CC Resolution 12962 - Certifying a Final Programmatic Environmental Impact Report12962
FINAL
ENVIRONMENTAL IMPACT REPORT
FOR THE
ENVISION CAMPBELL GENERAL PLAN AND HOUSING
ELEMENT UPDATE
(SCH: 2022030566)
MARCH 2023
Prepared for:
City of Campbell
City Hall 70 N. First St.
Campbell, CA 95008
Prepared by:
De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
D e N o v o P l a n n i n g G r o u p
A L a n d U s e P l a n n i n g , D e s i g n , a n d E n v i r o n m e n t a l F i r m
FINAL
ENVIRONMENTAL IMPACT REPORT
FOR THE
ENVISION CAMPBELL GENERAL PLAN AND HOUSING ELEMENT
UPDATE
(SCH: 2022030566)
MARCH 2023
Prepared for:
City of Campbell
City Hall 70 N. First St.
Campbell, CA 95008
Prepared by:
De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
TABLE OF CONTENTS TOC
Final Environmental Impact Report – Campbell General Plan Update TOC-1
FINAL EIR
Chapter Page Number
Executive Summary ..................................................................................................................... ES-1
1.0 Introduction .......................................................................................................................... 1.0-1
1.1 Purpose and Intended Uses of the EIR .................................................................... 1.0-1
1.2 Environmental Review Process ............................................................................... 1.0-2
1.3 Organization of the Final EIR ................................................................................... 1.0-4
2.0 Comments on Draft EIR and Responses ............................................................................... 2.0-1
2.1 Introduction ............................................................................................................. 2.0-1
2.2 List of Commenters ................................................................................................. 2.0-1
2.3 Comments and Responses ...................................................................................... 2.0-1
3.0 Errata .................................................................................................................................... 3.0-1
3.1 Revisions to the Draft EIR ........................................................................................ 3.0-1
Table Page Number
Table 2.0-1: List of Commenters on Draft EIR ............................................................................ 2.0-1
TOC TABLE OF CONTENTS
TOC-2 Final Environmental Impact Report – Campbell General Plan Update
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EXECUTIVE SUMMARY ES
Final Environmental Impact Report – Campbell General Plan Update ES-1
INTRODUCTION
The City of Campbell (City) has determined that a program-level environmental impact report (EIR)
is required for the proposed General Plan (General Plan, or project) pursuant to the requirements
of the California Environmental Quality Act (CEQA). CEQA requires the preparation of an EIR prior to
approving any project, which may have a significant impact on the environment. For the purposes
of CEQA, the term "Project" refers to the whole of an action, which has the potential for resulting in
a direct physical change or a reasonably foreseeable indirect physical change in the environment
(CEQA Guidelines Section 15378[a]).
A Program EIR is an EIR which examines the environmental impacts of an agency plan, policy, or
regulatory program, such as a general plan update. Program EIRs analyze broad environmental
impacts of the program, with the acknowledgement that site-specific environmental review may be
required for particular aspects of the program, or particular development projects that may occur
in the future.
The City of Campbell circulated a Notice of Preparation (NOP) of an EIR for the proposed Project on
March 23, 2022 to trustee and responsible agencies, the State Clearinghouse, and the public. A
scoping meeting was held on April 12, 2022 at the City of Campbell City Hall. Public comments on
the NOP related to the EIR were presented or submitted during the scoping meeting. During the 30-
day public review period for the NOP, which ended on April 25, 2022, nine written comment letters
were received on the NOP. A summary of the NOP commenters is provided later in this chapter.
The NOP and all comments received on the NOP are presented in Appendix A of the DEIR.
Campbell published a public Notice of Availability (NOA) for the Draft EIR on September 12, 2022,
inviting comment from the general public, agencies, organizations, and other interested parties. The
NOA was filed with the State Clearinghouse (SCH# 2022030566) and was published in the Santa
Clara County Clerk’s office and the Metro Silicon Valley Newspaper, pursuant to the public noticing
requirements of CEQA. The Draft EIR was available for public review from September 12, 2022,
through October 28, 2022. The Public Draft General Plan and Housing Element were also
available for public review and comment during this time period.
This Final EIR was prepared to address comments received in response to the Draft EIR. The City has
prepared a written response to the Draft EIR comments, and made changes to the Draft EIR where
warranted. The responses to the comments are provided in this Final EIR in Section 2.0, and all
changes to the text of the Draft EIR are summarized in Section 3.0. Responses to comments received
during the comment period for the Draft EIR do not involve any new significant impacts or
“significant new information” that would require recirculation of the Draft EIR pursuant to CEQA
Guidelines Section 15088.5.
ES EXECUTIVE SUMMARY
ES-2 Final Environmental Impact Report – Campbell General Plan Update
PROJECT DESCRIPTION
The General Plan, which includes the updated Housing Element, is the overarching policy document
that guides land use, housing, transportation, open space, public safety, community services, and
other policy decisions throughout Campbell. The Campbell General Plan includes all of the State-
mandated elements, as well as optional elements and issue areas, including Community Design,
Public Facilities, Economic and Fiscal Sustainability, Community Health and Wellness, and
Sustainability.
The General Plan sets out the goals, policies, and actions in each of these areas, serves as a policy
guide for how the City will make key planning decisions in the future, and guides how the City will
interact with Santa Clara County, surrounding cities, and other local, regional, State, and Federal
agencies.
As part of the General Plan Update, the City and the consultant team prepared several support
documents including the Existing Conditions Report, Land Use Alternatives Report and Outreach
Reports that serve as the building blocks for the General Plan and analyze the environmental impacts
associated with implementing the General Plan.
Refer to DEIR Chapter 2.0 (Project Description) of the Draft EIR for a more comprehensive
description of the details of the proposed Project, and Chapter 1.0 (Introduction) of the DEIR for
further information related to reposts prepared throughout the update process.
