actively controlled in the area. Larger mammals such as coyotes and foxes may also utilize cultivated fields for hunting and foraging but are not likely to inhabit these areas. EMC Planning Group Inc. 2 -25 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Uvas Creek. Uvas Creek, and the associated riparian woodland habitat (described below), is the most significant biological resource on the project. Willows (Salix spp.) and mugwort (Artemisia douglasiana) are the most common shrubs along the border of the creek channel. Annual grasses and forbs grow in the creek channel in the dry season. Vegetation in the channel is subject to removal by increased flow during the rainy season. There are no wetlands or waters of the United States on the project site other than Uvas Creek and associated temporary pools in the creek channel. Adult steelhead (Oncorhynchus mykiss irideus), a federally threatened species (discussed further below), is known to migrate upstream in Uvas Creek to spawn in winter and early spring. They rest in pools and spawn in shallow riffles. Other native and introduced fish, crayfish, and bullfrogs have been reported from the Uvas Creek Preserve upstream of the project site. Riparian Woodland. A narrow riparian corridor with an average width estimated to be approximately 25 feet from the centerline of Uvas Creek to the edge of canopy borders each side of the creek, although riparian vegetation is absent in some areas along the creek. A dirt road used for the adjacent agricultural operations is located along the entire edge of the riparian corridor. The riparian corridor supports a diversity of vegetation and provides valuable wildlife habitat. The dominant plant species in this corridor include mature western sycamore trees (Platanus racemosa), coast live oak (Quercus agrifolia) and valley oak (Quercus lobata), Fremont's cottonwood (Populus fremontii ), willow thickets, and California blackberry (Rubus ursinus). Eucalyptus (Eucalyptus spp.), black walnut (Juglans hindsii) and English walnut (Juglans regia) are occasional components of the riparian vegetation on the project site. Riparian woodland habitat is protected by the California Department of Fish and Game (discussed further below). Open areas in the riparian woodland habitat, the edge between riparian woodland habitat and the agricultural field, and the levee in the northwest portion of the project site are dominated by non - native annual grasses and forbs. Common species include oat (Avena spp.), ripgut brome (Bromus diandrus), thistles (Centaurea solstitialis, Cirsium vulgare, Silybum marianum), mallow (Malva spp.), and mustards (Brassica spp.). The large oak and sycamore trees provide excellent roost and nesting sites for raptors and other bird species, and the continuous tree canopy contributes to its value as a corridor for wildlife. White- crowned sparrows (Zonotrichia leucophrys), yellow - rumped warblers (Dendroica coronata), bushtits (Psaltriparus minimus), scrub jays (Aphelocoma coerulescens), black phoebe (Sayornis nigricans), and northern flickers (Colaptes auratus) were observed in the riparian vegetation between the agricultural fields and Uvas Creek. Holes drilled by red - breasted sapsucker (Sphyrapicus ruber) were observed in the trunks of riparian trees. A red - shouldered hawk (Buteo lineatus) was observed in the riparian woodland south of Farman Lane south of the project site, and red - tailed hawk (Buteo jamaicensis), sharp - shinned hawk (Accipiter striatus), and American kestrel (Falco sparverius) were seen in the riparian woodland on the project site. 2 -26 EMC Planning Group Inc. '1 �i 1 i i �l II I II !rl II II ic , U J1vl\ � )Ivll )I` If\ THOMAS I A.. i � �VANWS, INC RA'i!: • .t �+ • �n RA RA Ao f� RA ob Leirend 8 Proposed Boundary of A Agriculture USA Amendment L Landscape Trees Request RA Residence and ® Riparian Vegetation Agriculture © Levee Road Source: LSA Associates and EMC Planning Group Inc. No Scale ® Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Habitat Types 13 and Design Firm Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -28 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment EIR Section 2: Environmental Setting Grasses and (orbs in the riparian understory harbor insects and provide seed and nesting material for sparrows, finches, and small mammals. Botta's pocket gopher (Thomomys bottae) burrows were observed in loose soil among non - native grasses bordering the levee. Landscape Trees. In the northwest corner of the project site, mature landscape plantings of trees and shrubs persist around a former home site. Tree species in this area consist of incense cedar (Calocedrus decurrens), eucalyptus, pepper tree (Schinus molle), coast redwood (Sequoia sempervirens), and California fan palm (Washingtonia filifera). Along the eastern project site boundary of Monterey Frontage Road, houses, outbuildings, and associated landscape plantings alternate with cultivated fields. The mature landscape trees in the north corner of the project site provide a food source for birds, squirrels, and other small mammals. The large trees provide perching and nesting sites close to Uvas Creek and a source of food for resident and migratory birds. Special- Status Species Data from the U. S. Fish and Wildlife Service (USFWS), National Marine Fisheries Service (NMFS), California Department of Fish and Game (CDFG), and California Native Plant Society (CNPS), as well as local knowledge and the 1993 biological survey report, were reviewed to determine the potential for any special - status species to occur in any areas associated with the proposed project. Special- status species include species listed or proposed for listing by the USFWS, NMFS, CDFG, and /or CNPS as endangered, threatened, or species of special concern." Special- status species that have the potential to be found on the project site are listed in Table 3, along with their legal status and habitat requirements. This list was determined by evaluating the geographic ranges and habitat requirements of each species and habitat conditions at the project site. Plants. The CDFG Natural Diversity Database (Chittenden and Gilroy quadrangles) reports three special- status native plant species occurring within the vicinity of the project site, including Metcalf canyon jewelflower (Streptanthus albidus ssp. albidus), most beautiful jewelflower (Streptanthus albidus ssp. peramoenus), and Santa Clara Valley dudleya ( Dudleya setchellii). These plant species are restricted to serpentine soils. Since serpentine soils are not present on the project site, and since natural conditions on the project site have been disturbed by long -term agricultural use, it would be extremely unlikely that any of these species would occur on the site. EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR TABLE 3 Potential Special- Status Species Species Status Habitat (Federal/S tate /CNPS) Plants: None Wildlife: California tiger salamander Candidate /CSC Grassland with seasonal Ambystoma californiense water source Western spadefoot toad FSC /CSC Upland areas with seasonal Sca hio us hammondii water source Foothill yellow - legged frog FSC /CSC Upland areas associated with Rana bo lii rock - bottomed creeks California red - legged frog FT(USFWS) /CSC Lowlands/ foothills near Rana aurora draytonii permanent deep water sources Western pond turtle FSC /CSC Aquatic habitat Clemmt s marntorata Steelhead FT(NMFS) / -- Aquatic habitat Oncorhynchus mykiss irideus Burrowing owl FSC /CSC Nests and winters in small Athene cuniadaria mammal burrows in grasslands Nesting raptors /active raptor - /CSC Tall trees in woodland areas nests FT(USFWS): Listed as "Threatened" by the USFWS. FT(NMFS): Listed as "Threatened" by the NMFS. Candidate: A candidate for listing as threatened or endangered by the USFWS. FSC: USFWS "Special Concern". Prior to February 1996, the USFWS identified these species as "Category 2" candidates for listing (taxa for which information in the possession of the USFWS indicated that proposing to list as endangered or threatened was possibly appropriate, but for which sufficient data on biological vulnerability and threat were not currently available to support proposed rules). The designation of Category 2 species as candidates resulted in confusion about the conservation status of these taxa. To reduce that confusion, and to clarify that the USFWS does not regard these species as candidates for listing, the USFWS has discontinued the designation of Category 2 species as candidates. The USFWS remains concerned about these species, but further biological research and field study are needed to resolve the conservation status of these taxa. CSC: CDFG "Species of Special Concern". The CDFG "Species of Special Concern" does not afford these species any federal or state protection. These species should be taken into special consideration when decisions are made concerning the future of any land parcel. A species is included as a "Species of Special Concern" when their breeding populations in California are declining. Species are also included that are not declining worldwide, but in California the population is so low that it is potentially vulnerable to extirpation. Source: USFWS and CDFG 2 -30 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR section 2: Environmental Setting Wildlife. The CDFG Natural Diversity Database (Chittenden and Gilroy quadrangles) reports several special- status animal species occurring within the vicinity of the project site, including California tiger salamander (Ambystoma californiense), California red - legged frog (Rana aurora draytonii), western pond turtle (Clemmys marmorata), burrowing owl (Athene cunicularia), bank swallow ( Rpparia riparia), and tricolored blackbird (Agelaius tricolor). In addition, steelhead are known to migrate in Uvas Creek, and raptor nests could potentially be present in the riparian woodland trees on the project site. Other species not listed on the Natural Diversity Database that have the potential to occur on the project site include western spadefoot toad (Scaphiopits hammondii) and foothill yellow - legged frog (Rana boylii). Of those species listed on the Natural Diversity Database reports, bank swallow and tricolored blackbird most likely do not occur on the project site. Bank swallows require vertical banks or cliffs with fine- textured sandy soils to dig a nesting hole. The portion of Uvas Creek that occurs on the project site does not contain appropriate habitat for nesting bank swallows. Likewise, tricolored blackbirds typically nest in colonies in marshes or other open water areas, and no appropriate habitat for tricolored blackbirds occurs on the project site. Also, while not listed on the Natural Diversity Database reports, the project site was evaluated for potential use by other special - status species, including San Joaquin whipsnake (Masticophus flagellum ruddocki), pallid bat (Antrozous pallidus), and Townsend's western big -eared bat (Corynorhinus townsendii townsendii). These species most likely do not occur on the project site. San Joaquin whipsnakes are found in grassland habitats, and pallid and Townsend's western big -eared bats are found in deserts, pine forests and canyons with roost sites (caves, cliff overhangs and buildings). No appropriate habitat for these species occurs on the project site. The potential occurrence of the other species listed on the Natural Diversity Database (NDDB) reports is discussed below. California tiger salamander. The California tiger salamander is a candidate for listing as threatened or endangered by the USFWS, and is designated as a "Species of Special Concern" by the CDFG. Tiger salamanders primarily occur in valley floor and foothill grasslands. Adults utilize rodent burrows for refuge during the non- breeding season and, during the rainy season, they migrate to aquatic breeding sites, such as seasonal ponds, reservoirs, lakes, and occasionally stream pools. No California tiger salamanders were observed on the project site during the 1993 and 1998 field surveys. The NDDB lists known occurrences of California tiger salamanders near Tick Creek (four miles south of Gilroy), near the intersections of Castro Valley Road and Old Monterey Street with U.S. Highway 101 (three and four miles south of Gilroy, respectively), and in Farman Canyon pond and Reservoir Canyon Pond on the O'Connell Ranch in Gilroy (approximately 2.5 miles south of the project site). Breeding habitat for the California tiger salamander is potentially present in pools adjacent to the EMC Planning Group Inc. 2 -31 Section 2: Environunental Setting Gilroy Sports Park and LISA Amendment EIR Uvas Creek bed. However, it would be highly unlikely that they would occur on the majority of the project site due to the long history of agricultural disturbance. • Western spadefoot toad. The western spadefoot toad is designated as a "Species of Special Concern" by the USFWS and CDFG. Western spadefoot toads primarily occur in upland areas near aquatic breeding sites, such as seasonal ponds, reservoirs, lakes, and stream pools. No western spadefoot toads were observed on the project site during the 1993 and 1998 field surveys, and the NDDB does not contain any listings of occurrences of western spadefoot in the project vicinity. However, western spadefoot habitat is potentially present in pools adjacent to the Uvas Creek bed. However, it would be highly unlikely that they would occur on the majority of the project site due to the long history of agricultural disturbance. • Foothill yellow - legged frog. The foothill yellow - legged frog is designated as a "Species of Special Concern" by the USFWS and CDFG. Foothill yellow - legged frogs primarily occur in upland areas near rock - bottomed creek breeding sites. No foothill yellow - legged frogs were observed on the project site during the 1993 and 1998 field surveys, and the NDDB does not contain any listings of occurrences of foothill yellow - legged frogs in the project vicinity. However, foothill yellow - legged frog habitat is potentially present in Uvas Creek. However, it would be highly unlikely that they would occur on the majority of the project site due to the long history of agricultural disturbance. California red - legged frog. The California red - legged frog is listed as threatened by the USFWS, and is designated as a "Species of Special Concern" by the CDFG. California red - legged frogs occur in different habitats depending on their life stage and the season. All life history stages are most likely to be encountered in and around breeding sites, which include many aquatic habitats, such as ponded and backwater portions of streams. Creeks and ponds where California red - legged frogs are found often have dense growths of woody riparian vegetation, especially willows. The presence of this kind of vegetation is an important indicator that the site may provide foraging or breeding habitat for California red - legged frogs. No California red - legged frogs were observed on the project site during the 1993 and 1998 field surveys. The NDDB lists known occurrences of red - legged frogs along Tick Creek (three to four miles south of Gilroy), near the intersection of Old Monterey Street with U.S. Highway 101 (four miles south of Gilroy), and along the Pajaro River near the U.S. Highway 101/25 interchange (four miles southeast of Gilroy). California red - legged frogs may potentially occur and breed in seasonal pools in the Uvas Creek channel, and may potentially disperse to the adjacent riparian woodland after the end of 2 -32 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting the rainy season. However, it would be highly unlikely that they would occur on the majority of the project site due to the long history of agricultural disturbance. Western pond turtle. The western pond turtle is designated as a "Species of Special Concern" by the USFWS and CDFG. Western pond turtles are aquatic turtles that live in ponds, marshes, rivers, streams, and irrigation ditches with aquatic vegetation. They need basking sites and suitable upland habitat (sandy banks or grassy open fields) for egg - laying. No western pond turtles were observed on the project site during the 1993 and 1998 field surveys, and the NDDB does not contain any listings of occurrences of western pond turtles in the project vicinity . Western pond turtles are potentially present in Uvas Creek Preserve north of the project site. Western pond turtle habitat is potentially present in pools adjacent to the Uvas Creek bed. However, it would be highly unlikely that they would occur on the majority of the project site due to the long history of agricultural disturbance. • Steelhead. Steelhead is listed as threatened by the NMFS but is given no special status by the CDFG. Steelhead spend the first few years of their lives in fresh water before migrating to the ocean. They return to their spawning grounds as adults to breed. Steelhead are known to migrate and spawn in gravel areas in Uvas Creek. • Burrowing owl. The burrowing owl is designated as a "Species of Special Concern" by the USFWS and CDFG. Burrowing owls nest and winter in burrows in the ground, especially in abandoned ground squirrel burrows. Optimal habitat conditions include large, open grasslands or prairies. No burrowing owls were observed on the project site during the 1993 and 1998 field surveys, and no California ground squirrels (Spermophilus beecheyi) or their burrows were observed during the field surveys. The NDDB lists known occurrences of burrowing owls along the Pajaro River near the U.S. Highway 101 /25 interchange (four miles southeast of Gilroy). Potential owl habitat exists along the slope of the levee in the northwest corner of the site. Raptor nests. Nesting raptors and active raptor nests (i.e., nests in which raptors are breeding or raising young) are protected by the CDFG. Raptors, including white - tailed kite, northern harrier, Cooper's hawk, and short -eared owl, could potentially maintain active raptor nests in the riparian woodland habitat on the project site during the breeding season. Urban Service Area Amendment Area The Urban Service Area amendment area contains all of the habitat types and the potential for all of the special - status species described above. The majority of the area contains agricultural fields with low habitat value. Uvas Creek and the associated riparian woodland habitat are located along the western boundary of the EMC Planning Group Inc. 2 -33 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Urban Service Area amendment area. The mature landscape trees associated with a former home site are located in the northwest corner of the Urban Service Area amendment area. Sports Park Area The sports park site contains all of the habitat types (with the exception of the mature landscape trees) and the potential for all of the special - status species described above. The majority of the sports park site contains agricultural fields with low habitat value. Uvas Creek and the associated riparian woodland habitat are located along the western boundary of the sports park site. Uvas Creek Trail The Uvas Creek trail will pass through all of the habitat types (with the exception of the mature landscape trees) with the potential for all of the special - status species described above. The northern end of the trail extension along the north side of Thomas Road - Luchessa Avenue is proposed to be constructed in an area currently vegetated with pines, live oaks, and small landscaping plants and shrubs. Some of the live oaks in this area could be considered to be "significant" trees as defined in the City of Gilroy Consolidated Landscaping Policy. "Significant" trees are defined to be native trees that are six inches or more in diameter at a point four and one half feet above the ground, as well as other trees that are important to the historical or visual aspect of Gilroy. After crossing Thomas Road - Luchessa Avenue, the Uvas Creek trail will pass through disturbed non - native grasses and thistles along the levee road and continue south approximately 50 feet from the top of the Uvas Creek bank and outside of the riparian woodland habitat. The trail will pass through the riparian corridor, another area containing "significant" trees, leading to and from a pedestrian bridge over Uvas Creek, and then continue south of Uvas Creek to Mesa Road and to Gavilan Community College. Recycled Water Line Area — Potential Uvas Creek Alignment The east side of the Uvas Creek levee is a potential alignment of the proposed recycled water distribution line. If the recycled water distribution line is built along this alignment, the distribution line would pass through open space behind residential areas and through agricultural land. , Project Analysis Urban Service Area Amendment Area No development plans currently exist for those areas of the Urban Service Area amendment outside of the sports park site and the Uvas Creek trail. These parcels are expected to remain in agricultural use in the near term. 2 -34 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Sports Park Area Development of the sports park site would result in the conversion of existing agricultural fields into play fields and facilities associated with the sports park. The existing agricultural fields do not represent a significant biological resource since the fields do not provide habitat for naturally occurring plants and provide only marginal habitat for wildlife. However, development of the sports park site may create increased night -time lighting and may allow increased access to Uvas Creek by people and domestic animals that could harm or kill wildlife species or disrupt the ability of wildlife to disperse or travel along the riparian corridor. Uvas Creek Trail Area Construction of the Uvas Creek trail will involve minor grading, excavation and paving outside of the existing riparian woodland habitat, as well as through a small part of the riparian habitat leading to and from a pedestrian bridge over Uvas Creek in the southwestern portion of the project site. The Uvas Creek trail will pass through areas containing trees on the north side of Thomas Road - Luchessa Avenue, in the riparian habitat, and on the north side of Mesa Road, and some of these trees may be "significant" trees as defined by the City of Gilroy Consolidated Landscaping Policy. The Uvas Creek trail is proposed to be located a minimum of 50 feet from the top of the Uvas Creek bank. Since the existing riparian corridor is no more than 25 feet wide (from creek centerline to edge of canopy) in most areas of the project site, and since riparian vegetation is absent in some areas along the creek, the proposed 50 -foot habitat buffer will substantially increase the amount of habitat and provide an adequate buffer since the area outside of the buffer will include the trail, native grass plantings, and /or turf areas associated with the sports park. No buildings or other permanent development is proposed to be located near the buffer area. The currently unvegetated portion of the 50 -foot buffer area west of the trail will be planted with locally - obtained native grasses and riparian species, which will replace the existing dirt road along the edge of the existing riparian corridor, as well as a portion of the existing agricultural fields west of the proposed pedestrian trail. The habitat buffer area will transition from native grasses near the pedestrian trail, to native shrubs and riparian understory vegetation near Uvas Creek. Wherever possible, the east side of the trail will be planted with native grasses or other native species to provide additional native habitat before giving rise to the turf playfields. Figures 14 and 15 illustrate the current and proposed condition along Uvas Creek, respectively. Recycled Water Line If the recycled water distribution line is installed east of the Uvas Creek levee, construction activities would include excavation and grading in open space and agricultural land separated from Uvas Creek by the levee. The potential exists that EMC Planning Group Inc. 2 -35 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR construction activities would cause erosion along the levee or that hazardous materials could spill and contaminate the riparian habitat. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: • have a substantial adverse effect, either directly or through habitat modifications, on any 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 Game or U.S. Fish and Wildlife Service; • have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; • conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (i.e., the City of Gilroy Consolidated Landscape Policy); and /or • conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional or state habitat conservation plan. No Impact —Loss of Habitat. Amending the Urban Service Area and construction of the sports park facilities in the eastern portion of the project site will not result in the loss of any vegetation or wildlife habitat. Due to continuous human interaction, agricultural fields typically provide little habitat for wildlife and do not represent a significant biological resource. Since the continuation of existing agricultural operations in the Urban Service Area amendment area will not affect biological resources on the project site, and construction of the sports park facilities in the eastern portion of the project site will not substantially diminish plant or wildlife habitat, there is no significant impact and no mitigation is required. - Beneficial Impact— Riparian Buffer. The Uvas Creek trail will be located a minimum of 50 feet from the top of the Uvas Creek bank. Since the existing riparian corridor is approximately 25 feet wide (from creek centerline to edge of canopy) in most areas of the project site, and since riparian vegetation is absent in some areas along the creek, the proposed 50 -foot habitat buffer will substantially increase the amount of native habitat and provide an adequate buffer. The 50 -foot buffer will be planted with native grasses and native shrub and riparian understory vegetation, which will replace the existing dirt road along the edge of the existing riparian corridor, as well as a portion of the existing agricultural fields west of the proposed pedestrian trail. No buildings or other permanent development is proposed to be located near the buffer area. The provision of a 50 -foot (minimum) habitat buffer is a beneficial impact. 2 -36 EMC Planning Group Inc. Source:The BealsGroup PRO ) I Gilroy Sports Park and USA Amendment EIR A Use Planning and Design Firm Current Conditions Along Uvas Creek and No Scale Figure 14 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -38 EMC Planning Group Inc. RIPARIAN CORRIDOR FACILITIES TRAIL PROTECTED HABITAT BUFFER C, OF GREEK Source:The BealsGroup No Scale Gilroy Sports Park and USA Amendment EIR Figure ALand Use Planning Firm rm Proposed Conditions Along Uvas Creek 15 and Design F Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2_40 EMC Planning Group Inc. J Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Potentially Significant Impact— Invasive Plant Species. The existing riparian habitat along Uvas Creek, as well as the proposed expansion of the habitat buffer, are sensitive areas that could be affected by the presence of non - native, invasive plant species. Any deterioration of habitat quality caused by the introduction of non - native, invasive plant species into the riparian habitat and /or buffer would be a potentially significant impact. Implementation of the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 4. Project plans, subject to the review and approval of the City of Gilroy Planning Division, shall include a habitat buffer designed to include appropriate native plant species and shall not include plantings of non- native, invasive plant species. The currently unvegetated portion of the 50- foot (minimum) buffer area west of the trail shall be planted with locally - obtained native grass, shrub and riparian understory species. Wherever possible, the east side of the trail shall be planted with native grasses or other native species to provide additional native habitat before giving rise to the turf athletic fields. Potentially Significant Impact —Loss of Significant Trees. The Uvas Creek trail along the north side of Thomas Road — Luchessa Avenue, along the north side of Mesa Road, and through the riparian habitat leading to and from the proposed pedestrian bridge passes through areas with trees. Some of the trees in these areas may be considered "significant" trees, as described in the City of Gilroy Consolidated Landscaping Policy. Although specific construction plans have not yet been prepared, tree removal may be necessary. Should the construction of the Uvas Creek trail require the removal of any significant trees, the loss of these trees could be a potentially significant impact. In addition, grading or other construction activities in or adjacent to significant trees that are not proposed for removal could result in injury to the trees. Should the construction of the Uvas Creek trail result in inadvertent injury and /or death to any significant trees not proposed for removal, the loss of these trees would be a potentially significant impact. Implementation of the following mitigation measures will reduce these potential impacts to a less than significant level. Mitigation Measures 5. Prior to the removal of any significant tree(s), a field survey shall be conducted by a certified arborist to determine the number and location of each significant tree to be removed, the type and approximate size of each significant tree, and the reason for removal. These findings shall be included in a written report that contains specifications for replacing significant trees to EMC Planning Group Inc. 2 -41 Section 2: Environmental Park and USA Amendment EIR be removed. The written report shall be prepared prior to the commencement of grading activities that take place along the north side of Thomas Road — Luchessa Avenue, along the north side of Mesa Road, and through the riparian habitat leading to and from the proposed pedestrian bridge, subject to approval by the City of Gilroy Planning Division. 6. Prior to the commencement of construction activities, the protected zone (one to 1.5 times the distance from the trunk to the dripline, depending on the tree species) of any trees or groups of trees to be retained shall be fenced to prevent injury to the trees during construction. Soil compaction, parking of vehicles or heavy equipment, stockpiling of construction materials, and /or dumping of materials shall not be allowed within the protected zone. The fencing shall remain in place until all construction activities are complete. The trees or groups of trees to be fenced shall be indicated in a written report prepared subject to approval by the City of Gilroy Planning Division. Significant Impact— Riparian Habitat. A portion of the Uvas Creek trail will pass through riparian woodland habitat leading to and from a pedestrian bridge over Uvas Creek. Riparian woodland habitat is protected by the CDFG. Removal of riparian woodland vegetation due to construction of the Uvas Creek trail would be a significant impact. Implementation of the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 7. Prior to commencement of trail construction activities the City of Gilroy Planning Division shall have a qualified biologist prepare a Habitat Mitigation Plan for approval by the City of Gilroy and the California Department of Fish and Game. The Habitat Mitigation Plan shall identify the exact amount and location of impacted and replacement habitat, and shall specify the use of locally - obtained native riparian species. Any loss of riparian woodland vegetation resulting from Uvas Creek trail construction activities shall be mitigated on -site within the 50 -foot (minimum) habitat buffer at a minimum 3:1 replacement ratio. Significant Impact— Riparian Habitat. A pedestrian bridge will be constructed over Uvas Creek to facilitate the extension of the Uvas Creek trail to Mesa Road and Gavilan Community College. Installation of the pedestrian bridge will involve construction work in the creek bed and /or banks to construct the bank abutments. This construction activity could introduce fill material into the creek and /or increase turbidity in the creek and interfere substantially with the movement of steelhead, which are known to occur in Uvas Creek, as well as other fish and aquatic wildlife species, resulting in a potentially significant impact. Implementation of the following mitigation measures will reduce this impact to a less than significant level. 2 -42 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Mitigation Measures 8. Prior to the commencement of bridge construction activities, a Section 1603 Streambed Alteration Agreement shall be obtained from the California Department of Fish and Game. Compliance with this mitigation measure may include, but not be limited to, the following: • Bridge construction work shall be initiated and completed during the summer and fall months when this portion of the creek is dry, or at least has a very low flow. Typically, no construction work shall be allowed in the creek between October 15 and early June. • From June to October 15, when construction is allowed, if any water is flowing in the creek, the flow shall be diverted into an open, gravel -lined bypass channel for the duration of the bridge construction work. Prior to commencement of bridge construction activities the City shall contact the U.S. Army Corps of Engineers to determine who has jurisdiction over the bridge construction activities and if a permit is required for bridge construction. 