Loading...
HomeMy WebLinkAboutStaff Report 299-10TO: FROM: DATE: SUBJECT: CITY OF PALO ALTO Memorandum HONORABLE CITY COUNCIL CITY MANAGER JULY 21, 2010 DEPARTMENT: PLANNING AND COMMUNITY ENVIRONMENT CMR: 299:10 Stanford University Medical Center Facilities Renewal and Replacement Project Draft Environmental Impact Report -Comment on the Draft Environmental Impact Report, including an overview of the Alternatives Chapter and Mitigation Measures. Attached is the City Manager Report (CMR) for the Stanford University Medical Center Facilities Renewal and Replacement Project Draft Environmental Impact Report (DEIR). This meeting is the fourth opportunity for the City Council to provide comments on the DEIR. The City Council previously held public hearings to accept DEIR comments on June 7, June 14, July 12 and July 19, 2010. This item was previously sent to you in your packet of July 14, 2010. Hardcopies are available at the Council Chambers, the Planning Department on the 5th Floor and can also be viewed at http://www.cityofpaloalto.org/knowzone/reports/cmrs.asp Staff will provide an overview of the Alternatives Chapter and Mitigation Measures at the meeting. This item was heard by the Planning and Transportation Commission (P&TC) on July 7, 2010. Minutes from this meeting is attached. Although staff will provide an overview of the chapters listed above, the City Council and members· of the public may provide comments on any topics within the DEIR. CURTIS WILLIAMS Director of Planning and Community Environment ATTACHMENTS Attachment A: CMR 299:10 Attachment B: Excerpt Minutes of the P&TC meeting dated July 7,2010 (Council only) ATTACHMENT A TO: HONORABLE CITY COUNCIL PLANNI~G AND TRANSPORTATION COMMISSION FROM: CITY MANAGER DEPARTMENT: PLANNING AND COMMUNITY ENVIRONMENT DATE: JULY 26, 2010 CMR: 299:10 REPORT TYPE: PUBLIC HEARING SUBJECT: Stanford University Medical Center Facilities Renewal and Replacement Project Draft Environmental Impact Report -Comment on the Draft Environmental Impact Report, including an overview of the Alternatives Chapter and Mitigation Measures. EXECUTIVE SUMMARY Staff recommends that the City Council and Planning and Transportation Commission (P &TC) provide and accept public comments on the Draft Environmental hnpact Report (Draft EIR) for the Stanford University Medical Center Facility Renewal and Replacement Project (SUMC Project) and forward comments to staff and consultants for response in the Final Environmental Impact Report (Final EIR). The Draft EIR began a 69-daypublic review period on May 20, 2010. The review period ends on July 27, 2010. Multiple meetings have been held with the City Council and P &TC to accept comments on the Draft EIR. The July 26, 2007 City Council meeting will be last public meeting where oral comments may be presented. However, written comments will be accepted until the close of business on July 27,2010. This staff report provides an overview of the Alternatives chapter of the Draft EIR, including the key impacts and mitigation measures. The P &TC will comment on these chapters on June 30, 2010 and the City Council on July 26,2010. RECOMMENDATION Staff recommends that the City Council and the Planning and Transportation Commission: 1. Accept public comments on the Draft EIR with focus on the Alternatives Chapter and mitigation nleasures; and 2. Forward cpmments on the Draft EIR to staff and the consultant for response in the Final EIR. BACKGROUND On May 20, 2010, the SUMC Project Draft EIR was published starting a 69-day public review period. On July 7th the P&TC will hold a public hearing and on July 26 th the City Council will hold a public hearing to review the Alternatives and Mitigation Measures. Copies of the Draft EIR can be obtained at the City of Palo Alto Development Center, at the Palo City of Palo Alto Page 1 Alto Main Library and via the City's website, www.cityofpaloalto.orglsumc. ENVIRONMENTAL REVIEW Staffwill provide an overview of the following at the meeting: • Alternatives (pages 5-1 through 5-228) • Mitigation Measures (Summary Table S-4, pages S-25 through S-92) The comments should be focused on whether the information presented in the Draft EIR adequately covers the environmental impacts that could result from the proposed SUMC Project and the adequacy of the proposed mitigation measures. The hearings are not meant to provide a forum for dialogue about the project merits, but to be opportunities to collect comments on the Draft EIR to ensure that it adequately describes the environmental impacts of the Project. 1. Alternatives An EIR is required to examine a range of project alternatives in order to assess whether impacts can be reduced or eliminated while also achieving project goals. Alternatives are addressed in Section 5 of the Draft EIR. The chapter analyzes seven (7) alternatives including two (2) No Project Alternatives, two (2) Reduced Intensity Alternatives, Tree Preservation Alternative, Historic Preservation Alternative, and a Village Concept Alternative. The range of alternatives was determined through the scoping process and supplemented later by staff and the applicants as project impacts, such as historical and biological, were identified through additional analysis. The Draft EIR provides a detailed description of each alternative, followed by an analysis of how each alternative meets the Project objectives. The list of Project Sponsor and City objectives is contained in Attachment A. Section 5.5 -Impact Assessment, starting on page 5-50, evaluates whether the. alternatives would reduce or eliminate significant impacts of the SUMC Project and/or generate impacts other than those identified for the SUMC Project. Table 5-8 (Attachment B) provides a comparison of the impacts identified under each alternative to the impacts of the SUMC Project. When assessing the feasibility of alternatives, it is important to assess whether they meet the objectives of the applicant and the City. City of Palo Alto Page 2 Below is a comparison summary of the basic program features of the different alternatives. Comparative Description of SUMC Project Alternatives Floor Area New Floor Demolished Area Net Increase SHC Total LPCH Total Alternative (square feet) (square feet) (square feet) Beds Beds SUMC Project 1,213,759 2,525,277 1,311,518 600 361 No Project Alternatives: A. Retrofitting only' 0 0 0 o or 456 2 o or 257 2 B. Replace SB 1953 665,128 674,115 8,987 287 141 noncompliant structures Reduced Intensity Alternatives: A. Right-size SHC and LPCH 1,200,005 1,645,928 445,923 456 257 B. Right-size SHC and LPCH plus add floor area (in an 1,213,836 2,137,538 923,702 542 319 amount less than the SUMC Project) Preservation Alternatives: Tree Preservation Alternative 1,213,759 2,525,277 1,311,518 600 361 Historic Preservation 357,581 1,681,300 1,323,719 600 361 Alternative Village Concept Alternative: Village Concept Alternative 1,213,759 2,525,277 1,311,518 600 361 No Project Alternative A: Retrofitting Only/No New Structures Under No Project Alternative A, only those hospital facilities that could be modified to meet the Senate Bill (SB) 19532013 and 2030 deadlines would be retrofitted. No new buildings would be constructed. In the long-term, portions of the hospital facilities would not meet SB 1953 requirements for the 2030 deadline, and one or both of the hospitals would be closed. This alternative would require SHC and LPCH hospitals to continue to operate beyond the 2013 deadline with reduced patient capacity. By 2013, SHC would have to move hospital functions out of the portion of the original 1959 Hospital Building complex that could not be retrofitted to SB 1953 standards and into compliant existing facilities. The L:PCH and the SoM would continue to use existing buildings for medical treatment, research, and teaching purposes, subj ect to seismic retrofit work. Under this alternative, there would he no new construction at the Hoover Pavilion Site and the interior of the existing Hoover Pavilion building would not need to be renovated to relocate the users of 11 01 Welch Road. The demolition of existing sheds at that site would not occur and no rezoning, lOne or both hospitals would likely close in 2030 under this alternative. 2 Depending on which hospital closes City of Palo Alto Page 3 annexation, or changes to existing land use designations would be required. In addition, this alternative would include no function upgrades to meet current standards and technological requirements. This alternative would not achieve the basic SUMC Project or City objectives. This alternative eliminates eight (8) significant and unavoidable impacts. No Project Alternative B: Replace SB 1953 Noncompliant Structures at Maximum Allowable FAR Under No Project Alternative B, hospital facilities that are not compliant with Office of Statewide Health Planning and Development (OSHPD) structural standards would be replaced with new structures. New structures would be built out to the maximum size allowed under PF zoning. Under PF zoning for the Main SUMC Site, the maximum allowable floor to area ratio (FAR) is 1.0, allowing for an additional 9,000 -square-foot expansion ofhospital facilities. No additional buildings would be added at Hoover Pavilion. No rezoning, annexation, or changes to existing land use designations would be required to replace the SB 1953 noncompliant buildings with the maximum allowable FAR. LPCH would continue to use its existing facilities, with non-structural renovations made to noncompliant critical care areas. The SoM functions are presently located in other portions of the 1959 Hospital Building complex (Grant, Alway, Lane, and Edwards Buildings) and would continue to occupy those areas under this alternative. This alternative would not meet the majority of the SUMC Project objectives and would not attain the primary City objectives. This alternative eliminates six (6) significant and unavoidable impacts. Reduced Intensity Alternative A: Right Size SHC and LPCH Facilities without Adding Beds Under Reduced Intensity Alternative A, noncompliant facilities would be demolished and replaced with new structures. All other uses on the Main SUMC Sites would remain the same as under current conditions, subject to minor seismic retrofit work. In addition, the Hoover Pavilion would be internally renovated to accommodate additional clinic and office uses; however, no new structures would be constructed at this site. .Construction of new hospital facilities would be limited to the minimum additional square footage required to right-size the existing LPCH and SHC facilities without adding space for additional growth. The net increase in building square footage would be 445,923 square fe,et. A detailed breakdown of the demolition and replacement is included in Table 5- 3 of the Draft EIR. This alternative would expand the hospitals' existing floor area to provide additional space for the hospitals' existing number of beds, associated support areas, and emergency room. This alternative would require rezoning of the Main SUMC Sites to accommodate proposed development intensities because the PF -zoned area is almost entirely built out under existing co'nditions. This alternative also would necessitate annexation of the 0.75-acre portion of the Main SUMC Site and would involve construction above the 50-foot height limit, requiring Comprehensive Plan amendments arid zoning changes. This alternative would meet some, but not all, of the SUMC Project and City objectives. This alternative eliminates six (6) significant and unavoidable impacts. City of Palo Alto Page 4 Reduced Intensity Alternative B: Right-Size SHC and LPCH Facilities Plus Add Floor Area in an Amount Less Than the SUMC Project Reduced Intensity Altenlative B would include all of the components of Reduced Intensity Alternativ.e A, but would also include additional square footage for clinics/medical offices, research facilities, and other non-hospital uses. The net increase in building square footage would be 923,702 square feet. This would result in approximately 60 percent of the SUMC Projects' additional beds. A detailed breakdown of the demolition and replacement is included in Table 5-4 of the Draft EIR. Hoover Pavilion would be renovated for the users of 1101 Welch Road, but no new medical office building would be added at the Hoover Pavilion Site. This alternative would require construction above the 50-foot height limit; therefore, like Reduced Intensity Alternative A, Comprehensive Plan amendments, zoning changes, and annexation would be necessary under this alternative. This alternative would meet some short-term objectives, but overall would not meet all of the objectives of the SUMC Project. This alternative would not attain the basic City objectives. This alternative eliminates four (4) significant and unavoidable impacts. Tree Preservation Alternative The Tree Preservation Alternative comes from collaborative discussions between the applicant and the City. It was designed to reduce the SUMC Project's impact on Protected Trees. The Tree Preservation Alternative would seek to preserve the nlajority of the aesthetically and biologically significant Protected Trees at Kaplan Lawn, the FIM 1 Grove, and along Welch Road. Under this alternative, there would be no development on the Kaplan Lawn, and no Protected Trees would be removed at that location. In addition, the FIM 1 building would be redesigned to save as many Protected Trees as possible in this area. Lastly, two Protected oak trees along Welch Road would be retained. The site plan for this alternative would avoid 13 biologically and aesthetically significant Protected Trees that would be affected by the SUMC Project. Further, this alternative would seek to relocate three more Protected Trees that would otherwise be affected under the SUMC Project. Figure 5-1 of the Draft EIR shows the revised site plan, the Protected Trees that would be preserved and the potential zones for planting of relocated trees. The Tree Preservation Alternative maintains the same square footage and programmatic functions as the SUMC Project, but proposes design modifications to the new hospital building as well as FIM 1 to accomplish tree preservation. The Project sponsor is promoting the Tree Preservation Alternative and has indicated to City staff that it now prefers this alternative over its original proposal. As such, his Alternative is currently being reviewed by the City's Architectural Review Board and was presented to the P&TC on June 9 and the City Council on June 14, 2010. The Tree Preservation would be similar to the SUMC Project, with the following exceptions: • There would be no hospital module constructed in Kaplan Lawn. The program would be absorbed into the remaining portion of the SHC Hospital building footprint off Welch Road and Pasteur Drive. Although the resulting SHC Hospital building square footage would be the same as under the SUMC Project, the design would change in the following ways: o The first four floors (below~grade and Levels 1,2, and 3) of the central portion of the City of Palo Alto Page 5 new SHC Hospital building would contain enclosed program, along with an atrium (rather than courtyard space, as proposed under the SUMCProject), extending from Floor 1 to Floor 3. o The central atrium would include a glass-domed ceiling at Level 3 and the area above the atrium would remain open. o The four SHC Hospital modules surrounding the central atrium would be seven stories tall, using the full amount of the 130-foot height envelope identified for the proposed SUMC Project. o The fifth SHC Hospital module, at the northeast comer of the proposed new SHC Hospital building, would be seven stories tall (130 feet). This height also matches the height identified under the proposed SUMC Project. o Additional "platform" area would be located northeast of the SHC Hospital building, containing additional diagnostic and treatment programs. • All four modules of the Clinics would be 112 feet tall (as compared to the SUMC Project, which would have one module at 112 feet and three modules at 64 feet). • The ambulance route to and from the emergency department would be reconfigured to avoid the century-old solitary oak at the edge of the Main SUMC Site, adjacent to Welch Road. In addition, the fifth SHC Hospital module would be farther from the century-old oak tree than under the SUMC Project. • The parking structure at the Welch RoadlPasteur Drive intersection would be constructed as a 40-foot tall structure with three levels underground and four levels aboveground. On top of the garage would be a Wellness Center accessible to the pUblic. • The Emergency Department entrance/parking would be moved to the Pasteur Drive side of the new SHC Hospital building. • The SHC patient and visitor drop-off loop would be located farther down Pasteur Drive, more centrally located adjacent to the future clinics expansion and the existing D, E, and F pods. • In order to activate the pedestrian experience at the entry level to the new SHC Hospital building, the building perimeter would be planned to accommodate the public functions of the hospital building program: the cafe, gift shop, outdoor seating, and a small retail component. • Portions of the Main SUMC Site are susceptible to liquefaction; therefore, under this alternative, the SHC Hospital foundation would be supported by piles in order to meet OSHPD's heightened standards for hospital buildings. • The FIM 1 building footprint would be altered to save Protected Trees at the northeast comer of the building. • The Protected oak tree that is east of the proposed LPCH hospital building, adjacent to Welch Road, would relocate this tree to another location. • A new road would be created running east-west directly down the middle of Kaplan Lawn, City of Palo Alto Page 6 replacing the function of two roads that exist today between the two barrels of Pasteur Drive (Blake-Wilbur Drive and the SUMC Promenade). This design would also allow the creation of a new arrival plaza at the pedestrian exits from Parking Structure 4, permitting a safer pedestrian entry sequence to the SHC Hospital building. In addition, it would remove a large percentage ofvehicle/pedestrianlbicycle interactions along the SUMC Promenade, creating better pedestrian opportunities between the hospitals and the SoM. Kaplan Lawn would be further enhanced with additional landscaping, including the placement of two relocated trees from the FIM 1 Site. As proposed under the SUMC Project, the Tree Preservation Alternative would require the demolition of the 1959 Hospital Building complex. In its place, the Tree Preservation Alternative would construct the replacement SHC clinic/medical office building and SoM FIM Buildings 2 and 3 in the same locations as under the SUMC Project. The site plans at the LPCH and the Hoover Pavilion would be the same as under the SUMC Project. The Tree Preservation Alternative would necessitate the same Comprehensive Plan amendments, zoning changes, and annexation as the proposed SUMC Project. This alternative would attain all of the SUMC Project objectives and the majority of the City'S . objectives. This alternative eliminates one (1) significant and unavoidable impact in the area of construction air pollution emissions and would reduce, though not eliminate, the biological effect on protected trees. Historic Preservation Alternative The Historic Preservation Alternative would preserve all of the essential historic aspects needed to maintain the eligibility of the 1959 Hospital Building complex for listing on the California Register of Historic ResoUrces (CRHR). The alternative would retain the 1959 Hospital Building conlplex, which includes SoM buildings (Grant, Alway, Lane, and Edwards), along with the following SHC Hospital/clinic buildings: West Pavilion ("West"), East Pavilion ("East"), Boswell, and Core. This alternative would preserve the historic integrity of Pasteur Drive and its landscaping, which serve as the main approach to the 1959 Hospital Building complex. The Historic Preservation Alternative would not construct a new SHC clinic/medical office building in place of the 1959 Hospital Building Complex. However, the existing buildings at the 1959 Hospital Building complex have a low seismic rating and do not comply with structural and non­ structural criteria that must be met by the 2013 and 2030 deadlines imposed by SB 1953 for retrofit or replacement of hospital facilities. Accordingly, under the Historic Preservation Alternative, these buildings would not be used as hospital buildings, as defined by OSHPD. This alternative would necessitate the same Comprehensive Plan amendments and zoning changes as the SUMC Project, including an amendment to allow for the exceedance over the 50-foot height limit. Annexation would not be needed for this alternative. This alternative would not adequately meet the SUMC Project objectives but would meet the majority of the City's objectives. This alternative eliminates three (3) significant and unavoidable impacts. City of Palo Alto Page 7 Village Concept Alternative The City has developed the Village Concept Alternative for the purposes of reducing the vehicle miles traveled, traffic congestion, and vehicular air and noise emissions that are associated with the SUMC Project. The Village Concept Alternative would accomplish this purpose primarily by recommending dedication of nearby housing for Sl1MC Project employees, and enhancing pedestrian connectivity in the Village Concept Study Area (see Figure 5-2, Attachment C). The Village Concept Alternative would provide opportunities to enhance the SUMC Project by creating a more walkable, bikeable, mixed-use, transit-oriented, and well-connected urban environment. The Village Concept Alternative considers comprehensively and long-term the SUMC Project and the SUMC Project's relationship to its surrounding context. This alternative includes 490 previously approved but not yet constructed housing units along Quarry Road and Pasteur Drive, on Stanford lands, be below market rate units that would be dedicated for occupancy by SUMC Project employees, and a recommendation by the City that the housing be constructed within a specified timeline. It is important to note that the Village Concept Alternative does not propose to construct the 490 housing units as those units have been separately proposed and considered for construction under the Stanford Community Plan/General Use Permit and Sand Hill Road Corridor Projects; and pedestrian linkages between the SUMC Project, the Stanford Shopping Center, Stanford University, the Palo Alto Intermodal Transit Station (p AITS), and Downtown, with corresponding urban design recommendations. The pedestrian linkages were prepared by the City's Urban Desigh Consultant and are included as Figures 5-2 through 5-5 (Attachment C). These enhancenlents under the Village Concept Alternative can be implemented through one or more of the following mechanisms: zoning amendments associated with the SlTMC Project, conditions of approval, or through the Development Agreement conditions. The recommendations in this alternative can be combined with the Project as proposed and any of the other Alternatives. This alternative would attain all of the SUMC Project objectives and all of the City's objectives. This alternative eliminates one (1) significant and unavoidable impact. 