ALTERNATIVES TO THE PROPOSED PROJECT
Section 15126.6 of the CEQA Guidelines requires an EIR to describe a reasonable range of
alternatives to the Project or to the location of the Project which would reduce or avoid significant
impacts, and which could feasibly accomplish the basic objectives of the proposed Project. The
alternatives analyzed in this EIR are briefly described as follows:
• Alternative 1: No Project Alternative. Under Alternative 1, the City would not adopt the
General Plan Update. The existing Campbell General Plan would continue to be
implemented and no changes to the General Plan, including the Land Use Map, Circulation
Diagram, goals, policies, or actions would occur. Subsequent projects, such as amending
the Municipal Code (including the zoning map), would not occur. The Existing General Plan
Land Use Map is shown on Figure 5.0-1.
• Alternative 2: Modified Project Alternative. Under Alternative 2, the City would adopt the
updated General Plan policy document, but would retain the existing land use map. This
alternative would result in the same growth as the existing General Plan Alternative 1, but
would implement the updated goals, policies, and actions found in the General Plan Update.
This Alternative would result in less residential growth than the proposed Project or
Alternative 3.
EXECUTIVE SUMMARY ES
ES-3 Final Environmental Impact Report – Campbell General Plan Update
• Alternative 3: Corridor Enhancements: Alternative 3 is a residential and employment
growth-oriented option, which identifies the Bascom and Hamilton corridors for mixed use
development, revitalization, and appropriate transitions from the more intense urban
development densities located adjacent to Campbell in the City of San Jose. This alternative
also promotes and encourages additional high tech and office uses within the Research and
Development land use designation. This alternative would allow for more residential and
employment growth than the existing General Plan and Alternative 2. Figure 5.0-2 depicts
the Land Use Map proposed for Alternative 3. This alternative was developed as part of the
City’s review of potential growth strategies and land use changes during development of the
Preferred Land Use Map.
Alternatives are described in detail in Section 5.0 of the Draft EIR. As summarized in Chapter 5.0 of
the Draft EIR, the proposed Project is the environmentally superior alternative when looked at in
terms of the potential to reduce significant environmental impacts identified throughout this EIR.
All of the alternatives fail to reduce any significant and unavoidable impacts to a less than significant
level. Throughout the preparation of the General Plan Update, the City Council, Planning
Commission, and GPAC all expressed a desire and commitment to ensuring that the General Plan
not only reflect the community’s values and priorities, but also serve as a self-mitigating document
and avoid significant environmental impacts to the greatest extent feasible. To that end, the
proposed General Plan includes the ful range of feasible minimization policies and actions to reduce
potential impacts to the greatest extent possible.
COMMENTS RECEIVED
The Draft EIR addresses environmental impacts associated with the proposed Project that were
known to the City, raised during the Notice of Preparation (NOP) process, or raised during
preparation of the Draft EIR. The Draft EIR discusses potentially significant impacts associated with
aesthetics, agriculture and forest resources, air quality, biological resources, cultural and tribal
cultural resources, geology, greenhouse gas emissions and energy, hazards and hazardous materials,
hydrology and water quality, land use planning and population/housing, mineral resources, noise,
public services and recreation, transportation, utilities and service systems, wildfire, and cumulative
impacts.
NOP Comments
The City received 9 written comment letters on the NOP. Additionally, oral comments were also
received during the Public Scoping Meeting held on April 12, 2022. Copies of these letters are
provided in Appendix A of this Draft EIR and the comments are briefly summarized below.
• Native American Heritage Commission: The Native American Heritage Commission provided
direction regarding tribal consultation in accordance with Assembly Bill 52 and Senate Bill
18.
ES EXECUTIVE SUMMARY
ES-4 Final Environmental Impact Report – Campbell General Plan Update
• Santa Clara Valley Audubon Society: The Audubon Society suggested information related to
bird safe design and light pollution impacts.
• California Department of Fish and Wildlife (CDFW): The CDFW offers comments and
recommendations to assist the City in adequately identifying and/or mitigating the Project’s
significant, or potentially significant, direct and indirect impacts on fish and wildlife
(biological) resources.
• Office of Planning & Environmental Analysis Department of Toxic Substances Control: DTSC
recommends that the following issues be evaluated: hazardous wastes/substances,
contaminated soils, and demolition surveys.
• California Department of Transportation (Caltrans): Caltrans suggested information to
include in the EIR traffic study and provided input with respect to content of the General
Plan related to Travel Demand Analysis planning, Transportation Impact Fees, and equitable
access.
• Valley Transportation Authority (VTA): VTA provided comments related to the reduction of
Vehicle Miles Traveled, Transportation Network Assumptions, and equity planning.
• Sierra Club Loma Prieta Chapter: The Sierra Club provided comments related to
Biotechnology developments and siting issues in shoreline areas identified as flood zones,
and sea levels rise and 100-year flood events, which can create vulnerabilities for the Bay
ecology.
• Valley Water: Valley Water Provided comments related to water supplies, groundwater
recharge, storm water quality, and the future coordination to ensure that there are
adequate water supplies to serve proposed and future development
• Planning Commission (PC) Scoping Meeting Notes: comments offered during the public
scoping meeting included topics related to: water resources, fire, GHG, noise, air quality,
traffic, public services and utilities, biological resources, and lighting standards.
• Nancy Tepperman: The commenter is concerned about maintaining community character
and roadway safety. This commenter also noted that additional allowed development would
necessitate the need for more parks, and current development has pressured existing parks
within the city.
EXECUTIVE SUMMARY ES
ES-5 Final Environmental Impact Report – Campbell General Plan Update
Draft EIR Comments
During the Draft EIR review process, the City received comments from the following public agencies,
organizations, or individuals:
• Valley Water
• California Department of Fish and Wildlife (CDFW)
• Santa Clara County Fire Department (SCCFD).
• Tim Pasquinelli (Consigliare - Campbell Technology Pk LLC)
• Vikki Essert
• Julie Schaer, WVCWA and Vishakha Atre, SCVURPPP
• Liz Gibbons
• Stacie Wolny
Acting as lead agency, the City of Campbell has prepared a response to the Draft EIR comments. The
responses to the comments are provided in this Final EIR in Section 2.0 (Comments on Draft EIR and
Responses) and all changes to the content of the Draft EIR are summarized in Section 3.0 (Errata).
