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Home My WebLink AboutRESO 10047 1 0160077_20220512_AY16 RESOLUTION NO. 10047 Resolution of the Council of the City of Palo Alto Certifying the Adequacy of the Final Environmental Impact Report (EIR) for the Castilleja School Project, Making Certain Findings Concerning Significant Environmental Impacts, Mitigation Measures, and Alternatives, and Adopting a Mitigation Monitoring and Reporting Program (MMRP) On June 6, 2022, the City Council of the City of Palo Alto (“City Council”), in certifying the Final EIR for the Castilleja School Project and adopting the MMRP, finds, determines, and RESOLVES as follows: R E C I T A L S A. The Castilleja School Foundation (“Applicant”) has proposed the Castilleja School Project, which includes approval of a Conditional Use Permit, Variance, and Architectural Review associated with a phased increase in enrollment to 540 students, demolition and redevelopment of several campus buildings, and construction of an underground parking garage (the “Project”). B. Approval of the Project would constitute a project under the provisions of the California Environmental Quality Act of 1970, together with related state and local implementation guidelines promulgated thereunder (“CEQA”). C. The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Project. D. The City, in compliance with CEQA, prepared an Environmental Impact Report (EIR) to provide an assessment of the potential environmental consequences of approving the Project. E. A Draft Environmental Impact Report (“Draft EIR”) was circulated for public review from July 17, 2019, through September 16, 2019. During the Draft EIR public comment period, two public hearings were held allowing public testimony on the Draft EIR: (1) the Planning and Transportation Commission (PTC) hearing of August 14, 2019; and (2) the Historic Resources Board (HRB) hearing of September 12, 2019. F. The Draft EIR identified mitigation measures that would reduce each of the Project’s potentially significant effects to a less-than significant level; one unmitigated impact (the TIRE impact on Emerson Street) was due to the Project’s creation of one student drop-off location within a proposed underground parking facility. G. The City of Palo Alto considered the comments received during the Draft EIR public review DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C 2 0160077_20220512_AY16 period and prepared responses to comments. H. In February 2020, the Applicant submitted a Project Alternative, the “Disbursed Circulation/Reduced Garage Alternative”, intending to address the Emerson TIRE impact and other community concerns voiced during the Draft EIR comment period . I. The City considered the comments received during the Draft EIR public review period and prepared a Final EIR. The Final EIR also analyzed the Applicant’s Disbursed Circulation/Reduced Garage Project Alternative (EIR Alternative #4), and further analyzed or discussed other previously identified alternatives. The Final EIR, which identified Project Alternative #4 as fully mitigated, was published July 30, 2020. In accordance with the California Environmental Quality Act (CEQA), the City provided notice of availability of the Final EIR. J. The City conducted hearings before the Architectural Review Board, Hi storic Review Board, and Planning and Transportation to consider the Final EIR and various discretionary applications on August 20, August 26, September 9, September 24, October 1, October 28, November 4, and November 5, 2020. K. The Council considered the Final EIR and discretionary applications on March 8, 15, and 29, 2021 but Council remanded the project to the Architectural Review Board and Planning and Transportation Commission on March 29, 2021 . Council directed staff to return with an ordinance to exempt a below-grade non-residential garage from gross floor area if it contains no more than 50% of the code-required parking spaces for the use, to reduce below grade parking to 50% of the code -required parking spaces, and to address additional direction; Council is the decision-making body for approval of the proposed Project. L. The Architectural Review Board met twice after Council’s March 29, 2021 direction, focusing on parking options and building revisions responsive to Council direction; the ARB supported building changes and parking changes on December 2, 2021 and March 17, 2022, with a recommendation for hybrid designs. M. The Planning and Transportation Commission met five times after Council’s March 29, 2021 direction, on December 8, 2021, December 15, 2021, January 19, 2022, March 30, 2022 and April 20, 2022, focusing on staff and the applicant’s responses to Council direction along with components within its purview including the Conditional Use Permit, Variance, and Parking Adjustment. N. CEQA requires that in connection with approval of a project for which an environmental impact report has been prepared that identifies one or more significant environmental effects of the project, the decision-making body of a public agency make certain findings regarding those significant effects on the environment identified in the environmental impact report. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C 3 0160077_20220512_AY16 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS FOLLOWS: SECTION 1. Certification and Statements of Findings The City Council, in the exercise of its independent judgment, makes and adopts the following findings in addition to those contained in Exhibit A, “Castilleja School Project Statement of Findings,” dated May 2022, which is incorporated by reference as though included in the body of this Resolution. These findings comply with the requirements of CEQA, including Sections 15091, 15092, and 15093 of the CEQA Guidelines, and are based upon the entire record of proceedings for the Project. All statements set forth in this Resolution and its Exhibits constitute formal findings of the City Council, including the statements set forth in this paragraph and in the recitals above. (a) The Final EIR was presented to and reviewed by the City Council on March 8 and March 15, 2021. Due to the Council’s March 15 and 29, 2021 direction, revisions to the project were developed and reviewed, along with memorandums regarding ‘Schemes D and E’ (aka Options D and E) and the pool excavation, with associated attachments (clarifications regarding responsive changes). (b) The Final EIR was prepared under the supervision of the City and reflects the independent judgment of the City. The City Council has reviewed the Final EIR, and bases the findings stated below on such review and other substantial evidence in the record. (c) The City finds that the Final EIR considers a reasonable range of potentially feasible alternatives, sufficient to foster informed decision making, public participation and a reasoned choice, in accordance with CEQA and the CE QA Guidelines. (d) The City Council hereby certifies the Final EIR as complete, adequate and in full compliance with CEQA and as providing an adequate basis for considering and acting upon the Castilleja School Project and makes the following specific findings with respect thereto. The City Council has considered evidence and arguments presented during consideration of the Project and the Final EIR. In determining whether the Project may have a significant impact on the environment, and in adopting the findings set forth herein, the City Council certifies that it has complied with Public Resources Code sections 21081, 21081.5, and 21082.2. (e) The City Council agrees with the characterization of the Final EIR with respect to all impacts initially identified as “less than significant” and finds that those impacts have been described accurately and are less than significant as so described in the Final EIR. (f) The descriptions of the impacts in these findings are summary statements. Reference should be made to the Final EIR for a more complete description. SECTION 2. Mitigation Monitoring and Reporting Program DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C 4 0160077_20220512_AY16 (a) CEQA requires the lead agency approving a project to adopt a Mitigation Monitoring and Reporting Program (MMRP) for the changes made to the project that it has adopted in order to mitigate or avoid significant effects on the environment. An MMRP has been prepared and is recommended for adoption by the City Council concurrently with the adoption of these findings to ensure compliance with standard project requirements incorporated as part of the project and mitigation measures during Project implementation. As required by Public Resources Code section 21081.6, the MMRP designates responsibility and anticipated timing for the implementation of the mitigation measur es recommended in the Final EIR. The MMRP will remain available for public review during the compliance period. (b) The City Council hereby adopts the MMRP for the Project attached hereto as Exhibit B and incorporated by reference, and finds, determines, and declares that the adoption of the MMRP will ensure enforcement and continued imposition of the mitigation measures recommended in the Final EIR, and set forth in the MMRP, in order to mitigate or avoid significant impacts on the environment. INTRODUCED AND PASSED: June 6, 2022 AYES: BURT, CORMACK, DUBOIS, FILSETH, STONE, TANAKA NOES: KOU ABSENT: ABSTENTIONS: ATTEST: APPROVED: __________________________ _____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: __________________________ _____________________________ Assistant City Attorney City Manager _____________________________ Director of Planning and Development Services DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C EXHIBIT A Castilleja School Project Statement of Findings SCH # 2017012052 May 2022 DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C EXHIBIT A Castilleja School Project Statement of Findings 1 May 2022 TABLE OF CONTENTS Table of Contents ....................................................................................................................... 1 I. Overview and Introduction .............................................................................................. 1 II. Statutory Requirements for Findings .............................................................................. 3 III. Definitions ...................................................................................................................... 4 IV. Project Background ........................................................................................................ 5 V. Project Objectives and Description ................................................................................. 