2. Mitigation Measures In each staff report to review the Draft EIR, the mitigation measures identified in the Draft EIR proposed to mitigate each environmental impact have been identified. Table S-4 (Attachment D) provides a summary of all of the impacts and mitigation measures. Throughout the discussion on the individual chapters, the City Council, P&TC and members of the public have commented on the adequacy of the mitigation measures and in some instances, suggested others. Those comments have been collected and will be addressed in the Final EIR. This hearing will give the Council and the P &TC an opportunity to examine the mitigation measures in more detail while also examining them in the context with other measures. The CEQA Guidelines provide five broadcategories of mitigation nleasures: avoid, minimize, rectify, reduce, eliminate or conlpensate the identified significant impacts. To be considered adequate, mitigation measures should be specific, feasible actions that will actually improve adverse environmental conditions. Mitigation measures should be measurable to everyone monitoring their City of Palo Alto Page 8 implementation. Mitigation measures consisting only of further studies or consultation with regulatory agencies that are not tied to a specific action plan may not be adequate and should be avoided. Mitgation measures must be fully enforceable though conditions of approval or a development agreement When drafting mitigation measures, agencies should include only those that are feasible. A nlitigation measure is considered feasible if it is capable of being accomplished in a successful manner within a reasonable period of time, taking into consideration economic, environmental, legal, social and technological factors.An appropriate mitigation measure involves clearly explaining its objectives, specifically how it will be implemented, who is responsible for its implementation, where it will occur and when it will occur. If a project is approved, the City must adopt a Mitigation Monitoring and Reporting plan to ensure compliance with all mitigation measures and track their effectiveness. Traffic Mitigation There has been discussion about whether Transportation Demand Management (TDM) measures can be imposed as proj ect mitigation or whether they instead should be characterized as community benefits and imposed through the proposed development agreement. TDM encompasses a broad menu of strategies and policies to reduce travel demand (particularly single-occupancy private vehicles) ranging fronl simple programs such as the provision of bike racks and electric car chargers to more robust programs of Go Passes and shuttles. The attached memo from the City's outside legal counsel concludes that the City can lawfully impose TDM measures as mitigation (Attachment E). It should be noted that on other projects Palo Alto has imposed TDM as mitigation. For example, Palo Alto imposed TDM in both the Cancer Research project, in the Mayfield Soccer complex, and at the Taube-Koret Campus for Jewish Life project. In addition, other communities use TDM as an effective way to mitigate traffic impacts. For example, a very comprehensive TDM program, including Go Passes, is currently being proposed for the Bohannon Gateway proj ect in Menlo Park. NEXT STEPS The Alternatives and mitigation measures are the final topics for the P&TC and Council to consider. The public review period will close on July 27, 2010. Subsequent to public testimony and P&TC and Council comments, along with the written comments submitted on the Draft EIR during the 69-daypublic review period, the EIR consultant and staffwill prepare a Final EIRJResponse to Comments. The timing of this document is dependent on the number of comments received. However, the goal is to complete review of this Project and the EIR by the end of 201 O. Following preparation of the Final EIRJResponse to Comments document, the P &TC will conduct a public hearing(s) on the Final EIR and provide a recommendation to the City Council. The City Council will then review the Final EIRJResponse to Comments for action. City of Palo Alto Page 9 PREP ARED BY: STEVEN TURNER Advance Planning Manager DEPARTMENT HEAD: CURTIS WILLIAMS Director of PlalUling and Community Environment CITY MANAGER APPROVAL: ( .. NE ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: City of Palo Alto Project Sponsor and City Objectives (excerpt from Draft EIR Chapter 2: Project Description) Table 5-:8, Assessment of SUMC Proj ect Alternatives Figures 5-2 through 5-5, Village Concept Table S-4, SUMC Project Summary of Impacts ,and Mitigation Measures Employee Trip Reduction Programs Memorandum, July 2, 2010 from Rick Jarivis, Jarvis, Fay, Doporto & Gibson to Cara Silver, Senior Assistant City Attorney Page 10 ATTACHMENT A 2.3 PROJECT OBJECTIVES SUMC Project Sponsors Objectives The SUMC Project sponsors have identified various objectives for the SUMC Project. The objectives are listed below. These objectives are divided into three categories: Program, Siting, Circulation, and Cost. The Program objectives are further sub-divided by entity (SHC and LPCH, and SoM). Program Objectives SHe and LPCH. The Program objectives of SHC and LPCH are listed below. 3 4 2-4 • Optimize delivery of healthcare and services to patients. • Maintain each hospital's position as a leading provider of complex care. • Achieve timely compliance with the requirements of Senate Bill 19533 and other applicable code requirements: Replace the SHC portion of the 1959 Hospital Building complex (the 1959 Hospital Building complex is also referred to as the Stone Building complex), comprising 188 beds, in its entirety; Meet SB 1953's 2013 non-structural criteria for all 66 intensive care beds at SHC, the Emergency Department (ED), and the 21 operating rooms at SHC in the most efficient manner; Complete required non-structural renovations4 to critical areas at LPCH; Provide sufficient space for patients and families during construction of required renovations or replacements; Meet SB 1953's 2030 criteria in the most efficient manner; and Design new facilities to comply with applicable ventilation and structural requirements. • Meet existing and projected future demand for patient care:5 Relieve the existing shortages of beds at SHC and LPCH; Provide additional patient rooms and facilities at SHC to meet the projected needs of an aging population; Provide additional patient rooms and facilities at LPCH to meet projected growing demand for LPCH services; Please see Section 2.5, "Seismic Safety," for a description of SB 1953 and its requirements. Non-structural renovations consist of securing interior fixtures, ceilings, sprinkler systems, bracing, and duct work in the event of an earthquake. Such renovations are required for all critical care areas by 2013. A description of the existing demand for healthcare and the current deficit of available space to accommodate those demands is presented in Section 2.5, under the "Spatial Constraints" heading. Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Project Description Size the ED to provide adequate patient waiting and triage space, and trauma rooms consistent with contemporary facility standards; Meet existing and projected demand for clinic and other outpatient services that are important to the core academic and translational discovery process,6 or that otherwise should remain co-located with inpatient services; and Provide sufficient space to replace medical offices removed due to demolition, and to accommodate increased space for both medical offices and support services due to existing and projected future growth in need for patient services. • Provide modern, state-of-the-art facilities, designed to deliver high quality healthcare services and related teaching and research: Size facilities to accommodate advanced medical services, state-of-the-art imaging, modern diagnostic and other medical equipment, and to provide sufficient space for high quality patient care and associated support services; Design facilities to enhance the comfort and healing of patients and the productive care­ giving and general welfare of staff and visitors; Meet current hospital planning guidelines by providing space to accommodate patients in single-bed rooms as appropriate, including adequate space for treatment by healthcare providers, equipment and support by family members; Minimize the distance of travel from procedure room to patient room; Provide a safe, secure, and efficient route from operating rooms or the Emergency Department (ED) to patient rooms; and Minimize patients' risk of infection. • Meet regional needs for emergency and disaster preparedness: Design facilities to take into account needs identified in the region's Disaster Preparedness Program, such as the ability to quickly add or convert beds and procedure rooms to manage critically injured patients for mass population events such as earthquakes, pandemics (influenza), or man-made biological/chemical exposure (bioterrorism, etc); and Design facilities to maintain and further SUMC's role as a Levell Trauma Center for daily and extreme-disaster healthcare delivery. Translational Resources: To improve human health, scientific discoveries must be translated into practical applications. Such discoveries typically begin at "the bench" with basic research -in which scientists study disease at a molecular or cellular level -then progress to the clinical level, or the patient's "bedside." Scientists are increasingly aware that this bench-to-bedside approach to translational research is really a two­ way street. Basic scientists provide clinicians with new tools for use in patients and for assessment of their impact, and clinical researchers make novel observations about the nature and progression of disease that often stimulate basic investigations. Source: SoM, April 2008. Stanford University Medical Center Facilities. Renewal and Replacement Draft EIR -Project Description 2-5 • Maintain relationships with community physicians: Identify replacement space for community physicians who must relocate their medical offices to accommodate demolition of facilities due to the SUMC Project. • Provide responsible and sustainable design for the hospitals' operational systems, water systems, and use of physical materials, while meeting applicable requirements and hospital planning principles, including those applicable to infection control and patient safety. • Allow sufficient design and entitlement flexibility to be able to adapt to changes in healthcare needs, changes in technology, and changes in delivery practices. SoM Objectives. The Program objectives of the SoM are listed below. • Optimize the SoM's ability to translate medical research discoveries into treatments and cures. • Replace outmoded research buildings with state-of-the-art research facilities to support contemporary translational research: Design facilities to comply with code requirements for strong and reliable fire separations; Design research facilities to efficiently meet current building requirements, including those pertaining to: seismic safety; heating, ventilation, and air conditioning; mechanical, electrical, and plumbing (MEP) systems; and provision of emergency power; Design circulation and access to laboratories and offices to enhance handicapped accessibility, and to allow for safe and efficient access to a diverse array of laboratory and support functions; and Employ best available design techniques to provide for efficient, high quality facilities. • Provide sufficient faculty offices, research laboratories, and administrative support space to meet the SoM's projected needs. • Provide responsible and sustainable design for the SoM's operational systems, water systems, and use of physical materials, consistent with Stanford University'S existing sustainability practices. • Allow sufficient design and entitlement flexibility to be able to adapt to changes in medical research needs and changes in technology. Siting Objectives 2-6 • Site facilities to maximize highest and best use of SUMC and Stanford University lands. • Site SHC and LPCH facilities to efficiently use a single, shared ED. • Locate patient beds, ED, and SoM facilities in close proximity to each other to maintain and enhance program synergies and connections. • Locate outpatient healthcare facilities that are important to the core academic and translational discovery process in close proximity to inpatient facilities. Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Project Description • Site parking facilities for patients and visitors to provide clear, safe, and convenient access to SUMC facilities, with sensitivity to the needs of elderly, limited mobility, and ill patients. • Site parking facilities for staff with consideration of safe paths of travel after dark. • Locate new clinical, medical office, and support facilities for hospital staff and community physicians within reasonably close proximity to SHC and LPCH facilities. • Optimize department adjacencies that ensure the healthcare facilities are clinically safe environments, promote safe and efficient patient flow, and provide access to state-of-the-art technology. • Use the existing SUMC Sites in Palo Alto for all components of the SUMC Project. • Arrange the buildings, open space areas, and infrastructure within the SUMC Project boundaries to create a highly functional medical center environment. Circulation and Parking Objectives • Provide clear, safe, and convenient access to SUMC facilities for patients and visitors. • Provide efficient access to SUMC for healthcare providers and staff. • Provide sufficient convenient parking for patients, visitors, healthcare providers and staff, with sensitivity to the needs of elderly, limited mobility, and ill patients. • Enhance the pedestrian and bicycle connections within and between the SUMC, the Stanford Shopping Center, PAITS, and nearby open space areas. • Provide improved way finding to minimize unnecessary circulation. Cost' Objective • Select methods of construction to minimize the initial cost to the greatest extent feasible while producing facilities that are cost effective to operate over the long term. City Objectives In addition to the SUMC Project sponsor's objectives, the City has identified the following objectives for the SUMC Project: • Provide high quality employment districts, each with its own distinctive character and each contributing to the character of the City as a whole. • Employ state-of-the-art urban design principles and ensure adequate design review of the SUMC Project. • Create a more walkable, bikeable, mixed-use, transit-oriented, and well-connected urban environment that captures the potential travel behavior, air quality, and greenhouse gas reduction benefits associated with the performance of well-designed urban villages. Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Project Description 2-7 • Create walkable and bikeable connections that link together Stanford University Medical Center, Stanford University, PAITS, downtown, Stanford Shopping Center, and surrounding residential neighborhoods. • Promote sustainable development and green building design principles through thoughtful urban planning and site design, building design and construction,' energy production and conservation, and utility and transportation infrastructure design and construction, in a manner that improves the City's economic health, and improves the quality of life in the City. • Promote development that contributes to the design and implementation of comprehensive solutions to traffic problems near Stanford Medical Center and key connections. • Encourage employment districts to develop in a way that encourages transit, pedestrian and bicycle travel and reduces the number of auto trips for daily errands. • In conjunction with new development proposals, create new park, open space, recreation, plaza, or other public gathering spaces. • Provide for long-term utility and public infrastructure demands generated by the SUMC Project. • Address project-induced school impacts not mitigated by school impact fees. • Minimize environmental, financial, and municipal infrastructure impacts of the SUMC Project on the City. • Assist Stanford University Medical Center in responding to changes in the delivery of healthcare services. Work with the SUMC to plan for changing facility needs, but within the context of City of Palo Alto planning goals and policies, as well as the goals and policies of other relevant jurisdictions. • Support Stanford University's historic campus identity as "a place apart" with a "sense of higher purpose" as well as Stanford's commitment to innovative, high quality of design through their "interpretive approach to contextual design" in the architecture of campus buildings and the landscape. • Identify and implement strategies for accomplishing housing with a focus on below-market-rate residential units that would be available to help accommodate employment generated by the SUMC Project. • Locate work force housing close to SUMC Sites and train station in order to reduce traffic trips of both employees and employee household members. • Encourage public and private upkeep and preservation of resources that have historic merit. • Optimize delivery of healthcare and services to patients and meet regional needs for emergency and disaster preparedness. 2-8 Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Project Description Table 5-8 Assessment of SUMC Project Alternatives (Compared to the SUMC Project) Reduced Reduced No Project Intensity Intensity Tree Historic Alternative Alternative Alternative B A B Conflicts with Applicable Land Use Designations and Zoning Contlicts with Comprehensive Plan Policies SISU SISU SISU SILTS SILTS SILTS SILTS Compatibility with Adjacent Land Use Character and NI NI NI NI NI NI NI Conflicts with Established Residential, Recreational, Educational, Religious, or Scientific Uses in the Area Division of an Established Community and Farmland I NI NI NI NI NI NI NI NI Conversion Adverse Changes to Existing or Planned Land Use Pattern SILTS NI NI SILTS SILTS SILTS SILTS SILTS Cumulative Impacts LTS NI NI LTS LTS LTS LTS LTS Permanent Degradation of Visual Character Post SILTS LTS LTS SILTS SILTS SILTS SILTS SILTS Construction Alteration of Public Viewsheds, View Corridors, or SILTS NI LTS SILTS SILTS SILTS SILTS SILTS Scenic Roads Terrain Modification NI NI NI NI NI NI NI NI New Source of Light and Glare SILTS NI SILTS SILTS SILTS SILTS SILTS SILTS >- Shadowing of Public Open Spaces LTS NI LTS LTS LTS LTS LTS LTS -I > Cumulative Impacts LTS NI LTS LTS LTS LTS LTS LTS n J: ~ rTI Z -I NI = No Impact LTS = Less-than-Significant S=Signijicant SU= Significant Unavoidable eel University Medical Center Facilities Renewal and Replacement Draft EIR -Alternatives 5-51 Table 5-8 Assessment of SUMC Project Alternatives (Comp,ared to the SUMC Intersection LOS Impacts on Roadway Segments Local Circulation Impacts Freeway Impacts Bicycle and Pedestrian Impacts Transit Impacts Parking Impacts Emergency Impacts Cumulative Impacts Operational Criteria Air Pollution Emissions Construction and Operational TACs Cumulative Impacts Result in Significant Emissions of Greenhouse Gases NI = No Impact 5-52 SUMC S/SU S/SU SILTS LTS SILTS SILTS LTS SILTS SILTS S/SU LTS S/SU No Project Alternative A NI NI NI NI NI NI NI NI LTS NI LTS S/SU LTS = Less-than-Significant No Project Alternative B NI NI NI NI NI NI NI NI SILTS NI LTS S/SU Reduced Intensity Alternative A NI NI NI NI NI NI NI NI SILTS LTS LTS S/SU S = Significant Tree Historic S/SU S/SU S/SU S/SU SILTS S/SU S/SU S/SU SILTS SILTS SILTS SILTS LTS LTS LTS LTS SILTS SILTS SILTS SILTS SILTS SILTS SILTS SILTS SILTS LTS LTS LTS SILTS SILTS SILTS SILTS SILTS SILTS SILTS SILTS S/SU S/SU S/SU S/SU LTS LTS LTS LTS S/SU S/SU S/SU S/SU S/SU S/SU SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Alternatives Table 5-8 Assessment of SUMC Project Alternatives (Compared to the SUMC Project) Impact Impacts on the Stone Building Complex Impacts on the Hoover Pavilion bnpacts on Archaeological Resources and Human Remains Impacts on Paleontological Resources Cumulative Impacts iRi• Special Status Plant or Wildlife Resources Loss of Riparian or Other Sensitive Habitats Interference with Species Movement, Wildlife Corridors, or Nursery Sites Effect on Protected Trees Conflicts with a Habitat Conservation Plan or Natural Community Conservation Plan Exposure to Other Geotechnical Hazards SUMC Project' SISU SILTS SILTS SILTS SISU SILTS LTS SILTS SISU NI No Project Alternative A SISU NI SILTS SILTS SISU SILTS NI SILTS SISU NI NI = No Impact LTS = Less-than-Significant No Project Alternative B SISU NI SILTS SILTS SISU SILTS LTS SILTS SISU NI Reduced Intensity Alternative A SISU LTS SILTS SILTS SISU SILTS LTS SILTS SISU NI S=Signijicant Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Alternatives Reduced Intensity Alternative ·B SISU SILTS SILTS SILTS SISU SILTS LTS SILTS SISU NI Tree Preservation Alternative SISU SILTS SILTS SILTS SISU SILTS LTS SILTS SISU NI Historic Preservation Alternative SILTS SILTS SILTS SILTS SILTS SILTS LTS SILTS SISU NI LTS SU = Significant Unavoidable Village Concept Alternative SISU SILTS SILTS SILTS SISU SILTS LTS SILTS SISU NI LTS 5-53 Table 5-8 Assessment of SUMC Project Alternatives (Compared to the SUMC Reduced No Project No Project Intensity Intensitv Tree Historic SUMC I Alternative Alternative Alternative A B A -.... --~----.. -------~-.. -------~----------.----.------ -----" , ---~ --'" . -~. -----....------_ ... _-~.----._--_-._ ... _. -• 4 -_ • -..", _____ Population Increases LTS NI NI NI LTS LTS LTS LTS Displacement of Housing NI NI NI NI NI NI NI NI Jobs to Employed Residents Ratio N/A N/A N/A N/A N/A N/A N/A N/A Cumulative Impacts SISU NI NI NI LTS LTS LTS LTS --,---------------------------~ .... ---------_ _::;_--------~~-:_----7~r---: ---~:::--~-,..---.--.. ~: ----. ----.-~-.---. --- ~. ----------------------.-. -..... -------.----_______ • ___ ~~--..o..-_ __ - . ____ ---_0. _----.... ____ . _", _______________ ~--... -------- Impacts on Police Services LTS NI NI LTS LTS LTS LTS LTS Impacts on Fire Services LTS NI NI LTS LTS LTS LTS LTS Impacts on Schools LTS NI NI LTS LTS LTS LTS LTS Impacts on Parks and Recreation LTS NI NI LTS LTS LTS LTS LTS Cumulative Impacts LTS NI NI LTS LTS LTS LTS LTS -... .-~~~-:.~".-----. -~---.-----.-._-----.----------;-----~-;----.. --.--~----.--:----~.--:~-:--:-;----.~-~-.-.-~----. --~' .... ----------~ ---- -, ''-• ,'" -. •• .'. '" -. --< -.--• • --_~~" __ "'-"4':--...-..-.-. __ -..' ____ -_______ ~_L-. ______ ~ __ ~ _ ___'~-' ________ " _~ ________ .... _~ ____ .... ~_......:....... ____ ~_~_ --.- Water Demand LTS NI NI LTS LTS LTS LTS LTS Wastewater Generation LTS NI NI LTS LTS LTS LTS LTS Stormwater Generation LTS NI SILTS SILTS SILTS SILTS SILTS SILTS Solid Waste Generation LTS NI NI LTS LTS LTS LTS LTS Energy Demand LTS NI LTS LTS LTS LTS LTS LTS Cumulative Impacts LTS NI LTS LTS LTS LTS LTS LTS Source: PBS&J, 2010. Notes: a. Before mitigation/After mitigation (e.g. SILTS) NI = No Impact LTS = Less-than-Significant S = Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Alternatives 5-55 --'. Village Concept Study Area Stanford University Medical Center Projects FIGURE 5-2 Village Concept -Study Area 1110(\" Source: Fukuji Planning & Design. October 2009. ----------------------------------------------------------~----------------~----.---,--------041357.00 Stanford University Medical Center Facilities Renewal and Replacement Project ~ -t » o ::J: ~ m z -t o 1. Transit-Oriented Development 2. Stanford Barn Area 3. Housing Sites FIGURE 5-3 Village Concept -Land Use PRSJ® ----------_______ ........ _ ........ _ ........ ___ • ___ ~ ___ ~~~~"~'»~_M~·. ~.'"'"."."<.,,,., .. ,.,',",,".,','," D41357.00 Stanford University Medical Center Facilities Renewal and ) 1. EL Camino Real Grand Boulevard bike lanes and intersection improvements at Quarry Road 2. Quarry Road as urban, tree-lined arterial street 3. Quarry Road housing designed as walkable, residential neighborhoods with urban street and block pattern; residential entries with direct pedestrian access to face Quarry Road 4. Maintain Arboretum's rural character with landscape setbacks and design features along EI Camino Real, Palo Road and Arboretum Road; residential entrances with pedestrian access facing the Arbore­ tum 5. Stanford Barn area connec­ tion as potential pedestrian­ oriented shopping street 6. Welch Road as walkable, bikable tree-lined street with landscape setback for medical campus uses to the south 7. Durand Way and Pasteur Drive as landscaped campus entrances FIGURE 5-5 liUlilH RURAl CA.M~US STREtT lun Pf)Of$TRIAN SHOl'l'jN(;' STREJil __ •• I'n~~S'fIlIAN WAYS _ CNl'J'U$iO~N .$'ACe I'USI.iC S'tREU • •• CiW.JU$ mv.ATIi ~rREn Village Concept -Urban Design PBSI® ___________________ ~~""""'.._ ______ ''''"'''''''_~~,_""""''O·'''''~,~,,~*o,.