ES EXECUTIVE SUMMARY
ES-6 Final Environmental Impact Report – Campbell General Plan Update
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INTRODUCTION 1.0
Final Environmental Impact Report – Campbell General Plan Update 1.0-1
This Final Environmental Impact Report (FEIR) was prepared in accordance with the California
Environmental Quality Act (CEQA) and the State CEQA Guidelines (Section 15132). The City of
Campbell is the lead agency for the environmental review of the Campbell General Plan and Housing
Element Update (General Plan, General Plan Update, Envision Campbell, or Project) and has the
principal responsibility for approving the Project. This FEIR assesses the expected environmental
impacts resulting from approval and adoption of the Campbell General Plan and responds to
comments received on the Draft EIR.
The Campbell General Plan Update is the overarching policy document that guides land use, housing,
transportation, open space, public safety, community services, and other policy decisions
throughout Campbell. The General Plan includes the seven elements mandated by State law, to the
extent that they are relevant locally, including: Circulation, Conservation, Housing, Land Use, Noise,
Open Space, and Safety. The City may also address other topics of interest. The Campbell General
Plan includes all of the State-mandated elements, as well as optional elements and issue areas,
including Community Design, Public Facilities, Economic and Fiscal Sustainability, Community Health
and Wellness, and Sustainability.
The General Plan sets out the goals, policies, and actions in each of these areas, serves as a policy
guide for how the City will make key planning decisions in the future, and guides how the City will
interact with Santa Clara County, surrounding cities, and other local, regional, State, and Federal
agencies.
As part of the General Plan Update, the City and the consultant team prepared several support
documents including the Existing Conditions Report, Land Use Alternatives Report and Outreach
Reports that serve as the building blocks for the General Plan and analyze the environmental impacts
associated with implementing the General Plan.
Refer to DEIR Chapter 2.0 (Project Description) of the Draft EIR for a more comprehensive
description of the details of the proposed Project, and Chapter 1.0 (Introduction) of the DEIR for
further information related to reposts prepared throughout the update process.
1.1 PURPOSE AND INTENDED USES OF THE EIR
CEQA REQUIREMENTS FOR A FINAL EIR
This FEIR for the Campbell General Plan has been prepared in accordance with the California
Environmental Quality Act (CEQA) and State CEQA Guidelines. State CEQA Guidelines Section 15132
requires that an FEIR consist of the following:
• the Draft Environmental Impact Report (Draft EIR) or a revision of the draft;
• comments and recommendations received on the Draft EIR, either verbatim or in summary;
• a list of persons, organizations, and public agencies commenting on the Draft EIR;
• the responses of the lead agency to significant environmental concerns raised in the review
and consultation process; and
• any other information added by the lead agency.
1.0 INTRODUCTION
1.0-2 Final Environmental Impact Report – Campbell General Plan Update
In accordance with State CEQA Guidelines Section 15132(a), the Draft EIR is incorporated by
reference into this Final EIR.
An EIR must disclose the expected environmental impacts, including impacts that cannot be avoided,
growth-inducing effects, impacts found not to be significant, and significant cumulative impacts, as
well as identify mitigation measures and alternatives to the proposed Project that could reduce or
avoid its adverse environmental impacts. CEQA requires government agencies to consider and,
where feasible, minimize environmental impacts of proposed Projects, and obligates them to
balance a variety of public objectives, including economic, environmental, and social factors.
PURPOSE AND USE
The City of Campbell, as the lead agency, has prepared this Final EIR to provide the public and
responsible and trustee agencies with an objective analysis of the potential environmental impacts
resulting from approval and implementation of the General Plan. Responsible and trustee agencies
that may use the EIR are identified in Chapter 1.0 of the Draft EIR.
The environmental review process enables interested parties to evaluate the proposed Project in
terms of its environmental consequences, to examine and recommend methods to eliminate or
reduce potential adverse impacts, and to consider a reasonable range of alternatives to the Project.
While CEQA requires that consideration be given to avoiding adverse environmental effects, the lead
agency must balance adverse environmental effects against other public objectives, including the
economic and social benefits of a project, in determining whether a project should be approved.
This EIR will be used as the primary environmental document to evaluate all subsequent planning
and permitting actions associated with the proposed Project. Subsequent actions that may be
associated with the proposed Project are identified in Chapter 2.0 (Project Description) of the Draft
EIR. This EIR may also be used by other agencies within Santa Clara County, including the Local
Agency Formation Commission (LAFCO), which may use this EIR during the preparation of
environmental documents related to annexations, and Municipal Service Reviews in the Planning
Area.
1.2 ENVIRONMENTAL REVIEW PROCESS
The review and certification process for the EIR has involved, or will involve, the following general
procedural steps:
NOTICE OF PREPARATION
The City of Campbell circulated a Notice of Preparation (NOP) of an EIR for the proposed Project on
March 23, 2022 to trustee and responsible agencies, the State Clearinghouse, and the public. A
scoping meeting was held on April 12, 2022 at the City of Campbell City Hall. Public comments on
the NOP related to the EIR were presented or submitted during the scoping meeting. During the 30-
day public review period for the NOP, which ended on April 25, 2022, 9 written comment letters
were received on the NOP. A summary of the NOP commenters is provided later in this chapter.
The NOP and all comments received on the NOP are presented in Appendix A of the DEIR.
INTRODUCTION 1.0
Final Environmental Impact Report – Campbell General Plan Update 1.0-3
NOTICE OF AVAILABILITY AND DRAFT EIR
Campbell published a public Notice of Availability (NOA) for the Draft EIR on September 12, 2022,
inviting comment from the general public, agencies, organizations, and other interested parties. The
NOA was filed with the State Clearinghouse (SCH# 2022030566) and was published in the Santa Clara
County Clerk’s office and the Mercury News, pursuant to the public noticing requirements of CEQA.
The Draft EIR was available for public review from September 12, 2022, through October 28, 2022.