6 Project Objectives ............................................................................................... 6 Project Description .............................................................................................. 6 VI. Record of Proceedings ................................................................................................... 7 VII. List of Impacts of the Proposed Project Determined to be Less than Significant or No Impact without Implementation of Mitigation Measures ............................................. 8 Impacts Evaluated in the Draft EIR ..................................................................... 8 Impacts Evaluated in the Initial Study .................................................................10 VIII. Findings for Significant and Potentially Significant Impacts Reduced to Less Than Significant With Implementation of Mitigation Measures ..........................................13 Land Use and Planning ......................................................................................14 Aesthetics ..........................................................................................................16 Cultural Resources ............................................................................................16 Transportation ....................................................................................................17 Noise .................................................................................................................19 Air Quality ..........................................................................................................21 Significant and Unavoidable Impacts .................................................................22 IX. Project Alternatives Findings .........................................................................................22 Reasonable Range of Project Alternatives .........................................................23 Feasibility of Project Alternatives .......................................................................24 Analysis of Project Alternatives ..........................................................................24 X. Growth Inducement Findings .........................................................................................27 XII. Conclusion ....................................................................................................................28 DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C EXHIBIT A Castilleja School Project Statement of Findings 1 May 2022 I. OVERVIEW AND INTRODUCTION This Statement of Findings is made with respect to approval of the Castilleja School Project and states the findings of the City Council of the City of Palo Alto (City Council) relating to the potentially significant environmental effects of the project. This Statement of Findings addresses the environmental effects associated with the proposed Castilleja School Project, located on Assessor’s Parcel Numbers 124-12- 034 (at 1310 Bryant Street), 124-12-031 (1235 Emerson Street), and 124-12-033 (1263 Emerson Street). The City Council, in the exercise of its independent judgment, makes and adopts the following findings to comply with the requirements of the California Environmental Quality Act (CEQA; Pub. Resources Code, sections 21000 et seq.), and Sections 15091, 15092, and 15093 of the CEQA Guidelines (14 Cal. Code Regs., sections 15000 et seq.). All statements set forth in this Resolution constitute formal findings of the City Council, including the statements set forth in this paragraph. These findings are made relative to the conclusions of the City of Palo Alto Castilleja School Project Final Environmental Impact Report (State Clearinghouse No. 2017012052) (Final EIR), which includes the Draft Environmental Impact Report (Draft EIR), the EIR Errata (April 2022), and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum (March 2022). The Final EIR addresses the environmental impacts associated with implementation of the Castilleja School Project (the Project, as further defined in Sections IV and V below) and is incorporated herein by reference. The original Project proposal was defined in Draft EIR Chapter 3, Project Description; but the Project addressed in these Findings is the Modified Dispersed Circulation/Reduced Garage Alternative – Scheme E. The original Dispersed Circulation/Reduced Garage Alternative (also referred to as Project Alternative 4) is described in Final EIR Chapter 2, Master Responses, Master Response 4. The Scheme E modifications made to this alternative are shown in the document titled Updated Garage Studies with Scheme E (November 2021). The project requests that the City take the following actions: 1. Certify an Environmental Impact Report and adopt the Mitigation Monitoring Plan. 2. Approve a Conditional Use Permit (CUP) Amendment. 3. Approve a Variance to maintain existing above grade Floor-Area-Ratio (FAR). 4. Approve Architectural Review, Grading Permits, Tree Removal Permits, and Building Permits (phased development approval(s)). Approval of the requested entitlements constitutes the project for purposes of CEQA and these determinations of the City Council. These findings are based upon the entire record of proceedings for the Project. The City Council finds as follows: 1. The record of proceedings in Section VI of these findings are correct and accurate. 2. The Final EIR has been prepared in accordance with all requirements of CEQA, the CEQA Guidelines, and the City’s Environmental Impact Ordinance, codified in Title 11 of the City’s Municipal Code. 3. The Draft EIR was presented to and reviewed by the Planning and Transportation Commission (PTC) on August 14, 2019. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 2 May 2022 4. The Final EIR was presented to and reviewed by the Architectural Review Board (ARB) (August 20, 2020,) HRB (September 24, 2020), and PTC (August 26 and September 9, 2020). The ARB, HRB, and PTC each provided a recommendation to the City Council in support of certification of the Final EIR. 5. The Final EIR was presented to and reviewed by the City Council on March 8, March 15, and March 29, 2021. 6. Following the public hearings for the project and the EIR in 2020 and March of 2021, the project design was modified to respond to City Council direction. The project designs presented to the City Council in 2022 include ‘Scheme D,’ ‘Scheme E,’ and “Hybrid Scheme D/E.’ The Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum (March 2022) provides analysis of the potential differences in environmental effects associated with Schemes D and E compared to the conclusions of the Final EIR regarding the Disbursed Circulation/Reduced Garage Alternative (Project Alternative 4) and concludes that neither Scheme D nor Scheme E would increase the adverse environmental impacts of the project compared to Project Alternative 4 and all of the mitigation measures applicable to Project Alternative 4 would also be applicable to either Scheme D or Scheme E. It also concludes that, pursuant to CEQA Guidelines Section 15088.5, recirculation of the EIR is not required because there is no “significant new information” that has been or should be added to the EIR. 7. The revised project plans and additional information was presented to and reviewed by the HRB (September 24, 2021), ARB (March 17, 2022) and PTC (March 30 and April 20, 2022). The HRB, ARB, and PTC each provided recommendations to the City Council regarding project design elements. As noted in item 4 above, each of these bodies made recommendations to the City Council regarding certification of the Final EIR in 2020. Because none of the additional project alternatives that have been evaluated would result in new significant impacts or would increase the severity of the environmental impacts identified in the EIR, no further recommendations regarding EIR certification were warranted in September 2021 and March and April 2022. 8. The Final EIR was prepared under the supervision of the City and reflects the independent judgment of the City. The City Council has reviewed the Final EIR, and bases the findings stated below on such review and other substantial evidence in the record. 9. The City finds that the Final EIR considers a reasonable range of potentially feasible alternatives, sufficient to foster informed decision making, public participation and a reasoned choice, in accordance with CEQA and the CEQA Guidelines. 10. The City Council hereby certifies the Final EIR as complete, adequate and in full compliance with CEQA and as providing an adequate basis for considering and acting upon the Castilleja School Project and makes the following specific findings with respect thereto. The City Council has considered evidence and arguments presented during consideration of the Project and the Final EIR. In determining whether the Project may have a significant impact on the environment, and in adopting the findings set forth herein, the City Council certifies that it has complied with Public Resources Code sections 21081, 21081.5, and 21082.2. 11. The City Council agrees with the characterization of the Final EIR with respect to all impacts initially identified as “less than significant” and finds that those impacts have been described accurately and are less than significant as so described in the Final EIR. This finding does not apply to impacts identified as significant or potentially significant that are reduced to a less than DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 3 May 2022 significant level by mitigation measures included in the Final EIR. The disposition of each of those impacts and the mitigation measures adopted to reduce them are addressed specifically in the findings below. 12. All mitigation measures in the Final EIR are adopted and incorporated into the Castilleja School Project as described in the Mitigation Monitoring Program (MMP), which includes all mitigation measures adopted with respect to the project and explains how and by whom they will be implemented and enforced. 13. The mitigation measures and the MMP have been incorporated into the Conditions of Approval for the amended Conditional Use Permit and have thus become part of and limitations upon the entitlements conferred by the project approvals. 14. The descriptions of the impacts in these findings are summary statements. Reference should be made to the Final EIR for a more complete description. 