10. Prior to commencement of construction activities, siltation fencing or hay bales shall be installed along portions of Uvas Creek within 100 feet of construction and /or staging areas, or other erosion control measures shall be implemented to prevent sediment from filling the creek, subject to approval by the City of Gilroy Engineering Division. Potentially Significant Impact— Burrowing Owls. Potential burrowing owl habitat exists along the slope of the levee in the northwest corner of the project site. The Uvas Creek trail will be constructed along the top of the levee. Should active burrowing owl nests occur along the slope of the levee, any construction and site preparation activities within or immediately adjacent to nest habitat, if conducted during the nesting season, could result in the direct loss of nests, including eggs and young, or the abandonment of an active nest by the adults. Depending on the number and extent of burrowing owl nests on the site that may be disturbed or removed, the loss of active burrowing owl nests would be a potentially significant impact. Implementation of the following mitigation measures will reduce this impact to a less than significant level. Mitigation Measures 11. Subject to the review of the City of Gilroy Planning Division, no earlier than 45 days and no later than 20 days prior to commencement of grading or construction on or adjacent to the slope of the levee, field surveys shall be conducted at least four consecutive evenings by a qualified biologist to determine if burrowing owls are present in the construction zone or within 250 feet of the construction zone. These surveys shall be required only if any construction would occur during the nesting and /or breeding season of burrowing owls potentially nesting in the area (February 1 through August EMC Planning Group Inc. 2 -43 Section 2: Environmental Park and USA Amendment EIR 31) and /or during the winter residency period (December 1 and January 31). Pre - construction survey results shall be submitted to the California Department of Fish and Game for review and approval. If active nests are found in within the survey area, a burrowing owl habitat mitigation plan shall be submitted to the California Department of Fish and Game for review and approval. The burrowing owl habitat mitigation plan shall contain mitigation measures contained in the California Department of Fish and Game Staff Report on Burrowing Owl Mitigation (California Department of Fish and Game 1995). Compliance with this mitigation measure may include, but not be limited to, the following: • Avoidance of occupied burrows during the nesting season (February 1 through August 31); • Acquisition, protection and funding for long -term management and monitoring of foraging habitat adjacent to occupied habitat; • Enhancement of existing burrows and /or creation of new burrows; • , Passive relocation of burrowing owls. 12. Prior to commencement of construction activities, the city shall arrange for a qualified biologist to inform workers of the potential presence of the all special - status species, their protected status, work boundaries, and measures to be implemented to avoid loss of these species during construction activities. Potentially Significant Impact — Raptors. The riparian woodland habitat found along Uvas Creek contains potential nesting habitat for raptors, including white - tailed kite, northern harrier, Cooper's hawk, and short -eared owl, which are protected by the CDFG. Should active raptor nests occur in the area proposed for development (i.e., trail and bridge construction through the riparian corridor), any construction and site preparation activities within or immediately adjacent to nest habitat, if conducted during the nesting season, could result in the direct loss of nests, including eggs and young, or the abandonment of an active nest by the adults. Depending on the number and extent of raptor nests on the site that may be disturbed or removed, the loss of active raptor nests would be a potentially significant impact. Implementation of the mitigation measure presented above requiring a qualified biologist to inform construction workers of the potential presence of special- status species, and the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 13. Subject to the review of the City of Gilroy Planning Division, no earlier than 45 days and no later than 20 days prior to commencement of clearing, grading or construction in or adjacent to any riparian habitat, a field survey shall be conducted by a qualified biologist to determine if active raptor nests are present in the construction zone or within 250 feet of the construction zone. 2 -44 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting These surveys shall be required only if any construction would occur during the nesting and /or breeding season of raptors potentially nesting in the areas proposed for development (generally March 1 through August 1). If active nests are found within the survey area, at the discretion of the biologist, clearing and construction within 250 feet shall be postponed or halted until the nests are vacated and juveniles have fledged and there is no evidence of a second attempt at nesting. Potentially Significant Impact — Amphibians. The riparian woodland habitat found along Uvas Creek contains potential habitat for California red - legged frog, foothill yellow - legged frog, western spadefoot toad, California tiger salamander, and western pond turtle, which are protected by the USFWS and /or the CDFG. Should these species occur in the area proposed for development, any construction and site preparation activities within or immediately adjacent to the riparian woodland habitat, if conducted during the rainy season, could result in the direct loss of these species through injury or mortality from being crushed by construction equipment and materials, siltation and pollution of Uvas Creek, or consumption by predators attracted to the project site. Post- construction activities associated with uses at the sports park may result in incidental take of these species from being killed or harassed by pets and people, consumption by predators attracted to the project site, or killed or injured by contamination from use of chemical pesticides on turf areas. The loss of individuals of these protected species would be a potentially significant impact. Implementation of mitigation measures presented above, which require construction activities in or adjacent to Uvas Creek to occur when the creek is dry or has a very low flow (generally June through October 15), siltation fencing, hay bales or other erosion control measures to be installed along the portion of Uvas Creek occurring on the project site to prevent sediment from filling the creek, retention of a qualified biologist to inform construction workers of the potential presence of special- status species, and the following mitigation measures will reduce this impact to a less than significant level. Mitigation Measures 14. Subject to the review of the City of Gilroy Planning Division, a qualified biologist shall monitor the project site during construction activities within 100 feet of Uvas Creek. If California red - legged frog, foothill yellow - legged frog, western spadefoot toad, California tiger salamander, and /or western pond turtle turtles are observed at the site, construction activities shall be halted and the USFWS shall be contacted for further assistance. 15. All food - related trash items shall be enclosed in sealed containers and regularly removed from the project area to deter attraction of potential predators of the California red - legged frog, foothill yellow - legged frog, western spadefoot toad, California tiger salamander, and western pond turtle. Pets shall not be allowed on the construction site. The proper location of the trash containers shall be subject to the review and approval of the City of Gilroy Community Development Department. EMC Planning Group Inc. 2 -45 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Potentially Significant Impact— Habitat Disturbance During Construction. Construction vehicles and staging areas located near the riparian woodland habitat could potentially result in accidental spills of contaminants or other harmful materials, such as diesel fuel or oil, that could spread into the sensitive riparian woodland habitat and Uvas Creek and lead to harm or death of potential special - status species occurring in those areas. In addition, during the operations of the sports park, contamination of Uvas Creek could potentially occur from pesticides, fertilizers, and similar substances that are applied to the sports park athletic fields. The degradation of the riparian woodland and /or Uvas Creek, and the resulting harm or loss of special- status species, occurring as a result of contamination during construction or post- construction activities would be a potentially significant impact. Implementation of mitigation measures presented in Section 2.3 Hydrology which require a NPDES permit and a SCVWD permit, and the following mitigation measures will reduce this impact to a less than significant level. Mitigation Measures 16. Prior to the commencement of construction activities, a plan shall be prepared to allow a prompt and effective response to any accidental spills, and all workers shall be informed of the importance of preventing spills and of the appropriate measures to take should a spill occur, subject to approval by the City of Gilroy Engineering Division. This plan shall specify that all staging areas and all fueling and maintenance of vehicles and other equipment shall occur at least 100 feet from the riparian habitat and Uvas Creek. 17. Prior to approval of construction plans, guidelines shall be established for the prevention of contamination of the creek by pesticides, herbicides, fungicides, and fertilizers from maintenance of the athletic fields, subject to the review and approval of the City of Gilroy Engineering Division. The guidelines shall include a requirement for oil /grease separators to be installed in on -site storm drain systems and sweeping programs to be implemented for parking lots. Potentially Significant Impact— Habitat Disturbance During Recycled Water Line Construction. Construction activities on the Uvas Creek levee have the potential to produce erosion or accidental spills of contaminants or other harmful materials which could decrease habitat quality and interfere with the movement or well -being of special- status species potentially occurring in the riparian habitat. This would be a potentially significant impact. Implementation of mitigation measures presented above, which require siltation fencing, hay bales or other erosion control measures to be installed along the portion of Uvas Creek occurring on the project site to prevent sediment from filling the creek, and the preparation of a spill abatement and clean -up plan, would reduce this impact to a less than significant level. Potentially Significant Impact— Effects of Nighttime Lighting on Wildlife. Nighttime lighting of the sports park play fields may occasionally occur when night- time games are scheduled. Although nighttime lighting is not expected to occur daily or to remain on all night, lighting provided for the sports park could spill over 2 -46 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting into the riparian woodland habitat and could potentially disturb wildlife species occurring in the riparian habitat, restrict the movement or activity of wildlife species in the riparian habitat, or facilitate increased predation of wildlife species, which could potentially include special - status species. Restricted movement of wildlife species and increased predation of special- status species occurring as a result of increased levels of nighttime light would be a potentially significant impact. Implementation of the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 18. Prior to final project approval subject to the review and approval of the City of Gilroy Planning Division, a lighting plan for the sports park shall be developed. This lighting plan shall include at least the following elements: • All lighting in the western portion of the sports park will be directed away from the riparian habitat; • No lighting will be installed along the Uvas Creek Trail; and • No lighting will generally be allowed after 11:00 PM. Potential Impact— Domestic Activities. People and unleashed pets wandering off of the Uvas Creek Trail could potentially restrict the movement or activity of and /or disturb or kill wildlife species in the riparian woodland habitat and Uvas Creek, which could potentially include special- status species. Restricted movement of wildlife species and disturbance or death of special - status species occurring as a result of increased human and domestic animal activity would be a potentially significant impact. Implementation of the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 19. Prior to final project approval, a signage plan for the sports park shall be prepared to outline the language, number and location of signs to dissuade people from straying off the Uvas Creek Trail and to prohibit unleashed dogs on the Uvas Creek trail, subject to approval by the City of Gilroy Planning Division. 2.6 Transportation /Circulation Environmental Setting A transportation impact analysis was prepared by Fehr and Peers Associates, Inc. in December 1998. That report is included in the Technical Composite, available for EMC Planning Group Inc. 2 -47 Section 2: Environmental Setting Gilroy Sports Park and LISA Amendment EIR review at the City of Gilroy Community Development Department. The report specifically addresses transportation impacts of the proposed sports park. The following discussion is based on that report. No specific development plans exist for the remaining parcels on the project site. At this time those parcels are expected to remain in agricultural use. Regional Transportation Setting Figure 16 shows the existing transportation network in the project vicinity. Roadway Network. U.S. Highway 101 and State Highway 152 provide regional access to the project site. Local access is provided by Monterey Street (or Road), Monterey Frontage Road, Thomas Road — Luchessa Avenue and Princevalle Street. U.S. Highway101 transitions from a four -lane freeway (to the south) to a six-lane freeway (to the north) in the vicinity of the project site. South of Monterey Street, U.S. Highway 101 becomes a four -lane highway, and north of Cochrane Road, it is a four-lane freeway. U.S. Highway 101 extends northward to San Jose, San Francisco and beyond and southward to Salinas and beyond. Access to and from the project site is provided via the U.S. 101 interchange at Monterey Street. Monterey Street is generally a four -lane arterial through the City of Gilroy. Through downtown Gilroy (between Third Street and Seventh Street), Monterey Street narrows to two travel lanes, with angled parking on the east side of the street and a raised median. North of the city limits, Monterey Street is a rural highway with four travel lanes and a center turn lane. Monterey Street continues northward into San Jose. South of its interchange with U.S. 101, Monterey Street becomes Bolsa Road. Near the project site, the speed limit on Monterey Street is 50 miles per hour. (Monterey Street is officially Monterey Road in places; for simplicity's sake, this EIR uses Monterey Street throughout). Monterey Frontage Road is a two -lane road that extends southward from Monterey Street ending in a cul -de -sac south of the project site. Monterey Frontage Road provides direct access to the project site (and other properties). Thomas Road — Luchessa Avenue is a two -lane roadway, which extends northward from Santa Teresa Boulevard to Uvas Creek and then continues eastward. The City of Gilroy is currently in the process of changing the name of this roadway. The north /south segment between Santa Teresa Boulevard and Luchessa Avenue (where the road curves to the east) will remain Thomas Road. The segment from the curve to Monterey Street will be renamed Luchessa Avenue. The roadway segment east of Monterey Street is currently named Luchessa Avenue. Near the project site, the speed limit on this arterial roadway is 40 mph. Princevalle Street is a two -lane residential collector street that extends northward from Luchessa Avenue to First Street. 2 -48 EMC Planning Group Inc. Road Gilroy Golf Course a �ro o� m GI Sports Park Site Pro ec{. 0 Additional !! USA Amendment Area It Caltrain Station Gavilan nnesa Hoad - College � o• Source: California Automobile Association and EMC Planning Group Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land u aand se Firm Existing Transportation Network 16 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -50 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Transit Service. The Santa Clara Valley Transportation Authority (VTA) operates public transit service in Santa Clara County. Bus route 68 operates along Princevalle Street, north of Luchessa Avenue — Thomas Road and along Thomas Road, west of Princevalle Street. Route 68 provides service between San Jose Diridon Station and Gavilan Community College in Gilroy. Hours of operation are 4:30 AM to 1:00 AM on weekdays and 6:00 AM to 12:30 AM on weekends. Route 68 operates on a 15- minute headway during the commute hours and a 30- to 60- minute headway during other hours. Commuter rail service (CalTrain) is provided from Gilroy to San Francisco by the Joint Powers Board. CalTrain provides frequent train service between San Jose and San Francisco seven days a week. Extended service is provided to Morgan Hill and Gilroy during the weekday commute hours only. The Gilroy CalTrain station is located east of Monterey Street between Seventh and Ninth Streets, approximately 1.5 miles from the proposed sports park. Pedestrian and Bicycle Facilities. Pedestrian facilities include sidewalks, crosswalks, and pedestrian signals. There are no pedestrian facilities near the project site. A sidewalk is provided along the north side of Thomas Road — Luchessa Avenue between Monterey Street and Princevalle Street to the north of the project site. Sidewalks are not provided along Monterey Frontage Road or Monterey Street. Bicycle facilities include bike paths, bike lanes, and bike routes. Bike paths are paved trails that are separated from the roadway. Bike lanes are lanes on roadways that are designated for use by bicycles by striping. Bike routes are roadways that are designated for bicycle use with signs only. Currently, no bicycle facilities directly serve the project site. There is a bike path along the eastern side of Uvas Creek between Thomas Road — Luchessa Avenue and Westwood Avenue, north of the site. Bike lanes are designated on Princevalle Street from several blocks north of Thomas Road — Luchessa Avenue to Sixth Street. Existing Traffic Volumes, Lane Configurations and Level of Service There are currently four rural residences, agricultural lands and one commercial use located on the project site. Traffic generation from these uses is very low. The Uvas Creek Trail is currently an unpaved service road and farm road. Traffic on this road is minimal. Very little traffic is generated by existing uses on the project site. The transportation impact analysis identified the intersections of Monterey Street and Monterey Frontage Road, Thomas Road - Luchessa Avenue and Church Street and Thomas Road — Luchessa Avenue and Princevalle Street as key intersections for analysis. The operation of these intersections was evaluated for weekday evening (PM) and Saturday peak traffic conditions. The weekday PM peak conditions generally occur during the evening commute hours between 4:00 PM to 6:00 PM, Monday through Friday. The Saturday peak conditions generally occur between 1:00 PM and 3:00 PM. Intersection operations were evaluated for one hour during this period. Manual turning movement counts were conducted at the study EMC Planning Group Inc. 2 -51 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR intersections on Saturday, October 24, Wednesday, December 16 and Saturday December 19,1998 to obtain peak hour volumes. Additional weekday PM peak hour traffic counts were conducted by the City of Gilroy in 1998. Figure 17 shows the existing weekday PM and Saturday peak hour turning movement volumes at the key intersections. The intersection lane configurations are presented in Figure 18. Level of Service (LOS) is a qualitative description of an intersection's operation, ranging from LOS A, or free -flow conditions, to LOS F, or over - saturated conditions. The City of Gilroy's standard for unsignalized intersections, as well as signalized intersections and roadway segments is LOS C. Intersection levels of service were calculated for key intersections using the methodology presented in Chapter 10 of the 1994 Highway Capacity Manual for two -way stop - controlled intersections. This methodology evaluates an intersection's operation based on the total average delay at an intersection. The total delay for the unsignalized intersections was calculated using TRAFFIX analysis software and then correlated to a level of service. The level of service thresholds for two -way stop - controlled intersections are presented in Table 4. TABLE 4 Two -Way Stop - Controlled Intersection Level of Service Definitions Using Average Total Vehicular Delay Level of Service Average Total Delay Per Vehicle (Seconds) A < 5.0 B 5.1 to 10.0 C 10.1 to 20.0 D 20.1 to 30.0 E 30.1 to 45.0 F > 45.0 Source: Transportation Research Board, Highway Capacity Manual, Special Report 209,1994 Current operations of the key intersections are presented in Table 5. The results of the LOS calculations indicate that the key intersections are operating at a good level of service currently. Overall intersection operations at the intersections are at LOS A during the weekday PM and Saturday peak hours. 2 -52 EMC Planning Group Inc. -1 u I L Key: O= Study Intersection 00 (00) = PM (Saturday) Source: Fehr and Peers Associates Inc. No Scale Gilroy Sports Park and USA Amendment EIR ® Figure A Land Use Pla Existing Weekday PM and Planning Existing and Design Firm Saturday Peak Traffic Volumes Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -54 EMC Planning Group Inc. Key: O= Study Intersection T = Stop Sign Source: Fehr and Peers Associates Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land. Use Planning Existing Intersection Lane �� and Design Firm Configurations Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -56 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting TABLE 5 Existing Intersection Levels of Service Average total intersection delay for unsignalized intersections expressed in seconds per vehicle. LOS calculations were performed using TRAFFIX, and the 1994 Highway Capacity Manual methodology for two -way stop - controlled intersections Source: Fehr and Peers Associates, Inc. TABLE 6 Approved Developments in the Vicinity of the Project Site Development Weekday PM Peak Saturday Peak Average LOS Average LOS Intersection Delay East of Monterey Street; east of Delay Monterey Street and Monterey 0.6 A 0.2 A Frontage Road storage Eagle Ridge West of Santa Teresa Thomas Road — Luchessa Avenue 1.2 A 0.9 A and Princevalle Street The Villas West end of Oakbrook Drive, 75 single - family residential units Thomas Road— Luchessa Avenue 0.8 A 0.9 A and Church Street Luchessa Avenue Average total intersection delay for unsignalized intersections expressed in seconds per vehicle. LOS calculations were performed using TRAFFIX, and the 1994 Highway Capacity Manual methodology for two -way stop - controlled intersections Source: Fehr and Peers Associates, Inc. TABLE 6 Approved Developments in the Vicinity of the Project Site Development Location Use and Size Motel 6 East of Monterey Street; west of 129 rooms (replacing 56 rooms) U.S. Highway 101 Truck Stop East of Monterey Street; east of Overnight truck stop, gas station, U.S. Highway 101 convenience market, fast food restaurant, motel, and mini storage Eagle Ridge West of Santa Teresa 650 single- family and townhouse Boulevard, between Third units, 18-hole golf- course Street and Miller Avenue The Villas West end of Oakbrook Drive, 75 single - family residential units west of Thomas Road The Uplands West of Thomas Road; north of 60 single - family residential units Luchessa Avenue Source: Fehr and Peers Associates, Inc. and City of Gilroy . The weekday PM peak hour trip information for these projects was obtained from the traffic analysis reports prepared for each development. Traffic associated with EMC Planning Group Inc. 2 -57 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR these developments during the Saturday peak hour was estimated using trip generation rates in the Institute of Transportation Engineers Trip Generation (6' Edition) and the trip distribution information provided by the City of Gilroy. The traffic associated with the approved developments was added to the existing volumes at the key intersections to estimate traffic volumes for background conditions. Figure 19 illustrates the traffic volumes estimated at the key intersections for background conditions. Background Intersection Level of Service The results of the level of service calculations for background conditions are presented in Table 7. The key intersections will continue to operate at LOS A with the addition of traffic associated with already approved developments. TABLE 7 Background Intersection Levels of Service The average total intersection delay is expressed in seconds per vehicle. LOS calculations were performed using the CMF level of service analysis program, TRAFFIC, and the 1994 Highway Capacity Manual methodology for two -way stop - controlled intersections. Source: Fehr and Peers Associates, Inc. Project Analysis The transportation impact analysis specifically addresses transportation impacts of the proposed sports park. Additional traffic studies would be required when future development occurs on the remaining parcels within the project site. The potential transportation impacts of the proposed sports park and related on -site and off -site improvements are discussed below. 2 -58 EMC Planning Group Inc. Weekday PM Peak Saturday Peak Average LOS Average LOS Intersection Delay Delay (seconds) (seconds) Monterey Street and 0.8 A 0.5 A Monterey Frontage Road Thomas Road — Luchessa 1.2 A 0.8 A Avenue and Princevalle Street Thomas Road — Luchessa 0.8 A 0.8 A Avenue and Church Street The average total intersection delay is expressed in seconds per vehicle. LOS calculations were performed using the CMF level of service analysis program, TRAFFIC, and the 1994 Highway Capacity Manual methodology for two -way stop - controlled intersections. Source: Fehr and Peers Associates, Inc. Project Analysis The transportation impact analysis specifically addresses transportation impacts of the proposed sports park. Additional traffic studies would be required when future development occurs on the remaining parcels within the project site. The potential transportation impacts of the proposed sports park and related on -site and off -site improvements are discussed below. 2 -58 EMC Planning Group Inc. ♦/n ry ` n r 63(32) 298(117) 38(25)-w 38(25)-w 168(165) y Key: O= Study Intersection 00 (00) = PM (Saturday) Source: Fehr and Peers Associates Inc. I Gilroy Sports Park and USA Amendment EIR A Land Use Planning Background Traffic Volumes and Design Firm No Scale Figure 19 N 01 ,c V-103(35) .°n N m r U X224 (141) -p m F 31 (20) Tenth St. 147 (134) N m 0 S o a` m 14 m m` 27 (6) � a(a) t r o 11(3) zpq NnN Key: O= Study Intersection 00 (00) = PM (Saturday) Source: Fehr and Peers Associates Inc. I Gilroy Sports Park and USA Amendment EIR A Land Use Planning Background Traffic Volumes and Design Firm No Scale Figure 19 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2 -60 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Sports Park - Related Traffic The amount of traffic associated with the proposed sports park was estimated using a three -step process: trip generation; trip distribution; and trip assignment. In the first step, the projected traffic volumes that would enter and exit the sports park site were estimated for the PM peak and Saturday peak periods. In the second step, the general directions the trips would approach from or depart to were estimated. The trips were assigned to specific street segments and intersection turning movements in the third step. Sports Park Trip Generation. Peak hour trip generation was estimated based on the proposed number and types of playing fields and other uses, as well as input from the project architect on the expected operation of the sports park. The trip generation estimates assumed the use of all softball /baseball fields at one time. The softball /baseball fields overlay the soccer fields, so both would not be in use at the same time. Basing the trip generation on the use of all softball /baseball fields was more conservative than assuming the use of all soccer fields. Soccer teams are likely to have slightly fewer players than softball /baseball teams (12 players per soccer team compared to 15 to 18 per softball /baseball team) and there are fewer proposed soccer fields than softball /baseball fields (seven soccer fields compared to 13 softball /baseball fields). Trip generation estimates were developed for the weekday PM peak and Saturday peak periods. Estimates were made based on the following assumptions: • 30 players per field for softball and Little League and 36 players per field for Colt baseball; • One spectator per player for softball and colt baseball and 35 spectators per Little League game. (This represents slightly more than one spectator per player to reflect more parents watching their children); • Automobile occupancy rate of 2.0 persons per vehicle for softball and Colt baseball and 2.1 persons per vehicle for Little League. (The higher occupancy for Little League reflects more parents arriving with children); • 75 percent of the games beginning or ending during the peak hour, with the players and spectators associated with these games arriving or leaving during that hour; • Commercial recreation, general park use, and special events would add 200 trips (half inbound and half outbound) during the Saturday peak hour; and • Weekday PM peak hour trip generation would be 75 percent of the Saturday peak hour trip generation for softball and baseball games and 50 percent of Saturday peak hour trip generation for general park use, commercial recreation and special events. EMC Planning Group Inc. 1 2 -61 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Given these assumptions, the proposed project would generate approximately 550 weekday PM peak hour trips (275 inbound and 275 outbound) and 800 Saturday peak hour trips (400 inbound and 400 outbound). The trip generation estimates are presented in Table 8 by phase. TABLE 8 Trip Generation Estimates Phase Uses Weekday PM Peak Saturday Peak Hour Hour Trips . Trips (In plus Out) (In plus Out) I Access Road 0 0 II 1 Colt Baseball Field and 112 148 2 Little League Fields II 1 Softball Field and 68 116 Commercial Recreation IV 4 Softball Fields 156 220 V 4 Softball Fields 156 220 VI & 1 Softball Field and General 58 96 VII Park Development VIII & Roadway Improvements 0 0 XI and South Uvas Creek Trail Extension Project build -out is expected to occur over a 20 -year period. Source: Fehr and Peers Associates, Inc. Sports Park Trip Distribution. The trip distribution pattern for the sports park was estimated based on existing travel patterns in the vicinity of the site and the relative locations of complementary land uses in the area. The major directions for project - generated traffic to approach and depart the project site are estimated to be: 30 percent to and from the west on Thomas Road — Luchessa Avenue; 10 percent to and from the north on Princevalle Street; 15 percent to and from the north on Church Street; 10 percent to and from the north Monterey Street; 20 percent to and from the north on U.S. Highway 101; 2_62 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting 10 percent to and from the south U.S. Highway 101; and 5 percent to and from the neighborhoods north of Thomas Road — Luchessa Avenue, west of Monterey Street. This trip distribution pattern is illustrated in Figure 20. Sports Park Trip Assignment. The trips generated by the proposed sports park were assigned to the roadway system based on the directions of approach and departure discussed above. Figure 21 presents the peak hour project trip assignments by turning movement at the study intersections and on nearby roadway segments for build -out conditions. The projected sports park trips for each phase were added to the traffic volumes for Background Conditions to achieve turning- movement volumes at the key intersections for each phase of the project. The total traffic volumes under "with project" conditions are shown in Figure 22. Background Plus Sports Park Intersection Levels of Service Intersection level of service calculations were conducted to evaluate the operating conditions of the key intersections with project traffic added to background traffic to determine the potential impacts of the proposed sports park on the local roadway system. The intersection operations were evaluated for the completion of each phase of the sports park. The results of the intersection level of service calculations for background plus sports park conditions are summarized in Table 9. Operations