The Public Draft General Plan was also available for public review and comment during this time
period.
The Draft EIR contains a description of the Project, description of the environmental setting,
identification of Project impacts, and mitigation/minimization measures for impacts, as well as an
analysis of Project alternatives, identification of significant irreversible environmental changes,
growth-inducing impacts, and cumulative impacts. The Draft EIR identifies issues determined to
have no impact or a less than significant impact, and provides detailed analysis of potentially
significant and significant impacts. Comments received in response to the NOP were considered in
preparing the analysis in the Draft EIR.
RESPONSE TO COMMENTS/FINAL EIR
The City of Campbell received eight comment letters regarding the Draft General Plan and Draft EIR
from public agencies, organizations, and members of the public during the 45-day review period.
In accordance with CEQA Guidelines Section 15088, this Final EIR responds to the written comments
received on the Draft EIR. The Final EIR also contains minor edits to the Draft EIR, which are included
in Chapter 3.0 (Errata). This document and the Draft EIR, as amended herein, constitutes the Final
EIR.
CERTIFICATION OF THE EIR/PROJECT CONSIDERATION
The Campbell City Council will review and consider the Final EIR. If the City Council finds that the
Final EIR is "adequate and complete," then it may certify it in accordance with CEQA. The rule of
adequacy generally holds that an EIR can be certified if:
1) The EIR shows a good faith effort at full disclosure of environmental information; and
2) The EIR provides sufficient analysis to allow decisions to be made regarding the proposed
Project in contemplation of environmental considerations.
Upon review and consideration of the Final EIR, the Campbell City Council may take action to
approve, revise, or reject the Project. A decision to approve the Campbell General Plan and Housing
Element, for which this EIR identifies significant environmental effects, must be accompanied by
written findings in accordance with State CEQA Guidelines Sections 15091 and 15093.
1.0 INTRODUCTION
1.0-4 Final Environmental Impact Report – Campbell General Plan Update
Policies and actions to minimize potential environmental impacts have been incorporated into the
Project, to the extent feasible. No additional mitigation is feasible or available, as described in
Chapters 3.1 through 4.0 of the Draft EIR. The annual report on General Plan status required
pursuant to the Government Code will serve as the monitoring and reporting program for the
Project.
1.3 ORGANIZATION OF THE FINAL EIR
This Final EIR has been prepared consistent with Section 15132 of the State CEQA Guidelines, which
identifies the content requirements for Final EIRs. This Final EIR is organized in the following
manner:
CHAPTER 1.0 – INTRODUCTION
Chapter 1.0 briefly describes the purpose of the environmental evaluation, identifies the lead
agency, summarizes the process associated with preparation and certification of an EIR, and
identifies the content requirements and organization of the Final EIR.
CHAPTER 2.0 – COMMENTS ON DRAFT EIR AND RESPONSES
Chapter 2.0 provides a list of commenters, copies of written comments made on the Draft EIR (coded
for reference), and responses to those written comments.
CHAPTER 3.0 – ERRATA
Chapter 3.0 consists of minor revisions to the Draft EIR in response to comments on the Draft EIR.
The revisions to the Draft EIR do not change the intent or content of the analysis, mitigation
approaches, or increase the severity of any impact or identify any new impacts.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-1
2.1 INTRODUCTION
No new significant environmental impacts or issues, beyond those already covered in the Draft EIR for
the Envision Campbell General Plan Environmental Impact Report (DEIR), were raised during the
comment period. Responses to comments received during the comment period do not involve any new
significant impacts or add “significant new information” that would require recirculation of the Draft EIR
pursuant to CEQA Guidelines Section 15088.5.
CEQA Guidelines Section 15088.5 states that: New information added to an EIR is not “significant” unless
the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a
substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an
effect (including a feasible project alternative) that the project’s proponents have declined to implement.
Sections 2.0 and 3.0 of this Final EIR include information that has been added to the EIR since the close
of the public review period in the form of responses to comments and revisions.
2.2 LIST OF COMMENTERS
Table 2.0-1 lists the comments on the Draft EIR that were submitted to the City of Campbell (City) during
the 45-day public review period for the Draft EIR. The assigned comment letter or number, letter date,
letter author, and affiliation, if presented in the comment letter or if representing a public agency, are
also listed. Letters received are coded with letters (A, B, etc.).
TABLE 2.0-1 LIST OF COMMENTERS ON DRAFT EIR
RESPONSE
LETTER INDIVIDUAL /SIGNATORY AGENCY OR GROUP AFFILIATION LETTER
DATE
A Lisa Brancatelli Valley Water October 28, 2022 October 28,
2022
B Erin Chappell California Department of Fish and Wildlife (CDFW) October 28,
2022
C N/A Santa Clara County Fire Department (SCCFD) N/A
D Tim Pasquinelli Consigliare - Campbell Technology Pk LLC) October
27th, 2022
E Vikki Essert September
23, 2022
F Julie Schaer, WVCWA
and Vishakha Atre, SCVURPPP November 1,
2022
G Liz Gibbons October 28,
2022
H Stacie Wolny October 27,
2022
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-2 Final Environmental Impact Report – Campbell General Plan Update
2.3 COMMENTS AND RESPONSES
REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT EIR
CEQA Guidelines Section 15088 requires that lead agencies evaluate and respond to all comments on the
Draft EIR that regard an environmental issue. The written response must address the significant
environmental issue raised and provide a detailed response, especially when specific comments or
suggestions (e.g., additional mitigation measures) are not accepted. In addition, the written response
must be a good faith and reasoned analysis. However, lead agencies need only to respond to significant
environmental issues associated with the project and do not need to provide all the information
requested by the commenter, as long as a good faith effort at full disclosure is made in the EIR (CEQA
Guidelines Section 15204).
CEQA Guidelines Section 15204 recommends that commenters provide detailed comments that focus on
the sufficiency of the Draft EIR in identifying and analyzing the possible environmental impacts of the
project and ways to avoid or mitigate the significant effects of the project, and that commenters provide
evidence supporting their comments. Pursuant to CEQA Guidelines Section 15064, an effect shall not be
considered significant in the absence of substantial evidence.