15. The Planning and Community Environment Department is directed to file a Notice of Determination with the County Clerk within five (5) working days in accordance with CEQA section 21152(a) and CEQA Guidelines section 15094. II. STATUTORY REQUIREMENTS FOR FINDINGS Significant effects of the Castilleja School Project were identified in the Draft EIR. CEQA section 21081 and CEQA Guidelines section 15091 require that the Lead Agency prepare written findings for identified significant impacts, accompanied by a brief explanation of the rationale for each finding. Less than significant effects (without mitigation) of the project were also identified in the Draft EIR and Initial Study; these are listed in Section VII below. CEQA does not require that the Lead Agency prepare written findings for less than significant effects. CEQA requires that the Lead Agency adopt mitigation measures or alternatives, where feasible, to avoid or mitigate significant environmental impacts that would otherwise occur with implementation of the project. Project mitigation or alternatives are not required, however, where substantial evidence in the record demonstrates that they are infeasible or where the responsibility for modifying the project lies with another agency. Specifically, CEQA Guidelines section 15091 states: (a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are: (1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 4 May 2022 (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. The “changes or alterations” required or incorporated into the project which mitigate or avoid the significant environmental effects of the project, as stated to in CEQA Guidelines section 15091(a)(1) above, may include a wide variety of measures or actions as set forth in CEQA Guidelines section 15370, including avoiding, minimizing, rectifying, or reducing the impact over time, or compensating for the impact by replacing or providing substitute resources. III. DEFINITIONS The following definitions apply where the subject words or acronyms are used in these findings: “ARB” means the City of Palo Alto Architectural Review Board. “BAAQMD” means the Bay Area Air Quality Management District. “City Council” means the City of Palo Alto City Council. “CEQA” means the California Environmental Quality Act (Pub. Resources Code section 21000 et seq.). “City” means the City of Palo Alto. “Comprehensive Plan” means the City of Palo Alto Comprehensive Plan, as adopted in 2017 with subsequent amendments. “Condition” means a Condition of Approval adopted by the City in connection with approval of the project. “CUP” means Conditional Use Permit. “Draft EIR” means the Draft Environmental Impact Report dated July 2019 for the proposed Castilleja School Project. “EIR” means environmental impact report. “Environmental Impact Ordinance” means the City of Palo Alto Environmental Impact Ordinance, as codified in Title 11 of the City of Palo Alto Municipal Code. “FAR” means Floor-Area-Ratio as defined in the City of Palo Alto Municipal Code. “Final EIR” means the Final EIR as prepared for the project (which includes the NOP and Initial Study dated January 2017, the Draft EIR dated July 2019, and the Final EIR dated July 2020). “HRB” means the City of Palo Alto Historic Resources Board. “MMP” means the Mitigation Monitoring Program for the project. “Municipal Code” means the City of Palo Alto Municipal Code, including all amendments thereto. “NOP” means Notice of Preparation of an EIR. “PTC” means the City of Palo Alto Planning and Transportation Commission. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 5 May 2022 “PCE” means the City of Palo Alto Planning and Community Environment Department. “Project” means the proposed Castilleja School Project, Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E. “TDM” means Transportation Demand Management. “TIRE” means the Traffic Infusion in Residential Environments Index. “Tree Preservation and Management Regulations” means the City of Palo Alto Tree Preservation and Management Regulations, as defined in Municipal Code Chapter 8.10. “Zoning Ordinance” means the City of Palo Alto Zoning Ordinance, including all amendments thereto. IV. PROJECT BACKGROUND Castilleja School Foundation (the project applicant) requested approval of an amendment to the school’s existing Conditional Use Permit (CUP) to increase student enrollment at the campus, architectural review of a phased campus modification plan (referred to by the applicant as the Master Plan); a Tentat ive Map with Exception to merge two small parcels containing dwelling units with the larger parcel; a variance for below-grade setback encroachments related to the proposed underground parking structure; and a variance to maintain the existing floor-area-ratio by rebuilding 84,124 square feet above grade in a different configuration. The Draft EIR evaluated the originally proposed project and found that it would result in three significant and unavoidable impacts. One of those significant and unavoidable impacts was associated with the level of service at a particular roadway intersection. As discussed in the Final EIR, since the time that the Draft EIR was prepared, changes in the CEQA Statute and CEQA Guidelines now preclude reliance on measurements of automobile delay, such as the changes in intersection level of service, identifying environmental impacts. Specifically, pursuant to California Public Resources Code section 21099(b)(2) and CEQA Guidelines Section 15064.3, “a project’s effect on automobile delay shall not constitute a significant environmental impact.” Thus, one of the three significant and unavoidable impacts identified in the Draft EIR is no longer considered an environmental effect of the project. Castilleja School Foundation submitted a project alternative that would avoid the two remaining significant and unavoidable impacts (which were both related to the project’s increase in daily traffic volumes on adjacent neighborhood streets, as measured by the Traffic Infusion in Residential Environments [TIRE] Index) and would better address community concerns. This Disbursed Circulation/Reduced Garage Alternative (Project Alternative 4) was presented to the City Council as the preferred project design in March 2021. The Final EIR found that Project Alternative 4 would not result in any significant and unavoidable impacts. Following public hearings in 2020 and March 2021, Castilleja School Foundation prepare a series of potential revisions to the project design as presented in the Updated Garage Studies with Scheme E (November 2021). Of the set of revised project designs, these Findings address the Modified Dispersed Circulation/Reduced Garage Alternative – Scheme E. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 6 May 2022 V. PROJECT OBJECTIVES AND DESCRIPTION Project Objectives The Project Objectives of the project applicant are set forth in Draft EIR sections 1.3, 3.3, and 13.2, which is incorporated herein by reference. The Project Objectives listed herein are revised to reflect the site design presented in the Modified Dispersed Circulation/Reduced Garage Alternative – Scheme E. The project objectives include the following: 1. Maintain a single integrated campus for the middle and upper school with new structures that integrate state-of-the-art technology and teaching practices and retain flexibility. 2. Achieve better architectural and aesthetic compatibility with adjacent neighborhoods through building design and landscaping. 3. Increase enrollment to 540 students to allow more young women the unique opportunity to receive an all-girls education. 4. Increase on-site parking and reduce both parking visibility and surface parking. 5. Improve vehicular, pedestrian, and bicycle access for students and staff. 6. Ensure no increase in vehicle trips to and from the campus during AM peak hours; reduce the number of service deliveries; and provide noise screening for delivery truck and solid waste/recycling truck activities to decrease nuisance effects to neighbors. 7. Improve the campus’s sustainability and energy efficiency. 8. Phase construction to allow continued operation of Castilleja School during construction and to reduce impacts on the neighborhood. Project Description Under the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E, Castilleja School Foundation has requested an amendment of their existing CUP to increase the enrollment cap, and approval for building demolition, new building construction, and construction of a below-grade parking structure. Construction of proposed physical improvements would occur in four phases. These include constructing a below-grade parking structure, constructing a temporary campus, relocating the existing pool, and demolishing the existing Campus Center and classroom buildings and replacing them with a single Academic building. The project also includes implementation of an expanded Transportation Demand Management plan and a Sustainability Road Map. The Disbursed Circulation/Reduced Garage Alternative as proposed by the project applicant is provided in Final EIR Master Response 4. Additional description of the Modified Dispersed Circulation/Reduced Garage Alternative – Scheme E is provided in the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum (March 2022). Site plans of the proposed campus, including the parking garage, as well as technical data and information regarding this project alternative are shown in the following documents:  Kellogg Modifications Study (February 4, 2022); DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 7 May 2022  Updated Garage Studies with Scheme E (November 2021);  ARB Resubmission (November 2021); and  At Grade Delivery Noise Report (September 2021). VI. RECORD OF PROCEEDINGS In accordance with CEQA section 21167.6(e), the record of proceedings for the City’s decision on the Castilleja School project includes, without limitation, the following documents:  The NOP and all other public notices issued by the City in conjunction with the project;  All comments submitted by agencies or members of the public during the comment period on the NOP (provided in Appendix A of the Draft EIR);  The Draft EIR (July 2019) for the project;  All comments submitted by agencies or members of the public during the comment period on the Draft EIR;  All comments and correspondence submitted to the City with respect to the Project, in addition to timely comments on the Draft EIR;  The Final EIR (July 2020) for the project, including comments received on the Draft EIR and responses to those comments;  The Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum (March 2022)  Documents cited or referenced in the Draft and Final EIRs and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum;  The project MMP;  All findings and resolutions adopted by the City in connection with the project and