at the Monterey Street /Monterey Frontage Road intersection are projected to be acceptable (LOS C or better) during both peak hours through the completion of Phase IV. With the completion of Phase V, overall intersection operations are projected to deteriorate to LOS D during the weekday PM peak hour and LOS F during the Saturday peak hour. With the completion of Phases VI and VII, intersection operations during both peak hours are projected to be LOS F. Both of the Thomas Road — Luchessa Avenue intersections are projected to remain at LOS A through all phases of sports park development. U.S. Highway 101 Segment Level of Service According to Congestion Management Plan guidelines, freeway segments to which a proposed development is projected to add trips equal to or greater than one percent of the freeway segment's capacity must be evaluated. The segment of U.S. Highway 101 south of Monterey Street is not a freeway (it is a four -lane divided highway); however, no methodology is identified in the Congestion Management Plan guidelines for highways, so the freeway methodology was applied. EMC Planning Group Inc. 2 -63 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR TABLE 9 Background Plus Sports Park Intersection Levels of Service Monterey Street and Monterey Frontage Road At Completion of Project Phase Weekday PM Peak Saturday Peak Average Delay (seconds) LOS Average Delay (seconds) LOS Background 0.8 A 0.5 A Phase I & H 1.7 A 1.4 A Phase III 2.5 A 2.3 A Phase IV 6.0 B 6.1 B Phase V 28.4 D 45.6 F Phase VI & VII 60.0 F 117.1 F Thomas Road - Luchessa Avenue and Princevalle Street At Completion Weekday PM Peak Saturday Peak of Project Average Delay LOS Average Delay LOS Phase (seconds) (seconds) Background 1.2 A 0.8 A Phase I & 1[ 1.3 A 0.9 A Phase 111 1.9 A 1.0 A Phase IV 1.4 A 1.1 A Phase V 1.6 A 1.2 A Phase VI & VII 1.6 A 1.3 A Thomas Road - Luchessa Avenue and Church Street At Completion of Project Phase Weekday PM Peak Saturday Peak Average Delay (seconds) LOS Average Delay (seconds) LOS Background 0.8 A 0.8 A Phase I & II 0.9 A 0.9 A Phase III 1.0 A 1.0 A Phase IV 1.2 A 1.2 A Phase V 1.4 A 1.5 A Phase VI & VII 1.5 A 1.6 A EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Phase I does not include trip generating uses. Phase I operations would be the same as Background. Phase VI & VII is equal to project build -out conditions. Phases VIII and IX do not generate additional traffic. The average total intersection delay is expressed in seconds per vehicle. LOS calculations were performed using the CMP level of service analysis program, TRAFFIX, and the 1994 Highway Capacity Manual methodology for two -way stop - controlled intersections. Source: Fehr and Peers Associates, Inc. GSegments of U.S. Highway 101 were reviewed to determine if a significant amount of sports park traffic would be added to these segments during the weekday PM peak hour. Capacities of 2,200 vehicles per hour per lane (vphpl) for four -lane segments and 2,300 vphpl for freeway segments with six or more lanes were used in the analysis. Table 10 presents the capacities of each segment, the estimated number of trips added to each segment by the proposed development during the PM peak hour, and whether or not the freeway segment must be evaluated in greater detail. None of the U.S. Highway 101 segments required further analysis. TABLE 10 Background Plus Sports Park Freeway Segment Analysis (Weekday PM Peak Hour) Segment Capacity 1% of Project Requires Capacity Trips Analysis? Northbound U.S. Highway 101, 6,900 69 55 No Tenth Street to Monterey Street Southbound U.S. Highway 101, 6,900 69 55 No Tenth Street to Monterey Street Northbound U.S. Highway 101, 4,400 44 28 No Monterey Street to Castro Valley Road " Southbound U.S. Highway 101, 4,400 44 28 No Monterey Street to Castro Valley Road A capacity of 2,200 vehicles per hour per lane was used for four -lane highway segments and a capacity of 2,300 vehicles per hour per lane was used for freeway segments with six or more lanes. Source: Fehr and Peers Associates, Inc. EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Monterey Street/Monterey Frontage Road Pedestrian Improvements Proposed Facilities. As part of the proposed sports park development, six -foot wide sidewalks would be constructed along the west side of Monterey Frontage Road between Monterey Street and the park entrance and ten -foot sidewalks would be constructed along the west side of Monterey Street between Thomas Road — Luchessa Avenue and Monterey Frontage Road. Crosswalks are proposed across the north leg of the Monterey Street /Monterey Frontage Road intersection and the entire Thomas Road — Luchessa Avenue /Monterey Street intersection. A pedestrian island is proposed in conjunction with the crosswalk at Thomas Road — Luchessa Avenue and Monterey Street. Analysis. It is recommended that the crosswalk across Monterey Street at Monterey Frontage Road not be provided until traffic signal installation occurs at this intersection. The high travel speeds on Monterey Street (in excess of 50 mph) and the 120 -foot width of the street make it hazardous for pedestrians to cross without the protection of a traffic signal. The City of Gilroy plans to install a traffic signal, including crosswalks and pedestrian signals, at the intersection of Thomas Road — Luchessa Avenue and Monterey Street in Spring 1999. Proposed project improvements along Monterey Street should be coordinated with the city's planned improvements. Uvas Creek Trail Proposed Facilities. The project proposes to extend the Uvas Creek Trail from Thomas Road — Luchessa Avenue through the sports park and then southward to Gavilan College. The proposed trail crossing of Thomas Road — Luchessa Avenue in the near -term is at the intersection of Thomas Road — Luchessa Avenue with Princevalle Street. A future under- crossing at the Uvas Creek bridge located west of Princevalle Street is planned but not a part of the proposed project. The proposed near -term crossing at Princevalle Street would include construction of a separated paved trail along the north side of Thomas Road — Luchessa Avenue between the existing trail and Princevalle Street. The trail would then cross to the south side of Thomas Road — Luchessa Avenue. The trail would then follow along the south side of Thomas Road— Luchessa Avenue to the point where the existing levee top road meets Thomas Road — Luchessa Avenue. From there the trail would follow the levee top until it reaches the sports park site. Analysis., The extension of the Uvas Creek Trail will allow pedestrians and bicyclists to access the site from Thomas Road — Luchessa Avenue and the neighborhoods to the north. The proposed temporary alignment will require a pedestrian and bicycle crossing of Thomas Road — Luchessa Avenue at Princevalle Street. This T- intersection is controlled by a stop sign on the southbound Princevalle Street approach. This intersection is operating at acceptable levels of service currently and is projected to continue to operate at acceptable levels with build -out of the proposed sports park. Under build -out conditions, this intersection will not warrant a traffic signal. As land is developed in the area, traffic volumes along Thomas Road — Luchessa Avenue will increase and a signal may be warranted. 2 -66 EMC Planning Group Inc. I '4 a h Key: OStudy Intersection Source: Fehr and Peers Associates Inc. No Scale ® Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Trip Distribution Patterns 20 and Design Finn Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR J, i This side intentionally left blank. 2_68 EMC Planning Group Inc. 0 �S y �I I Key: OStudy Intersection XX (XX) = PM (Saturday) Source: Fehr and Peers Associates Inc. No Scale Gilroy Sports Park and USA Amendment EIR Peak Hour Figure A Land Use Planning r� and Design Firm Project- Related Trips L Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2_70 EMC Planning Group Inc. 1� I q I e s 1 'd N i .I 11 / ar « V_ 113(104) I �— 414(2a5) 38(25) 284(333)" °w m —136(83) X307 (281) 37 (17) 1 230 (254) y N Key: O= Study Intersection 00 (00) = PM (Saturday) Source: Fehr and Peers Associates Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Project Conditions 22 and Design Firm Traffic Volumes 1 I HEN 19 (13) m 220;(286) Sd *17 a ► 1 �B 94.(123) �..n H Key: O= Study Intersection 00 (00) = PM (Saturday) Source: Fehr and Peers Associates Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Project Conditions 22 and Design Firm Traffic Volumes Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR f This side intentionally left blank. 1 2_72 EMC Planning Group Inc. i� Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting This temporary alignment would result in a detour of approximately 350 feet on the south side of Thomas Road — Luchessa Avenue. It is probable that rather than follow this route over the extra distance, that pedestrians and bicyclists would cross either cross Thomas Road — Luchessa Avenue directly at the point where the trail first meets Thomas Road — Luchessa Avenue, or cut up or down the levee embankment at the Princevalle Street intersection. Due to travel speeds in excess of 40 miles per hour along Thomas Road — Luchessa Avenue, a crosswalk is not recommended without a pedestrian signal or all -way stop controls. According to Caltrans' "Warrant 3 - Minimum Pedestrian Volume" a signal is considered necessary if pedestrian volume in the crossing reaches a level of 100 or more for each of any four hours or 190 or more during any one hour during an average day. Data provided in the Santa Clara County Countywide Trails Master Plan (July 1995) indicates that usage of the Uvas Creek Trail (measured at Miller Avenue) was about 260 persons on a Saturday and 150 persons on a Tuesday in May 1994. While these use volumes do not warrant a pedestrian crossing, this street crossing will be utilized in the near -term as a connection for the Uvas Creek Trail and is expected to receive considerable use by bicyclists and pedestrians accessing the sports park. Transit Improvements Proposed Facilities. The sports park site plan shows a bus stop and turn around area on Monterey Frontage Road south of the project entrance. City staff has indicated that the VTA will extend service when other development in this area (including hotels and other commercial development along Monterey Street) generate sufficient demand for bus service. Analysis. This bus stop and turn around should be designed to VTA standards. Pedestrian access should be provided from the bus stop to the park, including a sidewalk along Monterey Frontage Road that connects to the internal pedestrian r; paths. It would be preferable that the bus stop location be on the same side of Monterey Frontage Road as the proposed sports park, to reduce potential conflicts between pedestrians crossing the street and automobiles entering or exiting the �i sports park, and to provide the most convenient transit access. The proposed bus stop location is on the opposite side of Monterey Frontage Road from the sports park site, though it is located beyond the sports park driveway and conflicts between crossing pedestrians and automobiles should be minimal. Site Access, On -Site Circulation, and Parking Site Access. The Gilroy Sports Park will be served by one driveway on Monterey Frontage Road. The intersection of the driveway with Monterey Frontage Road will be controlled by a stop sign on the driveway approach (exiting the sports park). During the worst case peak hour on a Saturday, 400 vehicles are projected to exit the EMC Planning Group Inc. 2-73 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR site during one hour. Due to the low volumes along Monterey Frontage Road (currently 17 vehicles during the Saturday peak hour and 56 vehicles during the weekday PM peak hour), the intersection of the access road with Monterey Frontage Road is projected to operate at LOS A. Entry to the park will be controlled by a cashier at the entry building located approximately 500 feet from the intersection of the access road with Monterey Frontage Road. A flat parking fee would be charged to vehicles entering the park with some park users, such as tournament players and members of league teams, using passes provided in advance. The hourly design capacity for a parking entrance with a cashier and a flat fee is approximately 300 vphpl. The project proposes to have two entry lanes. The highest inbound volume to the park is expected to occur during the Saturday peak hour. The estimated hourly peak _ volume is 400 vehicles. The 95' percentile queue was calculated using a Poisson distribution, a capacity of 300 vphpl, two entry lanes, and a peak volume of 400 vph. The maximum queue would be approximately 175 feet in each of two lanes. The 500 -foot storage length would be sufficient to serve this queue. Two turn - around areas are provided along the entry road: one between the park gates and Monterey Frontage Road and a second west of the entry building. These turn- around areas will allow vehicles arriving after the park has closed (or wishing to exit for other reasons) to make U -turns and exit the park. On -Site Circulation. On -site circulation was reviewed and generally found to be adequate. Pedestrian paths and sidewalks are located throughout the park and provide adequate internal pedestrian circulation and connections to the Uvas Creek Trail and Monterey Frontage Road. Pedestrian paths along the perimeter of the park are 12 feet -wide and double as emergency access roadways. Parking. The parking demand was estimated in a manner similar to trip generation, based on the planned operation of the sports park and assumptions regarding numbers of persons per vehicle for the different uses within the park. The parking demand after build -out of the park is estimated to be 996 parked vehicles. The recommended parking supply is the parking demand plus five percent to account for circulating vehicles. Therefore, the recommended parking supply for the Gilroy Sports Park is 1,047 spaces. The site plan includes 1,049 parking spaces, which will adequately serve the projected demand. A shortfall is projected to occur after the completion of Phase V. It is recommended that 180 of the 298 parking spaces that will be constructed with Phase VI be constructed instead with Phase V to offset the projected shortfall. The parking demand estimates and recommended supply by phase are presented in Table 11. C' 2 -74 EMC Planning Group Inc. ,1 0 Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting TABLE 11 Parking Demand and Supply Phase Cumulative Demand Cumulative Supply Recommended Provided Difference I 0 0 117 +117 II 196 206 278 +72 III 326 343 439 +96 IV 606 637 751 +114 V 886 931 751 -180 VI & VII 996 1047 1049 +2 VII & IX 996 1047 1049 +2 Source: Fehr and Peers Associates, Inc. The City of Gilroy Zoning Ordinance does not include an off - street parking requirement for ballparks. The most similar land use included in the ordinance is a theater or auditorium with fixed seats. The parking requirement for this lane use is one parking spaces per four seats or seven feet of bench space. The proposed sports park will have approximately 300 feet of bench space for each of the 13 ball fields, for a total of 3,900 feet of bench. The required off - street parking supply would be 558 spaces. The proposed 1,049 parking spaces would be sufficient to meet this requirement. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would • cause an increase in traffic that is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicles trips, the volume to capacity ratio on roads, or congestion at intersections); • exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways; • result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks; Planning Group Inc. 2-75 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR • substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? • result in inadequate emergency access; • result in inadequate parking capacity; or • conflict with adopted policies, plans or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks). Significant Impact —LOS Below City Standards. With completion of Phase V of the proposed project, the level of service at he intersection of Monterey Street and Monterey Frontage Road would be LOS D during the weekday PM peak hour and LOS E during the Saturday peak hour. This level of service does not meet the standards for roadway operation as contained in the City of Gilroy General Plan. This is a significant adverse environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure 20. Prior to completion of Phase IV of the proposed project the City of Gilroy �= shall install a traffic signal at the intersection of Monterey Street and 1 Monterey Frontage Road. The minimum lane configuration shall be: ^ • Southbound Approach - one left -turn lane, one through lane, one shared ' through /right -turn lane; • Westbound Approach - one shared lane for all movements; �^ • Northbound Approach - one left -turn lane, one through lane, one shared through /right -turn lane; • Eastbound Approach - one shared lane, one left -tum lane for all movements. Protected left -turn phasing shall be provided for the northbound and southbound approach, while a single signal phase shall be provided to serve r. the eastbound and westbound approaches. Less Than Significant Impact —State Highway Traffic. The project is estimated to not add traffic equal to or greater than one percent of the capacity to the four nearby freeway segments. Therefore the project's impact on the segments of U.S. Highway 101 in the study area is estimated to be less than significant and no mitigation measures are required. Significant Impact — Bicyclist and Pedestrian Safety. The temporary alignment of the Uvas Creek Trail crossing of Thomas Road — Luchessa Avenue would require a detour of approximately 350 feet in order to reach the street crossing point. It is probable that rather than follow this route over the extra distance, that pedestrians EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting and bicyclists would either cross Thomas Road — Luchessa Avenue directly at the point where the trail first meets Thomas Road — Luchessa Avenue, or cut up or down the levee embankment at the Princevalle Street intersection. This design would result in a potential safety hazard to users of the trail. This potential safety problem would be a significant environmental impact. Implementation of the following mitigation measures would reduce this impact to a less than significant level. Mitigation Measure 21. The final improvement plan for the Uvas Creek Trail extension, subject to the review and approval of the City of Gilroy Engineering Division, shall include a connection to Thomas Road — Luchessa Avenue that leaves the top of the levee at a point east of Princevalle Street and connects to Thomas Road— Luchessa Avenue at the intersection of Princevalle Street via a built -up earth ramp on the levee's north embankment. Significant Impact — Bicyclist and Pedestrian Safety. The temporary alignment of the Uvas Creek Trail crossing of Thomas Road — Luchessa Avenue would require bicyclists and pedestrians to cross at the intersection of Thomas Road — Luchessa Avenue and Princevalle Street. Thomas Road — Luchessa Avenue is an arterial roadway with a speed limit of 40 mph. The road curves towards the south as it crosses Uvas Creek; drivers approaching from the south have a sight line to the intersection from approximately 400 feet away. The intersection is controlled by a stop sign on Princevalle Street only. The relatively fast traffic speed on Thomas Road — Luchessa Avenue and somewhat short sight distance for north -bound traffic on Thomas Road — Luchessa Avenue would result in a potential safety hazard to bicyclists and pedestrians crossing Thomas Road— Luchessa Avenue. This potential safety problem would be a significant environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant n level. Mitigation Measure 22. The final improvement plan for the Uvas Creek Trail extension, subject to the review and approval of the City of Gilroy Engineering Division, shall include cross walks across Thomas Road — Luchessa Avenue at Princevalle Street and stop signs on Thomas Road— Luchessa Avenue at Princevalle Street. Significant Impact— Bicycle Access. Urban Growth and Community Design Policy 26 of the City of Gilroy General Plan requires safe and convenient access for bicycles. Monterey Street, south of Thomas Road— Luchessa Avenue is a city- designated bicycle route. The project plans do not indicate a bicycle route connection between Monterey Street and the sports park access road. The lack of a safe and convenient access to the park from a nearby designated bicycle route would be a significant environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Mitigation Measure 23. The City of Gilroy shall include a Class 1 path on the west side or Class II bicycle lanes on both sides of Monterey Frontage Road as a part of the design and construction of improvements to Monterey Frontage Road between Monterey Street and the sports park access road. The path or bicycle lanes shall be constructed at the same time as other planned improvements to these roads are made, subject to the review and approval of the City of Gilroy Engineering Division. Significant Impact — Pedestrian Access. There are currently no sidewalks along Monterey Street and Monterey Frontage Road. Project - related traffic increases along these streets will present hazardous conditions to pedestrians accessing the sports park along this route prior to the completion of Phase IV. The lack of a safe pedestrian access along Monterey Street and Monterey Frontage Road would be a significant environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure 24. Prior to completion of Phase IV of the proposed project the City of Gilroy shall construct a minimum 6 -foot wide sidewalk along the west side of Monterey Frontage Road and a minimum 10 -foot wide sidewalk along Monterey Street between Thomas Road — Luchessa Avenue and the sports park access road. Significant Impact— Parking Supply. The transportation impact analysis projects a demand for 931 parking spaces at the completion of Phase V of the proposed project. Project plans provide 751 parking spaces at the end of this phase. The proposed project would have a shortage of 180 parking spaces at the completion of Phase V. This would be a significant adverse impact related to circulation. With implementation of the following mitigation measure this impact would be reduced to a less than significant level. Mitigation Measure 25. The City of Gilroy shall include in project plans, subject to review and approval of the City of Gilroy Planning Division, an additional 180 parking spaces to be built prior to completion of Phase V. No Significant Impact — Internal Circulation. The transportation impact assessment studied the internal circulation of the proposed project. No significant environmental impacts were found and no mitigation measures are required. However, the following design recommendations were made. 2 -78 EMC Planning Group Inc. ti Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Recommendations The following design changes are recommended to improve internal circulation. • The outbound lanes of the entry road near Monterey Frontage Road should be narrowed to one lane with paint to allow two outbound lanes (with park personnel directing traffic), if needed. • An all -way stop sign control should be installed at the intersection of the entry road and the main north-south road. An all -way stop sign control will provide safer conditions for pedestrians crossing this intersection. The first driveway on the entrance road (closest to Monterey Frontage a� Road) should be widened to allow both inbound and outbound traffic and the landscape median along the entry road should be cut back to allow left turns from this parking area onto the entry road. Currently, the on -site traffic is concentrated at the intersection of the entry road and the main north-south circulation road. Allowing left turns out of the eastern-most driveway will diffuse some of this traffic. Landscaping in the median should be low (less than 2.5 feet in height) or taller trees with 4 thin trunks, which should be pruned to maintain adequate sight distance. • An additional north-south circulation aisle should be provided in the western-most parking area to break -up the long rows of parking spaces. `- The parking bays and circulation aisles should be extended eastward, eliminating the isolated landscaped barrier at the east end of the parking area. 2.7 Air Quality Environmental Setting The City of Gilroy is located within the jurisdiction of the BAAQMD, which is made up of several climatological subregions. The City of Gilroy is located within the subregion known as the Santa Clara Valley. Climate ' The Santa Clara Valley is bounded by the San Francisco Bay to the north and by mountains to the east, south and west. Temperatures are warm on summer days and cool on summer nights, and winter temperatures are fairly mild. At the northern end of the valley, mean maximum temperatures are in the low -80's during the summer and the high -50's during the winter. The mean minimum temperatures range from the high -50's in the summer to the low -40's in the winter. Further inland, f EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR where the moderating effect of the bay is not as strong, temperature extremes are greater. For example, in San Martin, located approximately two and one -half miles north of Gilroy, temperatures can be more than ten degrees warmer on summer afternoons and more than ten degrees cooler on winter nights. Winds in the valley are greatly influenced by the terrain, resulting in a prevailing flow that roughly parallels the valley's northwest - southeast axis. A north- northwesterly sea breeze flows through the valley during the afternoon and early evening, and a light south - southeasterly drainage flow occurs during the late evening and early morning. In the summer, the southern end of the valley (including Gilroy) sometimes becomes a "convergence zone," when air flowing from the Monterey Bay gets channeled northward into the southern end of the valley and meets with the prevailing north- northwesterly winds. Wind speeds are greatest in the spring and summer and weakest in the fall and winter. Nighttime and early morning hours frequently have calm winds in all seasons, while summer afternoons and evenings are quite breezy. Strong winds are rare, associated mostly with the occasional winter storm. The air pollution potential of the Santa Clara Valley is high. High summer temperatures, stable air and mountains surrounding the valley combine to promote ozone formation. In addition to the many local sources of pollution, ozone precursors from San Francisco, San Mateo, and Alameda Counties are carried by prevailing winds to the Santa Clara Valley. The valley tends to channel pollutants to the southeast. In addition, on summer days with low level inversions, ozone can be re- circulated by southerly drainage flows in the late evening and early morning and by the prevailing northwesterly winds in the afternoon. A similar re- circulation pattern occurs in the winter, affecting levels of carbon monoxide and particulate matter. This movement of the air up and down the valley increases the impact of the pollutants significantly. Pollution sources are plentiful and complex in this subregion (Santa Clara Valley). It has a high concentration of industry at the northern end in the "Silicon Valley" area. Some of these industries are sources of air toxics as well as criteria pollutants. In addition, Santa Clara Valley's large population and many work -site destinations generate the highest mobile source emissions of any subregion in the Bay Area (BAAQMD 1996). Air Quality Monitoring and Attainment Status According to the BAAQMD, the San Francisco Bay Area recently lost its designation by the U.S. Environmental Protection Agency (EPA) as an attainment area for the national ozone standard. There were a number of new exceedances during the past few years. with the tightening of regulations by the U.S. EPA. The Bay Area air district continues to violate the State ozone standard. The State one -hour ozone standard, nine parts per hundred million (nine pphm), is considerably more stringent than the national standard of 12 pphm. 2 -80 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting ~I The BAAQMD maintains an air quality monitoring station in the City of Gilroy. The station monitors ozone and carbon monoxide. At this monitoring station, the number of days with maximum one -hour concentration exceeding nine pphm for the years 1990 through 1995 are as follows: 1990 (5 days), 1991 (5 days), 1992 (12 days), 1993 (6 days), 1994 (3 days), and 1995 (10 days) (BAAQMD 1996). ' Project Analysis Only the sports park and trail extension are proposed for development at this time. _ It is not known what type of development will ultimately occur on the remaining parcels on the project site. Therefore it is not possible to determine how uses on that part of the project site may affect air quality. The potential effects of the proposed sports park and related on -site and off -site development is discussed below. Sports Park Operations Emissions The URBEMIS7 air quality modeling program was used to determine emissions based on vehicle trips generated by the proposed project. URBEMIS7 was developed by the California Air Resources Board (CARB) to determine pollutant emission levels based on traffic generation. The URBEMIS7 air quality modeling program incorporates various assumptions for trip data in the area of the project site, as well as for the propose project itself. These assumptions include trip generation rates; vehicle fleet mix; trips lengths; average miles per hour; climate; etc. The URBEMIS7 model was run for sports park build -out conditions in 2020. Daily trips were assumed to be 5,700 (weekend trip generation). The average trip length used in the model was 5.78 miles based on typical trip lengths for the specific land use type and county (Metropolitan Transportation Commission 1993). The results of the air quality modeling are summarized in Table 12. TABLE 12 Projected Sports Park Air Quality Impacts — URBEMIS7 Modeling Results (Pounds Per Day) Source: EMC Planning Group Inc. and BAAQMD EMC Planning Group Inc. ROG NOx CO Proposed Sports Park (Winter) 23.26 76.90 270.85 Proposed Sports Park (Summer) 21.39 69.63 235.81 BAAQMD Thresholds 80.00 80.00 550.00 Source: EMC Planning Group Inc. and BAAQMD EMC Planning Group Inc. Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR BAAQMD establishes thresholds for criteria pollutants. The criteria pollutants of concern in the operation of the proposed project would be those pollutants associated with automobile emissions. These are carbon monoxide (CO) and ozone precursors, i.e., reactive organic gases (ROG) and oxides of nitrogen (NOX). A proposed project exceeding any of these thresholds is considered to result in a significant adverse impact on air quality. None of these thresholds for air quality would be exceeded during operation of the proposed sports park. Use of the Uvas Creek Trail would not generate any automobile trips will not have any adverse impacts on air quality. The proposed trail extension would provide a non - motorized access to the project site and could result in a reduction in automobile use and an associated reduction in automobile emissions. Construction Emissions Construction- related emissions are generally short -term in duration, but may still cause adverse air quality impacts. Fine particulate matter (PMlp) is the pollutant of greatest concern with respect to construction activities. PMlp emissions can result from a variety of construction activities, including excavation, grading, demolition, vehicle travel on paved and unpaved surfaces, and vehicle and equipment exhaust. Construction- related emissions can cause substantial increases in localized concentrations of PMlo. Particulate emissions from construction activities can lead to adverse health effects as well as nuisance concerns such as reduced visibility and soiling of exposed surfaces ( BAAQMD 1996). I It is likely that grading and other construction activities associated with construction of the sports park and related on -site and off -site improvements would result in the emission of PM,o in excess of BAAQMD standards. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: • cause a violation of any air quality standard or contribute substantially to an existing or projected air quality violation; • result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non - attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors); or • expose sensitive receptors to substantial pollutant concentrations. Less Than Significant Impact — Sports Park Operations. The proposed sports park would result in approximately 5,700 daily automobile trips at full build -out. These trips would result in the emission of various pollutants into the atmosphere. According to the results of URBEMIS 7 modeling, these emissions would be below 2 -82 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting a the thresholds established by the BAAQMD. This would be a less that significant impact and no mitigation measure is necessary. Potentially Significant Impact — Project Construction. The BAAQMD's approach to CEQA analysis of construction- related air quality impacts is to emphasize the implementation of effective and comprehensive control measures rather than detailed quantification of emissions. The BAAQMD has identified a set of feasible control measures for construction emissions of PMlp. These control measures are applicable to construction sites that are large in area, and located near sensitive receptors, i.e., residential neighborhoods. Lack of feasible control measures could result in a significant adverse air quality impact due to construction activities. Implementation of the following mitigation measure will reduce this impact to a less than significant level. Mitigation Measure 26. The following dust control measures shall be incorporated into all permits for any phase of the project. The measures shall be implemented as necessary to adequately control dust subject to the review and approval of the City of Gilroy Planning Division. • Water all active construction areas at least twice daily; • Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard; • Pave, apply water three times daily, or apply (non- toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites; • Sweep daily (with water sweepers) all paved access roads, parking areas and staging areas at construction sites; • Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets; • Hydroseed or apply (non- toxic) soil stabilizers to inactive construction areas (previously graded areas inactive for ten days or more); • Enclose, cover, water twice daily or apply (non- toxic) soil binders to exposed stockpiles (dirt, sand, etc.); • Limit traffic speeds on unpaved roads to 15 mph; • Install sandbags or other erosion control measures to prevent silt runoff to public roadways; • Replant vegetation in disturbed areas as quickly as possible; EMC Planning Group Inc. 2 -83 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR r`: • Install wheel washers for all existing trucks, or wash off the tires or tracks of all trucks and equipment leaving the site; • Install wind breaks, or plant trees /vegetative wind breaks at windward side(s) of construction areas; • Suspend excavation and grading activity when winds (instantaneous gusts) exceed 25 miles per hour; • Limit the area subject to excavation, grading and other construction activity at any one time. 2.8 Noise Environmental Setting A noise study was prepared by Edward L. Pack associates, Inc. in November 1998. The noise report is included in the Technical Composite, available for review at the City of Gilroy Community Development Department. The report addresses noise impacts on the project site from surrounding sources and potential noise impacts on surrounding areas from activities at the proposed sports park. The following discussion is based on that report. Noise Measurement and Standards The noise study measured noise levels in dBDNL, a measurement method that accounts for increased sensitivity to sound at night (10:00 PM to 7:00 AM) by adding a ten - decibel penalty to nighttime noise levels. Noise standards presented in the City of Gilroy General Plan are expressed in LpN. LoN and dBONL are two different notations for the same measurement method. This EIR uses dBoNL throughout. Outdoor noise standards for the City of Gilroy are included in the City of Gilroy General Plan noise element. According to these standards, outdoor noise levels should not exceed 60 dBoNL for residential uses, 65dBpNL for commercial uses and 76 dBoNL for industrial uses. Noise level at residences should not exceed 60 dBoNL, as measured 15 feet outside the rear -most household wall, 20 feet outside the front -most household wall, six feet outside the side -most household wall and ten feet outside the side -most household wall facing a street. The City of Gilroy General Plan has no specific standards for parks, so the noise study used the residential standard for impact evaluation purposes. The city does not have noise standard for bicycle trails, but it would be reasonable to apply the same standard as was applied to the park. 2 -54 EMC Planning Group Inc. Gilroy Sports Park and USAAmet:dment EIR Section 2: Environmental Setting Existing Noise Levels Existing noise levels at the project site are primarily from traffic on adjacent roads. Principal noise sources identified in the noise study were U.S. Highway 101, Monterey Street and Monterey Frontage Road. Additional noise sources include semi- trucks, barking dogs and general household activity from farm residences along Monterey Frontage Road and Farman Lane. Existing noise levels were measured at two locations, using continuous recordings over two separate 24 -hour periods from October 29 to October 31, 1998. Details of the measurements taken and methodology used are contained in the noise study. The noise study found the existing noise level at the entry point to the sports park access road to be 63 dBoNL. This point is along Monterey Frontage Road. It is reasonable to assume that noise levels along the remainder of Monterey Frontage Road are similar. At the sports park site boundary nearest to Monterey Frontage _ Road (420 feet east of the centerline) the existing noise level is 52 dBDNL. Noise levels are of course higher near the noise source and lower farther from the noise source. It is reasonable to assume that existing noise levels along the proposed Uvas Creek Trail extension are lower than 52 dBDNL, based on the distances from the identified noise sources. Project Analysis Ambient Noise Exposure to the Proposed Project The noise study bases its project impacts analysis on projected noise levels at project build -out in 2020. Project traffic study projections for 2020 were used to estimate future noise levels from traffic on Monterey Street and Monterey Frontage Road. The noise study concludes that noise increases on these streets will be approximately 0.4 dB and 0.2 dB respectively. Future noise levels from traffic on U.S. Highway 101 were based on estimates made for the update of the Santa Clara County General Plan in 1994. Noise generated by traffic on U.S. Highway 101 was estimated to increase by approximately 3 dB by 2020. The ambient noise level in 2020 is projected to be approximately 56 dBDNL at the sports park site boundary nearest to Monterey Frontage Road (420 feet east of the centerline). This level is well within the standards of the City of Gilroy General Plan for all land uses. Ambient noise levels at the proposed sports park would be within city standards. The ambient noise level in 2020 at the entry point to the sports park access road is projected to be approximately 67 dBDNC. It could be assumed that the noise level would be similar along all of Monterey Frontage Road. This noise level exceeds the EMC Planning Group Inc. 2 -85 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR city standards for both residential and commercial uses, though at locations somewhat farther from Monterey Frontage Road, the noise levels may be within the standards for commercial uses. Sports Park Noise Impacts on Surrounding Uses Access Road Noise. The main portion of the sports park site is accessed from 'Monterey Frontage Road by a 600 foot long access road, designed to carry two lanes of traffic into and one lane of traffic out of the sports park site. The principal concern of noise from this access road traffic is its potential impact on existing nearby residences. There is one residence located adjacent to the proposed access road, and another approximately 300 feet north of the proposed access road. The average weekend traffic along the access road is projected to be 5,700 trips. = Assuming an average speed of 25 miles per hour, the noise level at the nearest residence would be 58 dBDNL. The 60 dBoNL contour would be 11 feet from the nearest side wall of the house. The noise levels would be within the city standards at the closest residence. Therefore there would be no significant noise impacts from access road traffic. Athletic Events Noise. Since no project specific data is available, projected sports park noise levels from athletic events is based on previous acoustical studies of athletic event sound levels. These noise levels include noise from athletic activity, crowds and public address systems. Table 13 lists typical noise levels from the types of athletic events expected to be held at the proposed sports park. TABLE 13 Athletic Event Noise Exposure Event Type DbpNL Distance from Source Youth Soccer 51 260 feet Youth Baseball 51 260 feet Adult Softball 50 260 feet Roller Skating 55 60 feet Note: Source locations are at the center of the soccer field and roller skating area, and home plate on the baseball and softball fields. Source: Edward L. Pack Associates, Inc. For purposes of projecting maximum future noise exposure from the proposed sports park, the noise study analyzed four different athletic event scenarios. These scenarios were: 2 -86 EMC Planning I Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting 1. Peak Soccer Season. • All seven soccer fields run competitions simultaneously from 9:00 AM until 10:00 PM. Games last 40 minutes with 20- minute breaks between games. 2. Peak Soccer Season and Skating Area Activity. • All seven soccer fields run competitions simultaneously from 9:00 AM until 10:00 PM. Games last 40 minutes with 20- minute breaks between games. • Both skating areas are in continuous use from 10:00 AM until 6:00 PM. 3. Peak Baseball Season. • All 13 baseball fields run competitions simultaneously from 9:00 AM until 10:00 PM. Games last one hour and there are 15- minute breaks between games. 4. Peak Baseball Season and Skating Area Activity. • All 13 baseball fields run competitions simultaneously from 9:00 AM until 10:00 PM. Games last one hour and there are 15- minute breaks between games. • Both skating areas are in continuous use from 10:00 AM until 6:00 PM. Other park uses are of low intensity and would not contribute significantly to the overall noise levels at the proposed sports park. These activities, which include bocci ball, volleyball, horseshoes and a playground were omitted from the noise study scenarios. Projected noise exposure levels were calculated for four different residential locations. These locations are illustrated in Figure 23. The noise exposure at each of these locations under each scenario is summarized in Table 14. The maximum projected noise impact would be at Residence A (the residence on Monterey Frontage Road 300 feet north of the park access road) under Scenario 4 (peak baseball season and hockey activity). The project noise level at this residence would be 57 dBo„L, which is within the city's standard. Therefore there would be no significant noise impacts from athletic events. Construction Noise Impacts on Surrounding Uses Construction of the sports park and related on -site and off -site improvements would involve grading, hauling of materials and installation of pavement. Short -term noise EMC Planning Group Inc. 2-87 Section 2: Environmental Setting Gilroy Sports Park and LISA Amendment EIR could occur from these construction activities. Construction equipment typically generates noise levels in the range of 70 to 90 decibels at a distance of 50 feet. The nearest residences to the sports park site are located along Monterey Frontage Road and north of Thomas Road — Luchessa Avenue. Residences along Monterey Frontage Road would be subjected to excessive noise from trucks hauling materials and equipment to the project site. TABLE 14 Projected Residential Noise Exposure from Athletic Events (dBDNd Scenario Residence A Residence B Residence C Residence D 1. Soccer 53 53 52 52 2. Soccer and Skating 54 54 53 52 3. Baseball 56 56 55 55 4. Baseball and Skating 57 56 55 55 Source: Edward L. Pack Associates, Inc. Residences north of Thomas Road — Luchessa Avenue are located approximately 700 feet from the sports park site, and residences along Monterey Frontage Road are located approximately 400 feet from the sports park site. Noise diminishes by between 3 and 6 dB for each doubling of distance from the noise source. If equipment generates noise at levels up to 90 dB at a distance of 50 feet, at approximately 800 feet the noise would diminish to between 78 and 66 dB. Houses located within 800 feet from the noise source would experience noise levels in excess of the city standards of 60 dB for residential uses. Construction activities would therefore generate noise levels that would exceed city standards. Other Project Noise Impacts on Surrounding Uses Existing portions of the Uvas Creek Trail are located adjacent to residences. The use of the trail by bicyclists, pedestrians and others would not be likely to result in noise levels that would exceed city noise standards. The proposed uses of the project site parcels outside the sports park site are not known, and no projection can be made with regard to potential noise impacts , associated with the future use of those parcels. A noise study would be required when those parcels are developed, to determine those potential impacts. EMC Planning Group Inc. I 1 I 1 L{JI a� II 3. .M E D .T.9T1 fit' 1 •— THOMAS e ROAD � cmc.N i� t (^ \ax3r�4r •o l6 s � N 5 — 11.86 At NET •LTA l'r 4 C6.00 .C. NET 14 21AC A. Tr ^. p - - 6 C / WNIIAXIIIIIIIIIIININNiII 20.87AC. �ET / / % re -�'. pWH� pNyXNNPNNNNNINM �3 /r 40 CALL. a LOCNES.A AVE al B c� / 6.30 AC. NET PTN. 27 e . ST PC NET �J C 1 \• 1f �' `a 3421 AC, TOTAL t � NETi5 Locations for which noise exposure calculations were made are labeled A, B, C and D. 24 -hour existing noise recordings were made at locations labeled 1 and 2. 3 W LQI- Aj Aj J O ti 101 Source: Edward L. Pack Associates, Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Noise Exposure Study 23 and Design Firm Locations O PTn. s a P JI i 7.43 AC. A - i1 ,�{ 2 � Q ,J{ ..JO M. NET a z9 al B c� / 6.30 AC. NET PTN. 27 e . ST PC NET �J C 1 \• 1f �' `a 3421 AC, TOTAL t � NETi5 Locations for which noise exposure calculations were made are labeled A, B, C and D. 24 -hour existing noise recordings were made at locations labeled 1 and 2. 3 W LQI- Aj Aj J O ti 101 Source: Edward L. Pack Associates, Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Noise Exposure Study 23 and Design Firm Locations Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G states that a project would normally have a significant effect on the environment if it would: • result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; • result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels; or • result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project; Less Than Significant Impact —Noise from Park Activities. Activities at the proposed sports park, including athletic events and traffic entering and exiting the project site would generate noise. The noise generated by these activities would be within acceptable city standards at surrounding locations. Noise generated by activities at the sports park would have a less than significant impact, and no mitigation measure is necessary. Significant Impact— Construction Noise. Construction activities at the project site would result in noise levels that exceed the standards specified in the City of Gilroy General Plan. This would be a significant environmental impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure. 27. The following language shall be included on any permits issued for the sports park, subject to the review and approval of the City of Gilroy Engineering Division. "All noise generating construction activities shall be limited to weekdays between 7:00 AM and 7:00 PM, and to Saturdays and City holidays between 9:00 AM and 7:00 PM. No construction is allowed on Sundays. In addition, temporary berms or noise attenuation barriers shall be utilized when necessary." 2.9 Archaeological Resources Environmental Setting A cultural resources evaluation of the project site was conducted by Archaeological Resource Management in October 1998. At the request of the California Historical EMC Planning Group Inc. 2 -91 7 '4- k Section 2: Environmental Setting Gilroy Sports. Park and USA Amendment EIR Resources Information System, -Northwest Information Center, the reports are not available for public review. California Government Code Section 6254.10 exempts archaeological site information from the California Public Records Act, which requires that public records be open to public inspection. The following discussion is based on the cultural resources evaluation. The project site is located along the banks of Uvas Creek, in an alluvial area of the Santa Clara Valley. These alluvial areas are known to contain many buried prehistoric resources. The preliminary archaeological investigation consisted of an archival search and surface reconnaissance. The archival search was conducted at the Northwest Information Center of the Archaeological Site Inventory. One recorded historic site was found to be located on the project site, in an area not currently proposed for development, and three reported historic sites were found to be located within one half mile of the project site. While no reported or recorded prehistoric archaeological sites were found on the project site, two such sites were found to be located within one half mile of the project site. The surface reconnaissance was conducted by a field archaeologist on the sports park site and the trail extension site. No prehistoric or historic cultural resources were observed. An historic site is located in the northwest corner of the project site. A small wooden cabin built in the 1850's was located there and still occupied as late as 1974 when it was recorded in a report to the California Archaeological Site Inventory. This structure no longer exists. Two prehistoric sites were identified in the archaeological record within one half mile of the project site. These consist of shells, mortars and other related artifacts, and are currently buried. Several houses of historic significance are located along Monterey Street. Project Analysis Construction of the sports park and related on -site and off -site improvements would involve the use of heavy equipment for grading, trenching and construction activities. It is possible that prehistoric or historic cultural resources would be discovered during these activities. At this time only the sports park and related on -site and off -site improvements are proposed for development. The remaining parcels on the project site are expected to remain in agricultural use in the near term. It is not likely that continuation of existing agricultural operations would affect potential prehistoric or historic cultural resources on the project site. 2_92 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines section 15064.5; • cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines section 15064.5; • directly or indirectly destroy a unique paleontological resource or site or unique geologic feature; and /or • disturb any human remains, including those interred outside of formal cemeteries. Potentially Significant Impact. Background research and a field reconnaissance conducted by Archaeological Resource Management in October 1998 indicates that the project area does not contain any known significant cultural resources. However, the Santa Clara Valley is known to be rich in buried prehistoric resources, especially the alluvial soils found near waterways. Therefore, due to the proposed project's location in a creek -side environment and the presence of a recorded historic resource directly adjacent to the trail extension, there is an elevated chance that currently unidentified buried cultural resources may be found during construction on the project site. Disturbance of prehistoric or historic cultural resources would be considered a significant impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measures 28. The City shall contract with a qualified archaeologist to arrange a schedule for monitoring during grading and excavation activities due to the project site's ,, creek -side location and proximity to recorded historic and prehistoric sites. 29. Due to the possibility that significant buried cultural resources might be found during construction the following language shall be included any permits issued for the project site, including, but not limited to building permits for future development, subject to the review and approval of the Gilroy Planning Division: If archaeological resources or human remains are discovered during construction, work shall be halted at a minimum of 200 feet from the find and the area shall be staked off. The project developer shall notify a qualified professional archaeologist. If the -' find is determined to be significant, appropriate mitigation measures shall be formulated and implemented. EMC Planning Group Inc. 2 -93 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR 30. In the event of an accidental discovery or recognition of any human remains in any location other than a dedicated cemetery, the City shall ensure that this language is included in all permits in accordance with CEQA Guidelines section 15064.5(e): If human remains are found during construction there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until the coroner of Santa Clara County is contacted to determine that no investigation of the cause of death is required. If the coroner determines the remains to be Native American the coroner shall contact the Native American Heritage Commission within 24 hours. The Native American Heritage Commission shall identify the person or persons it believes to be the most likely descendent from the deceased Native American. The most likely descendent may then make recommendations to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and associated grave goods as provided in Public Resources Code Section 5097.98. The landowner or his authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity on the property in a location not subject to further disturbance if: a) the Native American Heritage Commission is unable to identify a most likely descendent or the most likely descendent failed to make a recommendation within 24 hours after being notified by the commission; b) the descendent identified fails to make a recommendation; or c) the landowner or his authorized representative rejects the recommendation of the descendent, and the mediation by the Native American Heritage Commission fails to provide measures acceptable to the landowner. 2.10 Aesthetics Environmental Setting This section addresses the potential impacts of the proposed project on the aesthetic qualities of the area. The project site has a pastoral rural ambiance, with clusters of farm buildings and cultivated fields set to a backdrop of riparian vegetation. The land is primarily undeveloped farmland with several houses and their associated farm buildings located apart from one another along the eastern side of the project site. The project site is located adjacent to Thomas Road — Luchessa Avenue, Monterey Street and 2_94 EMC Planning Group Inc. I 1 -._ 1 Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting 1-, Monterey Frontage Road and within view of U.S. Highway 101. The farm fields and —4 buildings and.the vegetation lining the banks of Uvas Creek are visible from these vantage points. The level ground and lack of distinctive features makes it difficult to discern where one parcel ends and another begins. Figure 24 shows the existing character of the project site. U.S. Highway 1 affords a better overview of the project - -- site than other roadways because of the slight elevation of the highway. A propane gas facility is located at the corner of Monterey Street and Thomas Road— Luchessa Avenue. This corner is out of character with the remainder of the project site, but in character with other land uses north and east of the project site along Monterey Street. Adjacent land uses to the north and east of the project site present an abrupt edge to the predominately rural feeling of the project site. Two hotels are under construction on the land to the eastern side of Monterey Street, between U.S. , Highway 101 and the project site. Existing houses fronted by a six -foot tall concrete wall are visible immediately north of Thomas Road — Luchessa Avenue. Additional urban development is located to the east of U.S. Highway 101. The project site is on the southern edge of the Gilroy urbanized area. Project Analysis 'r Character of the Area Development of the project site would permanently alter the existing rural character of the area. The sports park site would largely remain, as open space. However, the access road, parking lots, parked cars, pathways and structures would introduce a noticeable developed aspect to the park area. Median strip plantings, other . landscaped areas and the green of the irrigated athletic fields would soften this. Though it would remain as open space, the overall aspect of the developed sports park would present a much more urban face than the existing rural scene. The context of the view is nearly as important as the physical view itself, as it alters J the perception of the viewer. In the context of a rural setting the sports park would appear rather stark and out -of- place. However, with surrounding parcels to the north and east already developed, the sports park would appear as an area of logical transition between the built and rural environments. Public attitudes toward a project can also affect the way in which the development is viewed. As may be the case with the sports park, a project in which there is considerable civic pride would likely be viewed more favorably from a visual standpoint. The proposed Uvas Creek Trail extension would have very little visual impact. The paved trail would measure approximately eight feet wide. No lighting is proposed for the trail. EMC Planning Group Inc. 2 -95 Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR Sports Park Nighttime Lighting The sports park is proposed to be lit for nighttime use. Athletic field lighting is generally quite intense and may be visible for a mile or more away. The effect of field lighting varies considerably with the type of lighting employed, intensity of the light, height of the lighting, and the viewer's distance from the source. Recent technical advances have resulted in lighting that is more directed and has less "spillage" into surrounding areas. Use of this technology reduces the severity of lighting impacts. The effect of sports field lighting differs greatly depending on the viewer's distance form the light source. Very close to the lighted fields the light would be more likely to shine into nearby yards and windows. The view of bright lights would affect the outward view from houses with a view line towards the light standards. From greater distances, the view is of a bright glow in an otherwise darker sky. This glow can be quite noticeable, particularly in a small city that is surrounded by mountains and farmland. The light could be perceived as a nuisance by anyone accustomed to the normal darkness of night. Nighttime lighting is of special concern to observatories, as it interferes with the ability to see stars and other outer space objects. The Lick Observatory on Mt. Hamilton is located approximately 20 miles north of the project site. Lighting at the project site could incrementally affect the observatory. Each field at the proposed sports park would be equipped with field lights. Each softball /baseball field would have six light poles. The two poles located nearest home plate would be approximately 50 feet tall and contain three to four lights each. Two poles located near first and third base would be approximately 50 feet tall and contain six to nine lights each. Two 60- to 70 -foot poles would be located in the outfield and contain ten to fifteen lights each. In most instances the preliminary plans show one soccer field overlaid on two softball /baseball fields. Therefore, soccer fields would be lit by up to 12 light poles. Field lights would be turned on only for fields on which there were games scheduled on a particular night. They would be used most often-for league play as opposed to tournament play (Derek McKee, personal communication, November 13, 1998). The field lights specified for the proposed sports park are manufactured by Musco Lighting. Company literature states that light spill and glare are reduced by up to 95 percent compared to standard sports lighting. The lights are a "shielded" design that directs light downward and reduces, the amount of light that escapes into the sky. Musco Lighting is one of several manufacturers recommended as producing sports lighting with reduced light emissions, by the public information office of the McDonald Observatory (Bill Wren, personal communication, December 1, 1998). 2_96 EMC Planning Group Inc. I Rural Character of the Project Site Urban Character of surrounding areas. This photo shows hotels under construction east of the project site. A residential area is located to the north of the project site. Source: EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Existing Character of and Design Firm 24 Proiect Site Section 2: Environmental Setting Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 2_98 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 2: Environmental Setting The field lights at the proposed athletic fields would be approximately 350 to 600 feet from the houses along Monterey Frontage Road and 700 feet from the closest subdivision houses near Thomas Road — Luchessa Avenue. The field lights nearest to these houses would be faced away from the houses. At the proposed distances the direct light intrusion into homes should be minimal or non - existent. The lights would be visible from homes in the area where the view is not obscured by landscaping close to the house. The lights would also be visible from nearby streets and U.S. Highway 101. The distant glow should be minimized due to the design of the lights. Impacts and Mitigation Measures Standards of Significance. CEQA Guidelines appendix G indicates that a project may have a significant effect on the environment if it would: • have a substantial adverse effect on a scenic vista; substantially degrade the existing visual character or quality of the site and its surroundings; or • create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Less than Significant Impact —Change in Rural Character. Development of the project site would permanently alter the existing rural character of the area. Though it would remain as open space, the overall aspect of the developed sports park would present a much more urban face than the existing rural scene. In the context of a rural setting the sports park would appear rather stark and out -of- place. However, with surrounding parcels to the north and east already developed, the sports park would appear as an area of transition between the built and rural environments. The change in character brought on by development of the sports park would be a less than significant impact. No mitigation measure is necessary, Less than Significant Impact— Nighttime Lighting. The proposed project would introduce a major new source of light to the local area. The lights are sufficiently distant from the nearest homes that they should not present a problem with interior light intrusion. The lights will be noticeable directly from area streets and as a general glow in the night sky from more distant locations. The lights specified in project plans use a shielded design that directs light towards the playing field and reduces fugitive light emission. With the use of this type of light the proposed project will have a less than significant effect on nighttime visual qualities of the area, and no mitigation measure is necessary. EMC Planning Group Inc. 2 -99 Section 2: Environmental Setting Gilroy Sports Park and LISA Amendment EIR 2.11 Issues Determined to Have Less Than Significant Impacts Pursuant to CEQA Guidelines section 15063 an initial study was prepared to determine the potentially significant effects of the proposed project. The initial study determined that certain issues would have a less than significant impact. These issues were population and housing and energy. These are discussed briefly in this section of the EIR. Population and Housing The proposed project would not alter the population of the community, and would have no effect upon the demand for housing. The sports park is estimated to provide approximately three to four permanent jobs and ten to 15 part -time or seasonal jobs when it is fully developed. The proposed project would have no significant adverse effects on population or housing. Energy The proposed project would not use energy in a wasteful or excessive manner. The sports field lighting would be used only for field on which games are scheduled on a given night. The lights specified in project plans use fewer light fixtures and require, less energy than do conventional athletic field lights. The proposed project would have no significant adverse effects on energy. 