CEQA Guidelines Section 15088 also recommends that revisions to the Draft EIR be noted as a revision in
the Draft EIR or as a separate section of the Final EIR. Chapter 3.0 of this Final EIR identifies all revisions
to the Draft EIR.
RESPONSES TO COMMENT LETTERS
Written comments on the Draft EIR are reproduced on the following pages, along with responses to those
comments. To assist in referencing comments and responses, the following coding system is used:
Each letter is lettered or numbered (i.e., Letter A) and each comment within each letter is numbered (i.e.,
comment A-1, comment A-2).
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
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2.0 COMMENTS ON DRAFT EIR AND RESPONSES
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COMMENTS ON DRAFT EIR AND RESPONSES 2.0
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2.0 COMMENTS ON DRAFT EIR AND RESPONSES
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COMMENTS ON DRAFT EIR AND RESPONSES 2.0
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2.0 COMMENTS ON DRAFT EIR AND RESPONSES
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COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-9
Response to Letter A: Santa Clara Valley Water District “Valley Water”
A-1: Valley Water provides an introduction to the comment letter.
This comment is introductory in nature and does not address the adequacy of the Draft EIR, and
no further response is required.
A-2: The Commenter states that “References to “Santa Clara County Water District” need to be corrected
to “Santa Clara Valley Water District” or “Valley Water” throughout both the 2040 General Plan and the
draft EIR.”
The City appreciates the comments and input provided by the commenter. The City has made
text revisions to references made to the Santa Clara Valley Water District throughout the DEIR
and General Plan to clarify naming consistent with Valley Water comments. Changes are shown
in strikethrough and underline format.
DEIR Pg. 3.1-16 Santa Clara County Valley Water District
DEIR Pg. 3.1-17 Santa Clara County Valley Water District
DEIR Pg. 3.4-21 Santa Clara County Valley Water District
DEIR Pg. 3.4-27 Santa Clara County Valley Water District
DEIR Pg. 3.4-30 Santa Clara County Valley Water District
DEIR Pg. 3.4-32 Santa Clara County Valley Water District
DEIR Pg. 3.4-36 Santa Clara County Valley Water District
DEIR Pg. 3.4-37 Santa Clara County Valley Water District
Text changed represent text corrections and or grammatical errors. This text change does not
involve any new significant impacts or “significant new information” that would require
recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0 Errata
presents all text changes warranted by comments, including this text update.
A-3. The Commenter references General Plan Action COS-7 and notes that it needs to be revised in both
documents to state the correct name “Guidelines and Standards for Land Use Near Streams”, not
“Guidelines for Land Use Near Streams”.
The City appreciates the comments and input provided by the commenter. The City has made
text revisions to the General Plan and DEIR to reflect “Guidelines and Standards for Land Use
Near Streams” naming updates. Changes are shown in strikethrough and underline format.
DEIR Pg. 3.4-27 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for Land
Use Near Streams into the Zoning Code.
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-10 Final Environmental Impact Report – Campbell General Plan Update
DEIR Pg. 3.4-30 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for Land
Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-32 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for Land
Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-36 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for Land
Use Near Streams into the Zoning Code.
Text changed represent text corrections and or grammatical errors. This text change does not
involve any new significant impacts or “significant new information” that would require
recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0 Errata
presents all text changes warranted by comments, including this text update.
A-4: The commenter has provided comments and input related to various goals, policies, and actions in
the General Plan.
The City appreciates the comments and input provided by the commenter. These comments do
not address the adequacy of the Draft EIR analysis. These comments have been forwarded to
the Planning Commission and City Council for consideration. No further response in this EIR is
required.
A-5: The commenter requests that “San Tomas “Aquinas” Creek to be corrected to San Tomas “Aquino”
Creek throughout the DEIR.
The City appreciates the comments and input provided by the commenter. San Tomas Aquino
Creek, is also known as San Tomas Aquinas Creek. The U.S. Environmental Protection Agency’s
List of Waters bodies and Waters GeoViewer GeoPlatform tool labels the creek as “San Tomas
Aquinas Creek” as does GIS mapping tools and Google maps and other resources. As such, for
mapping consistency this naming was incorporated. However, The City recognizes that “San
Tomas Aquino” is also used locally.
This comment does not involve any new significant impacts or “significant new information” that
would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. No
further response in required.
A-6: The commenter requests that references to “San Jose Water Company” be removed from the text
referring to Valley Water’s comments on the NOP, including on pages ES-2, 1.0-10, 3.9-1, and 3.15-1.
The City appreciates the comments and input provided by the commenter. Text changed
represent text corrections and or grammatical errors. Changes are shown in strikethrough and
underline format.
DEIR Pg. ES-2 San Jose Water Company (Valley Water)
DEIR Pg. 1.0-10 San Jose Water Company (Valley Water)
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-11
DEIR Pg. 3.9-1 The San Jose Water Company (Valley Water)
DEIR Pg. 3.15-1 The San Jose Water Company (Valley Water)
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-7: The commenter references DEIR Page 1.0-5, and requests that Valley Water be added to the list of
Known Responsible Agencies, as work on Valley Water's right of way requires discretionary permits from
Valley Water.
The City appreciates the comments and input provided by the commenter. Text revisions adding
Valley Water to the list of agencies will be included. Changes are shown in strikethrough and
underline format.
DEIR Pg. 1.0-5
• Santa Clara Valley Water District (Valley Water)
These text revisions represent minor text corrections. This text change does not involve any new
significant impacts or “significant new information” that would require recirculation of the Draft
EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0 Errata presents all text changes
warranted by comments, including this text update. These comments do not address the
adequacy of the Draft EIR analysis.