all documents cited or referred to therein;  All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the project prepared by the City, consultants to the City, or responsible or trustee agencies with respect to the City’s compliance with the requirements of CEQA and with respect to the City’s action on the project;  All documents submitted to the City (including the HRB, ARB, PTC, and City Council) by other public agencies or members of the public in connection with the project;  Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public hearings held by the City in connection with the project;  Any documentary or other evidence submitted to the City at such information sessions, public meetings and public hearings;  The City of Palo Alto Comprehensive Plan and all environmental documents prepared in connection with the adoption of the Comprehensive Plan; DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 8 May 2022  The City of Palo Alto Environmental Impact Ordinance and Zoning Ordinance (City of Palo Alto Municipal Code, Title 11 and Title 18), and all other City Code provisions cited in materials prepared by or submitted to the City;  Any and all resolutions and/or ordinances adopted by the City regarding the project, and all staff reports, analyses, and summaries related to the adoption of those resolutions;  Matters of common knowledge to the City, including, but not limited to federal, state, and local laws and regulations;  Any documents cited in these findings, in addition to those cited above; and  Any other materials required for the record of proceedings by CEQA section 21167.6(e). The City Council has relied on all of the documents listed above in reaching its decision on the project, even if not every document was formally presented to the City Council, PTC or City Staff as part of the City files generated in connection with the project. Without exception, any documents set forth above not found in the project files fall into one of two categories. Many of them reflect prior planning or legislative decisions of which the City Council was aware in approving the Castilleja School Project. (See City of Santa Cruz v. Local Agency Formation Commission (1978) 76 Cal.App.3d 381, 391-392; Dominey v. Department of Personnel Administration (1988) 205 Cal.App.3d 729, 738, fn. 6.) Other documents influenced the expert advice provided to City staff or consultants, who then provided advice to the City Council. For that reason, such documents form part of the underlying factual basis for the City Council’s decisions relating to approval of the Castilleja School Project. (See Public Resources Code section 21167.6(e)(10); Browning-Ferris Industries c. City Council of City of San Jose (1986) 181 Cal.App.3d 852, 866; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 153, 155.) The official custodian of the record is the Planning and Community Environment Director, 250 Hamilton Avenue, Palo Alto, CA 94301. VII. LIST OF IMPACTS OF THE PROPOSED PROJECT DETERMINED TO BE LESS THAN SIGNIFICANT OR NO IMPACT WITHOUT IMPLEMENTATION OF MITIGATION MEASURES The City Council agrees with the conclusions in the Final EIR with respect to all impacts initially identified as “no impact” or “less than significant” that do not require implementation of mitigation measures. This includes consideration of the project’s potential to have a significant contribution to cumulative impacts. The impacts determined to be less than significant or no impact without implementation of mitigation measures include: Impacts Evaluated in the Draft EIR Land Use and Planning Impact 4-4 Substantially contribute to cumulative land use impacts. Aesthetics Impact 5-1 Substantially degrade the existing visual character or quality of the site and its surroundings. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 9 May 2022 Impact 5-2 Substantially shadow public open space (other than public streets and adjacent sidewalks). Impact 5-4 Substantially contribute to cumulative impacts to the visual character of the region. Cultural Resources Impact 6-2 Disturb any human remains, including those interred outside of dedicated cemeteries. Impact 6-3 Contribute to a cumulative loss of cultural resources. Transportation Impact 7-2 Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the County congestion management agency for designated roads or highways. Impact 7-3 Result a change in air traffic patterns, including either an increase in traffic levels or a change in location resulting in substantial safety risks. Impact 7-6 Conflict with adopted policies, plans, or programs supporting alternative transportation or otherwise decrease the performance or safety of such facilities. Noise Impact 8-4 Expose people to noise levels that exceed established noise standards or generate a substantial permanent increase in ambient noise levels in cumulative plus project conditions. Air Quality Impact 9-2 Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air qualit y standard. Impact 9-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. Greenhouse Gas Emissions Impact 10-1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Impact 10-2 Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emission of greenhouse gases. Impact 10-3 Make a cumulatively considerable contribution to emissions of greenhouse gases in the cumulative scenario. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 10 May 2022 Energy Impact 11-1 Result in wasteful, inefficient, or unnecessary consumption of energy. Impact 11-2 Conflict with existing energy standards and regulations. Geology, Soils, Seismicity and Paleontology Impact 12-3 Substantial erosion or loss of topsoil. Impact 12-6 Substantially contribute to cumulative impacts associated with geology, seismicity, soils and paleontological resources. Impacts Evaluated in the Initial Study Agriculture and Forestry Resources Impact II.a Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non -agricultural use. Impact II.b Conflict with existing zoning for agricultural use, or a Williamson Act contract. Impact II.c Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). Impact II.d Result in the loss of forest land or conversion of forest land to non-forest use. Impact II.e Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use. Biological Resources Impact IV.b Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. Impact IV.c 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. Impact IV.d Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Impact IV.f Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 11 May 2022 Geology and Soils Impact VI.e Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water Hazards and Hazardous Materials Impact VIII.d Be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. Impact VIII.e For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area. Impact VIII.f For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area. Impact VIII.h Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Hydrology and Water Quality Impact IX.a Violate any water quality standards or waste discharge requirements. Impact IX.b Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted). Impact IX.c Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site. Impact IX.d Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Impact IX.e Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Impact IX.f Otherwise substantially degrade water quality. Impact IX.g Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 12 May 2022 Impact IX.h Place within a 100-year flood hazard area structures which would impede or redirect flood flows. Impact IX.i Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam. Impact IX.j Inundation by seiche, tsunami, or mudflow. Land Use and Planning Impact X.c Conflict with any applicable habitat conservation plan or natural community conservation plan. Mineral Resources Impact XI.a Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. Impact XI.b Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. Noise Impact XII.e For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels. Impact XII.f For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels. Population and Housing Impact XIII.a Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure. Impact XIII.b Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. Impact XIII.c Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere. Public Services Impact XIV.a Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services: Fire protection; Police protection; Schools; Parks; Other public facilities. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 13 May 2022 Recreation Impact XV.a Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impact XV.b Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Utilities and Service Systems Impact XVIII.a Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? Impact XVIII.b Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Impact XVIII.c Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Impact XVIII.d Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? Impact XVIII.e Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Impact XVIII.f Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs? Impact XVIII.g Comply with federal, state, and local statutes and regulations related to solid waste? VIII. FINDINGS FOR SIGNIFICANT AND POTENTIALLY SIGNIFICANT IMPACTS REDUCED TO LESS THAN SIGNIFICANT WITH IMPLEMENTATION OF MITIGATION MEASURES The City Council agrees with the characterization in the Final EIR with respect to all impacts initially identified as “significant” or “potentially significant” that are reduced to less than significant levels with implementation of the mitigation measures identified in the Final EIR. In accordance with CEQA Guidelines §15091(a), a specific finding is made for each impact and its associated mitigation measures in the discussions below. Mitigation measures are summarized below and are presented in full in the EIR and the MMP, which are incorporated herein by reference. This section includes findings specific to the project’s potential to result in a significant contribution to cumulative impacts. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 14 May 2022 Land Use and Planning Impact 4-1: Conflict with land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. Summary: As discussed in Final EIR Master Response 4 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in similar impacts as the originally proposed project that were evaluated in Draft EIR Impact 4-1. Specifically, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E could result in conflicts with the City’s land use plans, policies, and regulations by increasing the intensity of the existing educational use through potential increases in special events; removing trees and reducing tree canopy in the project vicinity; potential increases in traffic associated with increased enrollment; and generating noise levels that could exceed the Municipal Code standards during project construction and during use of the pool. Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measures 4a, 4b, 7a, 7b, 8a, and 8b will ensure that the potential for the project to result in new land use incompatibilities or exacerbate existing land use incompatibilities would be reduced to a less-than-significant level. Explanation: These mitigation measures will substantially lessen the project’s environmental effects by establishing requirements for special events (Mitigation Measure 4a, which includes defining a maximum number of special events, identifying restrictions on event size and timing, and identifying requirements for parking, ensuring that the level of special event activity would be slightly less than currently occurs); requiring tree protection and replacement consistent with the City’s Tree Preservation and Management Regulations (Mitigation Measure 4b); identifying performance standards that must be attained through implementation of an enhanced TDM program (Mitigation Measure 7a); requiring vegetation management to ensure adequate lines of sight are maintained at site driveways (Mitigation Measure 7b), and establishing noise performance standards that must be met by the loudspeaker system at the pool and during construction (Mitigation Measures 8a and 8b). Significance After Mitigation: Less Than Significant. Impact 4-2: Create land use incompatibility or physically divide an established community Summary: As discussed in Final EIR Master Response 4 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in similar impacts as the originally proposed project that were evaluated in Draft EIR Impact 4-2. Specifically, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in a land use compatibility conflict due to the potential to exacerbate existing land use conflicts between the school and its residential neighborhood. The analysis identifies potentially DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 15 May 2022 significant impacts that would result from any increases in special events that could increase disturbance to neighbors and generating noise levels that could exceed the Municipal Code standards during project construction and from use of the pool. Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measures 4a, 8a and 8b will ensure that the potential for the project to result in new land use incompatibilities or exacerbate existing land use incompatibilities would be reduced to a less-than-significant level. Explanation: These mitigation measures will substantially lessen the project’s environmental effects by establishing requirements for special events (Mitigation Measure 4a, which includes defining a maximum number of special events, identifying restrictions on event size and timing, and identifying requirements for parking, ensuring that the level of special event activity would be slightly less than currently occurs), and establishing noise performance standards that must be met by the loudspeaker system at the pool and during construction (Mitigation Measures 8a and 8b). Significance After Mitigation: Less Than Significant. Impact 4-3: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Summary: As discussed in Final EIR Master Response 4 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in similar but slightly reduced impacts as the originally proposed project that were evaluated in Draft EIR Impact 4-3. Specifically, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in tree removal and encroachment of construction activities into tree protection zones but would decrease the amount of tree removal and encroachment into tree protection zones compared to the originally proposed project and the Disbursed Circulation/Reduced Garage Alternative as described in the Final EIR. Finding: Changes in the project to substantially lessen the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measure 4b will ensure that the potential for the project to result in significant tree loss would be reduced to a less-than- significant level. Explanation: Mitigation Measure 4b will substantially lessen the project’s environmental effects associated with tree loss and adverse effects to retained trees by establishing requirements for tree protection during and after construction and tree replacement, consistent with the City’s Tree Preservation and Management Regulations and the City’s Tree Technical Manual. Significance After Mitigation: Less Than Significant. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 16 May 2022 Aesthetics Impact 5-3: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Summary: As discussed in Master Response 4 and in Draft EIR Impact 5-3 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would create new sources of light that could adversely affect day or nighttime views in the area, and tree removal associated with the project could increase the potential for outdoor lighting to shine on adjacent property. The Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E project plans (as identified in Section V of these findings) identify that lighting fixtures for the project would include bollards and ground-level fixtures along walkways and near building entrances, building-mounted lighting around building perimeters and at entrances, ground- level lighting in bicycle parking areas, and wall mounted lighting on steps and planter walls. The potential for windows to result in glare would be minimized with roof overhangs, tree retention and planting, and fencing that would reduce direct solar exposure on windows and reduce the potential for light reflecting off windows to create glare for drivers on adjacent streets. The project does not propose use of highly reflective surfaces, such as mirrored glass, black glass, or metal building materials and thus would not create potentially significant impacts associated with glare. Finding: Changes in the project to avoid the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measure 5a will ensure that the potential for the project to create substantial light spillover onto the adjacent public right-of-way or private property would be reduced to a less-than-significant level. Explanation: Mitigation Measure 5a requires the project applicant to develop a lighting plan for each development phase and requires that the lighting plans demonstrate attainment of the performance standards identified in the Palo Alto Municipal Code, which requires that lighting be installed such that no light source within the project site generates a light level greater than 0.5 foot-candle on any off-site residential property. Significance After Mitigation: Less Than Significant. Cultural Resources Impact 6-1: Cause a substantial adverse change in the significance of a historical or archeological resource. Summary: No archeological resources were identified through record searches and surveys, however, there are known archeological resources in the project region and thus there is a potential for earth-moving activities to disturb previously unknown archeological resources, if any occurred on site. The project also has the potential to indirectly or accidentally affect the existing historic resources onsite and adjacent to the site during construction by exposure to dust, debris, and accidental contact with construction equipment. The analysis in Draft EIR Chapter DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 17 May 2022 8 demonstrates that vibration associated with project construction is not anticipated to adversely affect any adjacent historic resources. Finding: Changes in the project to avoid the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measures 6a and 6b will ensure that the potential for the project to adversely affect significant below-grade archeological resources or cause damage to historic resources onsite and adjacent to the site during construction would be reduced to a less-than-significant level. Explanation: Mitigation Measure 6a requires development and approval of a preservation protection plan for each phase of construction to ensure that historic buildings within and adjacent to the site are not adversely affected by dust, debris, and/or damage from accidental contact with construction equipment. Mitigation Measure 6b requires education of construction workers on archeological resources and the steps to take in the event of the discovery of any previously unrecorded resource. Significance After Mitigation: Less Than Significant. Transportation Impact 7-1 Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel Summary: The Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E includes three drop-off/pick-up locations for Castilleja students. The project applicant proposed assigning a certain percentage of students to each of the three locations. As discussed in Master Response 4, the proposed percentage assignments would create an impact under the TIRE Index by increasing daily traffic volumes on two segments of Bryant Street and could result in vehicle queues that exceed capacity for the Bryant Street drop off location. Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as identified in the EIR are required. Implementation of Mitigation Measure 7a will ensure that the potential for the project to create a substantial increase in traffic volumes on Bryant Street or cause vehicle queues that extend into the public right-of-way would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each drop-off/pick-up location, consistent with the recommendations of the Transportation Impact Analysis prepared for this project and Final EIR Table MR4-2. It also includes a requirement that the drop-off assignments be reassessed through routine monitoring to balance traffic flows sufficient to avoid a significant TIRE Index increase in the project vicinity and maintain appropriate vehicle queues. Further, Mitigation Measure 7a identifies performance standards that must be attained by the school’s enhanced TDM program and establishes requirements for monitoring and reporting on the effectiveness of the TDM program. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 18 May 2022 Significance After Mitigation: Less Than Significant. Impact 7-4: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment Summary: Draft EIR Impact 7-4 evaluates whether the proposed project could introduce new roadway hazards by creating vehicle queues that extend into the public right-of-way or providing inadequate sight distance at driveways where vehicles exit the site and enter the public right-of-way. As discussed in Master Response 4 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in vehicle queues for the Bryant Street drop-off location that exceed the available storage and would extend into Bryant Street under the proposed allocations to each of the three drop-off locations. Additionally, sight distance could be constrained by landscaping and/or on-street parking at the project site driveways. These conditions would result in significant impacts. Finding: Changes in the project are required to avoid the significant environmental effect as identified in the EIR. Implementation of Mitigation Measures 7a and 7b will ensure that the potential for the project to substantially increase transportation hazards would be reduced to a less- than-significant level. Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each drop-off/pick-up location, consistent with the recommendations of the Transportation Impact Analysis prepared for this project and Final EIR Table MR4-2 to ensure that vehicle queues do not extend into the public right-of-way. It also includes a requirement that the vehicle queue lengths be monitored and drop-off assignments be reassessed to ensure that appropriate vehicle queues are maintained. Mitigation Measure 7b stipulates that a minimum of 150 feet of sight distance must be maintained through vegetation trimming and prohibiting on- street parking adjacent to each driveway. Significance After Mitigation: Less Than Significant. Impact 7-5: Result in inadequate emergency access. Summary: The project would not create traffic congestion or changes in roadway configurations that could interfere with emergency response or substantially lengthen response times but could result in interference with emergency response in the project vicinity if vehicle queues at the drop-off/pick-up locations extend into the public right-of-way. Finding: Changes in the project are required to avoid the significant environmental effect as identified in the EIR. Implementation of Mitigation Measure 7a will ensure that the potential for the project to cause vehicle queues that extend into the public right-of-way would be avoided, thus the impact would be reduced to a less-than-significant level. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 19 May 2022 Explanation: Mitigation Measure 7a requires that the drop-off/pick-up location assignments be assessed through routine monitoring and adjusted to balance traffic flows sufficient to maintain appropriate vehicle queues. Significance After Mitigation: Less Than Significant. Impact 7-7: Contribute to a cumulative increase in traffic that conflicts with adopted policies and plans. Summary: The City’s traffic model anticipates that background traffic volumes will continue to increase over time, but Castilleja traffic is expected to remain constant or decrease because the school would be required under the TDM plan and Mitigation Measure 7a to maintain a maximum daily trip rate of 2.4 trips per student. The project’s contribution to cumulative impacts would be less than significant for all roadways in the study area except the segments of Bryant Street between Embarcadero Road and Churchill Avenue. Finding: Changes in the project are required to substantially lessen the significant environmental effect as identified in the EIR. Implementation of Mitigation Measure 7a will ensure that the potential for the project to create a substantial increase in traffic volumes on Bryant Street would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each drop-off/pick-up location, consistent with the recommendations of the Transportation Impact Analysis prepared for this project. It also includes a requirement that the drop-off assignments be reassessed through routine monitoring to balance traffic flows sufficient to avoid a significant TIRE Index increase in the project vicinity. Further, Mitigation Measure 7a identifies performance standards that must be attained by the school’s enhanced TDM program and establishes requirements for monitoring and reporting on the effectiveness of the TDM program. Significance After Mitigation: Less Than Significant. Noise Impact 8-1: Expose people to or generate noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; or create a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project Summary: Nighttime outdoor special events and use of amplified sound during pool events has the potential to expose people to or generate noise levels in excess of the standards established in the Comprehensive Plan and Municipal Code. The project would not create significant noise impacts associated with vehicle traffic because it would not result in a doubling of traffic volumes on any roadway segments. The project would not create significant noise impacts associated with truck and bus activity because it would relocate delivery and trash DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 20 May 2022 pickup activity to a below-grade loading zone and would relocate bus loading to the interior of the project site. Finding: Changes in the project are required to substantially lessen the significant environmental effect as identified in the EIR. Implementation of Mitigation Measures 4a and 8a will ensure that the potential for the project to create a substantial increase in noise levels associated with special events would be avoided, thus the impact would be reduced to a less-than- significant level. Explanation: Mitigation Measure 4a, as identified in Draft EIR Chapter 4, Land Use, will ensure that excessive nighttime noise is not generated by special events by requiring that athletic competitions end by 8 p.m. Mitigation Measure 8a establishes a performance standard that must be attained at the time that the loudspeaker system for the pool area is designed, which must be demonstrated in a noise assessment prepared by a qualified acoustical consultant. Significance After Mitigation: Less Than Significant. Impact 8-2: Create a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the proposed project Summary: The project could generate substantial periodic increases in noise during nighttime outdoor special events and use of amplified sound during pool events and project construction activities could generate substantial temporary increases in noise. Finding: Changes in the project are required to substantially lessen the significant environmental effect as identified in the EIR. Implementation of Mitigation Measures 4a, 8a, and 8b will ensure that the potential for the project to create substantial periodic or temporary increases in noise levels associated with special events and construction would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure 4a, as identified in Draft EIR Chapter 4, Land Use, will ensure that excessive nighttime noise is not generated by special events by requiring that athletic competitions end by 8 p.m. Mitigation Measure 8a establishes a performance standard that must be attained at the time that the loudspeaker system for the pool area is designed, which must be demonstrated in a noise assessment prepared by a qualified acoustical consultant. Mitigation Measure 8b will ensure that noise levels during construction remain below the City’s standards for maximum instantaneous noise levels and for the amount by which construction noise levels exceed ambient noise conditions by requiring for each construction phase that Castilleja School submit to the City an inventory and schedule of the construction equipment proposed to be used during that phase, a technical analysis of the noise levels that could be generated during construction, and recommended measures to ensure that noise levels during construction meet the City’s standards. Significance After Mitigation: Less Than Significant. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 21 May 2022 Impact 8-3: Expose people to or generate excessive ground borne vibrations or ground borne noise levels Summary: Construction of the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would involve use of a variety of heavy equipment, which could cause ground borne vibration. None of the residential structures in the project vicinity would be exposed to vibrations that could cause vibration damage, but the onsite Administration/Chapel building could be subject to ground borne vibration damage during demolition of the adjacent academic building. The project does not include any operational activities that would result in groundborne vibration or noise that would be perceptible off site. Finding: Changes in the project are required to avoid the significant environmental effect as identified in the EIR. Implementation of Mitigation Measure 6a will ensure that the potential for the project to cause excessive ground borne vibration would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure 6a, as presented in Draft EIR Chapter 6, Cultural Resources, requires that a protection plan be implemented for the Administration/Chapel Theater building that documents the specific nature of demolition activities that would occur on any portion of the building that touches or is within 25 feet of the Administration/Chapel Theater building and provides recommendations for equipment usage and demolition techniques that will avoid adverse effects to the Administration/Chapel Theater building by ensuring that continuous vibrations remain below approximately 0.25 in/sec. Significance After Mitigation: Less Than Significant. Air Quality Impact 9-1: 1 Conflict with or obstruct implementation of the applicable air quality plan. Summary: Construction of the project is not expected to result in average daily emissions of criteria air pollutants that exceed the BAAQMD thresholds. However, the project could conflict with or obstruct implementation of the 2017 Clean Air Plan if the BAAQMD basic control measures for reducing construction emissions of coarse particulate matter are not implemented, as required by the Comprehensive Plan. Finding: Changes in the project are required to avoid the significant environmental effect as identified in the EIR. Implementation of Mitigation Measure 9a will ensure that the potential for the project to conflict with or obstruct implementation of the 2017 Clean Air Plan would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure 9a requires that the City of Palo Alto ensure that site plan notes include requirements for the construction contractor to implement the BAAQMD Basic Construction Emission Control Measures and perform visual inspections during construction. With implementation of Mitigation Measure 9a, project construction would be consistent with the 2017 Clean Air Plan and the City’s requirements for limiting construction emissions. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 22 May 2022 Significance After Mitigation: Less Than Significant. Impact 9-3 Expose sensitive receptors to substantial pollutant concentrations Summary: As discussed in Final EIR Master Response 4 and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum, the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E would result in similar impacts as the originally proposed project as discussed in Impact 9-3. As discussed under Draft EIR Impact 9-3, demolition of structures built prior to 1980 could result in the release of contaminated materials and hazardous substances that may be present in the buildings, such as lead- based paint or asbestos. Other construction activities would not expose students, workers, or neighbors to substantial air pollutant concentrations. Vehicle traffic during operation of the proposed project would not be expected to create carbon monoxide hotspots that could expose sensitive receptors to substantial concentrations of hazardous emissions. Finding: Changes in the project are required to avoid the significant environmental effect as identified in the EIR. Implementation of Mitigation Measure HAZ-1 will ensure that the potential for the project to expose sensitive receptors to substantial pollutant concentrations would be avoided, thus the impact would be reduced to a less-than-significant level. Explanation: Mitigation Measure HAZ-1, as identified in the Initial Study (Final EIR Appendix A), requires that prior to issuance of a demolition permit, the project applicant shall retain a qualified professional to complete a survey of the building proposed for demolition to determine if lead-containing materials, asbestos containing materials, and/or polychlorinated biphenyls are present; retaining a contractor trained and qualified to conduct lead- or asbestos-related construction work to carry out any demolition activities likely to disturb such materials; and following regulatory protocols for handling and disposal of these materials. Significance After Mitigation: Less Than Significant. Significant and Unavoidable Impacts The City Council agrees with the characterization in the Final EIR and the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum that all of the significant and potentially significant impacts that could result from the Modified Disbursed Circulation/Reduced Garage Alternative - Scheme E would be reduced to less-than-significant levels and thus the project would not result in any significant and unavoidable environmental impacts. IX. PROJECT ALTERNATIVES FINDINGS Public Resources Code section 21002 provides that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such project[s].” When a lead agency finds, even after the adoption of all feasible mitigation measures, that a project will still cause one or more significant environmental effects that cannot be substantially lessened or avoided, it must, prior to DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 23 May 2022 approving the project as mitigated, first determine whether there are any project alternatives that are feasible and that would substantially lessen or avoid the project’s significant impacts. As stated in Section VIII above, there are no significant and unavoidable impacts associated with the proposed project. However, an alternatives analysis was completed and included in the Final EIR. Reasonable Range of Project Alternatives CEQA Guidelines §15126.6(f) states that the range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. Further, CEQA Guidelines §15126(a) requires that an EIR describe a reasonable range of alternatives that would “feasibly obtain most of the basic project objectives” but would avoid or substantially lessen any of the significant environmental effects of the project and evaluate the comparative merits of the alternatives. Thus, the project objectives presented in the EIR provided the framework for defining the possible alternatives. Based upon guidance contained in the CEQA Guidelines and applicable case law as well as the project objectives, the Final EIR provides the following analysis regarding project alternatives:  The Draft EIR identified six alternatives that were preliminarily considered but rejected from detailed analysis because they were incapable of meeting most of the basic project objectives, would not reduce or avoid any of the project’s significant effects, and/or would require speculation to evaluate. These include: offsite alternative – relocate full campus, partial offsite alternative (relocate a portion of the student body and staff to a new second campus), other offsite options (relocate sports and special events to other locations), surface parking, modified circulation routes, and minimum enrollment increase.  The Draft EIR provided detailed analysis of three project alternatives: the No Project Alternative (as required by CEQA), the Moderate Enrollment Increase Alternative, and the Moderate Enrollment Increase with Reduced Parking Alternative.  In response to comments received on the Draft EIR, the Final EIR evaluated the Disbursed Circulation/Reduced Garage Alternative.  In response to recommendations and direction provided by the City’s HRB, ARB, PTC, and City Council, an additional five variants of the Disbursed Circulation/Reduced Garage Alternative have been developed and reviewed by the City. The environmental effects of two of these additional variants were evaluated in the Castilleja School Project – Environmental Effects of Scheme D and Scheme E Memorandum; and the Modified Disbursed Circulation/Reduced Garage Alternative – Scheme E has replaced the proposed project.  The Final EIR also considered the one additional alternative – the No Garage Alternative – and provided additional discussion of the alternatives that were preliminarily considered in the Draft EIR but rejected from detailed analysis as described above. These included consideration of various alternative enrollment caps, creating a split campus or a second campus, and relocating the school. The City Council finds that that a good-faith effort was made to evaluate a reasonable range of potentially feasible alternatives in the EIR that are reasonable alternatives to the project and could feasibly obtain DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 24 May 2022 most of the basic objectives of the project, even when the alternatives might impede the attainment of the project’s objectives and might be more costly. Feasibility of Project Alternatives Although an EIR must evaluate a range of potentially feasible alternatives, an agency decision-making body may ultimately conclude that a potentially feasible alternative is actually infeasible. (California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001-1002.) CEQA Guidelines §15126.6(f)(1) provides that 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, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” Grounds for a conclusion of infeasibility might be the failure of an alternative to fully satisfy project objectives deemed to be important by decision-makers, or the fact that an alternative fails to promote policy objectives of concern to such decision-makers. (Id. at pp. 992, 1000-1003.) It is well established under CEQA that an agency may reject alternatives based on economic infeasibility. (Foundation for San Francisco’s Architectural Heritage v. City and County of San Francisco (1980) 106 Cal.App.3d 893, 913- 914; San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656, 774; Association of Irritated Residents v. County of Madera (2003) 107 Cal.App.4th 1383, 1399-1400; Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, 1510.) In addition, the definition of feasibility encompasses “desirability” to the extent that an agency’s determination of infeasibility represents a reasonable balancing of competing economic, environmental, social, and technological factors supported by substantial evidence. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410; 417.) Thus, even if a project alternative will avoid or substantially lessen any of the significant environmental effects of a proposed project as mitigated, the decision-makers may reject the alternative for such reasons. Analysis of Project Alternatives No Project Alternative The No Project Alternative assumes that the proposed Castilleja School Project would not be constructed and that no changes to the existing Conditional Use Permit would be made. Castilleja would be restricted to a maximum enrollment of 415 students each year. No demolition or construction would occur within the campus, and no changes would be made to the school’s special event schedule or provisions for student, staff, and visitor parking. The EIR concluded that this alternative would have reduced impacts associated with land use, aesthetics, cultural resources, transportation, noise, and air quality; however the No Project Alternative would not meet any of the proposed project objectives and would not achieve the project’s aesthetic benefits associated with enhancing the site architecture, landscaping, and fencing and the project’s noise benefits of reducing neighbors’ exposure to noise associated with use of the pool. No Project Alternative Findings: The City Council finds that this alternative is infeasible in that it meets none of the project objectives. Specifically, it does not support the project objectives of increasing enrollment, increasing the campus’s sustainability and energy efficiency, increasing on-site parking, and improving architectural compatibility with the surrounding neighborhood. For all of the foregoing DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 25 May 2022 reasons, and for any of them individually, the City Council determines that the No Project Alternative is infeasible and is hereby rejected. Moderate Enrollment Increase Alternative This alternative considered a maximum enrollment of 506 students, which is 34 students fewer than proposed. The Moderate Enrollment Increase Alternative would include construction of the new academic building to include 30 classrooms, construction of the below-grade parking structure with 117 parking spaces (as contemplated in the original Castilleja School Project proposal), demolition of the two residential structures on Emerson Street (as contemplated in the original Castilleja School Project proposal), and a reduction in the number of parking spaces in the proposed surface parking lot at Emerson Street and Kellogg Avenue. The Moderate Enrollment Increase Alternative was found to slightly reduce