·,.",,,,,,"'m»<","O 041357.00 Stanford University Medical Center Facilities Renewal and Re Table 8-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts LU-I. Conflicts with Adopted Land Use Plans and Policies. Without mitigation measures to ensure consistency with the Comprehensive Plan's policies adopted for the purpose of avoiding or mitigating an environmental effect, the SUMC Project could conflict with Comprehensive Plan policies that avoid or reduce impacts related to visual quality, cultural resources, pedestrian circulation, urban forest resources, groundwater and runoff pollution, air quality degradation, and noise incompatibility. Impact Significance Without Mitigation S LU-2. Conflicts with Established Residential, Recreational, NI Educational, Religious, or Scientific Uses in the Area. The SUMC Project would not conflict with residential, recreational, educational, religious or scientific uses. LU-3. Physical Division of an Established Community. The NI SUMC Project would not physically divide an established community. NI = No Impact LTS = Less-thall-Significant Mitigation Measures MITIGATION MEASURES. The mitigation measures identified below would ensure that the SUMC Project would have no conflicts with Comprehensive Plan policies adopted for the purposes of avoiding or mitigating environmental impacts. These measures include Mitigation Measure VQ-2.l, which requires compliance with the City's Architectural Review process and recommendations; CR-I.2 through 1.4, which involves measures to minimize the loss of the historic Edward Durell Stone Building complex; CR-l.l and CR-1.5, which involve measures to minimize vibration impacts on the Hoover Pavilion; TR-6.l, wl~ich requires improvements for bicycle and pedestrian safety and access at" intersections affected by SUMC Project traffic; BR-4.l through BR-4.5, which require the preparation of a Tree Preservation RepOlt, a solar access study, a Tree Relocation Feasibility Plan, a Tree Preservation Bond/Security Guarantee, and minor site modifications to the current site plans; HW -3.1, which requires a work plan to protect groundwater from contamination; AQ-I.I through AQ-I.2, which would control construction dust and reduce diesel emissions; NO-4.l, which requires noise shielding or enclosure of equipment; and NO-l.l, which controls construction noise None required. None required. S=Significant SU=Signijicallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation LTS N/A N/A S-25 l> -I -I l> (") :::I: 3: m z -I C Table S-4 SUMC Project Summary of Impacts and Mitigation l\rleasures Impacts LU-4. Farmland Conversion. The SUMC Project would have no impact on conversion of farmland to non-agricultural uses. LU-5. Adverse Changes to Overall Existing or Planned Land Uses in the Area. Because the SUMC Project would intensify the planned uses within the SUMC Sites, the SUMC Project would have a significant impact pertaining to on-site character and views. LU-6. Cumulative Impacts on Changes to Overall Existing or Planned Land Uses in the Area. The SUMC Project, in combination with other reasonably foreseeable probable future development in the area. would have a less-than-significant cumulative impact on overall existing or planned land uses in the vicinity of the SUMC Sites. VQ-l. Temporary Degrad;ltion of Visual Character During Construction. The SUMC Project would substantially degrade the existing visual character and quality of the SUMC Sites during construction. (S) Impact Significance Without Mitigation NI S LTS S NI = No Impact LTS = Less-than-Significant S-26 Mitigation Measures N one required. MITIGATION MEASURE. Mitigation Measure VQ-2.1, requires and ensures compliance with Architectural Review Board (ARB) recommendations for final design and would reduce impacts from increased intensity under the SUMC Project. Based on the SUMC Project design guidelines, the Architectural Review would consider, among other factors, whether the SUMC Project has a coherent composition and whether its bulk and mass are hannonious with surrounding development. Thus, implementation of Mitigation Measure VQ-2.1 would reduce the significant impacts on overall surroundings to a less-than-significant level. N one required. MITIGATION MEASURE. Mitigation Measure VQ-l.l. below, would reduce visual impacts during construction to less than significant. (L TS) VQ-I.I Implement Construction Visual Improvements Plan. The SUMC Project sponsors shall develop and implement a Construction Visual Improvements Plan that would make visual improvements to construction zones within a given construction phase and between phases if the zone is not scheduled for construction S=Signijicant SU = Significant Unavoidable Impact Significance With Mitigation N/A LTS N/A Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts VQ-2. Permanent Degradation of Visual Character Post Construction. The SUMC Project would have a significant impact pertaining to degradation of the existing visual character or quality of the SUMC Sites and their surroundings. Impact Significance Without Mitigation S NI No Impact LTS Less-than-Significant Mitigation Measures activity or would remain unused for a period greater than six months. Construction zones subject to this mitigation measure shall be defmed by the Planning Director, and shall consider the size of the area, the nature and timing of the construction activity, and the proximity or visibility of the area to public vantage point~ or residential uses. The Construction Visual Improvements Plan shall be implemented by the project contractor( s) and must be approved by the Planning Director. The intent of the plan is to aesthetically improve portions of the project site that would remain unimproved for an extended period and screen the construction zone from view by passersby along the public streets and sidewalks. Possible improvements in the plan include, but are not limited tO,the following: a. The SUMC ProjeCt sponsors shall conceal staging areas with fencing material to be approved by the Planning Director prior to commencement of use of the staging area for construction equipment and vehicles. b. The SUMC Project sponsors shall frequently remove construction debris and refuse from the SUMC Sites. c. The SUMC Project sponsors shall install all landscaping as early as feasible to decrease visual impacts of construction. Existing landscaping within the SUMe Sites that would not· be removed by the construction shall be maintained. MITIGATION MEASURE. Mitigation Measure VQ-2.1, below, requires and ensures compliance with ARB recommendations for fmal design. Such compliance would ensure that impacts on on-site visual character and quality would be less than significant because the ARB's recommendations, through the Architectural Review process, would address massing, layout, landscaping, and architectural design impacts from the SUMC Project, as described further below. S=Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-27 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts VQ-3. Alteration of Public Viewsheds, View Corridors, or Scenic Resources. TIle SUMC Project would result in significant impacts on views. Impact Significance Without Mitigation s NI = No Impact LTS Less-thall-Significant S-28 Mitigation Measures VQ-2.1 Adhere to City's Architectural Reviel-l' Process and Recommendations. The SUMC Project sponsors shall submit fmal building and site plans to the ARB prior to issuance of any development permits. Architectural Review shall assess the appropriateness of proposed demolitions, proposed building heights and massing, siting of buildings and structures, architecture and fa~ade treatments, landscaping, circulation plans, and parking. The ARB may require alterations to any of the above project features, or the ARB may suggest new features, such as new landscaping or public art, to improve the proposed SUMC Project design. Any recommendations made by the ARB with respect to the design of the SUMC Project shall be implemented by the SUMC Project sponsors. MITIGATION MEASURE. Mitigation Measure VQ;"2.1, above, requires and ensures compliance with ARB recommendations for final design and would reduce impacts on views from the proposed buildings under the SUMC Project. The Architectural Review of the SUMC Project would consider, among other factors, whether the SUMC Project has a coherent composition and that its bulk and mass are harmonious with surrounding development. TIle ARB's recommendations regarding these factors will be forwarded to the City Council for consideration. The City Council would then review the recommendations and make findings, as appropriate, that natural features are appropriately preserved and integrated with the SUMC Project: the design promotes harmonious transitions in scale and character in areas between different designated land uses; and the planning and siting of the various functions and buildings on the site create an internal sense of order and provide a desirable environment for occupants, visitors, and the general community. Implementation of Mitigation Measure VQ-2.1 regarding the Architectural Review process would ensure that impacts on views would be less than significant. S = Significant SU = Significant Unavoidable Impact Significance With Mitigation LTS Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Table S-4 SUMC Project SunlDlary of Impacts and Mitigation Measures Impacts VQ-4. Terrain Modifications. The SUMC Project would not require substantial terrain modifications that would degrade the visual character of the SUMC Sites. VQ-5. New Sources of Light and Glare. The SUMC Project could increase light and glare nuisance from exterior lighting, resulting in a significant impact. VQ-6. Shadowing of Public Open Space. The SUMC Project would not substantially shadow public open space (other than public streets and adjacent sidewalks) between 9:00 a.m. and 3:00 p.m. from September 21 to March 21. VQ-7. Cumulative Impacts on Visual Character. The SUMC Project, in combination with other reasonably foreseeable probable future development in the area, would have a less­ than-significant cumulative impact on visual character in me vicinity of the SUMC Sites. Impact Significance Without Mitigation NI S LTS LTS NI No Impact LTS = Less-than-Significant Mitigation Measures None required. MITIGATION MEASURE. Mitigation Measure VQ-2.1. above, requires compliance with ARB reconunendations for final design and would reduce light and glare· impacts from the proposed buildings under the SUMC Project. The Architectural Review of the SUMC Project would consider, among other factors, whether the SUMC Project incorporates materials, harmonious colors, appropriate ancillary features, a cohesive design with a coherent composition, and an appropriate lighting plan. The ARB's recommendations regarding these factors will be forwarded to the City Council for consideration. The City Council would then review the recommendations and make findings, as appropriate, that the design is compatible with the immediate environment of the SUMC Sites; is appropriate to the function of the SUMC Project; promotes harmonious transitions in character in areas between different designated land uses; and is compatible with approved improvements both on and off the site. This Architectural Review process would ensure that exterior treatment. would not emit substantial glare and that exterior lighting impacts would be less than significant. None required. N one required. S=Signijicant SU = Sign{/icallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation N/A LTS N/A N/A S-29 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts VQ-8. Cumulative Impacts on Sensitive Views. The SUMC Project, in combination with other reasonably foreseeable future development in the area, would have less-than­ significant cumulative impacts on sensitive views. VQ-9. Cumulative Light and Glare. The SUMC Project, in combination with other reasonably foreseeable probable future development in the area, would be subject to Architectural Review and Municipal Code, and County requirements pertaining to light and glare. Impacts would therefore be less than significant. VQ-IO. Cumulative Shadows. Shadows from the SUMC Project are not expected to combine with shadows from other nearby .reasonably foreseeable probable future development. There would be no cumulative impacts. TR-l. Construction Impacts. Construction activity associated with the SUMC Project could result in significant traffic impacts. Impact Significance Without Mitigation .LTS LTS NI S NI = No Impact LTS = Less-thall-Significant 5-30 Mitigation Measures N one required. None required. None required. MITIGATION MEASURES. With implementation of the following mitigation measures,the significant construction related traffic impacts would be reduced to less-than-significant levels. TR-l.l Provide Off-Street Parking for Construction Related Vehicles. The SUMC Project sponsors shall be required to provide adequate off-street parking for all construction-related vehicles throughout the construction period. If adequate parking cannot be provided on the construction sites, a remote parking area shall be designated, and a shuttle bus shall be operated to transfer construction workers to the job site. S = Significant SU = Signijicallt Unavoidable Impact Significance With Mitigation N/A N/A N/A LTS Stanford University Medical Center Facilities Rene'r1'a1 and Replacement Draft EIR -Summary Impacts NI = No Impact Table 8-4 SUMC Project Summary of Impacts and Mitigation J.\<Ieasures Impact Significance Without Mitigation LTS Less-than-Significant Mitigation Measures TR-l.2 Maintain Pedestrian Access. The SUMC Project sponsors shall be prohibited from substantially limiting pedestrian access while constructing the SUMC Project, without prior approval from the City of Palo Alto Department of Public Works. Such approval shall require submittal and approval of specific construction management plans to mitigate the specific impacts to a less-than­ significant levels. Pedestrian access-limiting actions would include, but not be limited to, sidewalk closures, bridge closures, crosswalk closures or pedestrian re-routing at intersections; placement of construction-related material within pedestrian pathways or sidewalks, and other actions which may affect the mobility or safety of pedestrians during the construction period. If sidewalks are maintained along the construction site frontage, covered Walkways shall be provided. TR-l.3 Maintain Bicycle Access. The SUMC Project sponsors shall be prohibited from limiting bicycle access wlllle constructing the SUMC Project without prior approval from the City of Palo Alto Department of Public Works. Such approval shall require submittal and approval of specific construction management plans that warn cyclists prior to reaching the impacted bicycle lanes and provide alternative routing around the construction sites to mitigate the specific impacts to a less-than-significant level. Bicycle access-limiting actions would include, but not be limited to, bicycle lane closures or narrowing, closing ()r narrowing of streets that are designated bicycle routes, bridge closures, the placement· of construction-related materials within designated bicycle lanes or along bicycle routes, and other actions which may affect the mobility or safety of bicyclists during the construction period. S = Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Rene).val and Replacement Draft EIR Summary Impact Significance With Mitigation S-31 Impacts NI No Impacf S-32 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures TR-1A Restrict Construction Hours. The SUMC Project sponsors shall be required to prohibit or limit the number of construction material deliveries from 7:00 a.m. to 9:00 a.-m., and from 4pm to 6pm on weekdays. The SUMC Project sponsors shall be required to prohibit or limit the number of construction employees from arriving or departing the site from the hours of 4:30 p.m. to 6:00 p.m. TR-l.5 Restrict Construction Truck Routes. The SUMC Project sponsors shall be required to deliver and remove all construction­ related equipment and materials on truck routes designated by the cities of Palo Alto, East Palo Alto and Menlo Park. Heavy construction vehicles shall be prohibited from accessing the site from other routes. Figure 3.4-6 and 3.4-7 of the EIR illustrates the Stanford Area Truck Routes which must be used by all trucks. TR-l.6 Protect Public Roadways During Constnlction. The SUMC Project sponsors shall be required to repair any structural damage to public roadways, returning any damaged sections to original structural condition. The SUMC Project sponsors shall survey the condition of the public roadways along truck routes providing access to the proposed project site before construction, and shall again survey after construc:tion is complete. A before-and-after survey report shall be completed and submitted to the City of Palo Alto Public Works Department for review, indicating the location and extent of any damage. TR-l.7 Maintain Public Transit Access and Routes. The SUMC Project sponsors shall be prohibited from limiting access to public transit, and from limiting movement of public transit vehicles, without prior approval from the Santa Clara County Valley S=Significant SU= Significa/lt Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement Dr({ft EIR Summary Impacts NI = No Impact Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures Transportation Authority or other appropriate jurisdiction. Such approval shall require submittal and approval of specific impacts to a less-than-significant level. Potential actions which would impact access to transit include, but are not limited to, relocating or removing bus stops, limiting access to bus stops or transfer facilities, or otherwise restricting or constraining public transit operations. TR-l.8 Prepare and Implement Construction Impact Mitigation Plan. In lieu of the above mitigation measures. the SUMC Project sponsors shall submit· a detailed construction impact mitigation plan to the City of Palo Alto for approval by the Director of Public Works prior to commencing any construction activities with potential transportation impacts. This plan shall address in detail the activities to be carried out in each construction phase, the potential transportation impacts of each activity, and an acceptable method of reducing or eliminating significant transportation impacts. Details such as the routing and scheduling of materials deliveries, construction employee arrival and departure schedules, employee parking locations, and emergency vehicle access shall be described and approved. TR-l.9 Conduct Additional Measures During Special Events. The SUMC Project sponsors shall implement a mechanism to prevent roadway construction activities from reducing roadway capacity during major athletic events or other special events which attract a substantial number of visitors to the campus. This measure may require a special supplemental permit to be approved by either Santa Clara County or the City of Palo Alto prior to hosting such events during significant construction phases. S = Significant SU= Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-33 Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impacts TR-2. Intersection Level of Service. Implementation of the SUMC Project would result in significant impacts to intersections during Peak Hour conditions. Impact Significance Without Mitigation S NI = No Impact LTS Less-thall-Significant S-34 Mitigation Measures MITIGATION MEASURES. Given the magnitude of the SUMC Project's intersection impacts, there is no single feasible mitigation measure that can reduce the impacts to a less-than-significant level. However, there are a range of measures that, when taken individually, would each contribute to a partial reduction in the SUMC Project's impacts. When combined, these measures could result in a substantial reduction in the SUMC Project's impacts. Under all combinations of feasible mitigation measures below, impacts of the SUMC Project on intersection LOS would remain significant and unavoidable. Of aU of the feasible combinations, the one that would have the largest reduction in impact, and that mitigates the greatest number of the intersection impacts, is the combination of traffic adaptive signal technology, additional bicycle and pedestrian undercrossings, enhanced Travel Demand Management (TDM) program, and feasible intersection improvements. This combination of mitigation measures would reduce the SUMC Project impacts to a less-than-significant level at all of the impacted intersections during the AM Peak Hour. However, intersection impacts would remain significant and unavoidable in the PM Peak Hour at three intersections with mitigation. TR-2.1 Install Traffic Adaptive Signal Technology. The SUMC Project sponsors shall contribute to the Palo Alto Citywide Traffic Impact Fee program, for the installation of traffic adaptive signals. However, this fee.is not structured to mitigate one hundred percent of project related impacts, and an additional fee could be imposed by the City on the SUMC Project sponsors to mitigate the remaining share of the SUMC Project impacts. In Menlo Park, the SUMC Project sponsors shall contribute their fair share amount, which shall be tied to the amount of traffic added to analyzed intersections by the SUMC Project. The SUMC Project sponsors' contributions shall apply towards the S=Significant S[J = Significant Unavoidable Impact Significance With Mitigation SU Stanford Medical Center Facilities Rene·wal and Replacement Draft ElR -Summary Stanford Impacts Nl No Impact Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures installation of traffic adaptive signals as listed below. • Sand Hill Road (Oak Creek to Shopping Center) - 4 signals • Arboretum Road (Shopping Center to Palm Drive) - 3 signals • Embarcadero Road (Bryant to Saint Francis) -7 signals • University A venue (Palm to Lincoln) 13 signals • Lytton Avenue (Alma to Middlefield) -10 signals • Hamilton Avenue (Alma to Midd1efieJd) -10 signals • Middlefield Road (San Antonio to Homer) - 9 signals • Charleston Road (Alma to Middlefield) - 2 signals • EI Camino Real (northern city limits of Menlo Park to southern city limits of Palo Alto) -signals would require approval of Caltrans TR-2.2 Fund Additional Bicycle and Pedestrian Undercrossings. The SUMC Project sponsors shall connibute their fair share to the cost of construction of the Everett A venue undercrossing of the Cal train tracks in Palo Alto and the Middle A venue undercrossing in Menlo Park. In Palo Alto~ there is a Citywide Traffic Impact Fee program that the SUMC Project sponsors shall contribute to. However, this fee is not structured to mitigate one hundred percent of the SUMC Project related impacts, and an additional fee may be imposed by the City to mitigate the remaining share of the SUMC Project impacts. In Menlo Park, the fair share contribution shall be tied to the amount of traffic added to analyzed intersections by the SUMC S=Signijicanr SU= Significant Unavoidable InillPYfCif't1 Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-35 Impacts NT = No Impact S-36 Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation M~sures Project. The construction of the Everett A venue and Middle A venue undercrossings would reduce traffic volumes on nearby streets, such as Ravenswood Avenue and University Avenue. TR-2.3 Enhance Stanford University Travel Demand Management (TDM) Program. The SUMC Project sponsors shall enhance the currently-implemented TDM program in order to achieve 35.1 percent usage of alternative transportation modes (i.e, carpool, vanpool, bus, Caltrain, bicycle, and walk) by SUMC employees. The initial enhancements to the SUMC TDM program shall include the following: • Provide Caltrain GO Passes, or an equivalent TDM measure, to aU eligible hospital employees and set target Caltrain mode share for hospital employees equal to 15.8 percent. • If Caltrain GO Passes would be provided to SUMC employees, make arrangements with AC Transit to lease 75 spaces at the Ardenwood Park & Ride Lot, to serve SUMC employees who commute from the East Bay. • Expand bus service in support of the issuance of GO Passes. • Expand the Marguerite shuttle bus service, and integrate it with the other City of Palo Alto shuttle bus service. • Maintain load factors less than 1.00 on the U Line, and less than 1.25 on the Marguerite shuttle. • Expand and improve the bicycle and pedestrian networks. • Provide a full-time on-site TDM coordinator by 2015 for the hospital components. The coordinator would be responsible for organizing and disseminating TDM information primarily S=Significant SU = Significant Unavoidable Impact . Significance With Mitigation Starrjord University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impacts NI No Impact Table S-4 SUMC Project SW1llllary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation Measures to hospital employees and also to hospital patients. A central location would be made available to provide information on alternative travel modes. Also, the SUMC or hospitals' website would contain information on TDM programs. • Provide a guaranteed ride home program for all employees who use transit and other transport alternatives like carpool and vanpool. The guarantee ride home shall allow employees with dependent children the ability to use alternative modes to travel to and from work but still be able to travel home mid-day in case of an emergency. • Provide employees with shower facilities within the SUMC Sites to encourage bicycling to work. The SUMC Project sponsors shall also provide bicycle storage facilities on .the SUMC Sites that would be conveniently located near the employee showers. • Establish, in conjunction with the GO Pass implementation, a "Zip Car" (or other similar car-sharing program) with Zip Cars available at the medical complex. • Perform annual TDM monitoring and submit the report to the City of Palo Alto to ensure that the assumed modal split to alternative forms of travel and away from autos is actually achieved. These enhancements may not immediately change the mode split for SUMC employees, because many employees would be unable to change long standing commute patterns overnight. However, with the passage of a mutually agreed amount of time, it· is expected that the enhanced TDM program would gradually result in a shift in the mode split of SUMC employees. If this proves S =Signijlcant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-37 Impacts N! No!mpact S-38 Table S-4 SUMC Project Swumary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation Measures not to b~ the case, then a second round of improvements to the TDM program shall be implemented. Examples of additional measures could be to increase the parking permit charges while increasing the incentives to those who carpool or do not drive. If, by the year 2025, at least 35.1 percent of SUMC employees are not using alternative transpOltation modes, then a second round of improvements to the TDM shall be implemented. Examples of additional measures could be to increase the parking permit charges while increasing the incentives to those who carpool or do not drive. 