A-8: The commenter references DEIR Pages 2.0-20 and 3.4-22, and notes that Valley Water operates as
the flood protection agency for Santa Clara County. Valley Water also provides stream stewardship and
is the wholesale water supplier throughout the county, which includes the groundwater recharge
program. Valley Water’s water supply sources include groundwater, local surface water, and recycled
water in addition to imported water. In accordance with Valley Water’s Water Resources Protection
Ordinance, any work within Valley Water's fee title property or easement or work that impacts Valley
Water’s facilities require the issuance of a Valley Water permit and requires Valley Water to be
considered a responsible agency under CEQA.
The City appreciates the comments and input provided by the commenter. As shown under
response A-7, text revisions adding Valley Water to the list of Known Responsible Agencies was
included. These comments provide additional details related to Valley Water’s role within the
County and do not address the adequacy of the Draft EIR analysis. These comments have been
forwarded to the Planning Commission and City Council for consideration. No further response
in this EIR is required.
A-9: The commenter references DEIR Section 3.1, Aesthetics and Visual Resources, and states that Valley
Water is supportive of efforts to further protect riparian areas. The language under this section should
reference the Guidelines and Standards as it guides development along the creeks.
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-12 Final Environmental Impact Report – Campbell General Plan Update
The City appreciates the comments and input provided by the commenter. These comments
provide additional details related to Valley Water’s role within the County and do not address
the adequacy of the Draft EIR analysis. These comments have been forwarded to the Planning
Commission and City Council for consideration. No further response in this EIR is required.
A-10: The commenter references Section 3.4, Biological Resources, and states “the Guidelines and
Standards were developed and issued by the Water Resources Protection Collaborative” and requests
the language under this section be revised for accuracy.
The City appreciates the comments and input provided by the commenter. Text change represent
text corrections and or grammatical errors. Updated text is included on DEIR Page 3.4-22 to
reference the Water Resources Protection Collaborative. Changes are shown in strikethrough
and underline format.
DEIR Pg. 3.4-22 The SCVWD Water Resources Protection Collaborative issued Guidelines and
Standards for Land Use Near Streams:
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-11: The commenter references DEIR Page 3.4-22, and states that this section should be revised to
clarify that Valley Water owns much of the land where the Los Gatos Creek Trail is located, but the trail
is maintained and operated under joint use agreements with the County and the City of Campbell, where
the trail is located within the City of Campbell.
The DEIR Text has been updated to identify Valley Water. These revisions are shown in
strikethrough and underline format.
DEIR Pg. 3.4-22 The SCVWD Valley Water owns much of the land where the Los Gatos Creek Trail
located in the southeast corner of Campbell and would be a responsible agency if any future
projects would result in work within its title fee property. “Responsible agencies” are public
agencies that carry out or approve a project for which a lead agency is conducting CEQA review;
responsible agencies are all agencies other than the lead agency with discretionary approval
power over the project. In the case of the proposed project, a permit from the SCVWD would be
required for any work that occurs within the Los Gatos Creek trail corridor.
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-12: The commenter references DEIR Page 3.4-28, Impact 3.4-2, and states that this section should be
revised to provide detailed information related to percolation ponds.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-13
The City appreciates the comments and input provided by the commenter. These comments
provide additional details related to Valley Water’s role within the city and county and do not
address the adequacy of the Draft EIR analysis. These comments have been forwarded to the
Planning Commission and City Council for consideration. No further response in this EIR is
required.
A-13: The commenter references DEIR Page 3.9-3 and states that this section should be revised to include
other creeks within the city including: Smith Creek and East Smith Creek.
As noted on DEIR Page 3.4-28 Impact 3.4-2 aquatic resources found in the Planning Area include:
San Tomas Aquinas Creek, Smith Creek, and Los Gatos Creek. The City appreciates the comments
and input provided by the commenter. To provide DEIR consistency the language under Creeks
and Waterways, has been revised to list Smith Creek identified by the commenter in DEIR Page
3.9-3. These revisions are shown in strikethrough and underline format.
DEIR Pg. 3.9-3. Two Several creeks are located within the City’s Planning Area: Los Gatos Creek.
and San Tomas Aquino Creek, and Smith Creek.
The City appreciates the comments and input provided by the commenter. These comments do
not address the adequacy of the Draft EIR analysis. This text change does not involve any new
significant impacts or “significant new information” that would require recirculation of the Draft
EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0 Errata presents all text changes
warranted by comments, including this text update.
A-14: The commenter references Figure 3.9-4, and states that the figure should be revised to include the
Vasona Dam.
Figure 3.9-4 shows areas within the city impacted by dam failure. The City appreciates the
comments and input provided by the commenter. The Vasona Dam inundation maps were
reviewed and do not show inundation areas within any habitable portion of the city, within any
city facility, or within areas designated by the City for future development. Vasona Dam
Inundation areas show a small portion of the W Valley Fwy (SR 85) ROW impacted. Text revisions
to describe the Vasona Dam and Inundation areas and a new Exhibit (3.9-1) is included on DEIR
Pg. 3.9.-7. These revisions are shown in strikethrough and underline format.
DEIR Pg. 3.9.-7.
Vasona Dam and reservoir is located on Los Gatos Creek within the town of Los Gatos. The Vasona
Lake Dam and Reservoir is one of six original reservoirs approved by the voters in 1934. The
reservoir capacity is 495 acre-feet. The surface area is 57 acres. The dam was completed in 1935
and new gates were installed in 1997. The dam inundation area is shown below in Exhibit 3.9-1.
As shown the inundation area impacts the SR 85 Roadway in the southernmost portion of the
Planning Area.
Exhibit 3.9-1 Vasona Dam inundation Area:
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-14 Final Environmental Impact Report – Campbell General Plan Update
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis. No further response in
this EIR is required.
A-15: The commenter references DEIR Pages 3.9-4 and 3.15-28, and notes the Los Gatos Creek Trail runs
along “creek” rather than the “river “
The City appreciates the comments and input provided by the commenter. These text revisions
represent text corrections and or grammatical errors. These revisions are shown in strikethrough
and underline format.