potential land use and transportation impacts compared to the originally proposed project but would increase those impacts compared to the Disbursed Circulation/Reduced Garage Alternative. This alternative would result in similar aesthetic impacts as either the originally proposed project or the Disbursed Circulation/Reduced Garage Alternative because building scale, massing, materials, colors, and details as well as landscaping and fencing would be generally the same. The Moderate Enrollment Increase Alternative would also result in similar impacts associated with cultural resources, noise, air quality, greenhouse gas emissions, energy, and geology and soils as the proposed project because it would involve a similar level of construction and project site redevelopment. Moderate Enrollment Increase Alternative Findings: While the alternative may be feasible and capable of meeting most of the basic project objectives, this alternative does not substantially reduce impacts compared to the proposed project, and would increase the potential land use and transportation impacts compared to the Disbursed Circulation/Reduced Garage Alternative. Therefore, under CEQA, the Moderate Enrollment Increase Alternative is not environmentally superior to the proposed project. Moderate Enrollment Increase with Reduced Parking Alternative The Moderate Enrollment Increase with Reduced Parking Alternative would establish a maximum enrollment of 506 students and would reduce the on-site parking to the minimum required by code by reducing the size of the below-grade parking structure to 58 spaces and increasing surface parking within the project site. This alternative would require two fewer classrooms and 46 fewer parking spaces than the proposed project. The Moderate Enrollment Increase with Reduced Parking Alternative was found to slightly reduce potential land use and transportation impacts compared to the originally proposed project but would increase those impacts compared to the Disbursed Circulation/Reduced Garage Alternative. This alternative would result in a slight reduction in aesthetic impacts as either the originally proposed project or the Disbursed Circulation/Reduced Garage Alternative because building scale and massing would be slightly reduced, while building materials, colors, and details as well as landscaping and fencing would be generally the same. The Moderate Enrollment Increase with Reduced Parking Alternative would also result in similar impacts associated with cultural resources, noise, air quality, greenhouse gas emissions, energy, and geology and soils as the proposed project because it would involve a similar level of construction and project site redevelopment. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 26 May 2022 Moderate Enrollment Increase with Reduced Parking Alternative Findings: While the alternative may be feasible and capable of meeting most of the basic project objectives, this alternative does not substantially reduce impacts compared to the proposed project, and would increase the potential land use and transportation impacts compared to the Disbursed Circulation/Reduced Garage Alternative. Therefore, under CEQA, the Moderate Enrollment Increase with Reduced Parking Alternative is not environmentally superior to the proposed project. No Garage Alternative The No Garage Alternative eliminates the parking garage from the project while accommodating a slightly reduced level of redevelopment in other areas of the project. A surface parking lot would be created along Emerson Street, in place of the two existing residential structures. This alternative would use a similar disbursed circulation plan as the Disbursed Circulation/Reduced Garage Alternative, with drop-off/pick-up occurring at the Bryant Street loop driveway, the Kellogg Avenue loop driveway, and the Emerson Street surface parking lot. Based on the space available for the Emerson Street surface parking lot, the No Garage Alternative also includes a reduction in classroom space and a commensurate reduction in the enrollment cap. The No Garage Alternative would provide 92 parking spaces, allowing for construction of a total of 29 classrooms and accommodating an enrollment cap of 489 students. The No Garage Alternative would result in the following potential changes in the project’s environmental effects:  Increased potential for loss of community character by replacing landscaped residential lots (current condition) or a landscaped passive park setting (proposed project) with a surface parking lot. Landscaping and fencing could be used to shield public views of the parking lot, keeping this effect at a less than significant level.  Increased amount of tree removal in the parking lot location, but this impact would be reduced to a less-than-significant level with implementation of Mitigation Measure 4b, and thus, impacts would not be increased in comparison to the Disbursed Circulation/Reduced Garage Alternative.  Reduced potential transportation impacts due to the reduction in student enrollment, however the alternative would result in a potential for TIRE Index impacts on Bryant Street and for vehicle queues to extend into the public right-of-way. These impacts would be reduced to a less-than- significant level with implementation of Mitigation Measure 7a.  Potential for increased noise impacts to residences on Emerson Street associated with use of the surface parking lot for special event parking. During daytime special events, noise effects from use of the parking lot would be mitigated with an appropriate setback and noise barrier constructed along the northern boundary of the parking lot. During evening special events, when the City’s noise standards are lower to reflect the higher noise sensitivity in nighttime hours, it may be necessary to restrict parking within the northernmost portion of the surface parking lot to ensure that noise exposure for the adjacent residence remains at acceptable levels. This could result in additional on-street parking during evening events compared to the proposed project, however parking demand would not be greater than under existing conditions and thus this does not indicate that this alternative would result in a new significant impact.  Similar impacts associated with cultural resources, air quality, greenhouse gas emissions, energy, and geology and soils as the proposed project because it would involve a similar level of construction and project site redevelopment. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 27 May 2022 No Garage Alternative Findings: This alternative would require a substantial reduction in the proposed enrollment level. Thus, this alternative would impede attainment of one of the primary project objectives. Additionally, this alternative has the potential to increase some project impacts, although the impacts would be reduced to less-than-significant levels with implementation of mitigation measures. Further, this alternative does not substantially reduce impacts compared to the proposed project. Therefore, under CEQA, the No Garage Alternative is not environmentally superior to the proposed project. X. GROWTH INDUCEMENT FINDINGS Growth can be induced in a number of ways, such as through the elimination of obstacles to growth, through the stimulation of economic activity within the region, or through the establishment of policies or other precedents that directly or indirectly encourage additional growth. Induced growth would be considered a significant impact if it can be demonstrated that the potential growth would directly or indirectly have a significant effect on the environment. New employees from commercial or industrial development and new population from residential development represent direct forms of growth. These direct forms of growth have a secondary effect of expanding the size of local markets and inducing additional economic activity in the area. A project could indirectly induce growth by reducing or removing barriers to growth, or by creating a condition that attracts additional population or new economic activity. Construction of the Castilleja School Project would create short-term construction jobs. These are anticipated to be filled by workers who, for the most part, already reside in the surrounding area. Therefore, project construction is not expected to induce other growth in the City or region. The proposed increase in student enrollment would require add an additional 10 employees at full project buildout. The existing school currently employs 122 full time employees. These new employees could indirectly induce a small amount of economic growth in the City to the extent that the employees might seek housing and would be expected to purchase food and services in the area. However, the potential for growth inducement due to the increase in employees is not considered substantial because the scale of the expected increase in employment is insufficient to trigger noticeable changes in the housing market or demand for local goods and services, as evaluated in Draft EIR Section 14.4. Finding: The Castilleja School Project would not induce substantial growth in the project area or region. Explanation: The potential for growth inducement due to project construction and the increase in student enrollment is not considered substantial. The increase in employment opportunities associated with the project (10 new employees) would provide would be insufficient to trigger noticeable changes in the housing market or demand for local goods and services. In addition, construction of the proposed project would be temporary and these short-term construction jobs are anticipated to be filled by workers who, for the most part, reside in the surrounding area. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Castilleja School Project Statement of Findings 28 May 2022 XII. CONCLUSION The mitigation measures listed in conjunction with each of the findings set forth above, as implemented through the MMP, will eliminate or reduce to a less than significant level all adverse environmental impacts of the Castilleja School Project – Modified Disbursed Circulation/Reduced Garage Alternative - Scheme E. Taken together, the Final EIR, the mitigation measures, and the MMP provide an adequate basis for approval of the Castilleja School Project – Disbursed Circulation/Reduced Garage Alternative - Scheme E. DocuSign Envelope ID: E164B2CC-DA2E-48FA-A1AB-DD4CACBFE49C Certificate Of Completion Envelope Id: E164B2CCDA2E48FAA1ABDD4CACBFE49C Status: Completed Subject: Please DocuSign: RESO 10047 - Certifying the Adequacy of the Final Environmental Impact Report ... 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