111ereafter. SUMC Project sponsors shall monitor/survey employee use of alternative modes of transportation on an at least bi-annual basis, and shall continue to improve its TDM program, until it is confirmed to the satisfaction of the City that the target of 35.1 percent usage has been met. TR-2.4 Fund or Implement those Intersection Improvements that Have Been Determined to be Feasible. The SUMC Project sponsors shall implement the following measures: • For the intersection of El Camino Real/Page Mill Road - Oregon Expressway, the SUMC Project sponsors shall pay a fair share towards (1) provision of exclusive right-turn lane for westbound Oregon Expressway, in addition to the two through lanes. (2) increasing the cycle length to 160 seconds. Improvements to the westbound right turn lane would require right-of-way from the Santa Clara Valley Transportation Authority (VT A) park-and-ride lot. • At the intersection of Arboretum Road/Galvez Street, the SUMC Project sponsors shall install a traffic signaL S = Significant SU = Significant Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement Drqft ElR Summary Impacts NI No Impact Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impact Significarice Without Mitigation LTS Less-thclil-Signijicant . Mitigation Measures TR-2.5 Coordinate with Other Jurisdictions for Potentially Feasible Roadway Improvements. The City of Palo Alto shall work with other jurisdictions to try to achieve feasibility for the following roadway improvements or adjustments. In the event that one or more of the below improvements would then be determined to be feasible, the SUMC Project sponsors shall pay their fair share towards implementation of the improvements, if a fair share contribution would apply. • Alpine Road/I-280 Northbound Off-Ramp -Signalize this intersection. The City shall coordinate with Caltrans regarding feasibility of these improvements. • EI Camino Real/Ravenswood Avenue -Re-stripe the exclusive right-tum lane on southbound EI Camino Real to a shared through/right lane. Also, provide an additional through lane for northbound EI Camino Real by removing the right-tum slip island. Also, provide an exclusive right­ turn lane for eastbound Menlo Avenue. The City shall coordinate with the City of Menlo Park and Caltrans regarding feasibility of these improvements. • Bayfront Expressway/Willow Road -Provide one more right-tum lane for eastbound Willow Road and make the right-turn movement for southbound Bayfront Expressway "overlap" with the left-tum of eastbound Willow Road. The intersection has signals for the right-turn movement for southbound Bayfront Expressway, but the "overlap'" phase is not implemented. The City shall coordinate with the City of Menlo Park regarding feasibility of these improvements. • Middlefield Road/Ravenswood A venue -Provide an additional exclusive left-tum lane for northbound Middlefield S=Significant SU= Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR SummalY Impact Significance With Mitigation S-39 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts TR-3. Impacts on Roadway Segments. The SUMC Project would result in adverse traffic inlpacts to roadway segments in the City of Menlo Park. TR-4. Local Circulation Impacts. The SUMC Project could result insignificant traffic impact to the local circulation network in the immediate vicinity of the SUMC Sites. Impact Significance Without Mitigation S S NI = No Impact LTS = Less-than-Significant 5-40. Mitigation Measures Road. The City shall coordinate with the City of Menlo Park regarding feasibility of this improvement. • Junipero Serra Boulevard/Campus Drive West -Request that Santa Clara County change the signal cycle length at this intersection to 90 seconds. The City shall coordinate with the County of Santa Clara regarding feasibility of this adjustment. MITIGATION MEASURES. With the provision of additional bicycle and pedestrian undercrossings (Mitigation Measure TR-2.2), the enhanced TDM program (Mitigation Measure TR-2.3), and contribution to the City of Menlo Park shuttle fee (Mitigation Measure TR -7.2), there would still be significant impacts on four Menlo Park roadways, including Marsh Road, Willow Road, Sand Hill Road, and Alpine Road. Therefore, the traffic impacts to Marsh Road, Sand Hill Road, Willow Road, and Alpine Road would remain significant and unavoidable with mitigation. MITIGATION MEASURES. Mitigation Measure TR-4.1, involving funding and implementation of a traffic impact study, and Mitigation Measure TR-4.2, involving re-striping of Durand Way, would reduce the SUMC Project's impact to a less-than-significant level. . TR-4.1 Fund Traffic Impact Study. Upon construction of the SHC and LPCH Hospital components, the SUMC Project sponsors shall fund an independent traffic evaluation, commissioned by the City, based on actual travel patterns, volumes, and emergency access, with an emphaSIS on ease of circulation around and through the medical complex to determine if the private street connection between Roth Way and Pasteur Drive should be operated as a public street. If the independent traffic study demonstrates that the connection between Roth Way and Pasteur Drive as a public street would improve circulation, then the S =Signijicant SU = Significant Unavoidable Impact Significance With Mitigation SU LTS Stanford University Medical Center Facilities Renewal and Replacement Draft EIR _~m"mnr\1 Table 8-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts TR-S. Freeway Impacts. The SUMC Project would result in less-than-significant impacts on freeways. TR-6. Bicycle and Pedestrian Impacts. The SUMC Project could impede the development or function of planned bicycle or pedestrian facilities, and result in a significant impact. Impact Significance Without Mitigation LTS S NI No Impact LTS Less-thall-Significant Mitigation Measures connection shall be designated as a public street for all vehicular, bicyc1e, pedestrian, and transit traffic. TR-4.2 Fund Signing and Striping Plan and Signal Optimization. In addition to paying for the construction of the extension of Durand Way from Sand Hill Road to Welch Road, the SUMC Project sponsors shall also pay for the following improvements to ensure that queues from the Durand Way/Sand Hill Road intersection do not spillback onto the Durand Way/Welch Road intersection. • A signing and striping plan for the Durand Way extension, which would maximize the storage capacity by creating a four-lane roadway with a left and through/right at Sand Hill Road and a right and through/left at Welch Road; • The installation and optimization of the two signals at the intersections of Durand Way/Sand Hill Road and Durand Way/Welch Road. None required. MITIGATION MEASURES. Mitigation Measure TR-2.3 involving trip­ reducing measures, plus Mitigation Measure TR-6.1, which involves several bicycle and pedestrian improvements, would reduce the SUMC Project's impact to a less-than-significant level. The improved facilities would mitigate the hazards to pedestrians and bicyclists brought about by the increased vehicular traffic and congestion. TR-6.1 Bicycle and Pedestrian Infrastnlcture Improvements, The SUMC Project sponsors shall fund the expansion and improvement .pf the bicycle and pedestrian network in the immediate vicinity of the SUMC Project. The intent of these improvements is to: S = Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation N/A LTS S-41 Impacts NI = No Impact S-42 Table S-4 SUMC Project SWllmary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation Measures • reduce auto related traffic by providing the infrastructure for alternative travel modes: • improve the bicycle and pedestrian linkages between the SUMC Project and Downtown Palo Alto, and between the SUMC Project and the surrounding residential neighborhoods; and • mitigate the safety hazards to pedestrians and cyclists that will result from the SUMC Project related increase in vehicular traffic and congestion. The specific improvements to be funded by the SUMC Project sponsors shall include the following: • Provide an enhanced pedestrian crossing at Quarry RoadlEI Camino Real· to establish a strong connection between the SUMC Project and Downtown Palo Alto. The pedestrian crossing shall be 12 feet wide, have contrasting pavement, countdown signal heads, and high visibility markings. Even though the intersection of Quarry Road and El Camino Real is projected to operate at acceptable levels of service, added vehicular traffic through the intersection and added bicycle and pedestrian volumes across the intersection would potentially create safety hazards which would be mitigated by the proposed enhanced crossings. • Create a bicycle and pedestrian connection between the Stanford Shopping Center and SUMC. The connection shall provide an alternative route to Quarry Road, which is auto dominated. This connection shall extend between Vineyard Lane and Welch Road. Pedestrian traffic signals and crosswalks shall be placed at the crossing of Vineyard Lane S = Significant SU = Signijicallt Unavoidable Impact Significance With Mitigation Stanford University Medical Cellter Facilities Renewal and Replacement Draft ElR -Summary Impacts NI = No Impact Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation Measures and Welch Road. The crosswalk shall be enhanced either by striping or by the use of contrasting paving. • Provide a connection from the planned Everett Avenue bicycle and pedestrian undercrossing to the EI Camino Real/Quarry Road intersection. Once the tunnel is completed. this linkage shall provide a direct connection between the SUMC Project and Downtown North. • Provide a bicycle and pedestrian trail through the Arboretum Drive as part of future campus planning in the SUMC area. TIus trail shall improve access to the SUMC Project. To support this off-street path, bicycle and pedestrian crossings at Arboretum Road and Palo Road shall be enhanced to provide safe crossing of these streets. The crosswalks shall be properly signed, marked, and lighted with enhanced pavement markings and imbedded crosswalk lights. Signalization of this crossing may ultimately be required. • Incorporate into the Quarry Road corridor, from EI Camino Real to Welch Road, continuous sidewalks according to the SUMC Project's Design Guidelines. The extension of Quarry Road west of Welch Road shall continue the pedestrian facilities into the SUMC Project. • Enhance all signalized intersections in the Project Vicinty, particularly along Quarry Road, Vineyard, and Welch Roads to include 12-foot pedestrian crosswalks on all legs, with textured or colored paving or diagonal or longitudinal zebra striping as determined by the City, pedestrian push buttons and countdown pedestrian signal heads, and other specific improvements that are determined as necessary during the design process, such as median refuge islands, advanced signing, flashing beacons, in­ pavement lighting, etc. S=Signijicant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-43 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts TR-7. Transit Impacts. Implementation of the SUMC Project could impede the operation of the transit system as a result of increased ridership, and result in a significant impact. Impact Significance Without Mitigation S NI = No Impact LTS Less-thall-Significant S-44 Mitigation Measures • Install the appropriate number of Class I and Class III bicycle parking spaces as required by the City's Zoning Ordinance for the total amount of existing and future development. The SUMC Project sponsors shall install the required number of bicycle parking spaces equally distributed throughout the SUMC Sites. MITIGATION MEASURES. Mitigation Measure TR-7.1 involves the addition of transit centers to the SUMC Project's site plans, and Mitigation Measure TR-7.2 involves [mancial contributions towards the expansion of transit service. Implementation of these measures would reduce the SUMC Project's transit impacts to a less-than-significant level. TR-7.1 Incorporate Transit Centers Into Site Plans. The SUMC Project sponsors shall revise their SUMC Project site plan to incorporate two transit centers to reduce the impact to transit service caused the SUMC Project. These transit centers shall be located at Hoover Pavilion and at SHC, and shall be off-street facilities. The transit centers shall accommodate three to four buses simultaneously, and shall have shelters, seating, lighting, signs, maps, bus schedules, and bicycle parking. On-street bus stops along Welch Road and Quarry Road shall also be provided, but the transit centers shall accommodate the majOlity of transit riders and shall be located to maximize the convenience of employees, patients, and visitors. One transit center shall be' located in the vicinity of Welch Road and Pasteur Drive to serve SHC. The other transit center shall be located near the entrance to Hoover Pavilion. Both of these transit centers shall provide the focal point for transit use for the SUMC. TR-7.2 Provide Expanded Transit Service. The SUMC Project sponsors shall make a fair share financial contribution to the cost of expanding existing bus service of the Marguerite, Crosstown, S = Significant SU = Significallt Unavoidable Impact Significance With Mitigation LTS Stanford University Medical Cellter Facilities Renewal and Replacement Draft EIR -Summary Impacts NI = No Impact Table 8-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures and Menlo Park Shuttle bus services, and to the VT A Community Bus Service. • Marguerite Shuttle. The SUMC Project sponsors shall make a financial contribution to expand the Marguerite shuttle service into Palo Alto. • U Line. The SUMC Project sponsors shall make a financial contribution towards the operation of the U Line. Arrangements with AC Transit shall be made to increase U Line service (such as decreasing headways) to meet the increase in demand attributable to the SUMC Project, and ensure that load factors remain below 1.0. • Crosstown Shuttle. The SUMC Project sponsors shall participate in operating the Palo Alto Crosstown Shuttle service, by contributing to the Citywide Traffic Impact Fee" which would include covering the costs of this service. Then current fee is $2,861 per net new PM Peak Hour trips. A portion of Stanford's Citywide Traffic Impact Fee shall be used by the City to expand City shuttle services. • VTA Community Bus Sen ice. The SUMC Project sponsors shall contribute to fund the project's fair share of Palo Alto' s share of expanded VT A Community Bus Service. • Menlo Park Shuttle Bus. The SUMC Project sponsors shall pay into the City of Menlo Park shuttle fee at $0.105 per square foot of new development annually or a percentage agreed between Menlo Park and SUMC Project sponsors. In Menlo Park. the contribution shall be tied to the amount of project traffic added to analyzed roadway segments and intersections. S=Significant SU= Signijicallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-45 Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts TR-S. Parking Impacts. The SUMC Project would provide adequate parking for its demand, and would thus have a less­ than-significant parking impact. TR-9. Emergency Access. Implementation of the SUMC Project could potentially result in inadequate emergency access due to increased congestion, a significant impact. TR-IO. Cumulative Construction Impacts. The SUMe Project, in combination with concurrent construction projects in the vicinity of the SUMC Sites, could result in a significant construction-period impact. The contribution of the · SUMC Project would be cumulatively considerable. TR-ll. Cumulative Transit Impacts. Cumulative growth would result in a less-than-significant cumulative impact on transit services. AQ-l. Construction Criteria Air Pollutant Emissions. Without mitigation, construction activities associated with the SUMe Project could cause emissions of dust and pollutants from equipment exhaust that could contribute to existing air quality violations or expose sensitive receptors to substantial pollutant concentrations . Impacts would be significant. . Impact Significance Without Mitigation LTS S S LTS S NI = No Impact LTS = Less-thall-Signijicant S-46 Impact Significance With Mitigation Measures . Mitigation N one required. N / A MITIGATION MEASURES. Mitigation Measure TR-9.1 involVes the LTS installation of emergency vehicle traffic signal priOlity (OptiCom) at all intersections significantly impacted by the SUMC Project. Implementation of this measure would reduce the SUMC Project's impact to less-than- significant levels. TR-9.1 Pay Fair Share TOl'vards OptiCom Installatioll. The SUMC Project sponsors shall pay their fair-share financial conttibution towards the City of Palo Alto, to assist with the installation and operation of emergency vehicle traffic signal priority (OptiC om) at all significantly impacted intersections. MITIGATION MEASURES. With implementation of Mitigation Measures LTS TR-1.1 through TR-1.9, which involve transportation-related construction management measures, the SUMC Project's contribution to the significant cumulative construction-period impact would be reduced to less than cumulati vely considerable. None required. Nt A MITIGATION · MEASURES . To minimize dust emissions, the Bay Area Air Quality Management District (BAAQMD) has identitied a set of feasible PMIO control measures for all construction activities in the air basin. Implementation of the BAAQMD-recommended measures (Mitigation Measure AQ-1.1 below) would reduce the impacts caused by construction dust to a less-than-significant level. Additionally, implementation of S =Signijicant SU = Significallt Unavoidable Stanford University Medical Center Facilities Rellewal and Replacement Draft EIR -Summary SU Impacts NI = No Impact Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures construction equipment emission reduction measures (Mitigation Measure AQ-1.2 below) would further reduce NOx, ROG, PMlO and PM2.5 emissions during construction. However, reduction of NOx emissions below 80 lbs/day during the first year of construction could not be guaranteed, and this impact would still be considered significant and unavoiaable. AQ-l.l Implement Recommended Dust Control Measures. To reduce dust emissions during project demolition and construction phases, the SUMC Project sponsors shall require the construction contractors to comply with the dust control strategies developed by the BAAQMD. The SUMC Project sponsors shall include in construction contracts the following requirements: a. Cover all trucks hauling soil, sand, and other loose materials including demolition debris, or require all trucks to maintain at least two feet of freeboard; b. Water an active construction areas (exposed or disturbed soil surfaces) at least twice daily; c. Use watering to control dust generation during demolition of structures or break-up of pavement; d. Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved parking areas and staging areas; e. Sweep streets daily (with water sweepers) all paved access roads, parking areas and staging areas during the earthwork phases of construction; f. Sweep daily (with water sweepers) if visible soil material is carried onto adjacent public streets; g. Hydroseed or apply (non-toxic) soil stabilizers to inactive construction areas (previously graded areas inactive for ten days or more); S=Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-47 Impacts NI No [mpact S-48 Table S-4 SUMC Project Smnmary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-titan-Significant Mitigation Measures h. Enclose, cover, water twice daily, or apply non-toxic soil binders to exposed stockpiles (dirt, sand, etc.); i. Limit traffic speeds on unpaved roads to 15 mph; j. Install sandbags or other erosion control measures to prevent silt runoff to public roadways; and k. Replant vegetation in disturbed areas as quickly as possible. AQ-l.2 Implement Equipment Exhaust Emission Reduction Measures. To reduce emissions from construction equipment dming project demolition and construction phases, the SUMC Project sponsors shall require the construction contractors to comply with the following emission reduction strategies to the maximum feasible extent. The SUMC Project sponsors shall include in construction contracts the following requirements: a. Where possible, electrical equipment shall be used instead of fossil-fuel powered equipment. b. The contractor shall install temporary electrical service whenever possible to avoid need for fossil-fuel powered equipment. c. Running equipment not being actively used for construction purposes for more than five minutes shall be turned off. (e.g., trucks waiting to deliver or receive soil, aggregate, or other bulk materials: however, rotating-drum concrete trucks may keep their engines running continuously as long as they are on site). d. Trucks shall be prohibited from idling while on residential streets serving the construction site (also included. in Mitigation Measure NO-l.l). S=Significant SU = Significant Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts AQ-2. Operational Criteria Air Pollutant Emissions. Combined mobile and stationary source emissions during operation of the SUMC Project would exceed the Bay Area Air Quality Management District's significance threshold of 80 pounds/day of ROG, NOx and PMlO. Therefore, air emissions would result in a substantial contribution to an existing regional air quality problem and a significant impact. AQ-3. Localized Carbon Monoxide Impacts from Motor Vehicle Traffic. The SUMC Project would have less-than­ significant localized air emissions resulting from additional traffic. AQ-4. Toxic Air Contaminants. Simultaneous exposures to DPM and T ACs from the construction and operational components of the SUMC Project would have a less-than­ significant impact on air quality. Impact Significance Without Mitigation S LTS LTS NI No Impact LTS Less-thall-Significant Mitigation Measures e. Diesel-powered construction equipment shall be Tier III or Tier IV California Air Resources Board (CARB) certified equipment to the maximum feasible extent. f. The engine size of construction equipment shall be the smallest practical to accomplish the task at hand. MITIGATION MEASURES. Mitigation Measure TR-2.3 involves implementation of enhanced TDM measures. The enhanced TDM measures include provision of the Caltrain GO Pass to SUMC employees, or an equivalent TDM measure. If the GO Pass would be provided, then remote parking spaces at the Ardenwood Park and Ride Lot in the East Bay would also be provided to serve commuters from the East Bay. Provision of the GO Pass plus remote parking spaces in the East Bay would reduce Vehicle Miles Travelled by 13.5 percent. This reduction in SUMC Project VMT, however. would not be sufficient to prevent project ROG. NOx and PMJO emissions from exceeding the BAAQMD significance thresholds. In addition, the City shall consider the feasibility of Mitigation Measure PH- 3.1. Nonetheless, impacts would be significant and unavoidable even with mitigation. None required. None required. S=Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR SlImmnrv Impact Significance With Mitigation su N/A N/A S-49 Table S~4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts AQ-5. Objectionable Odors. TIle SUMC Project would have a less-than-significant impact related to exposing the public to objectionable odors that would affect a substantial number of people. AQ-6. Cumulative Construction Emissions. Construction equipment NOx emissions associated with the SUMC Project could contribute considerably to regional air quality problems. AQ-7. Cumulative Operational Emissions. SUMC Project operation could contribute considerably to a degradation of regional air quality as defined by the BAAQMD. AQ-8. Cumulative Construction and Operational T AC Emissions. SUMC Project TAC emissions could contribute considerably to the health risk of sensitive receptors on and near the SUMC Project site and, thus, have a significant cumulative impact. Impact Significance Without Mitigation LTS S S S NI No Impact LTS = Less-thall-Significant S-50 Mitigation Measures None required. MITIGATION MEASURES. Mitigation Measures AQ-l.l and AQ-L2 would reduce the SUMC Project's contribution to cumulative construction emissions, although the contribution to NOx would remain cumulatively considerable. MITIGATION MEASURES. Mitigation Measure TR-2.3 involves implementation of enhanced TDM measures. The enhanced TDM measures include provision of the Caltrain GO Pass to SUMC employee.s, or an equivalent TDM measure. If the GO Pass would be provided, then remote. parking spaces at the Ardenwood Park and Ride Lot in the East Bay would also be provided to serve commuters from the East Bay. As additional mitigation, the City shall consider the feasibility of Mitigation Measure PH-3.l, as identified and discussed in more detail in Section 3.13, Population and Housing. These measures would reduce the contribution to criteria pollutants during operation of the SUMC Project. However, even with mitigation. einissions would still exceed the BAAQMD significance thresholds, and the contribution would remain considerable. MITIGATION MEASURE. Mitigation Measure AQ-L2 (Implement Equipment Exhaust Emission Reduction Measures) has been identified primarily to reduce construction-phase criteria pollutant emissions. but it would also reduce Diesel Particulate Matter (DPM) emissions. However, the emissions of criteria and DPM emissions from project construction sources were based on current best estimates of the type, number, and duration of use of the SUMC Project construction equipment. While some additional reductions of Toxic Air Contanrinants (TACs) would be expected with Mitigation Measure AQ-L2, where their implementation is feasible, their S=Significant SU = Significant Unavoidable Impact Significance With Mitigation N/A SU SU SU Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Table S-4 SUMC Project Swnmary of Impacts and Mitigation ~:leasures Impacts CC-l. Furthering Goals and Policies of the Palo Alto Climate Protection Plan. The proposed Emissions Reduction Program would minimize greenhouse gas emission increases associated with the proposed development progranl. However, the proposed Emissions Reduction Program would not be sufficient to further the goals of the City's Climate Protection Plan. . . Impact Significance Without l\iitigation S NI = No Impact LTS ·= Less-thall-Significant Mitigation Measures potential additional reductions were not included in the SUMC Project's DPM estimates that were the basis of the Health Risk Assessment. However, it is not likely that the additional reductions in SUMC Project T AC emissions resulting from their implementation would reduce the SUMC Project health risk to the point where it would not be cumulatively considerable in the context of Palo Alto's high TAC background levels. Thus, SUMC Project TAC enlissions would remain cumulatively significant even after the implementation of all feasible TAC reduction measures. MITIGATION MEASURES. The mitigation measures below, which in addition to the proposed Emissions Reduction Program, would further minimize the increase in greenhouse gas emissions from this project. However, even