DEIR Pg. 3.9-4 river creek
DEIR Pg. 3.15-28 river creek
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-16: The commenter references DEIR Page 3.9-16, and Page 3.9-27, and Impact 3.9-2, that reference
Valley Water’s 2016 Groundwater Management Plan and notes that the description should be updated
to reference Valley Water’s updated 2021 Groundwater Management Plan which was adopted by the
Board of Directors on November 21, 2021.
The City appreciates the comments and input provided by the commenter. Information related
to the Groundwater Management Plan including background information and the preparation of
the Existing Conditions Report during the General Plan Update process was accesses in late 2020.
As such several reverences to the 2016 plan are also included.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-15
The Regulatory Setting and References section has been revised to include this text revisions.
These revisions are shown in strikethrough and underline format.
DEIR Pg. 3.9-16
Santa Clara and Llagas Subbasins 2016 2021 Groundwater Management Plan
The 2016 2021 Groundwater Management Plan (GWMP) for the Santa Clara and Llagas Subbasins
describes the SCVWD's comprehensive groundwater management framework, including existing
and potential actions to achieve basin sustainability goals and ensure continued sustainable
groundwater management.
DEIR Section 7.0 (Reference)
Santa Clara Valley Water District Water Supply Master Plan 2040. November 2019. Available At:
https://www.valleywater.org/sites/default/files/Water%20Supply%20Master%20Plan%202040
_11.01.2019_v2.pdf
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-17: The commenter references DEIR Page 3.9-17, and notes the acronym SVCWP needs to be corrected
to WVCWP.
The City appreciates the comments and input provided by the commenter. These text revisions
represent text corrections and or grammatical errors. These revisions are shown in strikethrough
and underline format.
DEIR Pg. 3.9-17 SVCWP WVCWP
This text change does not involve any new significant impacts or “significant new information”
that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis.
A-18: The commenter references DEIR Page 3.9-17 & 18, and page 3.15-36, Impact 3.15-5, and states the
language under these sections should be revised to note the Regional Water Quality Control Board
(RWQCB) renewed the Municipal Regional Stormwater NPDES Permit on May 11, 2022 (Order No. R2-
2022-0018, NPDES Permit No. CAS612008) and notes this new permit also changes the threshold for
compliance with Provision C.3 to 5,000 square feet from the previous 10,000 square feet.
The City appreciates the comments and input provided by the commenter. Information related
to this section including background information for the DEIR and Notice of Preparation of this
DEIR was accessed prior to the renewed the Municipal Regional Stormwater NPDES Permit on
May 11, 2022. The NOP for the Project was published prior to this order on 3/21/22.
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-16 Final Environmental Impact Report – Campbell General Plan Update
Permits and thresholds of compliance and review requirements will change throughout the life
of the General Plan. No development is specifically proposed or would be approved as part of
the proposed General Plan Update.
Additionally, General Pan Policy CSF-5.2 and actions COS-7.b COS-7.j CSF-5.f require a
development review process and as required by the San Francisco Bay Region Municipal Regional
Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, and would
continue to implement a comprehensive municipal stormwater pollution-prevention program in
compliance with requirements of the Santa Clara Valley Urban Runoff Pollution Prevention
Program (SCVURPPP) and the C.3 Stormwater Handbook. Compliance with these policies and
actions would require compliance with the updated permit and the thresholds associated with
Project review requirements.
The References section has been revised to include this text revisions. These revisions are shown
in strikethrough and underline format.
DEIR Section 7.0 (Reference)
Regional Water Quality Control Board (RWQCB) Municipal Regional Stormwater NPDES Permit.
May 11, 2022 (Order No. R2-2022-0018, NPDES Permit No. CAS612008)
These comments do not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. These comments do not address the adequacy of the Draft EIR analysis. As
such, no additional response is required.
A-19: The commenter references DEIR Pages 3.9-7, 3.9-37, and 3.9-38, Dam Inundation, and notes that
a portion of the city is also within the inundation area of Vasona Dam and a description of this dam should
be included. Also, commenter notes Valley Water’s Dam Safety Program does not cover non-Valley Water
owned dams.
The City appreciates the comments and input provided by the commenter. As stated previously
the Vasona Dam inundation maps were reviewed and do not show inundation areas within any
habitable portion of the city or within any City facility. Vasona Dam Inundation areas show a small
portion of the W Valley Fwy (SR 85) ROW impacted. Text revisions to describe the Vasona Dam
and Inundation areas and updated text related to the Dame Safety Program is included on DEIR
Pg. 3.9.-7 as presented under Response A-14.
Text revisions presented under Response A-14 represent text corrections and revised text
descriptions. This text change does not involve or identify any new significant impacts or
“significant new information” that would require recirculation of the Draft EIR pursuant to CEQA
Guidelines Section 15088.5. Section 3.0 Errata presents all text changes warranted by comments,
including this text update. These comments do not address the adequacy of the Draft EIR
analysis.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-17
A-20: The commenter references DEIR Page 3.13-10, and Table 3.13-1 and states: Valley Water owns and
operates six groundwater recharge ponds within the City of Campbell. These recharge facilities consist of
the Page, Sunnyoaks, Budd Avenue, McGlincey, Oka, and Camden Ponds and notes that the discussion
and Table 3.13-1 incorrectly identify the “Camden Recharge Ponds” as the “Hacienda Percolation Ponds.
Hacienda/ Winchester Percolation Ponds are listed in as facilitates to identify the location of the
facilities in Table 3.13.1 consistent with city documents.
https://www.campbellca.gov/facilities/facility/details/Hacienda-Winchester-Percolation-Ponds-
24
However, to provide consistency with Valley Water Facilities naming the following text edit has
been made to reflect the updating naming per Valley Water comments. These revisions are
shown in strikethrough and underline format.
DEIR Pg. 3.13-10 The Hacienda Percolation Ponds Camden Ponds
These text edits do not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. These comments do not address the adequacy of the Draft EIR analysis. As
such, no additional response is required.
A-21: The commenter references DEIR Page 3.15-14, and notes the 2012 Water Supply and Infrastructure
Master Plan was updated in 2019 to the Water Supply Master Plan 2040.
These text revisions represent text corrections and revised text descriptions. These revisions are
shown in strikethrough and underline format.