2 -100 EMC Planning Group Inc. 3.0 Related Environmental Issues 3.1 Unavoidable Significant Adverse Environmental Impacts An unavoidable significant adverse environmental impact is a significant adverse impact that cannot be reduced to a less than significant level through the implementation of mitigation measures. CEQA Guidelines section 15093 requires that a lead agency make findings of overriding considerations for unavoidable significant adverse environmental impacts before approving a proposed project. The loss of prime farmland is generally considered a significant and unavoidable adverse environmental impact. The proposed project would result in the loss of the 133.2 acres of prime farmland (though some of this land is used for commercial and residential farm- related uses). The establishment of the Gilroy Agricultural Lands Area by both the City of Gilroy and the County of Santa Clara serves as a regional i mitigation for losses of prime farmland in southern Santa Clara County, outside of the agricultural lands area. Although this regional mitigation has been implemented, it does not serve to reduce the loss of prime farmland to a less than significant level and the proposed project would still be considered to have a significant and unavoidable impact on prime farmland. CEQA Guidelines section 15093(a) requires the decision - making agency (City of Gilroy, ag well as the Santa Clara County LAFCO) to, balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable ". Section 15093(b) states that when the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the final EIR and /or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. The City of Gilroy is expected to make the following findings regarding the loss of prime farmland prior to approving the project: The Gilroy Agricultural Lands Area is, at least partial mitigation for the loss of the 133.2 acres of prime farmland. -- EMC Planning Group Inc. 3 -1 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR • The project site is adjacent to urban uses to the north (residential) and east (commercial), and is easily accessed from U.S. Highway 101. • The sports park is a social benefit highly desired by the City of Gilroy and its citizens. • There are no alternative sites for the sports park that would not result in the conversion of prime farmland. • The project site is in a flood zone, which makes it undesirable for intensive urban development and therefore, was available at a price the City of Gilroy could afford. Alternative sites were not available at a price affordable to the City. 3.2 Cumulative Impacts CEQA Requirements CEQA Guidelines section 15130 requires a discussion of the significant cumulative impacts associated with the proposed project. A cumulative impact is an impact that is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts. CEQA Guidelines section 15130(b) requires the following: The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact... CEQA requires a cumulative development scenario to consist of either a list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency, or, a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area -wide conditions contributing to the cumulative impact. When based on a list of past, present, and probable future projects, factors to consider when determining whether to include a related project should include the nature of each environmental resource being examined, the location of the project and its type. "Probable future projects" may be limited to those requiring an agency approval for an application which has been received at the time the notice of 3_2 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues preparation is released, unless abandoned by the applicant; projects included in an adopted capital improvements program, general plan, regional transportation plan or other similar plan; projects included in the summary of projections of projects (or development areas designated) in a general plan or a similar plan; projects anticipated as later phases of a previously approved project; or those public agency projects for which money has been budgeted. The geographic area affected by the identified cumulative impacts, and an explanation of the basis of the geographic scope used in analyzing cumulative impacts, must be presented. Cumulative Conditions Basis Cumulative conditions used for the proposed project include existing development, approved but not yet built projects, and probable projects in the southern part of Gilroy. The two projects that were probable at the time that the cumulative traffic analysis was prepared, The Hilton Garden Inn and the Gilroy Cinemas, have since been approved by the City of Gilroy. Traffic from the proposed project was anticipated to have a potentially significant impact on the local area, and to be likely to contribute with other projects towards significant cumulative impacts. Southern Gilroy was selected as the area of study for cumulative impacts because traffic from the proposed project would most affect southern Gilroy. Approved projects included in the cumulative analysis are summarized in Table 15. Figure 25 shows the locations of approved projects included in the cumulative analysis. Investigation indicates that the proposed project may have potentially significant cumulative impacts in the areas of agricultural resources, hydrology, transportation/ circulation and air quality. The project is unlikely to have potentially significant cumulative impacts in the areas of geology, biological resources, public services, noise, archaeological resources or aesthetics. Agricultural Considerations The proposed project would add 133.2 acres of prime farmland (including some land currently developed with rural residential and commercial structures) to the City of Gilroy Urban Service Area. Land within the Urban Service Area is generally expected to be developed within an approximate five -year timeframe. Prime farmland is a non - replaceable resource. Each project that involves the conversion of prime farmland to non - agricultural uses contributes to the depletion of this resource. Approximately 1,900 acres of prime farmland have been converted to non- agricultural uses in Santa Clara County since 1990 (California Department of Conservation 1996 and Santa Clara County 1994). This represents a loss of approximately 5.4 percent of the total prime farmland that existed in Santa Clara County in 1990. The proposed project would transfer approximately 0.4 percent of the remaining prime farmland in the county into the City of Gilroy Urban Services Area. While some of this land would remain in agriculture for an indefinite period, the land would ultimately be developed. EMC Planning Group Inc. 3 -3 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR TABLE 15 Approved Projects in the Vicinity of the Project Site Projects Location Use and Size Motel 6 East of Monterey Street; 129 rooms (replacing 56 rooms) west of U.S. Highway 101 Truck Stop East of U.S. 101; east of Overnight truck stop, gas station, Monterey Street convenience market, fast food restaurant, motel, and mini storage Eagle Ridge West of Santa Teresa 650 single - family and townhouse Boulevard, between Third units, 18-hole golf- course Street and Miller Avenue The Villas West end of Oakbrook 75 single - family residential units Drive, west of Thomas Road The Uplands West of Thomas Road; 60 single- family residential units North of Luchessa Avenue Hilton East of Monterey Street; 113 rooms Garden Inn west of U.S. Highway 101 Gilroy West of Monterey Street; 1,100 seat theater Cinemas south of Tenth Street Source: Fehr and Peers Associates, Inc. and City of Gilroy The establishment of the Gilroy Agricultural Lands Area serves as partial mitigation for development elsewhere on the region's prime farmlands, however, this mitigation does not replace the un- protected prime farmland, and it's conversion to non - agricultural uses is a significant environmental impact. The proposed project, along with The Uplands, The Villas and Eagle Ridge residential developments and the truck stop project, would convert prime farmland to non - agricultural uses. The proposed project and cumulative projects would convert approximately 173 acres of prime farmland. The conversion of prime farmland would be a significant cumulative environmental impact. Hydrology Urban development in the Pajaro River watershed has resulted in the covering of many acres of permeable land with impermeable surfaces such as pavement and structures. Essentially none of the rainfall that hits impervious surfaces is absorbed into the surfaces on which it falls. When rainfall lands on these impermeable surfaces, it drains on the surface and eventually into a drainage pipe or watercourse. Storm water in the Pajaro River watershed that is not absorbed into the soil or retained in reservoirs eventually makes its way into the Pajaro River. 3 -4 EMC Planning Group Inc. Qs C G I L R 0 Y , d in 4 Tenth Street 4 Gilroy Q Q$M,m High School 40 O <eehes�e e a APPROVED PROJECTS M' V,� ®Motel 6 © Truck Stop // °' �• o' ® Eagle Ridge (residential) Project Srte Q The Uplands (residential) i Q The Villas (residential) Q Gilroy Cinimas e © Hilton Garden Inn Note: Projects 6 and 7 were Probable Projects at the time the �'�. k, transportation impact analysis was prepared. 6& Source: California Automobile Association and EMC Planning Group Inc. No Scale Jil Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Cumulative Projects 25 and Design Firm Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 3 -6 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues Under certain storm conditions increases in the amount of area covered in impervious materials results in increased rates of run -off into streams. The increased rate of storm water run -off can result in higher flows in streams and in a more rapid rise in streams' water levels. Increased flows in streams often result in local or widespread flooding in areas adjacent to the stream. Two major floods have occurred in the lower reaches of the Pajaro River in the past several years, resulting in extensive property damage and displacement of residents. However, during flood conditions it is likely that the increase in run -off due to new impervious surfaces would be less than significant, since under these conditions the run -off rate from pervious surfaces is typically high also. Transportation /Circulation Traffic volumes for cumulative conditions were estimated by adding traffic associated with probable projects to traffic volumes estimated for project conditions (the proposed project and approved projects). PM peak -hour traffic volumes for these developments were estimated based on traffic reports prepared for the developments and provided by the city. Saturday peak -hour volumes were estimated using trip generation rates from ITE Trip Generation Manual. The operation of the key intersections was evaluated as to the probable level of service. Intersection levels of service under cumulative conditions are presented in Table 16. Under cumulative conditions, the intersection of Monterey Street and Monterey Frontage Road, with two -way stop -sign control, is projected to operate at LOS F_ during both peak hours. With the installation of a traffic signal, the intersection is projected to operate at LOS C during both the PM and Saturday peak hours. The intersections of Thomas Road — Luchessa Avenue and Princevalle Street and Thomas Road — Luchessa Avenue and Church Street are projected to continue to operate at acceptable levels. The intersections would operate at LOS A during both the PM and Saturday peak hours. The cumulative conditions level of service at the intersection of Monterey Street and Monterey Frontage Road would be below the standards prescribed by the City of Gilroy General Plan. A mitigation measure in Section 2.6 Transportation/ Circulation would require the installation of a signal light at this intersection prior to completion of Phase IV of the proposed sports park. With implementation of this mitigation measure the proposed project would not result in a significant cumulative traffic impact. EMC Planning Group Inc. 3-7 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR TABLE 16 Cumulative Conditions Intersection Levels of Service Average total intersection delay for unsignalized intersection and whole intersection weighted average stopped delay for signalized intersections, expressed in seconds per vehicle LOS calculations performed using the CMP level of service analysis program, TRAFFIX, and the 1994 Highway Capacity Manual methodology for two-way stop - controlled intersections and the 1985 Highway Capacity Manual delay methodology for signalized intersections Source: Fehr and Peers Associates Inc. Air Quality The BAAQMD does not set a specific threshold for cumulative mobile- source emission increases in local jurisdictions. It is assumed that the cumulative projects will exceed BAAQMD project - specific thresholds for at least one pollutant. The individual projects when analyzed together are anticipated to result in a significant cumulative impact on air quality. The San Francisco Bay Area recently lost its designation by the U.S. EPA as an attainment area for the national ozone standard. On June 25, 1998, the U.S. Environmental Protection Agency changed the Bay Area's classification for national 1 -hour ozone standard from a "maintenance" area to an "unclassified nonattainment" area. The re- designation action is EPA's formal recognition that the region has had recent violations of the national ambient air quality standard for ozone. The notice requires San Francisco Bay Area co -lead agencies to prepare a revision to the State Implementation Plan (SIP), a compilation of plans and regulations that govern how the region compiles with the Federal Clean Air requirements. The 1999 SIP will identify how the region will re- establish an attainment record in the future. 3,8 EMC Planning Group Inc. I PM Peak Saturday Peak Intersection Average LOS Average LOS Delay (sec) Delay (sec) Monterey Street and 116.9 F 241.4 F Monterey Frontage Road (Two -Way Stop Controlled) Monterey Street and 16.7 C 18.8 C Monterey Frontage Road (Signalized) Thomas Road— Luchessa 1.7 A 1.3 A Avenue and Princevalle Street (Two -Way Stop Controlled) Thomas Road— Luchessa 1.7 A 2.1 A Avenue and Church Street (Two -Way Stop Controlled) Average total intersection delay for unsignalized intersection and whole intersection weighted average stopped delay for signalized intersections, expressed in seconds per vehicle LOS calculations performed using the CMP level of service analysis program, TRAFFIX, and the 1994 Highway Capacity Manual methodology for two-way stop - controlled intersections and the 1985 Highway Capacity Manual delay methodology for signalized intersections Source: Fehr and Peers Associates Inc. Air Quality The BAAQMD does not set a specific threshold for cumulative mobile- source emission increases in local jurisdictions. It is assumed that the cumulative projects will exceed BAAQMD project - specific thresholds for at least one pollutant. The individual projects when analyzed together are anticipated to result in a significant cumulative impact on air quality. The San Francisco Bay Area recently lost its designation by the U.S. EPA as an attainment area for the national ozone standard. On June 25, 1998, the U.S. Environmental Protection Agency changed the Bay Area's classification for national 1 -hour ozone standard from a "maintenance" area to an "unclassified nonattainment" area. The re- designation action is EPA's formal recognition that the region has had recent violations of the national ambient air quality standard for ozone. The notice requires San Francisco Bay Area co -lead agencies to prepare a revision to the State Implementation Plan (SIP), a compilation of plans and regulations that govern how the region compiles with the Federal Clean Air requirements. The 1999 SIP will identify how the region will re- establish an attainment record in the future. 3,8 EMC Planning Group Inc. I Park and USA Amendment EIR Section 3: Related Environmental Issues The addition of the vehicular trips and associated emissions from the proposed project would contribute to cumulative air quality impacts in a non - attainment area. 3.3 Significant Irreversible Environmental Changes The proposed project would result in the permanent loss of prime agricultural land. While this loss is mitigated in part by the establishment of the Gilroy Agricultural Lands Area, the prime agricultural land lost to the proposed project is not replaceable. The loss of prime agricultural land would be a significant irreversible change. 3.4 Growth Inducing Impacts Growth inducement generally refers to the likelihood that a proposed project will foster growth in the surrounding: area, either directly or indirectly. The most common factor in fostering growth is the removal of obstacles to population or economic growth. Potential growth - inducing impacts should be discussed in relation to both the potential impacts on existing community service facilities and the way a project may encourage. and facilitate other activities that could significantly affect the environment. The proposed project would require the extension of a recycled water distribution line. Recycled water is used primarily for irrigation of large park or open space areas, and extension of this line would not be likely to induce concentrated urban growth. All other infrastructure is currently available near the project site. The project site is currently within the City of Gilroy 20 -year development area. The proposed project would transfer the project site into the Urban Service Area. Development within an urban service area is generally expected to occur within an approximate five -year timeframe. Currently only the sports park site is proposed for development. Development of those parcels that are not part of the proposed sports park could be hastened by the development of the sports park. The proposed project could have growth inducing impacts on the project site and possibly on adjacent areas. 3.5 Alternatives CEQA Guidelines section 15126.6 (a) requires a description of reasonable alternatives to the project, or to 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, and an evaluation the comparative merits of the alternatives. An E1R need not consider every conceivable alternative to EMC Planning Group Inc. Section 3• Related Environmental Issues Gilroy Sports Park and USA Amendment EIR a project, but must consider a reasonable range of potentially feasible alternatives that will foster informed decision - making and public participation. CEQA Guidelines section 15126.6 (b) further requires that the discussion of alternatives focus on those alternatives capable of eliminating any significant adverse environmental impacts or reducing them to a level of insignificance, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly. The following project alternatives were analyzed: • Alternative #1 "No Project" Alternative; • Alternative #2 (Alternative Location A) Santa Teresa Boulevard at State Highway 152; • Alternative #3 (Alternative Location B) Santa Teresa Boulevard and Miller Avenue; • Alternative #4 (Alternative Location C) Monterey Road at Bolsa Road. The alternative project locations are shown in Figure 26. Alternative #1 "No Project" Alternative CEQA Guidelines section 15126.6 (e) stipulates that the "No Project" alternative be evaluated along with its impacts. The "No Project" alternative analysis must discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The City of Gilroy General Plan and the Santa Clara County General Plan both require that only land within the city limits be developed. Land which is annexed to the city must be within or concurrently added to the city's Urban Service Area. The Urban Service Area is that area which is currently developed or expected to be developed within an approximate five -year time period. The project site is currently within the city's planning area and 20 -year growth boundary, but outside the city limits and Urban Service Area. The project site is currently used for agricultural production. It would be expected to remain in agriculture for at least the next five years, but could be developed in the approximate five- to 15 -year timeframe. Under the Santa Clara County General Plan the land is designated OPEN SPACE RESERVE, which is an interim designation for land for which the ultimate use has not been established. It is not possible to predict the type of future development that would occur on the site under the "No Project" scenario. The following analysis is based on the project site remaining in its current agricultural use for at least five years. 3 -10 EMC Planning Group Inc. o\ I& Gilroy Golf Course Alternative`' • , T G I Location A` Alternative Tenth Location B Gilroy cJm '`.High School Alternative Location fM Project Sports Park Site Site Ei Additional ,i"�� Alternative USA Amendment Area Location C Gavilan MBSa HOaO College f �y 'a Source: California Automobile Association and EMC Planning Group Inc. No Scale Gilroy Sports Park and USA Amendment EIR Figure A Land Use Planning Alternative Site Locations 26 and Design Firm Section 3: Related Environmental Issues Gilrou Svorts Park and USA Amendment EIR This side intentionally left blank. 3 -12 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues Agricultural Concerns Under the "No Project' alternative, the land would remain in agricultural production. It is possible that the land would be developed within the 20 -year time frame, consistent with its designation in the City of Gilroy General Plan. The "No Project' alternative is consistent with existing land use policies. The "No Project' alternative is superior to the proposed project in terms of agricultural concerns. Geology There would be no geologic impacts under the "No Project' alternative. The "No Project' alternative is slightly superior to the proposed project in terms of geologic hazards. Hydrology The 'No Project" alternative would not result in the paving of pervious surfaces and would not increase storm water run -off or discharge of urban pollutants into surface waters. Some discharge of agricultural chemicals, fuels and oils is possible under the 'No Project" alternative. These discharges are not known to occur currently on the project site, but are a potential occurrence with the current land use. Discharge of pollutants would be more of a concern with urban development than with the current use. The "No Project' alternative is superior to the proposed project in terms of hydrology. Biological Resources The "No Project' alternative would retain the land surrounding the Uvas Creek riparian habitat in agricultural use. No construction activities would occur near the sensitive habitat areas, and no mitigation measures would be necessary. However, the proposed project would result in a widening of the habitat buffer from approximately 25 feet to a minimum 50 feet wide. This widening of the habitat buffer is a beneficial impact. The proposed project is superior to the "No Project' alternative in terms of biological resources. EMC Planning Group Inc. 3 -13 Section 3: Related Environmental Issues Gilroy Sports Park and LISA Amendment EIR Transportation/Circulation The "No Project" alternative would add no trips to the existing roadway conditions. The "No Project' alternative would have less impact on traffic than the proposed project. The "No Project' alternative is the superior project in terms of traffic impacts. Public Services The project site currently receives its public services from Santa Clara County or from agencies other than the City of Gilroy. Under the 'No Project' alternative Santa Clara County would continue to provide the same services at approximately the same level. The "No Project' alternative would have no impacts on public services. The "No Project' alternative is the superior project in terms of public services. Air Quality The current agricultural land use periodically produces airborne particulate matter from farming operations. A minor amount of ozone precursors are emitted from the project site from the operation of vehicles and farm equipment. The proposed project would result in limited short -term emission of particulate matter and much greater long -term emissions of ozone precursors. The 'No Project' alternative is superior to the proposed project in terms of air quality. Noise The agricultural use of the land generates occasional low levels of noise from the operation, of farm equipment and trucks. The proposed project would result in noise from automobiles accessing the project site and from athletic activities. The "No Project' alternative is superior to the proposed project in terms of noise. Archaeological Resources Most farming operations disturb the soil to a relatively shallow depth. The current farming operations are not known to have unearthed any significant archaeological resources. Construction activities have the potential to disturb the soil to a greater extent than farming operations, and are more likely to unearth culturally significant buried resources. The "No Project' alternative is superior to the proposed project in terms of archaeological resources. 3 -14 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues Aesthetics The project site currently presents a pastoral scene of farm fields against a backdrop of riparian vegetation. Under the "No Project" alternative, the land could be expected to remain in its current state for at least five years. The proposed project would introduce parking areas and lights that would detract from the scenic nature of the setting. The "No Project' alternative is superior to the proposed project in terms of aesthetics. Alternative #2 (Alternative Location A) Santa Teresa Boulevard at State Highway 152 The Alternative 2 site is comprised of five parcels located south State Highway 152 and to the west of Santa Teresa Boulevard in western Gilroy. The Assessor's parcel numbers are 810 -21 -002, 810 -21 -003, 810 -21 -004, 810 -21 -005 and 810 -21 -006. The total acreage of the site is 120.06 acres. Approximately one third of this total is located within the Uvas Creek channel or on the opposite side of the creek from the rest of the site, so the total usable area from a practical standpoint is approximately 80 acres. The site is bounded by Santa Teresa Boulevard on the east, State Highway 152 on the north, and private property on the west and south. Uvas Creek flows from west to east through the southern third of the site. The site contains three rural residences and associated farm buildings, and greenhouses. The eastern half of the Alternative 2 site is within the Gilroy city limits and Urban Service Area and is designated RESIDENTIAL - RURAL, RESIDENTIAL MEDIUM DENSITY and RESIDENTIAL LOW DENSITY in the City of Gilroy General Plan. A sports park with similar facilities to the proposed project would be built on the site. Agricultural Considerations Most of the usable land on the site is in agricultural production with row crops and tree crops. Land to the north and east of the site is predominantly urbanized, with some pockets of agricultural use and vacant land. The usable land is identified on the Santa Clara County Important Farmland Map as Prime Farmland. None of the parcels on the Alternative 2 site is under Williamson Act contract. The eastern half of the site is within the Gilroy city limits. Alternative 2 would result in approximately 50 fewer acres of prime farmland converted to non - agricultural use. Half of the site is already within the Gilroy city limits and Urban Service Area. EMC Planning Group Inc. 3 -15 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR Alternative 2 is superior to the proposed project in terms of agricultural considerations. Geology There would be no unusual geologic impacts associated with Alternative 2. Alternative 2 and the proposed project are approximately equal in terms of geologic hazards. Hydrology Uvas Creek flows through the southern third of the Alternative 2 site. The usable portions of the site are located in Flood Zone C, an area of minimal flooding. Though this site's location outside of a flood zone does not make it inappropriate for a sports park, a sports park can make very good use of land that is in a flood zone and otherwise limited in its usability. This consideration makes the sports park a desirable use of the project site. Storm water run -off and surface water quality issues at this site would be similar to those at the project site. Alternative 2 and the proposed project are approximately equal in terms of hydrology. Biological Resources Uvas Creek flows through the southern third of the Alternative 2 site, and is surrounded by similar habitat as at the project site. Biological resource issues at this site would be similar to those at the project site. Alternative 2 and the proposed project are approximately equal in terms of biological resources. Transportation/Circulation The Alternative 2 site is located at the intersection of State Highway 152 and Santa Teresa Boulevard. West of the site, State Highway 152 is a winding two -lane mountain road connecting Gilroy to Watsonville. East of the site State Highway 152 follows two and four -lane city streets through downtown Gilroy to an interchange with U.S. Highway 101 at Tenth Street. Santa Teresa Boulevard is a predominately two -lane arterial. Santa Teresa Boulevard would provide a direct approach from the south if it were extended to U.S. Highway 101. Approximately 30 percent of the sports park related traffic is expected to use U.S. Highway 101. The most direct access to the Alternative 2 site from U.S. Highway 3 -16 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues 101 is via the Tenth Street and Leavesley Road exits to Monterey Street and First Street (State Highway 152). An additional 40 percent of trips that would be expected to use Monterey Street or Church Street to reach the project site would likely use First Street to reach the Alternative 2 site. Approximately 70 percent of the traffic to the Alternative 2 site would be expected to use First Street. The existing level of service at the intersection of State Highway 152 and Santa Teresa Boulevard is LOS C. The existing level of service at the intersection of First Street (State Highway 152) and Monterey Street is LOS B. Projected weekend mid -day levels of service at these intersections under cumulative ` conditions are LOS E and LOS F respectively, and with mitigation under cumulative conditions LOS C at both intersections (Robert Bein, William Frost and Associates 1997). Trips to the Alternative 2 site would use mostly the same roads as the project site, but would be concentrated on Monterey Street and First Street in built -out areas, where existing traffic levels are higher and physical roadway expansion possibilities are limited. The increase in traffic would be likely to result in significant traffic impacts to these intersections. The existing western terminus of the Uvas Creek Trail is at Laurel Drive and Uvas Creek Drive, approximately one - quarter mile from the site. An underpass for the trail is proposed beneath Santa Teresa Boulevard, as is a western extension of the trail. Santa Teresa Boulevard has bicycle lanes. Bicycle and pedestrian access to the site would be good. Because Alternative 2 would likely result in traffic impacts that would be difficult to mitigate, the proposed project is superior to Alternative 2 in terms of traffic impacts. Public Services Half of the Alternative 2 site is located outside the Gilroy city limits. Existing service conditions at those parcels are similar to those at the project site. The SSCCFD statiori.at State Highway 152 and Burchell Road is located one mile west of the site. The other half of the site is within the Gilroy city limits and receives its public services from the City of Gilroy. Alternative 2 would have less impact on services than the proposed project. However, neither the proposed project nor Alternative 2 would have a significant impact on public services. Alternative 2 and the proposed project are approximately equal in terms of public services. Air Quality Alternative 2 would result in the same number of trips as the proposed project. Alternative 2 and the proposed project are approximately equal in terms of air quality. EMC Planning Group Inc. Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR Noise Alternative 2 would generate the same amount of noise as the proposed project. The Alternative 2 site is equally isolated from surrounding residential uses as the proposed project and would not result in any significant impacts. The ambient noise level at the Alternative 2 site would be lower, but ambient noise did not present a significant impact at the project site. Alternative 2 and the proposed project are approximately equal in terms of noise. Archaeological Resources The Alternative 2 site is located in an archaeologically sensitive area, as is the project site. Alternative 2 and the proposed project are approximately equal in terms of archaeological resources. Aesthetics State Highway 152 and Santa Teresa Boulevard are both designated scenic roadways in the City of Gilroy General Plan. The sports park use would be appropriate in these scenic areas. The location has similar scenic qualities to the proposed site, though it is closer to the mountains and has a more remote feel than the project site. Nearby development is less dense than at the project site. The nighttime lighting would have a somewhat lesser impact on surrounding uses and a somewhat greater impact on the remote ambiance of the area. Alternative 2 and the proposed project are approximately equal in terms of aesthetics. Alternative #3 (Alternative Location B) Santa Teresa Boulevard and Miller Avenue The Alternative 3 site is comprised of five parcels located between Miller Avenue and Santa Teresa Boulevard in western Gilroy. The assessor's parcel numbers are 808 -18 -014, 808 -18 -015, 808 -18 -016, 808 -18 -017 and 808 -18 -018. The total acreage of the site is 97.30 acres. The site is bounded by Santa Teresa Boulevard on the southwest, private land on the southeast, Miller Avenue on the east, and city -owned and private land on the north. Approximately 90 percent of the Alternative 3 site has been used for field and tree crops, though no active agriculture is presently on- going. Along the northern edge of the site is a wooded area that includes a small reservoir. The City of Gilroy General Plan designation is RESIDENTIAL - LOW DENSITY. The site is zoned Limited Industrial and an industrial park was previously approved for the site. One EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues road is built into the site. The land to the west and south is undeveloped and Christmas Hill Park is located to the east of the site. A sports park with similar facilities to the proposed project would be built on the site. Agricultural Considerations Most of the land on the site has been in agricultural production with field crops and tree crops, but the site is not currently in agricultural use. Some of the land is on wooded slopes and not farmable. Approximately two- thirds of the farmable land is identified on the Santa Clara County Important Farmland Map as Prime Farmland, and approximately one -third is identified as Farmland of Local Importance, defined as "small orchards and vineyards primarily in the foothill areas; also land cultivated as dry cropland for grains and hay." None of the parcels on the Alternative 3 site is under Williamson Act contract. The site is within the Gilroy city limits. Alternative 3 would result in approximately 50 fewer acres of prime farmland or farmland of local importance converted to non - agricultural use. The site is already within the Gilroy city limits and Urban Service Area. Alternative 3 is superior to the proposed project in terms of agricultural considerations. Geology There would be no unusual geologic impacts associated with Alternative 3. Alternative 3 and the proposed project are approximately equal in terms of geologic hazards. Hydrology Uvas Creek is located approximately one - quarter mile north of the Alternative 3 site. The site is located in Flood Zone C, an area of minimal flooding. Though this site's location outside of a flood zone does not make it inappropriate for a sports park, a sports park can make very good use of land that is in a flood zone and otherwise limited in its usability. This is a consideration that makes the sports park a desirable use of the project site. Storm water run -off and surface water quality issues at this site would be similar to those at the project site. Alternative 3 and the proposed project are approximately equal in terms of hydrology. EMC Planning Group Inc.. 3 -19 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR Biological Resources Several wooded areas are located on the Alternative 3 site. Oak woodland is the predominate habitat at the Alternative 3 site. A small reservoir is located on the site. Preserved natural areas are located north and east of the site. Biological resource issues at this site would be similar to those at the project site. Alternative 3 and the proposed project are approximately equal in terms of biological resources. Transportation/Circulation The Alternative 3 site is located north of the intersection of Santa Teresa Boulevard and Miller Avenue. Existing access to the site is from Miller Avenue. The City of Gilroy parcel map shows street rights -of -way connecting the site to Santa Teresa Boulevard as well. Santa Teresa Boulevard is a predominately two -lane arterial. Santa Teresa Boulevard would provide a direct approach from the south if it were extended to U.S. Highway 101. Miller Avenue is a two -lane collector. Approximately 30 percent of the sports park related traffic is expected to use U.S. Highway 101. The most direct access to the Alternative 3 site from U.S. Highway 101 is via the Tenth Street to Uvas Park Drive and Miller Avenue. An additional 20 to 40 percent of trips that would be expected to use Monterey Street or Church Street to reach the project site would likely use Uvas Park Drive and Miller Avenue to reach the Alternative 3 site. The remaining traffic would likely use Santa Teresa Boulevard to reach the site Half or more of the traffic to the Alternative 3 site would use Uvas Park Drive (classified in the City of Gilroy General Plan as a collector street) and Miller Avenue (not classified in the City of Gilroy General Plan). Increases in traffic on these relatively minor streets would be likely to result in significant traffic impacts at intersections along Uvas Park Drive and Miller Avenue. Impacts would be especially severe during the Gilroy Garlic Festival at adjacent Christmas Hill Park, although shuttle service is provided for the festival from remote parking lots. Trips to the Alternative 3 site would be concentrated on Tenth Street and Uvas Park Drive both relatively minor roads and would likely result in traffic impacts to intersections along these roads. The Uvas Creek Trail passes within approximately one - quarter mile of the site. Santa Teresa Boulevard has bicycle lanes. Bicycle access to the site would be good, but the site is relatively isolated for good pedestrian access. Because access to the Alternative 3 site would likely result in traffic impacts to relatively minor streets, (Uvas Park Drive and Miller Avenue) the proposed project is the superior project in terms of traffic impacts. 3 -20 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment EIR Section 3: Related Environmental Issues_ Public Services The Alternative 3 site is located within the Gilroy city limits and receives its services from the City of Gilroy. The recycled water distribution line currently serves the site. Alternative 3 would have less impact on services than the proposed project. However, neither the proposed project nor Alternative 3 would have a significant impact on public services. Alternative 3 and the proposed project are approximately equal in terms of public services. Air Quality Alternative 3 would result in the same number of trips as the proposed project. Alternative 3 and the proposed project are approximately equal in terms of air quality. Noise Alternative 3 would generate the same amount of noise as the proposed project. The Alternative 3 site is more isolated from surrounding residential uses, however neither the proposed project nor Alternative 3 would result in any significant impacts. The ambient noise level at the Alternative 3 site would be similar to the project site, but ambient noise did not present a significant impact at the project site. Alternative 3 and the proposed project are approximately equal in terms of noise. Archaeological Resources The Alternative 3 site is located in an archaeologically sensitive area, as is the project site. Alternative 3 and the proposed project are approximately equal in terms of archaeological resources. Aesthetics Santa Teresa Boulevard is a designated scenic roadway in the City of Gilroy General Plan. The sports park use would be appropriate in this scenic area. The location has similar scenic qualities to the proposed site, though it is adjacent to larger areas of parkland than the project site. Nearby development is less dense than at the project site. The nighttime lighting would have a somewhat lesser impact on surrounding uses and a somewhat greater impact on the remote ambiance of the area. Alternative 3 and the proposed project are approximately equal in terms of aesthetics. EMC Planning Group Inc. 3 -21 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR Alternative #4 (Alternative Location C) Monterey Road at Bolsa Road The Alternative 4 site is comprised of three parcels located north and east of Monterey Road and Bolsa Road in southern Gilroy. The assessor's parcel numbers are 841 -31 -003, 841 -31 -019 and 841 -31 -022. The total acreage of the site is 103.03 acres. The site is bounded by Monterey Road on the southwest, Bolsa Road on the south, Camadero Avenue on the southeast, the Union Pacific Railroad on the northeast and private property on the northwest. The Alternative 4 site is in agricultural production with field crops and row crops. The land to the west and south and east is undeveloped. The land to the north is commercial industrial. The site is outside the Gilroy city limits but within the Urban Service Area. The site is designated OPEN SPACE in the City of Gilroy General Plan. A sports park with similar facilities to the proposed project would be built on the site. Agricultural Considerations The land on the Alternative 4 site is in agricultural production with field crops and row crops. The land to the west and south and east is undeveloped. The land is identified on the Santa Clara County Important Farmland Map as Prime Farmland. The land is adjacent to extensive areas of Prime Farmland and to the Gilroy Agricultural Lands Area. None of the parcels on the Alternative 4 site is under Williamson Act contract. The site is outside the Gilroy city limits but within the Urban Service Area. Alternative 4 would result in approximately 30 fewer acres of prime farmland converted to non - agricultural use. The site is currently within the Gilroy Urban Service Area. However, even though the land is outside the Gilroy Agricultural Lands Area, it is part of an extensive contiguous area of prime farmland, adjacent to the preserve area. Contiguous areas of farmland are considered to have greater value as farmland than noncontiguous areas. These factors considered together make the two sites approximately equal in terms of their impact on agricultural resources. Alternative 4 and the proposed project are approximately equal in terms of agricultural considerations. Geology There would be no unusual geologic impacts associated with Alternative 4. Alternative 4 and the proposed project are approximately equal in terms of geologic hazards. 3 -22 EMC Planning Group Inc. Gilrou Snorts Park and USA Amendment EIR Section 3: Related Environmental Issues Hydrology Uvas Creek is located approximately one - quarter mile south of the Alternative 4 site, across Bolsa Road. The site is located in Flood Zone C, an area of minimal flooding. Though this site's location outside of a flood zone does not make it inappropriate for a sports park, a sports park can make very good use of land that is in a flood zone and otherwise limited in its usability. This consideration makes the sports park a desirable use of the project site. Storm water run -off and surface water quality issues at this site would be similar to those at the project site. Alternative 4 and the proposed project are approximately equal in terms of hydrology. Biological Resources The Alternative 4 site is entirely agricultural and would not support any significant biological resources. There would be no significant environmental impacts on biological resources on the Alternative 4 site. Alternative 4 is superior to the proposed project in terms of biological resources. Transportation/Circulation The Alternative 4 site is located south of the U.S. Highway 101 and Monterey Road interchange on Bolsa Road. Bolsa Road is the southern extension of Monterey Road. It is currently a two -lane rural road south of the freeway ramps. Approximately 30 percent of the sports park related traffic is expected to use U.S. Highway 101. The remaining traffic would likely use a variety of surface streets to reach Monterey Road and Bolsa Road. There are no bicycle or pedestrian facilities serving the site. While bicycle lanes could be provided to the site, the site's distance from residential areas makes pedestrian access unlikely. Alternative 4 and the proposed project are approximately equal in terms of traffic impacts. Public Services The Alternative 4 site is located outside the Gilroy city limits and currently receives its public services from Santa Clara County or from agencies other than the City of Gilroy. Alternative 4 would result in the same impacts to public services as the proposed project. Neither the proposed project nor Alternative 4 would have a significant impact on public services. EMC Planning Group Inc. 3 -23 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR Alternative 4 and the proposed project are approximately equal in terms of public services. Air Quality Alternative 4 would result in the same number of trips as the proposed project. Alternative 4 and the proposed project are approximately equal in terms of air quality. Noise Alternative 4 would generate the same amount of noise as the proposed project. The Alternative 4 site is more isolated from surrounding residential uses, however neither the proposed project nor Alternative 4 would result in any significant impacts. The ambient noise level at the Alternative 4 site would be similar to the project site, but ambient noise did not present a significant impact at the project site. Alternative 4 and the proposed project are approximately equal in terms of noise. Archaeological Resources The Alternative 4 site is located in an archaeologically sensitive area, as is the project site. Alternative 4 and the proposed project are approximately equal in terms of archaeological resources. Aesthetics The Alternative 4 site has similar scenic qualities to the proposed site, though it is not adjacent to any residential areas. Nearby development is sparse. The nighttime lighting would have a somewhat lesser impact on surrounding uses and a somewhat greater impact as viewed from a distance. The lighting would tend to be more noticeable in a location separated from the rest of the illuminated urban area. Alternative 4 and the proposed project are approximately equal in terms of aesthetics. Evaluation of Alternatives CEQA Guidelines section 15126.6 (d) requires the EIR to present enough information about each alternative to allow meaningful evaluation, analysis and comparison with the proposed project. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the 3_24 EMC Planning Group Inc. Gilroy Sports Park and LISA Amendment EIR Section 3: Related Environmental Issues significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed. CEQA Guidelines section 15126.6(e) requires the selection of an environmentally superior alternative. If the 'No Project " alternative is the environmentally superior alternative, then the environmentally superior alternatives amongst the remaining alternatives must be identified. The "No Project " alternative is the environmentally superior alternative, because it eliminates the unavoidable significant impact of loss of prime farmland. The remaining alternatives and the proposed project are all approximately equal in terms of their environmental impacts, and the selection of one alternative as the environmentally superior is based on very fine shades of interpretation. Though very close to the other remaining alternatives and the proposed project in terms of its environmental effects, Alternative 3 (Alternative Location B —Santa Teresa Boulevard and Miller Avenue) is the environmentally superior alternative among the remaining alternatives. The principal factor that favors Alternative 3 is its reduced impact on prime farmland compared to Alternatives 2 and 4. Other factors on which the alternatives vary to any significant degree are biological resources, traffic and land use. The biological resource impacts are easily mitigated to a less than significant level. Traffic impacts associated with Alternative 3 are approximately the same as Alternative 2, though greater than Alternative 4. Alternative 4 is more remote from existing urban development and closer to large areas of contiguous farmland than the other locations and less appropriate from that standpoint. The relative environmental merits of each alternative are summarized below. The environmentally superior alternative is identified. Table 17 summarizes the environmental effects of each alternative as well as the proposed project. Table 18 compares the relative environmental impacts of each alternatives to the proposed project. EMC Planning Group Inc. 3 -25 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR TABLE 17 Summary of Environmental Effects of Proposed Project and Alternatives Environmental Proposed Alternative 1 Alternative 2 Alternative 3 Alternative 4 Issue Project "No Project" "Santa Teresa/ "Santa Teresa/ "Monterey/ State Hwy 152' Miller" Bolsa" Agricultural Significant No Impact Significant Significant Significant Considerations Unavoidable Unavoidable Unavoidable Unavoidable Geology Less Than No Impact Less Than Less Than Less Than Significant Significant Significant Significant Hydrology Mitigated to No Impact Mitigated to Mitigated to Mitigated to Less Than Less Than Less Than Less Than Significant Significant Significant Significant Biological Mitigated to No Impact Mitigated to Mitigated to No Impact Resources Less Than Less Than Less Than Significant Significant Significant Transportation Mitigated to No Impact Potentially Potentially Mitigated to / Circulation Less Than Significant Significant Less Than Significant Mitigation may Mitigation may Significant be Required be Required Public Services Less Than No Impact Less Than Less Than Less Than Significant Significant Significant Significant Air Quality Mitigated to No Impact Mitigated to Mitigated to Mitigated to Less Than Less Than Less Than Less Than Significant Significant Significant Significant Noise Mitigated to No Impact Mitigated to Mitigated to Mitigated to Less Than Less Than Less Than Less Than Significant Significant Significant Significant Archaeological Mitigated to No Impact Mitigated to Mitigated to Mitigated to Resources Less Than Less Than Less Than Less Than Significant Significant Significant Significant Aesthetics Less Than No Impact Less Than Less Than Less Than Significant Significant Significant Significant Source: EMC Planning Group Inc. 3 -26 EMC Planning Group Inc. ' - Gilroy Sports Park and USA Amendment EIR Section 3: Related Environmental Issues TABLE 18 Comparison of Environmental Effects of Alternatives to Proposed Project Environmental Issue Alternative 1 "No Project" Alternative 2 "Santa Teresa/ State Hwy 152' Alternative 3 "Santa Teresa/ Miller" Alternative 4 "Monterey/ Bolsa" Agricultural Considerations Much Better Slightly Better Slightly Better Similar Geology Slightly Better Similar Similar Similar Hydrology Better Similar Similar Similar Biological Resources Slightly Better Similar Similar Much Better Transportation/ Circulation Much Better Worse Worse Slightly Worse Public Services Slightly Better Slightly Better Better Similar Air Quality Better Similar Similar Similar Noise Better Similar Similar Similar Archaeological Resources Slightly Better Similar Similar Similar Aesthetics Better Slightly Worse Similar Slightly Worse Source: EMC Planning Group Inc. EMC Planning Group Inc. 3 -27 Section 3: Related Environmental Issues Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 3_28 EMC Planning Group Inc. 4.0 Bibliography and Project Team 4.1 Persons Contacted Ms. Melissa Durkin, Planner II, City of Gilroy Community Development Department. Mr. William Faus, Planning Director, City of Gilroy Community Development Department. Mr. Robert Friedrick, Senior Appraiser, Santa Clara County Office of the Assessor. Mr. William Headley, Jr., Facilities and Parks Development Manager, City of Gilroy. Mr. Henry Hilken, Senior Transportation Planner, Bay Area Air Quality Management District. Mr. Roger Maggio, Deputy Fire Marshall, City of Gilroy. Mr. Derek McKee, Vice President, the beals group inc. Ms. Kathy Sakahara, Human Resources Department, City of Gilroy. Mr. Bryan Stice, Planner I, City of Gilroy Community Development Department. Mr. Kirk Wheeler, P.E. Principal, Schaaf and Wheeler. Mr. Bill Wren, Public Information Specialist, McDonald Observatory, University of Texas at Austin. 4.2 Literature Cited Archaeological Resource Management. Cultural Resource Evaluation of Lands for the Gilroy Sports Complex and Uvas Creek Trial Extension Project in the City of Gilroy, California. October 20, 1998. San Jose, California. Association of Bay Area Governments. On Shaky Ground. 1995. *Bay Area Air Quality Management District. Bay Area Air Quality Management District CEQA Guidelines. April, 1996. San Francisco, California. EMC Planning Group Inc. 4-1 Section 4.Bibliography and Project Team Gilroy Sports Park and USA Amendment EIR *Bay Area Air Quality Management District. Bay Area '97 Clean Air Plan. December 17, 1997. San Francisco, California. California Department of Conservation. Santa Clara County Important Farmland Map. 1993. Sacramento, California. California Department of Fish and Game. Staff Report on Burrowing Owl Mitigation. September 1995. *Camp, Dresser & McKee, Inc. City of Gilroy Water Master Plan. 1993. *Camp, Dresser & McKee, Inc. City of Gilroy Wastewater Master Plan. 1993. *City of Gilroy. City of Gilroy General Plan. as amended June 3,1996. Gilroy, California. *City of Gilroy. City of Gilroy General Plan Map. as revised May 14,1997. Gilroy, California. *City of Gilroy, County of Santa Clara, Santa Clara County Local Agency Formation Commission. Strategies to Balance planned Growth and Agricultural Viability in the Areas South and East of Gilroy. October 1996. *County of Santa Clara. Santa Clara County General Plan. December 1994. San Jose, California. County of Santa Clara. Santa Clara County Relative Seismic Stability Map. 1974. *County of Santa Clara Local Agency Formation Commission. Santa Clara County Local Agency Formation Commission Policies and Guidelines. February 1997. San Jose, California. *Crawford, Multari and Starr. Study of the South County Agricultural Preserve. February 1995. Creegan and D'angelo. Blocher Property Hydrology and Drainage Report. January 16, 1993. *Edward L. Pack Associates, Inc. Noise Assessment Study for the Environmental Impact Report, Gilroy Sports Park. November 18,1998. Los Gatos, California. *Federal Emergency Management Agency. Flood Insurance Rate Map (Panel 755). August 17,1998. *Federal Emergency Management Agency. Flood Insurance Rate Map (Panel 760). August 17,1998. *Fehr and Peers Associates. Transportation Impact Analysis, Gilroy Sports Park. December 1998. San Jose, California. 4_2 EMC Planning Group Inc. Gilroy Sports Park and USA Amendment EIR Section 4: Bibliography and Project Team *LSA Associates, Inc. Preliminary Assessment of the Biological Resources of the Lands of Blocher - Filice. January 1993. *Robert Bein, William Frost and Associates. Gilroy Municipal Golf Course Project Environmental Impact Report. Revised Draft, April 1997. *United States Army Corps of Engineers. Pajaro River Basin Uvas - Carnadero Creek, California; General Design memorandum Phase I Report. July 1981. *United States Department of Agriculture Soil Conservation Service. Soil Survey of Eastern Santa Clara Area, California. September 1974. Washington, DC. Documents marked with an asterisk may be viewed at the City of Gilroy Planning Division office at 7351 Rosanna Street, Gilroy CA. All documents are available for review at EMC Planning Group Inc., 99 Pacific Street, Suite 155F, Monterey, CA. 4.3 Project Team EMC Planning Group Inc. Teri Wissler, Planning Associate Project Manager Richard James, Planning Technician Report Preparation and Graphics Cara Galloway, Planner /Biologist Biological Assessment Archaeological Resource Management Dr. Robert Cartier, Principal Investigator Preliminary Archaeological Reconnaissance Edward L. Pack Associates, Inc. Fehr and Peers Associates, Inc. EMC Planning Group Inc. 4 -3 Section 4.-Bibliography and Project Team Gilroy Sports Park and USA Amendment EIR This side intentionally left blank. 4-4 EMC Planning Group Inc. Appendix A Notice of Preparation Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Notice of Preparation To: Responsible and Trustee Agencies From: City of Gilroy Community Development Department Planning Division Subject: Notice of Preparation of a Draft Environmental Impact Report Gilroy Sports Park and Urban Service Area Amendment Request Location: The 133.2 -acre project site is located immediately south of the City of Gilroy in unincorporated Santa Clara County, approximately 35 miles south of San Jose, 10 miles south of Morgan Hill, and 30 miles northeast of Salinas. Figure 1 illustrates the regional location. The project site is located at the south end of town at the southwest corner of Monterey Road and Thomas Road — Luchessa Avenue. It is bordered by Thomas Road — Luchessa Avenue to the north, Uvas Creek and Farman Lane to the south, Monterey Road and Monterey Frontage Road to the east, and Uvas Creek to the west. Surrounding land uses are residential (single- family), commercial (hotels under construction), and agricultural (row crops). U.S. Highway 101 is located approximately 300 feet from the south end of the site, to approximately 1,100 from the north end of the site. Figure 2 illustrates the project vicinity. The City of Gilroy will be the Lead Agency and will prepare an Environmental Impact Report for the project identified in this notice of preparation. In connection with the proposed project, we need to know the views of your agency as to the scope and content of the environmental information which is germane to your agency's statutory responsibility. Due to the time limits mandated by State law, your response must be sent at the earliest possible date but not later than 30 days after receipt of this notice. Please respond by November 23, 1998. Please send your response to Bryan Stice at the City of Gilroy Planning Division. We will need the name of a contact person in your agency. Date: Signature: Title: Planner I City of Gilroy Planning Division 1 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Project Description Existing Conditions The entire 133.2 -acre project site is located in unincorporated Santa Clara County, immediately south of both the city limits of Gilroy and the Urban Service Area limits. The site is currently in agricultural row -crop production. Three rural residences are located along the site's eastern boundary on Monterey Frontage Road. Uvas Creek is located at the western boundary and a portion of the southern boundary. A flood - control levee was constructed on a portion of the site. The levee extends from ten feet landward of the levee toe, to the bank of the channel. 4t extends approximately 1,100 feet (on -site) south of Thomas Road— Luchessa Avenue to 4,500 feet upstream (and off -site) to Miller Avenue. The City of Gilroy general plan land use designations for the project site is open space and park /public facility. General plan land use designations surrounding the site include residential (east and north), general services (east and north), visitor serving (east), and open space (west). Proposed Conditions The proposed project consists of three components: an Urban Service Area Amendment request to Santa Clara County LAFCo; development of the Gilroy Sports Park; and construction of off -site improvements including extension of the Uvas Creek Trail north to Thomas Road— Luchessa Avenue, and south to Gavilan College (including a pedestrian /bicycle bridge), extension of the city's recycled water distribution line to the sports park, and roadway improvements. Urban Service Area Amendment Request The entire 133.2 -acre site is proposed for inclusion into the city's Urban Service Area. This would include the 78.4 -acre sports park site and 54.8 acres of adjacent parcels. Figure 3 identifies the project site and it's relation to the existing Urban Service Area. Table 1 includes identification of affected parcels. The sports park is the only project proposed for development at this time within the Urban Service Area Amendment request. A small portion of the sports park site is located adjacent to the existing Urban Service Area boundary along Monterey Frontage Road. However, in an effort to not create an "island ", the city has included the adjacent parcels to the north and east in the Urban Service Area Amendment request. The adjacent parcels' general plan land use designation of open space will not be modified as part of this project. Planting Division Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation rr:111-10M Assessor's Parcels Project Component Assessor's Parcel Number Acres Sports Park Area 808 -21 -030 26.269 808 -21 -028 31.53 808 -21 -026 20.56 Additional Area 808 -21 -021 7.00 808 -21 -018 0.87 808 -21 -016 26.05 808 -21 -008' 0.10 808 -21 -009 0.70 808 -21 -031 7.42 808 -21 -029 4.70 808 -21 -027 6.20 808 -21 -013 4.51 808 -21 -014 1.35 808 -21 -015 32.95 Total 133.209 Source: City of Gilroy Gilroy Sports Park The sports park preliminary master plan is presented in Figure 4. The Gilroy Sports Complex Draft Master Plan, prepared by Beals Landscape Architecture, Inc. in May 1998, is available for public review at the City of Gilroy Community Services Department. Preliminary plan components include the following: recreational play fields (eight softball diamonds and four soccer fields and concession / restrooms); premier play fields (one 90 -foot baseball diamond, two little leagues diamonds and one soccer field and concession / restrooms); competition play fields (one softball /baseball diamond and one soccer field and concession / restrooms); 8.8 acres of park preserve with volleyball, family picnic; concessions /restrooms, bocce ball courts, and plav area; commercial recreation (indoor soccer, roller hockey, community building, storage); corporation yard; parking (1,043 spaces); and a night watch park ranger station. Soccer fields overlav baseball /softball fields. Football may also be played on the soccer fields. The preliminary master plan also includes the following: a habitat buffer zone, ti measured from 50 feet from top of bank, along Uvas Creek to be enhanced with City of Gilroy Planning Division 3 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation native plantings; a six -foot perimeter fence; walking /bicycle paths throughout the site; entry gates and an entry building at the Monterey Frontage entrance; and the extension of the Uvas Creek Trail from Thomas Road — Luchessa Avenue through the site and continuing on to the south. The trail extension will cross Uvas Creek via a pedestrian /bicycle bridge at the southern boundary where it will eventually continue south to connect with Gavilan College. Off -Site Improvements Off -site improvements include the extension of the Uvas Creek Trail north to Thomas Road — Luchessa Avenue, and south to Gavilan College; extension of the city's recycled water distribution line to the sports park; and roadway improvements. Uvas Creek Trail Extension. The proposed Uvas Creek Trail Extension is illustrated in Figure 5. The project's trail system will connect to the existing Uvas levee trail, which ends just past Thomas Road — Luchessa Avenue, to the Gavilan College area. A bridge crossing is proposed at the central, southern portion of the project site. The trail then continues south to Mesa Road where the trail system would turn east into the Gavilan College campus. Recycled Water Distribution Line. The city would extend a recycled water distribution line to serve the landscape needs of the sports park. Roadway Improvements. To enable pedestrian traffic, a six -foot wide sidewalk is = proposed southward from the Thomas Road — Luchessa Avenue /Monterey Road intersection to the Monterey Frontage Road. There would also be a crosswalk at the Monterey Frontage Road, with appropriate project signs and introduction to the sports park. The crosswalk and intersection of Monterey Road and Monterey Frontage Road would be signalized in the future. This improvement would be based on a demand and use level with traffic/ circulation for the sports park. The sidewalk would then continue down the Monterey Frontage Road and into the park itself. The sidewalk would be buffered from the road with a parkway strip consisting of shade trees and accent planting. Phasing The sports park will be developed in approximately nine phases. The proposed phasing plan is illustrated in Figure 6. Phases are being proposed in sequence of construction from the entrance to the west end of the site for Phases One through Seven. Phases Eight through Nine can occur at any time, and have been separated based on that area being able to be constructed independently of the other phases. City of Gilroy Planning Division g Source: Califomia State Automobile Association and EMC Planning Group Inc. No Scale j L[ ) IGilrov Sports Park and USA Amendment EIR NOP Figure A Land Use Planning Regional Location and Design Firm 1 Suurce: California Automobile Association and EMC Planning Group Inc. JCale: 1 = L,Lllu Gilroy Sports Park and USA Amendment EIR NOP Figure A Land D ^ and Design Firm Project Vicinity L i I i i �r--J-V r-r;a'ZkiM) EXISTING lh . I. Asneurr Cl. t.Hawlhorne SI. 5. Foa0lave CL - - - - -- 1 n e,. I 10 URBA { N 1, E I -- J LuSn ✓,���\ �a 9 oe I 7 1 V lIii + SERVICE No '4 \ N \ L, i AREA II / USA REQUEST N It 111 (Parcel Ws as of'98-'991 File USA 98.03 vq Sports Park Area: 808.21 -030 ff 808.21 -028 808 -21 -026 Additional Area 808.21 -021 i O 808 =21 -018 BOB•21 -016 ..iV- !\ \ }� 808 -21 -008 �� ,, �� �,� 308 -21 -009 - 808 -21 -031 ' . t \ s C,' cr, 808.21 -029 \ y�� 808.21 -027 �• 808 -21 -013 ♦ 808 -21 -011 Source: city of cilrov 808 -21 -015 No Scale Gilroy Sports Park and USA Amendment EIR NOP Figure A Land Use Planning Project Site and Relation 3 and Design Firm to Existing Urban Service Area Z� ZOIC Source: BVAS L.mdscape Ardateeturv, Im. A land Use Planning and Design Firm IOiIXlul W FI Gilroy Sports Park and USA Amendment EIR NOP Preliminary Master Plan C t/ No Scale Figure 4 m„Z - Ww —nom" TMnw�ow \ . m� TNp�Y�nOaD w,fC`� G10QIr \ ODSrOA Uvas Levee Trail Svstem Extension to Thomas Road Bridge J Uvas Levee Trail System Extension to Gavilan College Source: Beals Landscape Archneaure. Inc. A Land Use Planning and Design Firm No Scale Gilroy Sports Park and USA Amendment EIR NOP Figure Uvas Creek Trail Extension 5 H WE AREA I ITURY WRAS I HUL I LINE. EN HANCL. CORPORATION YAODAFO WdSCREEH 1FWL DIEHSIOMROUGH GFIV InO WE MIER LIME 1 LAl:11E FIEI D AREA, PANNING AND WAS CREEK TMIt L A TENSION TO INDFV S ROAD COMMERCM RECREA[ION AND MIA I [ISE BALL FIELD NORM WILD USE FIELD AREA AND PARKING SCUTM MULTLUSE FIELD MG AND PARKING PREMIER SOFTB UBASEEI L FIELD AREA AND PARKING INFORMAL RECNEAIIONAHFA MONI EHEY FRON IAGE ROAD IMPHOV WEmS WAS CREEK TRAIL EXTENSION 10 GAVMN COLLEGE (� `,� IMPROVEMEIFTS TO TIOI.N9 READ K 1 MSTOD BIKE(RAL II•� -- - -�rN> - - 1 ' I IU ` ` �I , I 1 i\ -• - T�.. f /I. F}i; , ,(Il` - w / 1 VI . \ � Hp, k 'iLySi• J.L r6�l.L yy' �{1y�,.