with these measures the SUMC Project would contravene the goals in the City's Climate Protection Plan and would have a cumulatively considerable contribution to global climate change. CC-I.l Commission and Retro-Commission Energy Systems for Ne'rl' and Existing Buildings. New construction and existing buildings altered by construction of the SUMC Project shall undergo commissioning of energy and HV AC systems during construction and on an annual basis during the fust five years of operation. The commissioning process shall follow the standards of the American Society of Heating, Refrigerating, and Air­ Conditioning Engineers (ASHRAE) Guideline 0-2005 or the International Performance Measurement and Verification Protocol (MVP). This process would ensure that new and existing energy systems would perform interactively according to construction documents, the SUMC Project design intent and the owner's operational needs. S = Significant SU = Signijicallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -SumllulIY Impact Significance With Mitigation SU S-51 Impacts NI No Impact S-52 Table S-4 SUMC Project Summary of Impacts and Mitigation l\leasures Impact Significance Without Mitigation LTS = Less-than-Significant Mitigation Measures CC-I.2 Participate in Palo Alto Green Energy Program. Other Equivalent Renel-vable Energy Program, or combination thereof Under the Palo Alto Green program, residential, business and industrial customers purchase renewable energy equivalent to their electricity needs at an additional cost of 1.5 cents per kWh above standard electric rates. The SHC and LPCH facilities shall participate in this program to offset electricity emissions; develop new renewable generation sources in collaboration with the CP AU; incorporate a renewable energy source (such as photovoltaics) into the SUMC Project. or a combination thereof, such that a minimum of 54,640 MWh of electricity usage is offset alillually. CC-I.3 Provide Annual Greenhouse Gas Reporting. The SHC and LPCH shall perform an annual inventory of greenhouse gas emissions associated with hospital and medical facilities on the SUMC Sites. This inventory shall be performed according to a common industry-standard emissions reporting protocol, such as the approaches recommended by California Air Resources Board, The Climate Action Registry, or Business Council for Sustainable Development (BCSD). This inventory shall be shared with the City of Palo Alto to facilitate the development of future collaborative Emissions Reduction Programs. Emissions associated with energy, water, solid waste~ transportation, employee commute and other major sources shall be reported in tIns inventory. CC-IA Prepare Waste Reduction Audit. The SUMC Project sponsors shall perform a waste reduction audit of waste management practices at the hospitals prior to construction of new facilities and after completion of the SUMC Project to determine post­ project diversions. This audit shall be repeated annually, and S = Significant SU = Significant Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement Draft ElR Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts CC-2 Emit Significant Greenhouse Gas Emissions. The proposed Emissions Reduction Program would minimize the greenhouse gas emission increases associated with the proposed· development program, although the proposed Emissions Reduction Program would not reduce emissions to 30 percent below business as usual (BAU) emissions. Therefore the SUMC project would have a cumulative considerable contribution to global climate change. Impact Significance Without Mitigation S NI = No Impact LTS = Less-thall-Significant Mitigation Measures with the results being made available to the public or to City of Palo Alto staff. CC-J.5 Implement Constntction Period Emission Reduction Measures. Prior to the issuance of a grading permit the SUMC Project sponsors shall incorporate the following measures into the construction phasing plan and submit to City Planning for approval. • Use alternative-fueled (e.g., biodiesel, electric) construction vehicles! equipment of at least 15 percent of the fleet; • Use local building materials of at least 10 percent; and • Recycle at least· 50 percent of construction or demolition materials. MITIGATION MEASURE. Mitigation Measures CC-l.l through CC-1.5, and TR-2.3 would reduce greenhouse gas emissions. In addition, to further reduce impacts related to greenhouse gas emissions, the City shall consider the feasibility of Mitigation Measure PH-3.1. However, even with the implementation of all feasible mitigation measures, the anticipated emissions would remain above both the City of Palo Alto's Climate Protection Plan and the CARB's reduction emission goals of 30 percent below BAU emissions. Because these reduction levels cannot be achieved, the SUMC Project would emit significant amounts of greenhouse gases and would have a cumulatively considerable contribution to globaf climate change. S=Signijicant SU= Significant Unavoidable Stanford University Medical Center Facilities Rene)val and Replacement Draft EIR Summary Impact Significance With Mitigation SU S-53 Table S-4 SUMC Project SWllmary of Impacts and Mitigation Measures Impacts NO-I. Construction Noise. Construction of the SUMC Project would create a substantial temporary increase in ambient noise levels on the SUMC Sites compared to existing ambient noise levels. The noise increase would be a significant impact to the sensitive uses (i.e .. patients) on the Main SUMC Site during construction. Impact Significance Without Mitigation S NI = No Impact LTS = Less-thall-Significant S-54 . Mitigation Measures MITIGATION MEASURE. The following IDltlgation measures would not reduce construction noise impacts to on-site sensitive receptors to less-than­ significant levels, although they wou1d ·lessen construction-related noise. NO-i.i Implement Best Management Practices to Reduce Construction Noise. The SUMC Project sponsors shall incorporate the following practices into the construction documents to be implemented by the SUMC Project contractor: a. Provide enclosures such as heavy-duty mufflers for stationary equipment, shrouding or shielding for impact tools, and barriers around particularly noisy operations on the site. b. Use quiet construction equipment whenever possible, particularly air compressors. c. Provide sound-control devices on equipment no less effective than those provided by the manufacturer. d. Locate stationary equipment, material stockpiles, and vehicle staging areas as far as practicable from sensitive receptors. e. Prohibit unnecessary idling of internal combustion engines. f. Require applicable construction-related vehicles and equipment to comply with the City'S truck route ordinance. g. Designate a noise disturbance coordinator who shall be responsible for responding to complaints about noise during construction. The telephone number of the noise disturbance coordinator shall be conspicuously posted at the construction site and shall be provided to the City. Copies of the construction schedule shall also be posted at nearby noise­ sensitive areas. S=Signijicant SU = Significallt Unavoidable Impact Significance With Mitigation SU Stanford University Medical Center Facilities Renewal and Replacement Draft ElR -Summary Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impacts NO-2. Construction Vibration. Construction of the SUMC Project would have less-than-significant vibration impacts. NO-3. Operational Noise Impacts from Transportation Sources. Increased traffic and helicopter noise levels due to implementation of the SUMC Project would be less than significant. However, noise from ambulances due to implementation of the SUMC Project would increase along Sand Hill Road west of EI Camino Real, and would increase roadside noise levels by an amount considered unacceptable under the policies of the City Comprehensive Plan. NO-4. Operational Stationary Source Noise Impacts. Operational stationary source noise generated by the SUMC Project could potentially increase ambient noise levels in the vicinity of the SUMC Sites and result in a significant impact. Impact Significance Without Mitigation LTS S S Nl No Impact LTS = Less-thall-Significant Mitigation Measures None required. MITIGATION MEASURE. No mItIgation measure (short of forbidding ambulance access to the new emergency room via the Durand Way access route; a measure that may be practically impossible given the emergency nature of anlbulance activity) would prevent or reduce the identified SUMC Project-related ambulance noise impact at the noise-sensitive uses along Sand Hill Road. As such, the impact would be significant unavoidable impact. MITIGATION MEASURE. The following mitigation measure would reduce noise impacts to sensitive receptors from HVAC equipment and emergency generators proposed for SUMC Project. Implementation of this measure would reduce the SUMC Project's noise impacts at 1100 Welch Road. NO-4.1 Shield or Enclose HVAC Equipment and Emergency Generators. Noise levels from mechanical equipment shall be minimized to the degree required by the City Noise Ordinance by proper siting and selection of such equipment and through installation of sufficient acoustical shielding or noise emission controls. Noise levels for the emergency generators near Welch Road shall be reduced such that noise levels do not exceed the City's General Daytime Exception standard of 70 dBA at 25 feet. An acoustical analysis shall be prepared by a qualified professional to ensure that the new mechanical equipment is in compliance with noise standards of the Noise Ordinance. S = Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement ElR Summary , Impact Significance With Mitigation N/A SU LTS S-55 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts NO-5. Cumulative Construction Noise Impacts. If other foreseeable construction in the immediate vicinity of the SUMC Sites would occur simultaneously with the proposed SUMC Project construction. then significant cumulative noise impacts to adjacent residential and other noise-sensitive uses could occur. The SUMC Project's contribution would likely be cumulatively considerable. NO-6. Cumulative Construction Vibration Impacts. Vibration during construction activities under the cumulative scenario would result in a less-than-significant cumulative impact. NO-7. Cumulative Operational Transportation Source Noise Impacts. Cumulative development would result in less-than­ significant cumulative noise impacts. NO-S. Cumulative Operational Stationary Source Noise Impacts. Cumulative development would not result in a significant increase in cumulative noise levels from operational stationary sources at sensitive receptors. CR-l. Impacts on Historical Resources. The SUMC Project would have a significant impact on historical resources. Impact Significance Without Mitigation S LTS LTS LTS S NI = No Impact LTS = Less-thall-Significant S-56 Mitigation Measures MITIGATION MEASURE. Although measures under Mitigation Measure NO-I.I would lessen the resulting noise contribution from the construction of the SUMC Project at 1100 Welch Road and on-site receptors, the contribution of the SUMC Project construction noise would remain cumulatively considerable. None required. N one required. N one required. MITIGATION MEASURES. Implementation of the Mitigation Measures CR-l.I and CR-1.5 would reduce potential vibration and construction­ related impacts to the Hoover Pavilion resulting from demolition of adjacent sheds and storage facilities , impacts from falling construction debris, and impacts from . movement of heavy equipment to a less-than­ significant level. Implementation of Mitigation Measures CR-1.2 through CR-1.4 would reduce impacts due to the loss of the Stone Building complex; however, the impact would remain significant and unavoidable. S = Significant SU= Signijicallt Unavoidable Impact Significance With Mitigation SU N/A N/A N/A SU Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impacts NI = No Impact Table 5-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thall-Significant Mitigation Measures Mitigation MeasureCR-1.5 requires implementation of the Stanford Hoover Pavilion Protection Documents (Documents) prepared by ARG and dated September 21, 2009 (see Appendix J). These Documents provide specifications for the treatment and protection of the Hoover Pavilion during SUMC Project construction activities that could damage the historic fabric of the building including the installation of protective. covering of certain exterior surfaces and the removal, cataloging, and storage of selective historic elements. The Documents are based on National Park Service and National Fire Protection Agency protection guidelines and include details on materials and methods of installation for the protective coverings to prevent damage from nearby demolition. Proper installation, as required in the Documents would prevent the protective covering itself from damage the building. The removal of historic elements would ensure their protection of some of the more fragile elements from construction activities and property cataloging and storage of such elements would ensure their proper care and reinstallation. The Documents include such details as specifying under what weather conditions it is acceptable to perform the various tasks that could be negatively impacted by different weather conditions. Any variations on the specifications of the Documents would not be allowed without prior consultation with ARG, or a qualified preservation architect. Refer to Appendix J, Stanford Hoover Pavilion Protection Documents, for a complete list of specifications for the Hoover Pavilion. CR-l.l Manually Demolish Stnlctures at the Hoover Pavilion Site. Where feasible. the project sponsors shall establish a perimeter of construction fencing around the Hoover Pavilion at a minimum of 25 feet to establish a protective buffer around the building. The demolition of these sheds and storage facilities shall be accomplished manually without the use of vibration causing equipment. Additional protective fencing at a height sufficient to prevent any debris from hitting the building shall S=Significant SU= Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation S-57 Impacts NI = No Impact S-58 Table S-4 SUMC Project Summary of Impacts and Mitigation .l\Ieasures bnpact Significance Without Mitigation LTS = Less-than-Significant Mitigation Measures also be installed between the Hoover Pavilion and demolition activities occurring within the 25 foot buffer. CR-l.2 Prepare HABS Documentation for the Stolle Building Complex. The SUMC Project sponsors shall prepare HABS-like documentation using the National Park Services' Historic American Building Surveys Level ITl guidelines for each of the buildings in the Stone Building complex prior to demolition of each building that comprises this historic resource (East, West, Core, Boswell, Edwards, Lane, Alway, and Grant). HABS-like recordation shall not be required until each of the individual buildings is vacated and prepared for demolition. The documentation shall include written and photographic documentation of each of the historic structures within the Stone Building complex. The documentation shall be prepared by a qualified professional meeting the Secretary of the Interior's Professional Qualifications Standards for Architectural History or History. The documentation shall be prepared based on the National Park Services' HABS standards and include, at a minimum, the following: • Site-specific history and appropriate contextual information regarding the Stone Building complex. This history shall focus on the reasons for the buildings' significance: heart transplantation program and the role of E.D. Stone in the design of the complex. • Accurate mapping of all buildings that are included in the Stone Building complex, scaled to indicate size and proportion of the buildings to surrounding buildings; if existing plans accurately reflect these relationships these may S=Significant SU= Significant Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement Draft ElR -Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance With Impacts Impact Significance Without Mitigation Mitigation Measures Mitigation N! No!mpact LTS = Less-than-Significant be reformatted for submittal per HABS guidelines for CAD submittals. • Architectural descriptions of the major exterior features and rooms within the Stone Building complex as well as descriptions of typical patient, office, laboratory, and operating rooms. • Photographic documentation of the interior and exterior of the Stone Building complex and Thomas Church-designed landscape features. Either HABS standard large format or digital photography may be used. If digital photography is used, the ink and paper combinations for printing photographs must be in compliance with National Register­ National Historic Landmark photo expansion policy and have a permanency rating of approximately 115 years. Digital photographs will be taken as uncompressed . TIF file format. The size of each image shall be 1600xl200 pixels at 300 ppi (pixels per inch) or larger, color format, and printed in black and white. The file name for each electronic image shall correspond with the Index to Photographs and photograph Jabel. CR-l.3 DistributeWrittell and Photographic Documentation to Agencies. The written and photogJ;'aphic documentation of historic resources shall be disseminated on archival-quality paper to Stanford University, the Northwest Information Center, and other local repositories identified by the City of Palo Alto. CR-l.4 Prepare Pennanent Interpretive Displays/Signage/Plaques. The SUMC Project sponsors shall install interpretive displays within the SUMC Sites that provide infonnation to visitors and residents regarding the history of the Stone Building complex. These S=Significanr SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary S-59 Table S-4 SUMC Project Smnmary of Impacts and Mitigation Measures Impacts CR-2. Impacts on Prehistoric or Archaeological Resources. The . SUMC Project could potentially encounter archaeological resources and result in a significant impact. Impact Significance Without Mitigation S NI No Impact LTS Less-thall-Signijicant S-60 Impact Significance With Mitigation Measures Mitigation displays shall be installed in highly visible public areas such as the property's open space or· in public areas on the interiors of buildings. The displays shall include historical data and photographs as well as physical remnants of architectural elements. Interpretive displays and the signage/plaques installed on the property shall be sufficiently durable to withstand typical Palo Alto weather conditions for at least five years. Displays and signage/plaques shall be lighted, installed at pedestrian­ friendly locations, and be of adequate size to attract the interested pedestrian. Maintenance of displays and signage/plaques shall be included in the maintenance program on the property. Location and materials for the interpretative displays shall be subject to review by the Palo Alto Architectural Review Board and approval by the Planning Director. CR-1.5 Implement Protection Documents for the Hoover Pavilioll. The SUMC Project sponsors shall ensure the implementation of the Stanford Hoover Pavilion Protection Documents (Documents) prepared by ARG and dated September 21. 2009. The SUMC Project sponsors shall comply with the specifications for the treatment and protection of the Hoover Pavilion during SUMC Project construction activities that could damage the historic fabric of the building as provided in the Documents. MITIGATION MEASURE. Mitigation Measure CR-2.1 provides discovery and evaluation procedures for any previously unknown archaeological resources on the SUMC Sites and requires that a professional archaeologist employ preservation in place, data recovery, or other methods that meet the Secretary of the Interior's Standards for Archaeological Documentation to reduce impacts on unique archaeological resources. Therefore, implementation of the following mitigation measure would ensure the impact remains less than significant. (L TS) S=Signijicant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary LTS Table S-4 SUMC Project Suntmary of Impacts and Mitigation Measures Impacts CR-3. Impacts on Human Remains. The SUMC Project could potentially encounter human remains and result in a significant impact. Impact Significance Without Mitigation S NI No Impact LTS Less-thall-Significant Mitigation Measures CR-2.1 Construction Staff Training and Consultation. Prior to any construction or earth-disturbing actlvltles, a qualified archaeologist shall inform construction supervisors of the potential to encounter cultural resources. All construction personnel shall be instructed to be observant for prehistoric and historic-era artifacts, subsurface archaeological features or deposits~ including accumulations of dark, friable sail ("midden"), stone artifacts, animal bone, and shell. In the event that any prehistoric or historic subsurface archaeological features or cultural deposits are discovered during construction-related earth-moving activities, all ground-disturbing activity within 100 feet of the resources shall be halted and the City shall be notified. The City shall consult with the Stanford University Archeologist to assess the significance of the find. If the find is determined to be an historical resource or a unique archaeological resource as defined by CEQA, then representatives of the City and the Stanford University Archaeologist shall meet to determine the appropriate course of action. All significant· cultural materials recovered shall be subject to scientitic analysis, professional museum curation, and a report shall be prepared by the qualified archaeologist according to current professional standards. MITIGATION MEASURE. Mitigation Measure CR-3.1 summarizes the procedures to be taken in the event that any previously unknown human remains are discovered on the SUMC Sites. Therefore, imp1ementation of the following mitigation measure would ensure that the potential impact remains less than significant. CR-3.1 Conduct Protocol and Procedures for Encountering Human Remains. If human remains (including disarticulated or cremated remains) are discovered at any SUMC Project construction site during any phase of construction. all ground-disturbing activity S=Significant SU= Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR SumllUlry Impact Significance With Mitigation LTS S-61 Table S-4 SUMC Project Summary of Impacts and Mitigation l\leasures . Impacts CR-4. Impacts on Paleontological Resources. The SUMC Project could have a significant impact on unique paleontological resources or unique geologic resources. Impact Significance Without Mitigation S NI No Impact LTS = Less-thall-Significant S-62 Impact Significance With Mitigation Measures Mitigation within 100 feet of the human remains should be halted and the Stanford University Archaeologist, City of Palo Alto, and the County coroner notified immediately, according to Section 5097.98 of the State Public Resources Code and Section 7050.5 of California's Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American.Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC adhered to in the treatment and disposition of the remains. The SUMC Project sponsors shall retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide professional assistance to the City of Palo Alto, including the excavation and removal of the human remains. If the human remains cannot be avoided, and the Most Likely Descendant requests that the human remains be removed from its location, the SUMC Project sponsors shall implement removal of the human remains by a professional archaeologist. The City of Palo Alto shall verify that the mitigation is complete before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered. MITIGATION MEASURE. Mitigation Measure CR-4.1 provides protocol for LTS encountering paleontological resources and would reduce the potential impacts resulting from disruption to unique paleontological resources to a less-than-significant level. CR-4.1 Conduct Protocol and Procedures for Encountering Paleontological Resources. Should paleontological resources be identified during SUMC Project ground-disturbing activities, the SUMC Project sponsors shall notify the City and the Stanford S=Signijicant SU= SignificaJlt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Sufimzary Impacts NI = No Impact Table S-4 SUMC Project Smllmary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-thall-Significant Mitigation Measures University Arc~aeologist and cease operations in the vicinity of the potential resource until a qualified professional paleontologist can complete the following actions when appropriate: • Identify and evaluate paleontological resources by intense field survey where impacts are considered high; • Assess effects on identified resources; and • Consult with the City of Palo Alto and the Stanford University Archaeologist. Before operations in the vicinity of the potential resource resume, the SUMC Project sponsors shall comply with the paleontologist's recommendations to address any significant adverse effects where determined by the City of Palo Alto to be feasible. In considering any suggested mitigation proposed· by the consulting paleontologist, the SUMC Project sponsors shall consult with the Stanford University Archaeologist and the City to determine whether avoidance is necessary and feasible in light of factors such as the nature of the find, project design, cost policies and land use assumptions, and other considerations. If avoidance is infeasible, other appropriate measures (e.g. data recovery) shall be instituted to avoid a significant impact. Work may proceed in other parts of the SUMe Sites while mitigation for paleontological resources is completed. S=Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation S-63 Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts CR-5. Cumulative Impacts on Historic Resources. The SUMC Project, in combination with other past, current, and probable future development in the City, would cause a substantial change in the significance of the City's historic resources and thus have a significant cumulative impact. The SUMC Project's contribution to the cumulative impact would be cumulatively considerable. CR-6. Cumulative Impacts on Prehistoric and/or Archaeological Resources and Human Remains. The SUMC Project, in combination with other reasonably foreseeable probable future development, could cause a substantial change in the significance. of prehistoric and/or archaeological resources or human remains and thus contribute to a significant cumulative impact. The SUMC Project is conservatively assumed to have a considerable contribution. CR-7. Cumulative Impacts on Paleontological Resources. The SUMC Project, in combination with other reasonably foreseeable probable future development where the Pleistocene-age creek bed may occur, could have a significant cumulative impact. Such an impact would occur if the buried Pleistocene-age creek bed is exposed in lengths greater than approximately 100 feet (or a sufficient length to support detailed hydrological study) and if such deposits contain substantially intact skeletons of extinct species. These conditions would represent a major find for regional paleontology. In the case that significant paleontological finds-such as stretches of buried Pleistocene-age creek bed greater than 100 feet in length and containing intact skeletons of extinct species-are made on the SUMC Site, then the Impact Significance Without Mitigation S S S NI = No Impact LTS = Less-than-Significant S-64 Impact Significance \Vith Mitigation Measures Mitigation MITIGATION MEASURES. Due to the demolition of the Stone Building SU complex, the SUMC Project's contribution would remain cumulatively considerable as this impact cannot be avoided. Implementation of Mitigation Measures CR-1.2 through CR-1.4 would reduce the SUMC Project's contribution to the cumulative impact, but not to a less than cumulatively considerable leveL MITIGATION MEASURES. Compliance with Mitigation Measures CR-2.1 LTS and CR-3.1 would reduce the SUMC Project's contribution to the cumulative impact to a less than cumulatively considerable level. MITIGATION MEASURE. Compliance with Mitigation Measure CR-4.1 LTS would reduce the SUMC Project's contribution to the cumulative impact to a less than cumulatively considerable level. S = Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts SUMC Project's contribution to the cumulative impact on paleontological resources could be cumulatively considerable. BR-l. Impacts on Special-Status Plant or Wildlife Resources. The SUMC Project could have a significant impact on special­ status wildlife resources. Impact Significance Without Mitigation S NI = No Impact LTS = Less-thall-Significant Mitigation Measures MITIGATION MEASURES. Mitigation Measures BR-1.1 through BR-1.5, below, to be implemented by the SUMC Project sponsors, would reduce the SUMC Project's impact on special-status bats and Cooper's hawk to a less- than-significant level. . BR-l.l Conduct Pre-Demolition Survey. The SUMC Project sponsors shall retain a qualified biologist ("bat biologist") to conduct a pre-construction survey for roosting bats in trees to be removed or pruned and structures to be removed. If no roosting bats are found, no further mitigation is required. If a bat roost is found, the SUMC Project sponsors shall implement the following measures to avoid impacts on roosting bats. BR-l.2 Avoid Roosting Areas. If non-breeding bats are found in a tree or structure to be removed, the individuals shall be safely evicted, under the direction of a qualified bat biologist, by opening the roosting area to allow airflow through the cavity. Demolition should then follow at least one night after initial disturbance for airflow. This action should allow bats to leave during darkness, thus increasing their chance of finding new roosts with a minimum of potential predation during daylight. If active maternity roosts are found in structures that will be removed as part of project construction, demolition of that structure shall commence before maternity colonies form (generally before March 1) or after young are flying (generally by July 31). S=Signijicant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation LTS S-65 Impacts NI = No Impact S-66 Table 8-4 8UMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-than-Significant Mitigation Measures BR-l.3 Develop and Employ Bat Nest Box Plan. If special-status bats are found in structures to be removed, the SUMC Project sponsors shall develop a bat nest box plan for the SUMC Sites employing state-of-the-art bat nest box tec1mology. The design and placement of nest boxes shall be reviewed by a qualified bat biologist. BR-l.4 Avoid Tree Removal During Nesting Season. Tree removal or pruning shall be avoided from February 1 through August 31, the nesting period for Cooper's hawk, to the extent feasible'. If no tree removal or pruning is proposed during the nesting period, no surveys are required. BR-l.5 Protect Cooper's Hawk in the Event of Nest Discovery. If tree removal or pruning is unavoidable during the nesting season, the SUMC Project sponsors shall hire a qualified biologist to conduct a survey for nesting Cooper's hawk within tive days prior to the proposed start of construction. If active Cooper's hawk nests are not present, project activities can take place as scheduled. The qualified biologist shall visit the site daily to search for nests until all nesting substrates are removed. This will avoid impacts to Cooper's hawk that may have moved into the site and initiated nest-building after the start of tree removal activities. Additionally, if more than 5 days elapses between the initial nest search and the tree removal, it is possible for new birds to move into the construction area and begin building a nest. If there is such a delay, another nest survey shall be conducted. If any active Cooper's hawk nests are detected. the SUMC Project sponsors shall delay removal of the applicable tree or shrub while the nest is occupied with eggs or young who have not fledged. A qualified biologist shall monitor any occupied nest to determine when the Cooper's hawk nest is no longer used. S=Significant SU = Significant Unavoidable Impact Significance With Mitigation Stanford Medical Center Facilities ReneJ.l'al and Replacement Draft EIR -Summa/)I Table 8-4 8UMC Project Summary of Impacts and Mitigation Measures Impacts BR-2. Loss of Riparian or Other Sensitive Habitats, Including Wetlands as Defined by Section· 404 of the Clean Water Act. Construction of the SUMC Project would have a less-than-significant impact on riparian or other sensitive habitat resources, including wetlands. BR-3. Interference with the Movement of Any Native Resident or Migratory Fish or Wildlife Species or with Established Native Resident or Migratory Wildlife Corridors, or Use of Native Wildlife Nursery Sites. The SUMC Project would have no impact on the movement of any native resident or migratory fish or wildlife species, or use of native resident or migratory wi1dlife corridors, but could impede the use of native wildlife nursery sites and thus result in a significant impact. Impact Significance Without Mitigation LTS S NI = No Impact LTS Less-thall-Significant Mitigation Measures None required. MITIGATION MEASURES. Mitigation Measures BR-3.1 and BR-3.2, below, would reduce the SUMC Project's impact on nesting migratory birds to a less-than-significant level .. BR-3.1 Avoid Tree Removal During Nesting Season. Tree or shrub removal or pruning shall be avoided from February 1 through August 31, the bird-nesting period, to the extent feasible. If no tree or shrub removal or pruning is proposed during the nesting period, no surveys are required. BR-3.2 Protect Birds in the Event of Nest Discovery. If tree and shrub removal or pruning is unavoidable during the nesting season, the Sl.JMC Project sponsors shall hire a qualified biologist to conduct a survey for nesting raptors and other birds within five days prior to the proposed start of construction. If active nests are not present, SUMC Project activities can take place as scheduled. The qualified biologist shall visit the site daily to search for nests unti1 all nesting substrates are removed. These procedures would avoid impacts to any birds that may have moved into the sites and initiated nest-building after the start of tree and shrub removal activities. Additionally, if more than five days elapses between the initial nest search and the vegetation removal, it is possible for new birds to move into the construction area and begin building a nest. If there is s.uch a delay, another nest survey shall be conducted. If any active nests are detected. the SUMC Project sponsors shall delay removal of the applicable S = Significant SU = Significant Unavoidable .. Stanford University Medical Center Facilities Renewal and Replacement Draft EIR SumllUlry Impact Significance With Mitigation N/A LTS S-67 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts BR-4. Result in a Substantial Adverse Effect on any Protected Tree as Defined by the City of Palo Alto's Tree Preservation Ordinance (Municipal Code Section 8.10). The SUMC Project could have a significant impact on Protected Trees. Impact Significance Without Mitigation S NI No Impacf LTS Less.than-Signijicant S-68 Mitigation Measures tree or shrub while the nest is occupied with eggs or young who have not fledged. A qualified biologist shall monitor any occupied nest to determine when the nest is no longer used. MITIGATION MEASURES. Mitigation Measures BR-4.1 through BR-4.5, below, to be implemented by the SUMC Project sponsors, would reduce the SUMC Project's impact on Protected Trees. In addition, Mitigation Measure BR-4.6 would require minor SUMC Project site plan adjustments to avoid removal of some biologically and aesthetically significant Protected Trees. However, the new Hospital District under the SUMC Project would allow the removal of up to 48 Protected Trees that are protected under the Municipal Code. In addition, minor modifications to the SUMC Project site plans would not be able to avoid the nine biologically and aesthetically significant Protected Trees in the Kaplan Lawn area. Therefore, the SUMC Project would result in a significant and unavoidable impact to Protected Trees. BR-4.1 Prepare a Tree' Preservation Report for all Trees to be Retained. An updated tree survey and tree preservation report (TPR) prepared by a certified arborist shall be submitted for review and acceptance by the City Urban Forester. For reference clarity, the tree survey shall include (list and field tag) all existing trees within the SUMC Sites, including adjacent trees overhanging the SUMC Sites. The approved TPR shall be implemented in including mandatory inspections and monthly reporting to City Urban Forester. The TPR shall be based on latest SUMC plans and anlended as needed to address activity or within the drip line area of any existing tree to be preserved, including incidental work (utilities trenching, street work, lighting, irrigation, etc.) that may affect the health of a preserved tree. The SUMC Project shall be modified to address recommendations identified to reduce impacts to existing ordinance-regulated trees. The S = Signijicant SU = Significant Unavoidable Impact Significance With Mitigation SU Stanford University Medical Center Facilities Rene'wal andReplacement Draft EIR Summary 25 Impacts Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation Mitigation Measures TPR shall be consistent with the criteria set forth in the Tree Preservation Ordinance, Palo Alto Municipal Code Section 8.10.030, and the City Tree Technical Manual, Section 3.00, 4.00 and 6.30.25 To avoid improvements that may be detrimental to the health of regulated trees, the TPR shall review the SUMC Project sponsors' landscape plan to ensure the new landscape is consistent with Tree Technical ManuaL Section 5.45 and Appendix L, Landscaping under Native Oaks. BR-4.2 Prepare a Solar Access Study (SAS) of Short and Long Term Effects on Protected Oaks. The SUMC Project sponsors shall prepare a SAS of Short and Long Term Effects on Protected Oaks. The SAS shall be prepared by a qualified expert team (horticulturalist, architect designer, consulting arborist) capable of determining effects. if any, to foliage, health, disease susceptibWty and also prognosis for longevity. The SAS shall provide alternative massing scenarios to provide sufficient solar access and reduce shading detriment at different thresholds of tree health/decline, as provided for in the SAS. The SAS adequacy shall be subject to peer review as determined necessary by the City. The SAS design alternatives shall be the subject of specific discussion at all levels of ARB, Planning Commission, City Council, and public review in conjunction with the SUMC Project sponsors, the City Urban Forester, and Director of the Planning and Community Environment Department, until a final design is approved. Impact Significance With Mitigation Palo Alto Municipal Code Section 8.10.030 and the City Tree Technical Manual, Section 3.00, 4.00 and 6.30 is available at: http://www .cityofpaloalto.org/environment/urban _canopy .asp. NI No Impact LTS Less-thall-Significant S=Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR SumlJUlry S-69 Impacts NI Nolmpacr S-70 Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS Less-than-Significant Mitigation Measures BR-4.3 Prepare a Tree Relocation Feasibility Plan for Any Protected Tree Proposed for Relocation and Retention. Because of inherent mortality associated with the process of moving mature trees, a Tree Relocation and Maintenance Plan (TRMP) shall be prepared subject to Urban Forester's approval. The SUMC Project sponsors shall submit a TRMP to determine the feasibility of moving the Protected Trees to an appropriate location on site. Feasibility shall consider current site and. tree conditions. a tree's ability to tolerate moving, relocation measures, optimum needs for the new location, aftercare, irrigation, and other long-term needs. If the relocated trees do not survive after a period of five years, the tree canopy shall be replaced with a tree of equivalent size or security d.eposit value. The TRMP shall be inclusive of the following 1Illmmum information: appropriate irrigation, monitoring inspections, post relocation tree maintenance, and for an annual arborist report of the condition of the relocated trees. If a tree is disfigured, leaning with supports needed, in decline with a dead top or dieback of more than 25 percent, the tree shall be considered a total loss and replaced in kind and size. The final annual arborist report shall serve as the basis for return of the Tree Security Deposit (see Mitigation Measure BR-4.4, below, for a discussion of the Tree Security Deposit). BR-4.4 Provide a Tree Preservation Bond/Security Guarantee. The natural tree resources on the SUMC Site include significant Protected Trees and those that provide neighborhood screening, including two trees proposed for relocation. Prior to building permit submittal, the Tree Security Deposit for the total value of the relocated trees, as referenced in the Tree Technical Manual, Section 3.26, Security Deposits, shall be posted to the City S = Significant SU = Significallt Unavoidable Impact Significance With Mitigation Stanford University Medical Center Facilities Renewal and Replacement DraftEIR -Summary Stanford Table S-4 SUMCProject Swnmary of Impacts and Mitigation Measures Impact Significance With Impacts Impact Significance Without Mitigation Mitigation Measures Mitigation NI = No Impact LTS = Less-thall-Significant Revenue Collections in a form acceptable by the City Attorney. As a security measure, the SUMC ~roject sponsors shall be subject to a Memorandum of Understanding (MOD) between the City of Palo Alto and the SUMC Project sponsors describing a tree retention amount, list of trees. criteria and timeline for return of security 1 and conditions as cited in the Record of Land Use Action for the SUMC Project. The SUMC Project sponsors and SUMC Project arborist, to be retained by the SUMC Project sponsors, shall coordinate with the City Urban Forester to determine the amount of bonding required to guarantee the protection and/or replacement of the regulated trees on the site during construction and within five years after occupancy. The SUMC Project sponsors shall bond for 150 percent of the value for the relocated trees, and 50 percent of the value of the remaining trees to be protected during construction (as identified in the revised and final approved Tree Protection Report). The SUM C Project sponsors shall provide an appraisal of the trees with the proposed level of bonding in a tree value table to be reviewed and accepted by the Director of Planning and Community Environment with the description of each tree by number, value, and total combined value of aU the trees to be retained. A return of the guarantee shall be subject to an annual followed by a final tree assessment report on all the relocated and retained trees from the SUMC Project arborist, as approved by the City Urban Forester, five years following final inspection for occupancy, to the satisfaction of the Director of the Planning and Community Environment Department. BR-4.5 ProFide Optimum Tree Replacement Jor Loss of Publicly-Owned . Trees Regulated Tree Category. There are many publicly owned trees growing in the right-of-way along various frontages (Welch Road. Pasteur Drive, Quarry Road, Sand Hill Road, etc.). S = Significant SU = Significant Unavoidable Medical Center Facilities Renewal and Replacement Draft EIR SumllullY S-71 26 S-72 Impacts Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation Mitigation Measures These trees provide an important visual and aesthetic value to the streetscape and represent a significant investment from years of public resources to maintain them. As mitigation to offset the net benefits loss from removal of mature trees, and to minimize the future years to achieve parity with visual and infrastructure service benefits (C02 reduction, extended asphalt life, water runoff management, etc.) currently provided by the trees, the new public trees on all roadway frontages shall be provided with best practices design and materials~ including, but not limited to, the following elements: • Consistency with the City of Palo Alto Public Works Department Street Tree Management Plan, in consultation with Canopy, Inc. 26 • Provide adequate room for natural tree canopy growth and adequate root growing volume. For large trees, a target goal of 1,200 cubic feet of soil shall be used. • For pedestrian and roadway areas that are to include tree planting or adjacent to existing trees to be retained. utilize City-approved best management practices for sustainability products, such as permeable ADA sidewalk surfaces, Silva Cell base support planters, engineered soil mix base, and other advantage methods. Impact Significance With Mitigation Canopy, Inc. is a non-profit organization that advises the City with regards to public trees. The City typically interfaces between appli~ants and the Canopy, Inc., but it is recommended that the SUMC Project sponsors consult with Canopy, mc. as well. " NI No Impact LTS = Less-thall-Significant S=Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts BR-S. Conflict with any Applicable Habitat Conservation Plan or Natural Community Conservation Plan. The SUMC Project would have no impact on any applicable Habitat Conservation Plan or Natural Community Conservation Plan. BR-6. Cumulative Impacts on Special-Status Wildlife Resources. The SUMC Project, in combination with other foreseeable development, would have a less-than-significant impact on Special-Status Plant Resources. BR-7. Cumulative Loss of Riparian or Other Sensitive Habitats. Including Wetlands as Defmed by Section 404 of the Clean Water Act. Cumulative impacts on riparian or other sensitive habitats could be significant. However, the SUMC Project's contribution to the cumulative impact would be less than cumulatively considerable. BR-S. Cumulative Interference with the Movement of Any Native Resident or Migratory Fish or Wildlife Species or With Established Native Resident or Migratory Wildlife Corridors, or Use of Native Wildlife Nursery Sites. Cumulative interference with movement of resident or migratory species or with established migratory corridors could be significant. However, the SUMC Project's contribution to the cumulative impact would be less than cumulatively considerable. Impact Significance Without Mitigation NI LTS LTS LTS NI = No Impact LTS Less-thall-Significant Mitigation Measures BR-4.6 Implement Minor Site Modifications to Preserve Biologically and Aesthetically Significant Protected Trees. The SUMC Project sponsors shall design and implement modifications to building design, hardscape, and landscape to incorporate the below and above ground area needed to preserve as many biologically and aesthetically significant Protected Trees as possible. None required. None required. .None required. None required. S=Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation N/A N/A N/A N/A S-73 Table 8-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts BR-9. Cumulative Impacts on Protected Tree as defined by the City of Palo Alto's Tree Preservation Ordinance (Municipal Code Section 8.10). Cumulative impacts on Protected Trees would · be significant. Because the SUMC Project would result in the loss of Protected Trees, the SUMC Project's contribution would cumulatively considerable. GS 1. Exposure to Seismic-Related Hazards. The SUMC Project would have a less-than-significant potential to expose people or structures to substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic groundshaking, seismic­ related ground failure (including liquefaction), landslides, expansive soil,. or major geologic hazards that cannot be mitigated through the use of standard engineering design and seismic safety techniques . GS 2. Exposure to Other Geotechnical Hazards. The SUMC Project would have a less-than-significant potential to be located on geologic units or on soil that is unstable, or that would become unstable as a result of the project and potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. as 3. Cause Substantial Erosion or Siltation. The SUMC Project would . have a less-than-significant potential to cause substantial erosion or siltation. Impact Significance Without Mitigation S LTS LTS LTS NI = No Impact LTS = Less-thall-Significant S-74 Mitigation Measures MITIGATION MEASURES. Mitigation Measures BR-4.1 through BR-4.6 would reduce the SUMC Project's contribution to cumulative impacts on Protected Trees. However, removal of some Protected Trees, including those identified by the City as being biologically and aesthetically significant Protected Trees, would be unavoidable. As such. the contribution of the SUMC Project to cumulative Protected Tree removal would remain cumulatively considerable. None required .. None required. None required. S = Significant SU = Significallt Unavoidable Impact Significance With Mitigation SU N/A N/A N/A Stanford University Medical Cellter Facilities Renewal and Replacement Draft ElR -Summary Table S-4 SUMC Project SWllmary of Impacts and Mitigation l\leasures Impacts GS-4. Cumulative Exposure to Substantial Erosion or Siltation. The SUMC Project, in combination with other foreseeable development in the San Francisquito Creek Watershed, would not substantially increase erosion or siltation because of State, federal, and local runoff and erosion prevention requirements. As a result, the cumulative impact would be less than significant. HW-l. Flood Risk and Flood Flows. The SUMC Project would have no impact on flood risk or flood flows. HW-2. Groundwater Recharge and Local Water Table. The SUMC Project would have a less-than-significant impact on groundwater recharge and the local groundwater table level. HW-3. Groundwater Quality. The SUMC Project could have a significant impact on groundwater quality during construction. Impact Significance Without Mitigation LTS NI LTS S NI = No Impact LTS = Less-thall-Significant Mitigation Measures None required. None required. None required. MITIGATION MEASURE. Mitigation Measure HW-3.1. below. would reduce the SUMC Project's impact on groundwater quality to a less-than­ significant level . HW-3.1 Develop a Work Plan for any UnknOlt'fl Contaminated Sites. During construction, if suspected contaminated soil, undocumented underground tanks, hazardous materials pipelines, or other evidence of potential hazardous materials are discovered, construction activities shall cease and the SUMC Project sponsors shall prepare a workplan to determine the potential risk to human and ecological health. The workplan shall be prepared by a Registered Environmental Assessor and in compliance . with the Department of Toxic Substances Control (DTSC) guidelines and the National Oil and Hazardous S = Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation N/A N/A N/A LTS S-75 Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impacts HW-4. Stormwater Runoff and Erosion. The SUMC Project would have a less-than-significant impact on stormwater runoff and erosion. HW -5. Flooding and Stormwater Conveyance Capacity. The SUMC Project would have a less-than-significant impact on flooding and stonnwater conveyance capacity. HW-6. Streambank Instability. The SUMC Project would have a less-than-significant impact on streambank instability. Impact Significance Without Mitigation LTS LTS LTS NI = No Impact LTS Less-than-Significant S-76 Mitigation Measures Substances Contingency Plan (the "National Contingency Plan" The SUMC Project sponsors, or their representative, shall be responsible for submitting the workplan for the DTSC's review and approval prior to implementing field activities. The workplan must include all information necessary for implementing field work. The workplan shall include a Site Safety Plan (SSP) and a Sampling Work Plan (SWP). The SSP must be submitted to the DTSC in conjunction with the submittal of the SWP. The objective of the SSP is to ensure protection of the investigative team as well as the general public during sampling activities. If risk to .human or ecological health is identified, the SUMC Project sponsors shall prepare and implement a Removal ~ction' Workplan (SB 1706 Stats. 1994, Chapter 441) (non-emergency removal action or remedial action at a hazardous substance . release site which is projected to cost less than $1,000.000) that is consistent with the NCP. None required. None required. None required. SU = Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A Stanford Universitv Medical Center Facilities Renewal and Replacement EIR -Summary Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts HW-7. Degradation of Surface Water Quality. The SUMC Project would have a less-than-significant impact on degradation of surface water HW-S. Dam Failure Inundation. The SUMC Project would have a less-than-significant impact regarding dam failure inundation. HW-9. Violation of Any Water Quality Standards or Waste Discharge Requirements (WDRs). The SUMC Project would have a less-than-significant impact regarding . water standards or WDRs. HW -10. Cumulative Groundwater Recharge and Local Water Table. The SUMC Project, in combination with reasonably foreseeable probable future development, would have a less­ than-significant cumulative considerable impact on groundwater recharge and the local groundwater table. HW-ll. Cumulative Groundwater Quality Impacts. The SUMC Project, in combination with reasonably foreseeable probable future development, would have a less-than­ significant cumulative impact on groundwater quality. HW -12. Cumulative Stormwater Runoff and Erosion. The SUMC ProjecL in combination with reasonably foreseeable. probable future development, would have a less-than­ significant cumulative impact on stormwater runoff and erosion. Impact Significance Without Mitigation LTS LTS LTS LTS LTS LTS NI No Impact LTS = Less-thall-Significant None required. None required. N one required. None required. None required. None required. S=Significant Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Mitigation Measures SU= Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A N/A N/A N/A S-77 Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impacts HW-13. Cumulative Flooding and Stormwater Conveyance. The SUMC Project, in combination with reasonably foreseeable probable future development, would have a less­ than-significant cumulative impact on stormwater runoff and erosion. HW-14. Streanlbank Instability. The SUMC Project, in combination with reasonably foreseeable probable future development, would have a less-than-significant cumulative impact on streambank instability. HW-15. Degradation of Surface Water Quality. The SUMC Project, in combination with reasonably foreseeable probable future development. would have a less-than-significant cumulative impact on degradation of surface water quality. HW-16. Dam Failure Inundation. The SUMC Project, in combination with reasonably foreseeable probable future development, would have a less-than-significant cumulative impact regarding dam failure inundation. HW-17. Violation of Any Water Quality Standards or Waste Discharge Requirements (WDRs). The SUMC Project, in combination with reasonably foreseeable probable future development, w()uld have a less-than-significant cumulative impact on violation of water quality standards and WDRs. Impact Significance Without Mitigation LTS LTS LTS LTS LTS NI No Impact LTS = Less-thall-Significant S-78 Mitigation Measures None required. None required. None required. None required. None required. S = Sign ificant SU = Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A N/A N/A Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts HM-I. Exposure from Hazardous Materials Use, Handling, and Disposal. The SUMC Project would not substantially increase exposure from hazardous materials use, handling, and disposal during operation. HM-2. Demolition and Construction-Related Hazardous Materials Disturbance. The SUMC Project could release hazardous materials in existing buildings. Impact Significance Without Mitigation LTS S NI = No Impact LTS = Less-thall-Significant Mitigation Measures None required. MITIGATION MEASURE. Implementation of the mitigation measure below would reduce impacts from exposure to asbestos containing materials to a less-than-significant level at the SUMC Sites by ensuring that all asbestos containing materials are identified and removed prior to structural modification andlordemolition. - HM-2.1 Conduct Asbestos Survey at the SUMC Sites. Prior to building renovation and/or demolition, an asbestos survey shall be performed on all areas of the building anticipated to be demolished and/or renovated. This survey shall be performed by a licensed asbestos abatement contractor. In the event that asbestos is identified in the buildings proposed to be demolished and/or renovated, all asbestos containing materials shall be removed and appropriately disposed of by a licensed asbestos abatement contractor. A site health and safety plan, to ensure worker safety, in compliance with OSHA requirements (8 CCR 5208) shall be developed by the SUMC Project sponsors and in place prior to commencing renovation or demolition work on portions of buildings containing asbestos. S=Signijicam SU = Signijicallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draff EIR -Summary Impact Significance With Mitigation N/A LTS S-79 Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts HM-3. Exposure to Contaminated Soil and/or Groundwate~ DUling Construction. The SUMC Project could expose construction personnel and public to existing contaminated groundwater and/or soil. Impact Significance Without l\<fitigation S NI No LTS = Less-than-Sigr:ijicant S-80 Impact Significance With Mitigation Measures Mitigation MITIGATION MEASURES. With implementation of Mitigation Measure LTS HM-3.1 through HM-3.4, below, the significant impact on construction personnel and the public due to exposure to contaminated soil and/or groundwater at the SUMC Sites would be reduced to less-than,..significant levels. In addition~ Mitigation MeasUre HW -3.1 in Section 3.11, Hydrology, would require the SUMC Project sponsors to develop a work plan for any unknown contaminated site, which would further reduce the impacts to less than significant. Mitigation Measure HM-3.4 would require specification of measures to prevent hazards from any remediation itself. As such, these would be less-than-significant impacts from any remediation. HM-3.1 Perfann a Phase II ESAjar the 701 WelcJz Site. A Phase II ESA shall be performed at 701 Welsh Site Building B. The Phase II ESAshall include sampling and analysis of soil, groundwater, wastewater, and residues on surfaces such as laboratories countertops, fume hoods, sinks, sumps, floors, and drain lines. The County DEH and PAFD shall be notified by the Project sponsors if contamination is discovered. If contamination is discovered, the SUMC Project sponsors shall prepare a site remediation assessment that (a) specifies measures to protect workers and the public from exposure to potential site hazards and (b) certifies that the proposed remediation measures would clean up contaminants, dispose of the wastes, and protect public health in accordance with federal, State, and local requirements. Site excavation activities shall not proceed until the site remediation has been approved by the County DEH and implemented by the SUMC Project sponsors. Additionally, the Site Remediation Assessment shall be subject to review and approval by the San Francisco Bay RWQCB. All appropriate agencies shall be notified. S=Signijicant SU = Significant Unavoidable Stanford University Medical Center Facilities Rene"waf and Replacement Draft ElR -Summary Impacts NI = No Impact Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impact Significance Without Mitigation LTS = Less-thau-Significant Mitigation Measures HM-3.2 . Excavate Contaminated Soilfrom the 703 Welch Site. For the 4- to 9-square-foot area near every discharge point from the building, soil samples shall be performed and contaminated soil excavated, removed, and transported to an approved disposal facility in compliance with OSHA requirements. The County DEH and the PAFD shall be notified by the SUMC Project sponsors if contamination is encountered during construction. HM-3.3 Conduct a Soil Vapor Program at the Hoover Pavilion Site. A qualified consultant, under the SUMC Project sponsors' direction, shall undertake the following activities: • Remove all buried underground storage tanks from the property after sheds and storage buildings on the Hoover Pavilion Site have been demolished: • To the extent necessary, additional soil sampling shall be collected to determine health risks and to develop disposal criteria; • If warranted based on soil sampling, a human health risk assessment shall be ptepared and implemented to determine potential for impacts on construction workers as well as to develop measures to ensure it is safe to redevelop the Hoover Pavilion Site within engineering controls (e.g., SVE or vapor barriers); and • To the extent required based upon the results of soil sampling and the results of a health risk assessment (if applicable), a Site Health and Safety Plan to ensure worker safety in compliance with OSHA requirements shall be developed by the Project sponsors, and in places prior to commencing work on any contaminated site. S = Significant SU= Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation S-8J Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts HM-4. Hazardous Waste Generation and Disposal Resulting in Increased Exposure Risk. The SUMC Project would not substantially increase exposure risk related to hazardous waste generation. HM-S. Emit Hazardous Emissions or Handle Hazardous Materials Within One-Quarter Mile of a School. The SUMC Project would not emit or handle hazardous materials within one-quarter mile of schooL HM-6. Construct a School on a Property that is Subject to Hazards from Hazardous Materials Contamination, Emissions or Accidental Release. The SUMC Project would not construct a school that is subject to hazards from hazardous materials contamination, emissions or accidental release. Impact Significance Without Mitigation LTS LTS NI NI = No Impact LTS = Less-thall-Significant S-82 Mitigation Measures The SUMC Project sponsors shall cooperate with the County DEH to proceed with closure of the Hoover Pavilion Site. HM-3,4 Develop a Site Management Plan for the Hoover Pavilion Site. The SUMC Project sponsors shall prepare a site remediation assessment that (a) specifies measures to protect workers and the public from exposure to potential site hazards. including hazards from remediation itself, and (b) certifies that the proposed remediation measures would clean up contaminants, dispose of the wastes, and protect public health in accordance with federal, State, and local requirements. Site excavation activities shall not proceed until the site remediation has been approved by the County DEH and implemented by the SUMC Project sponsors. Additionally, the Site Remediation Assessment shall be subject to review and approval by the San Francisco Bay RWQCB. All appropriate agencies shall be notified. None required. None required. None required. S = Significant SU = Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A Stanford University Medical Center Facilities.Renewal and Replacement Draft EIR Summary ~ Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts HM-7. Occur on a Site Included on the Cortese List, a List of Hazardous Materials Sites. The SUMC Project would result in construction of facilities on a site included on the Cortese List. HM-8. Wildland Fire Risk. The SUMC Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. HM-9. Occur on a Site Located Within an Airport Land Use Plan or Within Two Miles of a Public Airport, and Result in a Safety Hazard. The SUMC Project would not be located within an Airport Land Use Plan or within 2 miles of a Public Airport. HM-I0. Impairment of Emergency Plans. The SUMC Project could impair implementation or physically interfere with an adopted emergency response or evacuation plan. Impact Significance Without Mitigation S NI NI S NI=No LTS Less-thall-Significant Mitigation Measures MITIGATION MEASURES. Implementation of Mitigation Measures HM-3.3 and HM-3.4, which involve the implementation of a soil vapor program and development of a site management plan, would reduce the potential for exposure to hazardous materials at the Hoover Pavilion Site to less-than­ significant levels. Additionally, compliance with cunent federal, State and local regulations would help prevent any further exposure to hazardous materials. None required. None required. MITIGATION MEASURES. Mitigation Measure HM-IO.l requires advance coordination with the City of Palo Alto on construction routes or roadway closures. This measure, together with Mitigation Measures TR-l.l, TR-l.4 through TR-1.6, and TR-1.8, which all involve construction-period traffic controls, would reduce the significant construction-period impacts to a less-than-significant level. Mitigation Measure TR-9.1, would involve the installation of emergency vehicle traffic signal priority (OptiC om) at all intersections significantly impacted by the SUMC Project. Mitigation Measure TR-9.1 would reduce impacts on emergency access during operation. Implementation of these measures would reduce the SUMC Project' s impact to emergency evacuation and response plans to a less-than­ significant level. S = Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR Summary Impact Significance With Mitigation LTS N/A N/A LTS S-83 Table S-4 SUMC Project SUlllDlary of Impacts and Mitigation Measures Impacts HM-ll. Cumulative Handling, Storage, Disposal, and Transport of Hazardous Materials. Cumulative development would increase handling, storage, disposal, and transport within the SUMC Sites and adjacent areas. However, cumulative development would .be subject to applicable federa], State, and local regulations that would govern these activities. As a result, the cumulative impact would be less than significant. HM-12. Cumulative Disturbance of Hazardous Materials from Construction. The SUMC Project and adjacent development could result in cumulative release of hazardous materials during construction, a significant cumulative impact. The SUMC Project's contribution to the cumulative impact would be considerable. HM-13.Cumulative Exposure to Contaminated Soil and/or Groundwater, and from Cortese List Sites. The SUMC Project and adjacent development could result in cumulative disturbance of contaminated soils, release of hazardous materials during construction, a significant cumulative impact. Impact Significance Without Mitigation LTS S S NI No Impact LTS = Less-than-Significant S-84 Mitigation Measures HM-IO.l Coordinate COllstmction Activities with the City of Palo Alto. The SUMC Project sponsors shall provide to the City planned construction routes, roadway closures, and access and closures schedules. This information shall be provided to the City at least two weeks in advance of the planned access and closures. The City shall coordinate this information among affected emergency service providers, including the City's Fire and Police Departments, and private ambulance services, so that alternative routes could be planned and announced prior to the scheduled access and closures, as deemed necessary by the City. None required. MITIGATION MEASURE. Mitigation Measure HM-2.1, involving measures to reduce exposure of persons to hazardous materials (such as asbestos), would reduce the SUMC Project's contribution to a less-than-significant level MITIGATION MEASURES. Mitigation Measure HM-3.2, which involves remediation of known site contamination at the 703 Welch Road site, would reduce the SUMC Project's contribution to the cumulative impact to less than considerable. Also, Mitigation Measures HM-3.1, HM-3.3, and HM- 3.4, involving investigations at other SUMC areas and preparation of the S = Significant SU = Significant Unavoidable Impact Significance With Mitigation N/A LTS LTS Stanford University Medical Center Facilities Renewal and Replacement Draft EIR S;1Jmmnrll Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts The SUMC Project's contribution to the cumulative impact would be considerable. HM-14. Cumulative Exposure of Schools to Hazardous Materials and Waste. The SUMC Project, in combination with reasonably foreseeable probable future development. would have a less than cumulatively considerable impact on exposure of schools to hazardous materials. HM-15. Cumulative Impairment of Emergency Plans. Cumulative development could impair implementation or physically interfere with an adopted emergency response or evacuation plan. The SUMC Project's contribution to the cumulative impact would be considerable. PH-I. Population Growth. The SUMC Project would increase on-site employment and visitors and thus indirectly induce housing demand and population growth; however, the percentage of regional housing demand resulting from the SUMC Project would be relatively small in . comparison with projected housing growth in the region, and would compdse a less-than-significant environmental impact. PH-2. Displacement of Existing Housing or Residents. The SUMC Project would not displace existing housing or residents because the SUMC Project would involve infill of currently developed sites that do not contain housing. Thus, the SUMC Project would result in no impact with respect to displacement of housing or residents. Impact Significance Without Mitigation LTS S LTS NI NI = No Impact LTS = Less-thall-Significant Mitigation Measures Site Management Plan for remediation activities, would further ensure that any other risks associated with the SUMC Project would be less than cumulatively considerable. None required. MITIGATION MEASURES. Mitigation Measures HM-IO.l, above, and TR-l.l, TR-l.4 through TR-1. 6, and TR -1. 8 would reduce the SUM C Project's contribution to cumulative impacts on emergency evacuation and response plans to less than cumulatively considerable. None required. N one required. S = Significant SU = Signijicallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Impact Significance With Mitigation N/A LTS N/A N/A S-85 Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts PH-3. Impacts on Jobs to Employed Residents Ratio. The SUMC Project would have an adverse impact 011 the City's jobs to employed residents ratio because it would exceed the existing Comprehensive Plan and zoning allowances for the SUMC Sites and thus require anlendment to the Comprehensive Plan and rezoning, and it would increase the City's jobs to employed residents ratio by more than 0.01. However, this impact is not, itself, an environmental impact. This impact will result in secondary environmental impacts relating to additional commute traffic, including the significant and unavoidable impacts on air quality and climate change, as identified in Sections 3.5 and 3.6. The present analysis of impacts to the "jobs to employed residents" ratio is presented for informational purposes, and for the purpose of identifying additional mitigation measures for those identified impacts. Impact Significance Without Mitigation N/A NI No Impact LTS Less-thall-Significant S-86 Impact Significance With Mitigation Measures Mitigation MITIGATION MEASURE. Implementation of Mitigation Measure PH-3.1 N/A would reduce the impact on the City's jobs to employed residents ratio; however. such implementation would not fully avoid the SUMC Project's impact on the jobs to employed residents ratio because (1) the measures would not guarantee provision of housing units to cover the demand from the 1,052 households (or 8 percent thereof), and (2) due to the various factors that people consider in choosing where to live, it cannot be ascertained that the 1,810 workers would choose to live in Palo Alto. Due to the high concentration of jobs in Palo Alto, it is possible that a strong affordable housing program would result in reduced traffic congestion, vehicle miles traveled, and greenhouse gas emissions. Implementation of Mitigation Measure PH-3.1 is not directly required in order to mitigate a significant environmental impact, but rather should be considered as possible additional mitigation for Impacts AQ-2, AQ-7, CC-l, and CC-2, as discussed in Section Air Quality, and Section 3.6, Climate Change, of this EIR. However, it should be stressed that these measures are presented here only in conceptual terms, and the City may fmd that some or all of them are not feasible for various legal, practical, or other reasons. As such, Mitigation Measure PH-3.1 is presented for informational purposes, and to ensure that all possible options for mitigation of these impacts are adequately considered. PH-3.1 Reduce the Impacts on the Jobs to Employed Residents Ratio .. In order to reduce the SUMC Project's impacts on the City's jobs to employed residents ratio, one or more of the following measures shall be implemented by both the City and the SUMC Project sponsors: • The City shall explore amending the Zoning Code to permit more residential uses, particularly multifamily residential use; S = Significant SU = Significant Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Dralt EIR Summary? Table S-4 SUMC Project Sunnnary of Impacts and Mitigation Measures Impacts PS-l. Impacts Related to Fire Protection and Emergency Medical Facilities. The SUMC Project would require an increased level of fire and emergency services. However, the increased level of fire and emergency services would not be large enough to trigger the need for construction of new facilities, which could adversely affect the physical environment. Impacts would be less than significant. Impact Significance Without Mitigation LTS NI = No Impact LTS = Less-thall-Significant Mitigation Measures • The SUMe Project sponsors shall ensure that a specified number of housing units in the County shall be dedicated to SUMC employees; • The City shall amend the Zoning Code to remove the hospital exemption from payment of the affordable housing fee; • The City shall impose an additional ad hoc housing fee on development to ensure development of required affordable housing. The amount of the fee shall be based on the cost of the additional affordable housing units induced by the SUMC Project as well as the cost of the General Fund subsidy contribution to the existing housing impact fee; and/or . • The City sball provide an inclusionary housing requirement in the newly created Hospital District. The requirement shall provide a number of options for development of additional housing with an emphasis on affordable housing. None required. S = Significant SU = Significallt Unavoidable Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -SumllulIY Impact Significance With Mitigation N/A S-87 Table S-4 SUMC Project Swnmary of Impacts and Mitigation l\rleasures Impacts PS-2. Impacts from Police Protection Facilities. The SUMC Project would require an increased level of police services. However, the increased level of police services would not be large enough to trigger the need for construction of new facilities, which could adversely affect the physical environment. Impacts would be less than significant. PS-3. Impacts Related to School Facilities. An increase in students, which would require school expansions, would result as a tertiary impact of the SUMC Project, since increased employment from the SUMC Project could induce additional housing units within the City. Both the SUMC Project and induced housing projects would be subject to SB 50 School Impact Fees, which would mitigate impacts to less than significant. PS-4. Impacts Related to Construction of New or Altered Parks and Recreation Facilities. The SUMC Project would not result in the construction or expansion of new parks or fields, which would in turn result in adverse environmental impacts. The SUMC Project would be required to pay a City COInmunity Facility Fee. which would be used to fund new. parks or an alteration to an existing park, and would mitigate impacts to less than significant. PS-5. Deterioration of Park and Recreation Facilities. Increased recreational demand from SUMC Project employees could accelerate the physical deterioration of the City's parks and fields. The SUMC Project would be required to pay a City Community Facility Fee, which reduce or avoid any such deterioration, and would mitigate impacts to less than significant. Impact Significance Without Mitigation LTS LTS LTS LTS NI No Impact LTS = Less-than-Significant S-88 Mitigation Measures None required. None required. N one required. N one required. S=Significant SU = Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A' N/A Stanford 1nilll'1·.