�• -' -}y VII V Source: Beals Landscape Architecture, Inc.' A land Use Planning and Design Firm I) IK71� Gilroy Sports Park and USA Amendment EIR NOP Phasing Plan v' \DIPRDVEMENiSTO I `TL104A9 ROAD / 1 I i W KA hN No Scale Figure 6 I F i t� Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation CITY OF GILROY 7351 Rosanna Street Gilroy, California 95020 (408) 848 -0440 Initial Study I. BACKGROUND Project Name: Gilroy Sports Park and Urban Service Area Amendment Request Project Location: At the southwest corner of Thomas Road — Luchessa Avenue and Monterey Road, south of the city limits of Gilroy and south and west of the existing Urban Service Area boundaries. File No: USA 98 -03 Date Prepared: September 29,1998 Study Prepared By: EMC Planning Group Inc. P.O. Box 414, Monterey, California 93942 (408) 649 -1799 Name of Applicant: City of Gilroy Assessor's Parcel Number(s): See attached project description Acreage of Property: See attached project description Zoning: None General Plan Designation: Open Space and Park /Public Facility City of Gilroy Planning Division 11 Potentially Significant Potentially Unless Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact II. ENVIRONMENTAL IMPACTS 1. LAND USE AND PLANNING. Would the proposal: a) Conflict with general plan designation or ❑ ❑ ❑ ✓ zoning? (1, 2, 15, 16a, 16b) b) Conflict with applicable environmental plans or policies adopted by agencies with jurisdiction over the project? (1, 2, 3, 4, 5) ❑ ✓ ❑ ❑ c) Be incompatible with existing land use ❑ ❑ ❑ ✓ in the vicinity? (7, 15) d) Affect agricultural resources or operations ✓ ❑ ❑ (e.g. impacts to soils or farmlands, or impacts from existing adjacent farming activities)? (7,16i) e) Disrupt or divide the physical arrangement ❑ ❑ ❑ ✓ or an established community? (7,15) 2. POPULATION AND HOUSING. Would the proposal: a) Cumulatively exceed official regional or local ❑ ❑ ❑ ✓ population projections? (1, 2, 15,16a,16b) b) Induce substantial growth in an area either ❑ ✓ ❑ ❑ directly or indirectly (e.g. through projects in an undeveloped area or extension of major infrastructure)? (1, 2, 3, 4, 5, 7) c) Displace existing housing, especially affordable❑ ❑ ❑ ✓ housing? (7,15) 3. GEOLOGIC PROBLEMS. Would the proposal result in or expose people to potential impacts involving: a) Fault rupture? (16j) ❑ J D ✓ b) Seismic ground shaking? (16j, 17) ❑ J ✓ ❑ c) Seismic ground failure, including liquefaction?❑ ✓ ❑ (16j, 17) d) Landslides or mudflows? (16j) J J ✓ City of Gilroy Plannit ;e Division 12 City of Gilroy Plartttine Division 13 Potentially Significant Potentially Significant Unless Mitigation Less Than Significant No Impact Incorporated Impact Impact e) Erosion, changes in topography or unstable ❑ u ❑ ✓ soil conditions from excavation, grading, or fill? (6,7) f) Expansive soils, i.e., shrink -swell ❑ ✓ ❑ ❑ _ potential ? (6,17) g) Unique geologic or physical features? (7) ❑ ❑ ❑ ✓ 4. WATER. Would she proposal result in: a) Changes in absorption rates, drainage patterns,❑ ✓ ❑ ❑ or the rate and amount of surface runoff? (3, 7, 15, 17) b) Exposure of people or property to flooding? ❑ ✓ ❑ ❑ (15, 16f) c) Discharge into surface waters or other ❑ ❑ ✓ ❑ alteration of surface water quality? (7, 15,17) 11 d) Changes in the amount of surface water ❑ ❑ ❑ ✓ in any water body? (3,15) i e) Changes in currents, or the course or direction❑ ❑ ❑ ✓ of water movements? (3,15) f) Change in the quantity of ground waters, ❑ ❑ ❑ ✓ l either through direct additions or withdrawals, or through interception of an aquifer by cuts or excavations, or through substantial loss of groundwater recharge capability? (15) g) Altered direction or rate of flow of ❑ ❑ ❑ ✓ groundwater? (15) h) Impacts to groundwater quality? (15) ❑ ❑ ❑ ✓ i) Substantial reduction in the amount ❑ ❑ ❑ ✓ of groundwater available for public water supplies? (15) 5. AIR QUALITY. Would the proposal: a) Violate any air quality standard or ❑ ❑ ✓ ❑ contribute to an existing or projected air quality violation? (10) b) Expose sensitive receptors to pollutants? (17) : I ✓ ❑ ❑ City of Gilroy Plartttine Division 13 e) Hazards or barriers for pedestrians ❑ ❑ ❑ ✓ or bicyclists? (15) f) Conflicts with adopted policies ❑ ❑ ❑ ✓ supporting alternative transportation (e.g. bus turnouts, bicycle racks)? (1,15) g) Rail or air traffic impacts? (15) ❑ ❑ ❑ ✓ 7. BIOLOGICAL RESOURCES. Would the proposal result in impacts to: a) Endangered, threatened, or rare species or ❑ ✓ ❑ ❑ their habitats? (7) b) Locally designated species (e.g. oaks) (7) ❑ :3 -D ✓ c) Locally designated natural communities ❑ ❑ ❑ ✓ (e.g. oak forest) (7) d) Wetland habitat (e.g. marsh, riparian, ❑ ✓ ❑ ❑ and vernal pool)? (7) e) Wildlife dispersal or migration corridors? (7) ❑ ✓ ❑ ❑ City of Gilroy Planning Divisioti 14 Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant impact No Impact c) Alter air movement, moisture, or temperature,❑ ❑ ❑ ✓ or cause any change in climate? (15) d) Create objectionable odors? (15) ❑ ❑ ❑ ✓ 6. TRANSPORTATION /CIRCULATION. Would the proposal result in: a) Increased vehicle trips or traffic ❑ ✓ ❑ ❑ congestion? (1,15) b) Hazards to safety from design features ❑ ❑ ✓ ❑ (e.g. sharp curves or dangerous intersection) or incompatible uses (e.g. farm equipment) ?(7, 15) c) Inadequate emergency access or access ❑ ❑ ❑ ✓ to nearby uses? (15) d) Insufficient parking capacity on -site or ❑ ❑ ❑ ✓ off -site? (2, 15) e) Hazards or barriers for pedestrians ❑ ❑ ❑ ✓ or bicyclists? (15) f) Conflicts with adopted policies ❑ ❑ ❑ ✓ supporting alternative transportation (e.g. bus turnouts, bicycle racks)? (1,15) g) Rail or air traffic impacts? (15) ❑ ❑ ❑ ✓ 7. BIOLOGICAL RESOURCES. Would the proposal result in impacts to: a) Endangered, threatened, or rare species or ❑ ✓ ❑ ❑ their habitats? (7) b) Locally designated species (e.g. oaks) (7) ❑ :3 -D ✓ c) Locally designated natural communities ❑ ❑ ❑ ✓ (e.g. oak forest) (7) d) Wetland habitat (e.g. marsh, riparian, ❑ ✓ ❑ ❑ and vernal pool)? (7) e) Wildlife dispersal or migration corridors? (7) ❑ ✓ ❑ ❑ City of Gilroy Planning Divisioti 14 City of Gilroy Planning Division 15 Potentially Significant Potentially Significant Unless Mitigation Less Than Significant No Impact Incorporated Impact Impact S. ENERGY. Would the proposal: a) Conflict with adopted energy conservation ❑ ❑ ❑ ✓ plans? (15) b) Use non - renewable resources in a wasteful ❑ ❑ ❑ ✓ and inefficient manner? (15) 9. HAZARDS. Would the proposal involve: a) A risk of accidental explosion or release of ❑ ❑ ❑ ✓ hazardous substances (including, but not limited to: oil, pesticides, chemicals, or radiation)? (7,15) b) Possible interference with an emergency ❑ ❑ ❑ ✓ response plan or emergency evacuation plan? (15) c) The creation of any health hazard or potential ❑ ❑ ❑ ✓ health hazard? (7,15) _ d) Exposure of people to existing sources of ❑ ❑ ✓ ❑ potential health hazards? (7,15,17) e) Increase fire hazard in area with flammable ❑ ❑ ❑ ✓ brush,grass, or trees? (7, 15) 10. NOISE. Would the proposal result in: a) Increases in existing noise levels? (7, 15, 17) ❑ ✓ ❑ ❑ b) Exposure of people to severe noise ❑ ❑ ❑ ✓ levels? (7, 15) 11. PUBLIC SERVICES. Would the proposal have an effect upon, or result in a need for new or altered governmental services in any of the following areas: a) Fire protection? (1, 15) ❑ ❑ ✓ ❑ b) Police protection? (1, 15) ❑ _I ✓ ❑ c) Schools? (1, 15) ❑ ❑ ❑ ✓ d) Parks and Recreation Facilities? (1, 15) ❑ ❑ ❑ ✓ City of Gilroy Planning Division 15 13. AESTHETICS. Would the proposal: a) Affect a scenic vista or scenic highway? (1) ❑ ❑ ✓ ❑ _ b) Have a demonstrable negative ❑ ❑ ❑ ✓ aesthetic effect? (7, 15) c) Create light or glare? (7,15) ❑ ✓ ❑ ❑ 14. CULTURAL RESOURCES. Would the proposal: a) Disturb archaeological resources? (16h, 17) ❑ ✓ ❑ ❑ b) Affect historical resources? (7) ❑ ❑ ❑ ✓ E City or Gilroy Plannin•Q Division 16 _ Potentially Significant Impact Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact 12. UTILITIES AND SERVICE SYSTEMS. Would the proposal result in a need for new systems or supplies, or substantial alterations to the following utilities: a) Power or natural gas? (1,15) ❑ ❑ ❑ ✓ b) Communications systems (1,15) ❑ ❑ ❑ ✓ c) Water treatment or distribution ❑ ❑ ✓ ❑ facilities? (1,15) d) :.Sewer or septic tanks? (1, 4, 15) ❑ ❑ ❑ ✓ e) Storm water drainage? (1, 3,15) ❑ ✓ ❑ ❑ f) Local or regional water supplies? (1, 15) ❑ ❑ ✓ ❑ 13. AESTHETICS. Would the proposal: a) Affect a scenic vista or scenic highway? (1) ❑ ❑ ✓ ❑ _ b) Have a demonstrable negative ❑ ❑ ❑ ✓ aesthetic effect? (7, 15) c) Create light or glare? (7,15) ❑ ✓ ❑ ❑ 14. CULTURAL RESOURCES. Would the proposal: a) Disturb archaeological resources? (16h, 17) ❑ ✓ ❑ ❑ b) Affect historical resources? (7) ❑ ❑ ❑ ✓ E City or Gilroy Plannin•Q Division 16 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation INFORMATION REFERENCES 1. General Plan (City of Gilroy) 2. Zoning Ordinance (City of Gilroy) 3. Storm Drain Master Plan (City of Gilroy) 4. Sewer Master Plan (City of Gilroy) 5. Water Master Plan (City of Gilroy) 6. Soil Survey of Eastern Santa Clara County (U.S. Soil Conservation Service) 7. Field Inspection 8. Staff /Consultant Knowledge of Area 9. Santa Clara County Transportation Plan T2010 10. BAAQMD CEQA Guidelines, April 1996 (Table 6) 11. Site Specific Traffic Study 12. Site Specific Archaeological Study 13. Site Specific Noise Study 14. Site Specific Air Quality Impacts Study 15. Project Plans 16. Maps a. General Plan Land Use Map b. Zoning Map C. U.S.G.S. Topographic Quadrangle (7.5 Minute Series) d. Department of Fish and Game, Natural Diversity Data Base Map Overlays and Textual Reports e. Gilroy Slope Map (1" = 1,000') 1978 -79 General Plan Revision Program f. FEMA Flood Insurance Rate Map (1" = 1,000') h. Gilroy Archaeological Sensitivity Map (1" = 1,000') April 30, 1980 i. Santa Clara County Important Farmland Map (1" = 100,000') 1994 j. Santa Clara County Relative Seismic Stability Map (Scale Unknown) 17. See attached discussion (Proposed EIR Scope of Work) Note: This is an information reference list for all initial studies prepared within the City of Gilrov. Some of the references listed above may not have been utilized for this particular initial study. City of Gilroy Planning Division 17 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Proposed EIR Scope of Work The proposed EIR scope of work, which addressed the initial study checklist presented above, is as follows: Consistency With Local and Regional Plans This section will include a discussion of the proposed project's consistency with applicable local and regional plans. These plans include the City of Gilroy General Plan, the City of Gilroy Zoning Ordinance, Santa Clara County General Plan, applicable Santa Clara County LAFCo policies, and the Bay Area Air Quality Management District Air Quality Management Plan. Land Use and Planning Concern. The project site is currently in agricultural production and is considered prime farmland by the California Department of Conservation (Santa Clara County Important Farmland Map 1996). Loss of prime farmland is considered a significant, and generally unavoidable, adverse environmental impact. Approach and Methodology. The scope of work will include the following tasks: • Present the existing agricultural setting on the project site. Identify existing and proposed surrounding land uses. • Discuss the project site's designation as prime farmland by the California Department of Conservation. Discuss the project site's soil properties as described in the U.S. Department of Agricultural Soil Conservation Service Soil Survey for Eastern Santa Clara County. • Discuss the compatibility of the proposed project with existing, as well as proposed, surrounding land uses. • Discuss how the proposed project is compatible with surrounding land uses. • Present standards to determine significance. • Identify the impacts associated with loss of prime farmland. • Present feasible mitigation measures, if possible. • Determine if impacts can be reduced to a less than significant level. Water Concern. The project site is located adjacent to Uvas Creek and the U.S. Army Corps of Engineers levee. The project site is located within a known flood zone. City of Gilroy Plannin ;g Division 18 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Approach and Methodology. The scope of work will include the following tasks: Discuss flooding issues with lead agency staff, the Santa Clara Valley Water District, the U.S. Army Corps of Engineers, as well as other agencies and firms with knowledge or jurisdiction over the project site as it relates to flooding. Review previously prepared hydrological reports prepared for the project site and vicinity: Blocher General Plan Amendment Initial Study (1993) and the Blocher Property Hydrology and Drainage Report (1993), both of which were prepared by, or under contract to EMC Planning Group Inc. for the project site; the Update Insert Maps for this study (as noted in the August 13, 1998 memo to consultants from Bill Headley); and the Pajaro River Basin Uvas - Camadero Creek, California General Design Memorandum Phase I Report. • Present the existing surface water drainage patterns on the project site, as well as identification of the flood zone as presented on the FEMA Flood Insurance Rate Maps and study maps. • Identify how the proposed project would change the existing surface water drainage patterns, if at all. • Present standards to determine significance of impact. • Identify significant flooding impacts associated with the proposed project. • Present mitigation measures, as appropriate. • Determine if impacts can be reduced to less than significant levels. Note: The city has hired a hydrological engineering firm, separate from preparation of the EIR, to design the project to meet the requirements of the Santa Clara Valley Water District. Biological Resources Concern. The project site is located adjacent to Uvas Creek, a significant biological resource. A narrow riparian corridor with an average width estimated to be approximately 25 feet, borders Uvas Creek. A mixture of evergreen and deciduous mature native trees forms a canopy over the northeast bank of the creek. The riparian understory is well developed at the top of the bank adjacent to the western and southern borders of the agricultural field. Adult steelhead migrate upstream to spawn in winter and early spring. The Uvas Creek watershed provides one of the most important steelhead spawning grounds in the Pajaro River system. Special - status plant and wildlife species have the potential to be located within the creek City of Gilroy Planning Division 19 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation and riparian corridor. The proposed project includes a 50 -foot wide wildlife easement to include native plantings in an effort to widen the riparian corridor for Uvas Creek. Approach and Methodology. In association with preparation of the Blocher General Plan Amendment Initial Study, a reconnaissance level biological survey of the project site was completed in January 1993. Several recommendations were made regarding future development of the project site in order to assure that impacts to the creek corridor were minimized. The consultant will conduct a field survey to update the 1993 survey, focusing on the potential change in status for special - status plant and wildlife species. In addition, the off -site improvements (roadway improvement and bike trail extension) will also be analyzed for their poEenti'al impacts to biological resources. The scope of work will include the following tasks: Conduct a field survey to verify the results of the 1993 survey and make any necessary adjustments to the status of special - status plants and wildlife species as determined by the California Department of Fish and Game (CDFG), the U.S. Fish and Wildlife Service, and the California Native Plant Society. • Meet with lead agency staff and Beals Landscape Architecture, Inc. to discuss CDFG recommendations for the creek corridor. Meet CDFG to discuss the issues. • Present the biological resources setting for the project site, as well as the areas for off -site improvements (roadway improvement and bike trail extension). Include vegetation maps and tables, as appropriate. Include a discussion of special - status plant and wildlife species. • Discuss how the proposed project would change the existing biological setting. • Present standards to determine significance of impact. • Identify significant biological impacts associated with the proposed project. • Review the previously presented recommendations in the Blocher General Plan Amendment Initial Study for their applicability with the proposed project. • Present mitigation measures (including applicable previous recommendations and new mitigations), as appropriate. • Determine if impacts can be reduced to less than significant levels. City of Gilroy Planning Division 20 �I 'I Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Transportation/Circulation Concern. The proposed project will increase vehicle trips/ traffic congestion on the roadways in the vicinity of the project site. In addition, the potential for hazards or barriers for pedestrians and bicyclists will need to be evaluated. Project access and parking will need to be reviewed. The study intersections include Thomas Road — Luchessa Avenue /Princevalle Street and Monterey Road /Monterey Frontage Road. Approach and Methodology. A traffic impact analysis, as set forth by both the City of Gilroy and the Santa Clara Valley Transportation Authority (VTA), will be prepared. The scope of work will include the following tasks: Collect data and evaluate existing conditions. Available traffic counts will be obtained from the lead agency and supplemented with new counts at the study intersections. According to lead agency staff, counts are available at both intersections for the weekday PM peak hour. New manual turning- movement counts will be conducted at the key intersection during the Saturday peak period. The peak period will be determined in consultation with lead agency staff, and a two hour count will be conducted at each intersection. Level of service calculations will be conducted using the TRAFFIX software package. • Present the existing LOS conditions at the study intersections. Evaluate existing plus approved project conditions. A list of approved, but not yet constructed projects will be obtained from the lead agency. The associated traffic projections for all approved developments will be obtained from traffic reports prepared for the developments, or estimated using standard traffic engineering practices. Traffic from approved development will be added to existing volumes to obtain traffic estimates for existing plus approved project conditions. Evaluate proposed project conditions (phasing). Proposed project generated traffic will be estimated for the PM peak hour and the Saturday peak hour for up to five phases. Trip generation will be estimated based on the planned operation of the sports park. The park's operation will be discussed with the lead agency staff and Beals Landscape Architecture, Inc. Based on these discussions, the trip generation will be estimated and these estimates will be submitted to lead agency staff for review and approval. The project trips for each of the five scenarios will be added to traffic volumes estimated for background conditions to obtain traffic volumes for each phase of the project. (The analysis of Saturday peak hour conditions will be a worst case analysis: the traffic generated by the proposed project during the peak hour of the generator will be added to intersection volumes measured during the existing peak hour of the intersection). City of Gilroy Planning Division 21 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Review site access. Site access and on -site circulation will be assessed. Queuing of vehicles waiting behind the gate to enter the park, as well as queuing of outbound vehicles will be evaluated. The operation of the intersection of the site driveway with Monterey Frontage Road will be evaluated during the PM and Saturday peak hours for buildout conditions. (If improvements are needed at this intersection, the phase at which the improvements are needed will be determined). • Evaluate pedestrian and bicycle access to and from the site. The focus of this analysis will be on access from Monterey Road via Monterey Frontage Road, from Thomas Road — Luchessa Avenue via the Uvas Levee Trail, and south to Gavilan College. • Compare the proposed parking supply to the estimated demand. The parking demand will be estimated in a manner similar to the project trip generation. The proposed supply will also be compared to the requirements of the city zoning ordinance. • Present standards to determine significance of impact. • Identify significant traffic and circulation impacts associated with the proposed project. • Present mitigation measures, as appropriate. • Determine if impacts can be reduced to less than significant levels. Air Quality Concern. The proposed project could result in potentially significant long -term air quality impacts related to an increase in vehicle trips /traffic congestion, as well as potentially significant short -term impacts related to earth - moving activities. Approach and Methodology. This task will be conducted in compliance with the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines. The scope of work will include the following tasks: • Present a description of the climate and topography of the region and discuss their influence on air quality. Discuss current air quality in the vicinity of the proposed project based on monitoring data from the BAAQMD. • Explain current federal, state, and local regulatory agency's air quality policies, regulations, and standards. • Identify major existing sources of air pollutants in the vicinity. • Identify the location of sensitive land uses in the vicinity. City of Gilroy Plannin,Q Division 22 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation • Discuss the BAAQMD's guidelines for CEQA compliance, specifically the significance thresholds for air quality impacts. Identify significant adverse air quality impacts utilizing the BAAQMD significance thresholds (significance criteria) for both construction impacts and operation impacts. URBEMIS7 computer modeling will be utilized to identify and quantify emissions generated from both operation. Traffic generation identified in the traffic impact analysis will be utilized in the computer modeling. • Present mitigation measures, as appropriate. • Determine if impacts can be reduced to a less than significant level. Noise Concern. An established residential neighborhood is located north of the project site along Thomas Road — Luchessa Avenue. The Uvas Creek, a significant wildlife corridor, is located along the western side of the project site. U.S. Highway 101 is located approximately one - quarter mile from the project site. The proposed project will add noise to the existing ambient noise levels. Project components anticipated to increase noise levels include the following: traffic, public announcement systems, and the general noise associated with sports play. The proposed project would cause an increase in the existing noise levels (although most like imperceptible); however, specific aspects of the proposed project could produce noise - related concerns from the neighbors. Approach and Methodology. An environmental noise assessment will be conducted to address potential noise impacts. The scope of work will include the following tasks: • Identify surrounding noise - sensitive land uses (residential /biological). • Identify surrounding noise - generating land uses (transportation infrastructure). • Conduct on -site noise level measurements along Thomas Road — Luchessa Avenue. • Calculate the Community Noise Equivalent Levels (CNEL) and evaluate the noise exposures against the standards of the City of Gilroy Noise Element. • Present standards to determine significance of impact. • Identify significant construction - related and long -term project operational noise impacts associated with the proposed project. • Present mitigation measures, as appropriate. City of Gilroy Planning Division 23 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation Archaeological Resources Concern. The project site is located in an archaeologically - sensitive area according to the Gilroy Archaeological Sensitivity Map, April 30,1980. A preliminary archaeological reconnaissance consists of both a literature search and visual site survey (which does not include movement of the soil). Because of the highly "disturbed" nature of the project site (agricultural production and levee improvements), it would be unlikely, although not impossible, that any evidence of archaeological surface material exist. There is, however, the possibility that archaeological resources are buried beneath the project site. Approach and Methodology. A preliminary archaeological reconnaissance will be conducted. The scope of work will include the following tasks: • Conduct an archival background study of the cultural resources in and near the study area with the Northwest Information Center. • Conduct a surface reconnaissance of the project area. • Present existing site conditions. • Present standards to determine significance of impact. • Identify the potential for significant archaeological resources to be buried beneath the project site. • Present the standard City of Gilroy mitigation measure requiring construction to halt in the event significant archaeological resources are uncovered, as well as any other mitigation measures that may be appropriate. • Determine if impacts can be reduced to less than significant levels. Aesthetics Concern. The proposed project will introduce light into a previously undeveloped area, although located in proximity to an existing residential neighborhood. Night- time lighted ballfields could produce light and glare to the existing residential neighborhood, as well as on the surrounding street system. Visual impacts from Highway 101 and /or Monterey Road and Thomas Road — Luchessa Avenue are expected to be less than significant but need to be addressed. Approach and Methodology. The scope of work will include the following tasks: • Present the existing visual setting from the residential neighborhood north of Thomas Road — Luchessa Avenue; from Highway 101 and from Monterey Road. City of Gilroy Planning Division 24 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation • Identify the project components that will change the existing visual setting, as well as those that will introduce light and glare. • Present standards to determine significance of impact. • Identify the visual impacts associated with development and operation of the proposed project. • Present mitigation measures, as appropriate. • Determine if impacts can be reduced to less than significant levels. Issues Determined to Have Less Than Significant Impacts Several issues are anticipated to be determined to have a less than significant impact through preparation of the expanded notice of preparation (including the initial study). These include the following: population and housing, geologic problems, energy, hazards, public services, and utilities and service systems. These issues will be briefly discussed. If one of these issues surfaces as having a potentially significant impact, it will be addressed in greater detail. Unavoidable Significant Adverse Environmental Impacts In accordance with CEQA Guidelines §15126(b), any significant adverse environmental impacts, as identified through analysis discussed above, which cannot be avoided or substantially lessened if the project is implemented, will be discussed in this section. Cumulative Impacts In accordance with CEQA Guidelines §15130, cumulative impacts shall be discussed when they are significant. The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided of the impacts attributable to the proposed project alone. Significant Irreversible Environmental Changes In accordance with CEQA Guidelines §15126(f), this section will include a discussion of the significant irreversible environmental changes associated with implementation of the proposed project. Use of nonrenewable resources during the initial and continued phases of a proposed project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impact generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with proposed projects. Irretrievable City of Gilroy Planning Division 25 Gilroy Sports Park and Urban Service Area Amendment EIR Notice of Preparation commitments of resources would be evaluated to assure that such consumption is justified. Growth Inducing Impacts In accordance with CEQA Guidelines §15126(8), this section will include a discussion of any methods by which the proposed project will directly or indirectly induce economic, population, or housing growth. "Growth inducing" generally refers to the likelihood that a proposed project will foster growth in the surrounding area, either directly or indirectly. The most common factor in fostering growth is the removal of obstacles to population or economic growth. Alternatives In accordance with CEQA Guidelines §15126(d), this section will describe a range of reasonable alternatives to the proposed project or to the location of the proposed project, which could feasibly attain the basic objectives of the proposed project. The following alternatives are being considered: 1. No Project Alternative. As required by CEQA Guidelines § 15126(d)(4), the no project alternative shall discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the proposed project were not approved, based on current plans and consistent with available infrastructure and community services. 2. Project Redesign to Reduce Environmental Impacts (if possible) 3. Alternative Location(s). Staff is reviewing several potential alternative locations for analysis in the EIR. The scope of work for this section is as follows: • Describe each of the alternatives to be analyzed. • Identify impacts associated with each alternative. • Evaluate the comparative merits of the alternatives in terms of the areas of concern identified in the scope of work for the proposed project. • Identify the environmentally superior alternative. • Discuss reasons behind selection of the environmentally superior alternative. City of Gilroy Plannin,QDivision 26 State of California - The Resources Agency DEPARTMENT OF FISH AND GAME ht-tp://www.dfg.ca.gov POST OFFICE BOX 47 YOUNTVILLE, CALIFORNIA 94599 (707) 944 -5500 November 17, 1998 Mr. Bryan Stice City of Gilroy 7351 Rosanna Street Gilroy, California 95020 Dear Mr. Stice: PETE WILSON, Governor i '19.98 lIre n", ._: f^�iGiiiJ ... 