~itv Medical Center Facilities Rene'wal and Replacement Draft EIR -Summary Table 5-4 5UMC Project Summary of Impacts and Mitigation Measures Impacts PS-6. Cumulative Fire Protection Demand and Emergency Medical Facilities. Cumulative growth would increase demand for fire protection and emergency response services within the P AFD' s service area; however, no new P AFD facilities would need to be constructed. Cumulative impacts would be less than significant. PS-7. Cumulative Police Protection Demand. Cumulative growth in the City could necessitate construction of new or expanded police facilities in order to meet increased demand for services. Construction of new or expanded police facilities could result in significant environmental impacts. As such, cumulative impacts related to police service could be significant. However the SUMC Project's contribution to the cumulative need for new or expanded police facilities would be less than cumulatively considerable. PS-S. Cumulative School Demand. Cumulative development in the City can be expected to necessitate expansion of school facilities, which could have adverse physical environmental impacts. This cumulative inlpact is conservatively assumed to be signlficant, although the SUMC Project's contribution to this cumulative impact would be less than cumulatively considerable. PS-9 Cumulative Demand for Parks and Recreation Facilities, and for New Parks. Cumulative impacts related to park deterioration would be less than significant due to the City'S Community Facility Fee. Cumulative growth in the City would necessitate acquisition or development of new parklands, which could result in significant environmental impacts; however, the contribution of the SUMC Project to Impact Significance Without Mitigation LTS LTS LTS LTS NI = No Impact LTS Less-than-Significant None required. N one required. None required. None required. S=Significant Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -Summary Mitigation Measures SU = Significant Unavoidable Impact Significance With Mitigation N/A N/A N/A N/A S-89 Table S-4 SUMC Project Swnmary of Impacts and Mitigation Measures Impacts this cumulative impact would be less than cumulatively considerable. UT-l. Water Demand. The SUMC Project would result in a less-than-significant water supply impact because it would not result in the need for new or expanded entitlements for water supplies. and would not require expansion or construction of water facilities. UT-2. Wastewater Generation. The SUMC Project would result in a less-than-significant wastewater impact because it would not exceed treatment requirements of the RWQCB. would not significantly increase use of the wastewater disposal system, and would not require expansion or construction of wastewater collection or treatment facilities. UT-3. Stormwater Generation. The SUMC Project would have a less-than-significant impact related to stonnwater collection system capacity because it would not significantly increase use of the stormwater collection system, and would not require expansion or construction of new stormwater facilities. UT-4. Solid Waste Generation. The SUMC Project would result in a less-than-significant solid waste impact because it would be served by landfills with sufficient capacity and, thus, would not contribute to the need to expand existing or construct new solid waste disposal facilities. Impact Significance Without Mitigation LTS LTS LTS LTS NI = No Impact LTS = Less-thall-Significant S-90 Mitigation Measures None required. None required. None required. None required. S=Signijicant SU = Significallt Unavoidable Impact Significance With Mitigation N/A N/A N/A N/A Stanford University Medical Cellter Facilities Rene"wal and Replacement Draft EIR -Summary Table S-4 SUMC Project Smnmary of Impacts and Mitigation Measures Impacts UT-5. Energy Demand. Although the SUMC Project is an urban infil1 project and would not require the expansion of natural gas facilities and would use existing utility facilities, it may require the installation of near-site electrical facilities and natural gas pipelines to accommodate the projected additional demand. However, this installation is included in the SUMC Project and no additional off-site construction relating to electrical and natural gas facilities would occur. Therefore, the SUMC Project would have a less-than-significant impact related to the construction of energy facilities. UT-6. Cumulative Water Impacts. Since the City has sufficient water supply to accommodate water demands for cumulative development up to 2025, new or expanded entitlements for. water supplies are not necessary. Therefore, cumulative development would have a less-than-significant cumulative impact related to water supply. UT-7. Cumulative Wastewater Impacts. Since the RWQCP has sufficient capacity to accommodate wastewater generated by cumulative development up to 2025, implementation of major facility and infrastructure improvements would not be necessary. In addition, general replacement and maintenance of old wastewater facilities is expected and would comply with applicable environmental regulations. Therefore, cumulative development would not have a significant cumulative impact related to wastewater. UT-8. Cumulative Stormwater Generation. Cumulative development in the City of Palo Alto and at Stanford University could increase the amount of stormwater runoff. This increased level of runoff may trigger the need for the Impact Significance Without Mitigation LTS LTS LTS LTS NI = No Impact LTS = Less-thall-Significant N one required. None required. None required. N one required. S = Significant Stanford University Medical Center Facilities Renewal and Replacement Draft EIR -SumllulIY Mitigation Measures SU = Signijicallt Unavoidable Impact Significance With Mitigation N/A N/A N/A N/A S-9J Table S-4 SUMC Project Summary of Impacts and Mitigation Measures Impacts replacement or maintenance of storm drain facilities. However, general replacement and maintenance of storm drain facilities is included in City plans and would comply with applicable environmental regulations. Theretore, cumulative development would have a less-than-significant cumulative impact related to the capacity or deterioration of storm drain facilities. UT -9. C\JIDulative Solid Waste Impacts. Cumulative development would generate solid waste within the permitted capacity of the SMART Station and Kirby Canyon Landfill. Cumulative development would not result in substantial deterioration of solid waste facilities. As such, cumulative impacts related to solid waste generation would be less than significant. UT-IO. Cumulative Demand. Cumulative development in the City of Palo Alto would consume additional energy and, therefore, would increase the demand for energy. The City's electrical and natural gas facilities are projected to have adequate capacity to serve the City's increased demand for energy. The increased level of energy demand may trigger the need for the replacement or maintenance of energy facilities. However, genera] replacement and maintenance of energy facilities is expected and would comply with applicable environmental regulations. Therefore, cumulative development would not have a significant cumulative impact related to energy demand and energy facilities. Impact Significance Without Mitigation LTS LTS NI = No Impact LTS = Less-thall-Significant S-92 None required. None required. S = Significant Mitigation Measures SU= Significant Unavoidable Impact Significance 'Vith Mitigation N/A N/A Stanford University Medical Cellter Facilities Rellel-val and Replacement Dralt EIR Summary JArlVIS FAY DOPORTO GIBSON,LLP LAND 11)[ At~D lOCAL GOV[R~JM(:\T LAW TO: Cara Silver FROM: Senior Assistant City Attorney City of Palo Alto Rick W. Jarvis Benjamin P. Pay 475 14th St., Suite 260 Oakland, CA 94612 tviain: 510-238··1400 Fax: 510-238 -1404 www.jarvisfay.com ATTACHMENT E RE: Stanford University Medical Center Proposed Expansion - City· Authority to Impose Employee Trip Reduction Programs DATE: July 2,2010 The Stanford University Medical Center ("SUMC") has filed an application with the City of Palo Alto ("the City") to expand its hospital facilities located within the City. This proposed expansion is referred to herein as "the Project." In order to approve the Project, the City will need to amend its Comprehensive Plan and rezone the Project site to accommodate the increase in density. The Draft Environmental Impact Report ("D EIR") for the Proj ect has concluded that it will result in a significant increase in traffic trips, thus resulting in significant impacts to various intersections both within and outside the City. The DEIR has also concluded that the increase in traffic will result in other significant environmental impact relating to air quality and climate change. To help mitigate these impacts, the DEIR identifies a proposed mitigation measure (TR-2.3) which would require SUMC to enhance its Travel Demand Management ("TDM") Program, to reduce vehicle trips by SUMC employees. The TDM Program would include the provision of Caltrain Go Passes to all SUMC employees. The DEIR concludes that implementation of this mitigation measure will mitigate to a level of "less than significant" the Project's impacts at several intersections. SUMC originally suggested the Go Pass measure, and continues to reaffirm its commitment to including such a measure, as part of a negotiated development agreement with the City. However, the question has nonetheless come up whether the City has the independent legal authority to impose this requirement, and other TDM measures, were SUMC not to otherwise agree to them. This question has arisen in light of section 40717.9 of the Health and Safety Code (hereafter "Section 40717.9"), which purports to prohibit "any ... public agency" from "requir[ing] an employer to implement an employee trip reduction program unless the program is expressly Re: SUMC Proposed Expansion -City Authority to Impose Employee Trip Reduction Programs Date: July 2, 2010 Page: 2 required by federal law .. ~ ." This memorandum analyzes that question and concludes that the City does have such authority, notwithstanding this apparent prohibition. Before proceeding to the analysis, it should be noted that, even if the City did not have the authority to impose such TOM measures, it was nonetheless appropriate for the OEIR to identify them as potential mitigation measures. EIRs are required to identify all potentially feasible mitigation measures. In this case, TOM measures clearly are "potentially feasible" given SUMC's expressed willingness to agree to them. Further, even if SUMC were not so willing, and even if Section 40717.9 prohibited the City from imposing them, these TOM measures nonetheless could be deemed to be "potentially feasible" given the very real possibility that the Legislature could amend or repeal Section 40717.9 sometime during the buildout of the Project. AB 32 and other recent legislative enactments suggest that Section 40717.9 is very much contrary to current legislative policy. Further, the OEIR certainly demonstrates that such TOM measures can be extremely effective in reducing traffic congestion. Furthermore, it should also be noted that it is becoming increasingly common for other jurisdictions to impose TOM requirements on new development to mitigate traffic, air quality, and greenhouse gas related impacts. For example, the City/County Association of Governments of San Mateo County (C/CAG) requires that if the project generates 100 or more peak: hour trips, "local jurisdictions must ensure that the developer and/or tenants will reduce the demand for all new peak hour trips (including the first 100 trips) projected to be generated by the development." (Revised C/CAG Guidelines for the Implementation of the Land Use Component of the Congestion Management Program, September 21,2004.) Question Presented Ooes the City have the legal authority to require SUMC to implement an employee trip reduction program and other TOM measures in order to mitigate the traffic, air quality, and climate change impacts of the Project prior to approving the Project? Short Answer As a charter city, the City has the power to require SUMC to implement an employee trip reduction program to mitigate traffic congestion, despite the apparent prohibition in Section 40717.9. Moreover, even if Section 40717.9 applied to the City, it would not prohibit the City from refusing to amend its Comprehensive Plan and zoning ordinances to accommodate the Project based upon its adverse traffic, air quality, and climate change impacts. Thus, the City could effectively and appropriately require SUMC to agree to such mitigation before granting SUMC the legislative approvals it needs for the Project to go forward. Re: SUMC Proposed Expansion City Authority to Impose Employee Trip Reduction Programs Date: July 2, 2010 Page: 3 Discussion A. Because Palo Alto is a charter city, it is not barred by Section 40717.9 from requiring SUMC to implement an employee trip reduction program to mitigate the traffic congestion impact of the Medical Center's expansion .. On its face, Section 40717.9 appears to prohibit the City from requiring SUMC to adopt an employee trip reduction program. It states: "Notwithstanding Section 40454, 40457,40717,40717.1, or 40717.5, or any other provision of law, a district, congestion management agency, as defined in subdivision (b) of Section 65088.1 of the Government Code, or any other public agency shall not require an employer to implement an employee trip reduction program unless the program is expressly required by federal law and the elimination of the program will result in the imposition of federal sanctions, including, but not limited to, the loss of federal funds for transportation purposes."The City is a "public agency," and it is not required by federal law to require enlployee trip reduction programs. Therefore Section 40717.9 appears to prohibit the City from requiring such programs.- The California Constitution grants all cities and counties the power (known as the local "police power") to "make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws." (Cal. Const. art. 11, § 7.) In addition, the California Constitution actually allows charter cities legislative authority over purely "municipal affairs" even if the charter city's legislation is in conflict with general state laws. (See Baron v. City of Los Angeles (1970) 2 Cal.3d 535.) The City of Palo Alto is a charter city. Thus, the question is whether Section 40717.9 applies to charter cities such as the City of Palo Alto. We conclude that it does not. For a state law to apply to a charter city such as Palo Alto, the state law must be "reasonably related to the identified statewide concern and narrowly tailored to avoid infringing legitimate municipal affairs." (City of Watsonville v. State Department of Health Services (2005) 133 Cal.App.4th 875, 888.) "The courts must be mindful that 'the sweep of the state's protective measures may be no broader than its interest." (Fielder v. City of Los Angeles (1993) 14 Cal.App.4th 137, 146 quoting California Federal Savings and Loan Association v. City of Los Angeles (1991) 54 Cal.3d 1, 25.) "[I]n articulating the test for preemption [of a charter city] the Supreme Court was concerned with ensuring that a state law does not infringe legitimate municipal interests other than that which the state law purports to regulate as a statewide interest." (City of Watsonville v. State Department of Health Services 133 Cal.App.4th. at p. 889.) We believe that Section 40717.9 fails this test because it impinges on two important municipal interests: traffic congestion and zoning. As a result, Section 40717.9 is not sufficiently narrowly tailored to apply to a charter city. Re: SUMC Proposed Expansion City Authority to Impose Employee Trip Reduction Programs Date: July 2, 2010 Page: 4 The mitigation of traffic congestion caused by development is a legitimate municipal concern. "[T]raffic congestion is a local problenl that cities ordinarily are authorized to address." (O'Connell v. City of Stockton (2007) 41 Ca1.4th 1061, 1076.) "There would not seem to be much question but that regulation of land use, particularly in relation to ... vehicular congestion ... is of vital concern to a municipality." (Hirsch v. City of Mountain View (1976) 64 Ca1.App.3d 425, 430 quoting Codding Enterprises v. City of Merced (1974) 42 Cal.App.3d 375,378.) It might be argued that traffic congestion is a matter of statewide concern and not a municipal affair, in light of court rulings that "the state has preempted the field of vehicular traffic regulation." (Rumfordv. City of Berkeley (1982) 31 Cal.3d 545,548). "The right of the state to exclusive control of vehicular traffic on pUblic streets has been recognized for more than forty years. While local citizens quite naturally are especially interested in the traffic on the streets in their particular locality, the control of such traffic is now a nlatter of statewide concern." (Mervyne v. Acker (1961) 189 Cal.App.2d 558, 561.) However, we believe that only the "control of vehicular traffic" -the rules for how vehicles can be used on the public roads -is a matter of statewide concern. The reduction of traffic congestion is not part of this statewide concern. The cases addressing the "statewide concern" in traffic control are distinguishable from cases dealing with the local interest in the mitigation oftraJfic congestion. For example, Ex Parte Daniels, (1920) 183 Cal. 636, concerned speed limits; Barajas v. City of Anaheim, (1993) 15 CaLApp.4th 1808, concerned the regulation of sales from cars parked on public streets; Los Angeles Railway Corp. v. City of Los Angeles (1940) 16 Ca1.2d 779, concerned the number of drivers required in a streetcar; and Brierton v. Department of Motor Vehicles, (2005) 130 Cal.App.4th 499, concerned the power of a university police department to enforce traffic laws. Although the State has preempted the specific rules of how vehicles can be operated and used on the public streets, it has not preempted how cities can address traffic congestion caused by development. Consequently, none of these cases contradict the cases that have held that traffic congestion is a legitimate municipal concern. (See, e.g., O'Connell v. City o/Stockton, supra, 41 Ca1.4th 1061, 1076; Hirsch v. City of Mountain View, supra, 64 Cal.App.3d 425, 430; Codding Enterprises v. City of Merced, supra, 42 Cal.App.3d 375, 378.) Land use regulation, zoning in particular, has long been held to be a municipal affair. "Land use regulation in California historically has been a function of local government." (Big Creek Lumber v. County of Santa Cruz (2006) 38 Ca1.4th 1139, 1151.) The chapter of the Government Code that contains zoning regulations (Chapter 4 of Division 1 of Title 7) specifically provides that it does not apply to charter cities. (Gov. Code § 65803.) Because Section 40717.9 impinges on two municipal concerns -traffic congestion and zoning­ it is our opinion that it is not sufficiently narrowly tailored to further a matter of statewide concern, and therefore its prohibition of employee trip reduction programs does not apply to charter cities. Indeed, the fact that Section 40717.9 appears in a section of the Health and Safety Code containing Re: SUMC Proposed Expansion City Authority to Impose Employee Trip Reduction Programs Date: July 2, 20 I 0 Page: 5 regulations applicable to air pollution control districts suggests that the Legislature was really not considering local concerns about traffic congestion or zoning.l Because traffic congestion is a particularly local problem that varies significantly across the state, from low density rural areas to high density urban areas, a court would be particularly hesitant to hold that Section 40717.9 preempts the City's ability to use an employee trip reduction program to mitigate the traffic congestion caused by new development. "We have been particularly reluctant to infer legislatiVe intent to preempt a field covered by municipal regulation when there is a significant local interest to be served that may differ from one locality to another. The common thread of the cases is that if there is a significant local interest to be served which may differ from one locality to another then the presumption favors the validity of the local ordinance against an attack of state preemption. Thus, when local government regulates in an area over which it traditionally has exercised control, such as the location of particular land uses, California courts will presume, absent a clear indication of preemptive intent from the Legislature, that such regulation is not preempted by state statute." (Big Creek Lumber v. County of Santa Cruz (2006) 38 Ca1.4th 1139, 1149.) It should be noted that, while 0 'Connell v. City of Stockton, supra, 41 Ca1.4th 1061, recognized that "traffic congestion is a local problem that cities ordinarily are authorized to address," it held that "they may not do so by means of an ordinance that, by allowing forfeiture of a vehicle used to commit a specific state law violation, impinges on an area fully occupied or exclusively covered by state law." (Id. at p. 1076.) The court, however, reached this conclusion with no analysis, and the Stockton ordinance directly impinged on an area of law that is fully covered by state law. In contrast, a employee trip reduction program imposed to mitigate traffic congestion would not impinge on the State's regulation of vehicle emissions. It therefore remains that, as a charter city, Palo Alto should be able to require SUMC to inlplement an employee trip reduction program to mitigate the traffic congestion that would be caused by the expansion of its medical center. B. Even if section 40717.9 applied to the City, the City could require SUMC to mitigate the traffic impacts of the medical center expansion, and an employee trip reduction program could be one of the mitigation methods. Section 40717.9 prohibits a public agency from requiring an employer to implement an employee trip reduction program. However, it does not prevent a city from requiring that traffic congestion impacts of new development be mitigated, and it does not prevent an employee trip reduction program from being selected by a developer as a mitigation measure. lThis is evident from both the legislative history and the fact that it is placed in Part 3 ("Air Pollution Control Districts") of Division 26 ("Air Resources") of the Health and Safety Code. Re: SUMC Proposed Expansion -City Authority to Impose Employee Trip Reduction Programs Date: July 2, 2010 Page: 6 In a 1996 opinion, the Attorney General concluded that an air pollution control district is not prohibited by Section 40717.9 from offering a trip reduction program as one of several options that employers can choose from to reduce emissions. (79 Ops. Cal. Atty. Gen. 214 (1996).) The Attorney General explained that Section 40717.9 only prohibits an air district from requiring that an employer adopt a trip reduction program. It does not prohibit an employer from deciding to adopt one. Consequently, provided the employer is given multiple options, one of the options can be a trip reduction program. The Attorney General's reasoning would apply with even more force to the City. As noted earlier, Section 40717.9 is directed at pollution control districts. As discussed above, its application to a charter city that is trying to mitigate the traffic congestion impact of new development -not trying to mitigate vehicle emissions -is very questionable. Moreover, the zoning change SUMC needs is a quasi-legislative act. (Corona-Norco Unified School District v. City of Corona (1993) 17 Cal.AppAth 985, 992.) The City has more discretion over whether to grant or deny the request than it would have with a quasi-judicial decision. "[Z]oning decisions are afforded more deference than adjudicative decisions made by a governmental agency." (William S. Hart Union High School District v. Regional Planning Commission of the County of Los Angeles (1991) 226 Cal.App.3d 1612,1624; Mira Development Corporation of San Diego v. City of San Diego (1988) 205 Cal.App.3d 1201, 1218 ("Zoning decisions are afforded more deference than an agency's adjudicative decisions.") As a result, the City could elect to deny the zoning change on the grounds that it would cause too much traffic congestion. However, the City could also decide that the traffic congestion impact would be sufficiently mitigated by an employee trip reduction program. In doing so, the City would not be requiring SUMC to adopt an employee trip reduction program. SUMC would be voluntarily agreeing to a trip reduction program as part of its voluntary application for a zoning change. Indeed, in this case, SUMC has stated that it is willing to "voluntarily" implement certain TDM measures, particularly the Go Pass measures. Conclusion Section 40717.9 does not apply to the City because it is a charter city. Furthermore, even if it did apply, it would not require the City to amend its Comprehensive Plan and zoning ordinances to accommodate the Project based upon the Project's traffic, air quality, and climate change impacts, in the absence of an agreement by SUMC to the implementation ofTDM measures to partially mitigate such impacts. Given this backdrop, the Council has broad discretion to determine whether the proposed TDM measures are feasible and whether they will effectively mitigate the identified impacts. J:\Clients\156 [City of Palo Alto]\OOlb [EIR]\Memo\TDM Memo 07-02-10.wpd