7v ` Gilroy Sports Park Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) SCH Number 98102079, Santa Clara County Department of Fish and Game personnel have reviewed the NOP of a Draft EIR for the Gilroy Sports Park project. The project would allow development of a sports complex on 133.2 acres adjacent to the Uvas Creek in Gilroy. Plans include 12 baseball and softball diamonds, six soccer fields; and volley ball, bocce ball, picnic, commercial recreation, concession, and associated facilities. We believe the following issues need to be addressed in the Draft EIR. Plant and wildlife species that are present or dependant upon potentially impacted habitats should be identified in the Draft EIR. Particular attention needs to be paid to State- and Federally- listed and candidate species, and unlisted species whose status is of regional concern. The California Natural Diversity Data Base and the California Native Plant Society should be consulted to identify sensitive species that have been documented in the area. Consultation with the data base should not preclude or substitute for qualitative and /or quantitative field surveys. Sensitive species that are likely to occur in this vicinity include the western pond turtle (Clemmys marmorata), California tiger salamander (Ambystoma californiense) , western spade foot (Scaphiopus hammondii) , California red - legged frog (Rana aurora dravtonii), foothill yellow - legged frog (Rana bo_ylii), San Joaquin whipsnake (.Masticophis flagellum ruddoc.ki), burrowing owl (Athene cunicularia), steelhead (Oncorhvnchus mvkiss) , several diurnal raptors, and-several sensitive bat species. The presence of these and other rare, threatened, endangered species, or California species of special concern must be addressed and e ,04,V-zt -41 edq044,�',t w.; e 544 � ID0. Mr. Bryan Stice November 17, 1998 Page Two appropriate surveys conducted by a qualified biologist. Details regarding specific survey protocol can be obtained from this Department. Impacts to these species and their habitats should be avoided. Impacts which are unavoidable must be identified and appropriate mitigation provided. If the project area contains suitable habitat for burrowing owls, this Department recommends that surveying for the owls be conducted over at least four consecutive evenings during the height of the nesting season, between April 15 and July 15, and over four evenings between December 1 and January 31 for winter residents. If burrowing owls are found during nesting season surveys, further survey work may be unnecessary. Details regarding recommended survey protocol may be obtained from this Department. If burrowing owls are observed during surveys, the extent of burrowing owl habitat on the site should be delineated by a qualified ornithologist. A 1:1 acreage replacement ratio will be required to offset permanent impacts to burrowing owl habitat. Land identified to off -set impacts to burrowing owls must be protected in perpetuity either by a conservation easement or fee title acquisition. Burrowing owl mitigation lands should be identified within the Gilroy area. If it is determined that burrowing owls occur on the project site, a burrowing owl habitat mitigation plan must be prepared and shall be subject to the review and approval of the - Department. A Mitigation Agreement (MA) that will legally bind the applicant to the conditions of the plan s ^all be executed between the Department and the applicant. The Department will not issue a permit to allow any owl relocation activities until the *.mitigation plan has been finalized and the MA has been executed. The plan should identify the mitigation site.and any activities necessary to enhance the site, including the construction of artificial burrows. The plan should also include a description of monitoring and management methods proposed at the mitigation site. Monitoring and management of any lands identified for mitigation purposes shall be the responsibility of the applicant for at least five years. An annual report should be prepared for submittal to the Department by December 31 of each year. Contingency measures for any anticipated problems should be identified in the plan. Mr. Bryan Stice November 17, 1998 Page Three Mitigation for "take" of individual burrowing owls and their nest sites is fulfilled by conducting a pre - construction survey for the species no more than thirty days prior to construction. Pre- construction surveys must be conducted according to the guidelines referenced above. Pre - construction survey results must be submitted to the Department for review and approval. It is unlawful to take, possess, or destroy burrowing owls, their nests, or their eggs, pursuant to Section 3503.5 of the Fish and Game Code and the Federal Migratory Bird Treaty Act. For this reason, any impacts to the species during the breeding season (February 1 to August 31) must be avoided. If there are construction activities proposed during the owl breeding season, and if burrowing owls are observed on, or within, 250 feet of a project site during pre- construction surveys, a 250 -foot protective buffer must be established with the placement of a "i barrier fence which shall remain in place for the duration of the 4 breeding season. If pre- construction surveys are conducted during the non - breeding season and burrowing owls are observed on the site, the Department will authorize owl eviction only after the habitat mitigation plan and MA have been finalized. The Draft EIR should contain a complete description and map of the habitats in the project area. The Department recommends mitigation for all habitat types; grasslands and scrub are often developed without mitigation, leading to an unaddressed cumulative loss of wildlife habitat. We recommend project applicants be required to offset development impacts by setting _. aside or acquiring an equal number of acres for open space.' Areas to be retained as open space should not be completely encircled by development as this decreases the value of the area for wildlife. We recommend that open space areas on and off project sites be connected to one another by corridors to permit wildlife passage between the areas. It is the policy of this Department that a project should cause no net loss of either wetland acreage or wetland habitat value. We recommend impacts to creeks be avoided where possible. Impacts would include, but are not limited to, road crossings, culverts, channelization, and rip rap. If improvements to creeks must be made for reasons of public health and safety, off - drainage retention basins would be preferable to channelization of the entire stream. In areas which must be channelized, we recommend the channel be oversized-in order to allow for vegetation along both banks. Mr. Bryan Stice November 17, 1998 Page Four For impacts to riparian habitat that cannot be avoided, we recommend a minimum mitigation ratio of 3:1, based on creation of in -kind acreage of equal or better habitat value. Replacement of habitat acreage at a lower ratio may be appropriate if -the replacement is completed prior to the destruction of the original habitat. Any revegetation plans should use native species, with seeds or cutting collected on -site. The Department recommends a minimum 100 -foot buffer, measured outward from the top of each creekbank, be established to protect the creek and its vegetation, and to provide a travel corridor for wildlife. No roads, buildings, yards, paved trails, or turf should be permitted within the buffer. Any unpaved pedestrian trails should be placed outside of the riparian corridor. We do not consider the 50 -foot buffer mentioned in the NOP to be adequate to protect this riparian corridor. The Department has direct jurisdiction under Fish and Game Code sections 1601 -1603 in regard to any proposed activities that would divert or obstruct the natural flow or change the bed, channel, or bank of any stream. We recommend early consultation since modification of the proposed project may be required to avoid impacts to fish and wildlife resources. Formal notification under Fish and Game Code Section 1601 should be made after all other permits and certifications have been obtained. Work cannot be initiated until a streambed alteration agreement is executed. The U. S. Army Corps of Engineers (Corps) also has jurisdiction over the discharge of fill to streams and wetlands under Section 404 of the Clean Water Act. We recommend that the Corps be contacted to determine if they have jurisdiction and if they require a permit. Project documents should include a complete description of methods that will be used to control erosion, prevent siltation and prevent fertilizers, herbicides, and other deleterious materials from entering waterways. Potential impacts caused by water quality changes due to grading and increased storm water runoff should be discussed. oil /grease separators should be required in storm drain systems, as should sweeping programs for parking lots. Mr. Bryan Stice November 17, 1998 Page Five Specific measures to adequately mitigate unavoidable impacts, including cumulative ones, need to be incorporated into project design prior to certification of the EIR. A monitoring program, as required by Assembly Bill 3180, must ensure that mitigation measures are effective and must provide for corrective action if they are not effective. We request that subsequent documents related to this project be submitted to this Department for our review. If you have any questions regarding our comments, please contact Martha Schauss, Wildlife Biologist, at (831) 623 -4989; or Carl Wilcox, Environmental Services Supervisor, at (707) 944 -5525. Sincerely, Brian Hunter Regional Manager Central Coast Region T__ Peter M. Rooney Secretaryfor Environmental Protection California Regional Water Quality Control Board Central Coast Region November 4, 1998 Intemet Address: http: / /www.swrcb.ca.gov 81 Higuera Street, Suite 200, San Luis Obispo, Califomia 93401 -5427 Phone (805) 549 -3147 • FAX (805) 543 -0397 Bryan Stice, Planning Department City of Gilroy, Community Development Department 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: 9-K (a Pete Wilson Govemor GILROY SPORTS COMPLEX — NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT REPORT, SANTA CLARA COUNTY , Thank you for the opportunity to review and comment on the Notice of Preparation of a Draft Environmental Impact Report (DEIR) concerning the proposed project. State Water Code, Division 7 establishes Regional Water Quality Control Board (Regional Board or RWQCB) as the principal agency with primary responsibility for the coordination and control of water quality ( §13001); including ocean waters, surface waters, ground waters, wetlands and stormwater. The Regional Board is responsible for administering regulations established by the Federal Clean Water Act. Additionally, the California Water Code establishes broad state authority for regulation of water quality. Any person discharging waste, or proposing to discharge waste, that could affect the quality of the waters of the state, other than into an already regulated community sewer system, shall file a report of waste discharge with our office. The Central Coast Regional Water Quality Control Plan (Basin Plan) explains the Regional Board's strategy for regulating water quality. The Basin Plan also describes the range of responses available to the Regional Board with regards to actions and proposed actions that degrade or potentially degrade the beneficial uses of the Waters of the State of California. The proposed project should conform to our Basin Plan's relevant programs and policies. We understand that the project involves construction of a multi -use 78.4 -acre sports park located on a 133.2 -acre site. Preliminary plan components include: Recreational play fields (8 softball diamonds and 4 soccer fields) Premier play fields (one 90 -foot baseball diamond, two little leagues diamonds and one soccer field) ♦ Competition play fields (one softball/baseball diamond and one soccer field) ♦ 8.8 -acres of park preserve with volleyball, bocce ball courts, concession/restrooms, family picnic and play area. ♦ Commercial recreation (indoor soccer, roller hockey, community building, and storage) California Environmental Protection Agency Qg Rccicled Paper Brvan Stice 2 November 4, 1998 0 1043 parking spaces ♦ Night watch park ranger station Infrastructure and facilities needed to support the proposed project Waste discharge could result from many aspects of the project and could take either a "point source" or "non -point source" form. NPDES Stormwater Program Water quality degradation is regulated by the Federal National Pollutant Discharge Elimination System ( NPDES) Program (established by the Clean Water Act), which controls and reduces pollutants to water bodies from point and nonpoint discharge's. In California the program is administered by the California Regional Water Quality Control Boards. The Regional Board has authority to issue NPDES permits for discharges to water bodies in the Central Coast area. Storm water is the major source of fresh water to creeks and waterways. The Regional Board regulates projects that may impact stormwater quality through the State NPDES General Permit for Discharges of Storm Water Associated with Construction Activity, and the State NPDES General Permit for Discharges of Storm Water Associated with Industrial Activity. Storm water quality is affected by a variety of land uses and the pollutants generated by these activities. Development and construction activities cause both site - specific and cumulative water .quality impacts. Water quality degradation may occur during construction due to discharges of sediment, chemicals and wastes to nearby storm drains or creeks. Water quality degradation may occur after construction is complete due to discharges of petroleum hydrocarbons, oil, grease and metals from vehicles, pesticides and fertilizers from landscaping, and bacteria from pets and people. Runoff may be concentrated and storm water flow increased by newly developed impervious surfaces, which will mobilize and transport pollutants deposited on these surfaces to storm drains and creeks. Concentrated runoff could also impact the geomorphology of the receiving water, which could affect the receiving water beneficial uses. Cumulatively, these discharges will increase pollutant loads in creeks and wetlands within the local watershed, and the Pacific Ocean. Storm Water Associated with Construction Activity Projects disturbing more than five acres of land during construction must be covered under the State NPDES General Permit for Discharges of Storm Water Associated with Construction Activitv. This can be accomplished by filing a Notice of Intent. The project sponsor must propose and implement control measures that are consistent with this State Construction Storm Water General Permit and with recommendations and policies of the local agency and the RWQCB. The State Construction Storm Water General Permit requires a SWPPP. Developing and implementing a Storm Water Pollution Prevention Plan (SWPPP) should minimize project impacts. The SWPPP should be consistent with the terms of the State Construction Storm Water General Permit (if the site is greater than five acres), policies and recommendations of the local urban runoff program (city and/or county) and Recommendations of the RWQCB. California Environmental Protection Agenct 2A Recycled Paper Bryan Stice 3 November 4, 1998 Storm Water Associated with Industrial Activity Projects that include facilities with discharges of Storm Water Associated with Industrial Activity must be covered under the State NPDES General Permit for Discharges of Storm Water Associated with Industrial Activity. This may be accomplished by filing a Notice of Intent. The project sponsor must propose control measures that are consistent with this, and with recommendations and policies of the local agency and the RWQCB. In a few cases, the project sponsor may apply for (or the RWQCB may require) issuance of an individual (industry or facility specific) permit. Storm Water Associated with Urban Development Runoff from. _storm events is part of the natural hydrologic process: rainwater that does not infiltrate into the ground flows by the force of gravity into water bodies such as lakes, streams, rivers, and oceans. As runoff heads for receiving waters, naturally vegetated depressions and fills slow the water and filter it for pollutants and sediments. In urban settings, however, natural vegetation and topography have been altered, graded, or paved and storm water is diverted in storm drain pipes. When the drainage pattern of a watershed is so altered, flows increase in concentration and velocity and pick up sediments and pollutants from land surfaces at an increased rate. Storm water that flows through urbanized areas to receiving waters is called "urban runoff." Urban runoff is known to carry a wide range of pollutants including nutrients, trash and debris, sediments, heavy metals, pathogens, petroleum hydrocarbons, and synthetic organics such as pesticides. Because urban runoff does not originate from a distinct "point" source (e.g., an industrial discharge pipe), it is also often referred to as nonpoint source pollution. These pollutants in urban runoff could negatively impact the vitality of your municipality on many levels. Urban runoff can alter the physical, chemical, and biological characteristics of water bodies to the detriment of aquatic and terrestrial organisms; can make beaches and rivers unsightly or unsafe for human contact; and can negatively impact beneficial activities and uses including water recreation, commercial fishing, tourism and aquatic habitat. In some cases pollutants of concern may not even be visible to the naked eye. SWPPPs should also be required for projects that may have impacts but are not required to obtain an NPDES permit. Preparation of an SWPPP should be a condition of development. Implementation of the S WPPP should be enforced during the construction period via appropriate options such as citations, stop work orders or withholding occupancy permits. The SWPPP should implement measures as described in • :IPodel Urban Runoff Program; A How -To Guide For Developing Urban Runoff Programs For Small Municipalities; July 1998; prepared by the City of Monterey, the City of Santa Cruz, the California Coastal Commission, the Monterey Bay National Marine Sanctuary, the Association of Monterey Bay Area Governments, Woodward - Clyde. and the Central Coast Regional Water Quality Control Board. • Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters; January 1993; U.S. Environmental Protection Agency;840 -B -92 -002 California Environmental Protection Agency Cd Rep cled Paper Bryan Stice 4 November 4, 1998 • Start at the Source; Residential Site Planning & Design Guidance Manual for Stormwater Quality Protection; January 1997; Bay Area Stormwater Management Agencies Association Stormwater runoff has the potential to impact the water quality of Uvas Creek. Best management procedures should be implemented during construction to minimize disturbances and impacts. Care should be taken in establishing a vegetated buffer zone to separate the existing riparian habitat from the newly developed area. Fertilizers may be carried by surface runoff or may leach below ground into Uvas Creek. Occurrences such as these may have adverse affects to water quality and should be given consideration. Wetlands Wetlands enhance water quality through such natural functions as flood and erosion control, stream bank stabilization, and filtration and purification of contaminants. Wetlands also provide critical habitats for hundreds of species of fish, birds, and other wildlife, offer open space, and provide many recreational opportunities. The Regional Board must certify that any permit issued by the U.S. Army Corps of Engineers pursuant to Section 404 of the Clean Water Act (covering dredging or filling of wetlands) complies with state water quality standards, or waive such certification. Section 401 Water Quality Certification is necessary for all 404 Nationwide permits, reporting, and non - reporting, as well as individual permits. All projects must be evaluated for the presence of jurisdictional wetlands. Water quality impacts occur in wetlands from construction of structures in waterways, dredging, filling, and altering drainage to wetlands. Destruction or impact to wetlands should be avoided. 401 Certification may be denied based on significant adverse impacts to "Waters of the State" The goals of the California Wetlands Conservation Policy include ensuring "no overall net loss and achieving a long -term net gain in the quantity, quality, and permanence of wetlands acreage and values ". In the event wetland loss is not avoidable, mitigation will be preferably in -kind and on -site with no net destruction of habitat value. Mitigation will preferably be completed prior to, or at least simultaneous to, the filling or other loss of existing wetlands. Successful mitigation projects are complex tasks and difficult to achieve. This issue will be strongly considered during agency review of any proposed wetland fill. Wetland features or ponds created as mitigation for the loss of existing "jurisdictional wetlands" or "waters of the United States" cannot be used as storm water treatment controls. Attached to this document are a list of control actions to avoid and /or minimize impacts to stormwater quality and wetlands. Wastewater Discharge The Gilroy Sports Park will produce wastewater, and as such will require connection existing wastewater treatment facilities or development of an on -site disposal system such as sewer or septic tanks. Consideration must be given to ensure adequate capacity exists for wastewater disposal. California Environmental Protection Agency Cd Recycled Payer Bryan Stice 5 November 4, 1998 Our Basin Plan includes the following Regional Water Quality Control Board Management Principle: The number of waste sources and independent treatment facilities shall be minimized and the consolidated systems shall maximize their capacities for wastewater reclamation, assure efficient management of and meet potential demand for reclaimed water. This principle conforms with our Basin Plan goals: 1. to manage,municipal and industrial wastewater disposal as part of an integrated system of fresh water supplies to achieve maximum benefit of fresh water resources for present and future beneficial uses and to achieve harmony with the natural environment, and 2. to continually improve waste treatment systems and processes to assure consistent high quality effluent based on best economically achievable technology. To meet these goals, our Board encourages comprehensive surface and ground water management plans prepared by local and regional water management agencies. It seems prudent to consolidate wastewater treatment and disposal in order to effectively implement wastewater reclamation. The proposed project should attempt to conform to our above - stated Basin Plan's Management Principle or goals. Specific Plans should develop wastewater infrastructure according to a comprehensive countywide plan. If you have any questions, please call Tom Kukol at (805)549 -3689 or tkukol@swreb.ca.gov. Sincerely, Roger W. ggs Executive Officer T1K \H: \CEQA \S- BENITO\EIR \Paicines Ranch Resort.doc Task: 121 -01 Pile: Agency: San Benito County California Environmental Protection Agency Cd Recycled Paper Os k p T n C L A R A T/' Valley Transportation Authority November 20, 1998 City of Gilroy Department of Community Development 7351 Rosanna Street Gilroy, CA 95020 -6141 Attention: Bryan Stice Subject: Gilroy Sports Park Notice of Preparation of a Draft EIR Dear Mr- Stice: Santa Clara Valley Transportation Authority (VTA) staff have reviewed the project referenced above for the development of the Gilroy Sports Park at the southwest corner of Thomas Road and Highway 101. VTA comments follow, and are separated into Transit Semire and Congestion Management Program issues to reflect our dual role in reviewing the project. Transit Service VTA currently maintains a bus stop within walking distance of the proposed project on Thomas Road, to the south and west of Princevalle Road. The stop is served by Line 68 which travels between San Jose Diridon Station and Gavilan College. To allow patrons of the project to safely and conveniently access existing and future transit services in the area, VTA staff recommend that the City consider including the following features in the project: • A sidewalk along Thomas Road. • Direct pedestrian pathways that link the various activity centers with the sidewalk on Thomas Road. VTA staff are also considering the possibility of bringing bus service to the sports park. Please continue to forward information about this project to VTA for review and comment. VTA staff will work with City and project staffs on this possibility. Congestion Management Program The Congestion Management Program (CMP) requires a Transportation Impact Analysis (TIA) for any project that is expected to generate 100 or more new peak hour trips. Based on the information provided on the size of the project, a TI.4 may be required. 3331 North First Street - San lose, (A 95134 -1906 • Administration 408.321.5555 - (uslomer Service 408.321.2300 City of Gilroy November 20, 1998 Page 2 of 2 The CMP's Transportation Impact Analysis Guidelines should be used when preparing the TIA. These guidelines include the analysis of bikeways, parking, site circulation and pedestrian access, as well as roadways. If there are any questions regarding the guidelines, please call the CMP at (408) 321 -5725. We appreciate the opportunity to review this project. If you have any questions, please call Lauren Bobadilla of my staff at (408) 321 -5776. Sin rely, Thomas Rountree Environmental Program Manager TDR:LGB :kh TO: Bryan Stice, Planner I FROM: Rafael Adame, BLES Manager/Building Official DATE: November 3, 1998 RE: EIR for Gilroy Sports Park The proposed sports facility must comply with the most current State and Federal Building Code requirements. The following a list of potential Building Code issues for this project based on the conceptual design information submitted for review and is not intended to be all inclusive: 1. All structures located within a flood zone will be required to meet FEMA requirements for finish floor elevations and protection of building systems (Electrical, mechanical etc.). 2. Disabled access for all activity areas (seating, fields, walk ways, pedestrian trails, concessions, bathrooms, etc.) must be provided. 3. Bathroom facilities must meet the number of fixtures required by State and Federal regulations. Assembly facilities and buildings are required to provide higher number of fixtures in women's bathrooms. 4. All proposed building and structure locations will require a soils investigation to address seismic motion, ground shaking or liquefaction of the soil. 5. If night lighting is planned for these fields, the impact on surrounding areas will need to be considered. If you have any questions or concerns on these comments contact me at XT 0431. JANT . CLs`"L'RA COUNgY STREqMS FOR TOMORROW Post Office BoX1409 San Martin, Caiifornia 95046 November 12, 1998 Mr. Bryan Stice - Planning Division City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: m C` j ~ Notice of Preparation of a Draft Environmental Impact Report for Gilroy Sports Park and Urban Service Area Amendment Request; Santa Clara County We have the following comments and recommendations regarding the scrape and content of your environmental assessment for subject project. Uvas Creek and its riparian vegetation corridor support fish and wildlife populations of local and regional importance. The proposed project has potential to adversely impact these resources and their habitats. In addition to evaluating potential impacts to special- status animals and plants, the Draft EIR also must address potential impacts to the seasonal patterns of fish and wildlife use of the Creek's aquatic and riparian habitats. Although the majority of fish and wildlife species potentially impacted may be relatively common species, their local abundance, diversity, and population vitality may be reduced and thus adversely effected by construction and use of the proposed Gilroy Sports Park and Trail Extensions. These projects and activities may impact sensitive wildlife habitat - directly or indirectly - forcing displacement and loss of the birds, mammals and other wildlife that use this unique stream /riparian habitat complex for escape cover, feeding and nesting. These impacts should be evaluated in the Draft EIR as both potential substantial project and cumulative environmental impacts. The project includes a "50 -foot wide wildlife easement "that appears to be measured from top of bank. This easement is insufficient to protect the biological integrity of the existing riparian corridor and its wildlife use. The easement width should be sized to protect the riparian habitat values from direct and indirect human - induced impacts. It should be sufficient to preserve and, where necessary, improve the "ecotone edge effect" attribute of this unique habitat, buffer the impacts of adjacent human activities, and provide secure corridors for wildlife travel and dispersal. Mr. Bryan Stice -2- November 12, 1998 As mitigation for direct, indirect and cumulative impacts to riparian and wildlife resources, the project design should be modified to provide a wildlife easement that is either a minimum of 100 -feet wide as measured from top of bank or extends to the outer tree dripline, whichever is greater. In addition, this dedication should include a vegetation planting program (and funding) to (1) widen narrow segments of the tree corridor; (2) infill gaps in the canopy cover; (3) improve corridor edge effect values; and (4) provide buffer and- barrier plantings between the tree dripline and outer edge of the easement. No public access, trails, roadways, structures nor developments should be allowed within this wildlife easement, except for the pedestrian bridge crossing to Gavilan College. Undisturbed shade canopy provided by trees and bushes is one of the most critical elements of riparian habitat quality. No unnecessary infringement should be allowed on this valuable riparian habitat. Active play and sports areas should be setback a minimum of 100 feet from the outer edge of the wildlife easement. The proposed multi -use trails should be setback at least 10 feet from the easement edge, as should picnic areas, interpretive features, and other passive use areas. If night lighting is proposed for active recreational facilities such as ball play fields, volleyball courts, etc., a setback of at least 200 feet from easement edge is preferred. However, we recognize that the exact distance should be determined by a site - specific analysis in consultation with a qualified biologist. The Draft EI.4 must identify the agency responsible for the wildlife easement and include a commitment to prepare, fund and implement a comprehensive Wildlife Easement Corridor Habitat Preservation and Enhancement Plan. The Draft ER must provide a complete description of the Best Management Practices and project- specific features and measures that will be used during both project construction and operation to control erosion and prevent silt and other deleterious materials from entering Uvas Creek. All potential impacts to Uvas Creek water quality must be evaluated and fully mitigated. Potential Uvas Creek water quality degradation due to grading activities; increased storm water runoff; hydrocarbons and sediments from roa&e7ays and parting lots; and fertilizer, herbicide and pesticide applications rust be discussed. Impacts to Uvas Creek surface water quality must be thoroughly evaluated. Mitication measures to prevent contaminated runoff from entering the Creek must be identified. In accordance with CEQA Guidelines Section 15126 (d), the Draft EIE should describe alternative project locations that would site the Sports Park awav from stream channels, thus avoiding the environmental concerns, impacts and mitigations necessary for a project located adjacent to a major stream and riparian corridor such as Uvas Creek. Such an alternative may prove to be the CC.^A environmentally superior alternative. Mr. Bryan Stice -3- November 12, 1998 Please notify us in advance of any public scoping meetings, workshops, 41-discussions or hearings on subject project and CEQA process. Also, please send us a copy of your Public Notice regarding eventual availability of the Draft EIR for public comment. Thank you for the opportunity to provide comments and recommendations in response to your Notice of Preparation. If you have any questions about our response, please contact me at the letterhead address or telephone me at (408) 683 -4330 (voice and fax). Sincerely, Keith R. Anderson Environmental Advocate cc: The Honorable Don Gage Supervisor, District 1 Board of Supervisors Ms. Rosemary Kamei Director, District 1 Santa Clara Valley [dater District Mr. Brian Hunter Regional Manager Department of Fish and Game Mr. Craig Breon Environmental Advocate Santa Clara Valley Audubon Society Ms. Debbie Ruddock Chapter Director Sierra Club, Irma Prieta Chapter �J tVT Sec7�°� �vCs 14497'1NEr AAW- ' lJvt. 71:: November 2, 1998 Mr. Bryan Stice Community Development Department City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 Dear Mr. Stice: Santa Clara Valley Water District 5750 ALMADEN EXPRESSWAY SAN JOSE, CA 95118 -3686 TELEPHONE (408) 265 -2600 FACSIMILE (408) 266 -0271 www. s c v w d. d s t. c a. u AN EQUAL OPPORTUNITY EMPLOYER Subject: Notice of Preparation of a Draft Environmental Impact Report for Gilroy Sports Park pt� The Santa Clara Valley Water District (District) has reviewed the subject document received on October 22, 1998. The proposed scope of work identified in the Notice of Preparation indicates that issues related to flooding of the site will be addressed in the Draft Environmental Impact Report (DEIR). The City of Gilroy (City) or the hydrological engineering firm hired by the City to address this issue may contact me at (408) 265 -2607, extension 2253, to discuss District concerns. We look forward to review of the DEIR and share the City's excitement for this proposed sports park, as it is an excellent use of this land considering the constraints of the flooding easement. Sinc ?rely, Sue A. Tippets, P.E. Supervising Engineer Community Projects Review Unit i` recvclud UJpta County of Santa Clara Roads and Airports Department Land Development Services 101 Skyport Drive San Jose, California 95110 November 23, 1998 v/ Mr. Bryan Stice Community Development Department City of Gilroy 7351 Rosanna Street 1998 Gilroy Flaslnilig Diu. Gilroy, California 95020 Subject: Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) Gilroy Sports Park Dear Mr. Stice: Your October 20, 1998 NOP concerning the proposed project has been reviewed. Our comments are as follows: (1) In addition to the intersections listed on Page 21, the traffic report should analyze Thomas Road/Church Street and Thomas Road/Santa Teresa Blvd. intersections also. The methodology should be acceptable to Santa Clara County Roads and Airports Department also. (2) The Draft EIR should include a traffic analysis demonstrating the traffic impacts of the potential traffic generated by the proposed development on the County's facilities, i.e., Santa Teresa Blvd., Thomas Road, Mesa Road, etc. The traffic report should list the proposed mitigation measures and also include a funding source of the proposed mitigations. (3) A copy of the Draft EIR should be famished for our review and comments. Board of Supervisors: Donald F. Gage, Blanca Alvarado, Pete McHugh, James T. Beall, Jr., S. Joseph Simitian County Executive: Richard Wittenberg Mr. Bryan Stice Page 2 November 23, 1998 We thank you for the opportunity to review this matter. Please call me at 573 -2462 if you have any questions. S' cerely, Ashok Vyas Project Engineer AAV:rtj cc: DEC MA JNIE File'