DEIR Page 3.15-14 Santa Clara Valley Water District Water Supply and Infrastructure Master
Plan 2040
DEIR Page 3.15-14 The SCVWD’s 2012 Water Supply and Infrastructure Master Plan 2040
This text revision does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. Section 3.0 Errata presents all text changes warranted by comments, including
this text update. These comments do not address the adequacy of the Draft EIR analysis.
A-22: The commenter references DEIR Impact 3.15-1 on page 3.15-15, and Impact 3.15-2 on pages 3.15-
17 and 18, as notes that the UWMPs for both agencies assume expanded water conservation efforts
throughout the county. All cities within the county must take action to ensure that impacts on water
supply from future growth are minimized, and Valley Water appreciates Campbell’s commitment to
water conservation in the General Plan.
The City appreciates the comments and input provided by the commenter. These comments do
not address the adequacy of the Draft EIR analysis. These comments have been forwarded to
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-18 Final Environmental Impact Report – Campbell General Plan Update
the Planning Commission and City Council for consideration. No further response in this EIR is
required.
A-23: The commenter references DEIR Page 3.15-28, and notes the Clean, Safe Creeks and Natural Flood
Protection (CSC) Plan was replaced in November 2012 by the Safe, Clean Water and Natural Flood
Protection Program, which has the following 6 priorities:
• Priority A: Ensure a Safe, Reliable Water Supply
• Priority B: Reduce Toxins, Hazards, and Contaminants in our Waterways
• Priority C: Protect our Water Supply and Dams from Earthquakes and Other Natural
Disasters
• Priority D: Restore Wildlife Habitat and Provide Open Space
• Priority E: Provide Flood Protection to Homes, Businesses, Schools, Streets, and
Highways
• Priority F: Support Public Health and Public Safety for Our Community
Text revisions per comments represent text corrections and revised text descriptions. These
revisions are shown in strikethrough and underline format.
DEIR Page 3.15-28: The Safe, Clean Water and Natural Flood Protection Program, has
the following 6 priorities:
Priority A: Ensure a Safe, Reliable Water Supply
Priority B: Reduce Toxins, Hazards, and Contaminants in our Waterways
Priority C: Protect our Water Supply and Dams from Earthquakes and Other Natural
Disasters
Priority D: Restore Wildlife Habitat and Provide Open Space
Priority E: Provide Flood Protection to Homes, Businesses, Schools, Streets, and
Highways
Priority F: Support Public Health and Public Safety for Our Community
The Clean, Safe Creeks and Natural Flood Protection (CSC) Plan was approved by Santa Clara
County voters in November 2000 to create a countywide special parcel tax to accomplish the
following four goals:
• 100-year flood protection for homes, schools, businesses, and transportation;
• Clean, safe water in Santa Clara County creeks and bays;
• Healthy creek and bay ecosystems; and
• Trails, parks, and open space along waterways.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-19
This text change does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. Section 3.0 Errata presents all text changes warranted by comments, including
this text update. These comments do not address the adequacy of the Draft EIR analysis. No
further response in this EIR is required.
A-23: The commenter references DEIR Page 3.15-32, West Valley Clean Water Program, and notes the
discussion should remove the reference to SCVWD.
The following text revisions have been made to the DEIR to clarify information included in the
regulatory setting. These revisions are shown in strikethrough and underline format.
DEIR Page 3.15-32 The West Valley Clean Water Program (WVCWP) was established in 1994 as a
collaborative effort between the smaller west valley communities (Campbell, Monte Sereno,
Saratoga, and Los Gatos) to implement stormwater pollution control and management efforts. The
WVCWP goal is to reduce pollutants in storm drain discharges, comply with MRP regulations and
requirements, and maximize the effectiveness of pollution prevention efforts. The Santa Clara Valley
Water District (SCVWD) administers an Urban Runoff Management Plan to reduce stormwater
pollution, which includes the following specific actions:
• Municipal controls such as storm drain stenciling, storm drain operation and maintenance
(O&M), street sweeping, street/public facilities maintenance, and illegal discharge
response.
• Construction and development measures including on-site inspections, grading and erosion
controls, and educating developers.
• Commercial and industrial facility inspections to prevent wastes from discharging into the
storm drain system.
Public education activities to increase awareness and change behavior.
By agreement with the participating cities and towns, the WVSD collects an additional surcharge
from residences and commercial properties to fund the WVCWP. The SCVWD complies with the
requirements of the MRP for urban runoff pollution control.
The West Valley Clean Water Program Authority (Authority) serves as the Stormwater Pollution
Prevention Authority for the cities of Campbell, Monte Sereno, Saratoga, and the Town of Los
Gatos. The Authority was created to maximize the effectiveness, efficiency, and cost-benefit of
collective stormwater pollution prevention efforts of the four West Valley communities. The
Authority was formally established in February 2018 but has been operating as a collaborative
stormwater management program since 1992.
The Authority’s member agencies must comply with the NPDES stormwater permit, which
mandates certain activities including maintenance of the stormwater drain system.
The Authority develops an annual work plan to fulfill the requirements of its MRP and to reduce
the amount of pollutants discharged in urban runoff. The plan is a comprehensive program that
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-20 Final Environmental Impact Report – Campbell General Plan Update
is designed to reduce the discharge of pollutants to the maximum extent practicable and
encompasses best practices for the following operational areas:
• Construction Site Stormwater Runoff Control
• Commercial Facilities
• Illicit Discharge Detection and Elimination
• Industrial Facilities
• Municipal Operations/Pollution Prevention and Good Housekeeping
• Post Construction Storm Water Management
• Public Education
• Public Participation
The Authority also participates in the Santa Clara Valley Urban Runoff Program (Program). The
Program is an association of thirteen cities and towns in Santa Clara Valley, the County of Santa
Clara, and the Santa Clara Valley Water District that share a common permit to discharge
stormwater to South San Francisco Bay. Member agencies include Campbell, County of Santa
Clara, Cupertino, Los Altos, Los Altos Hills, Los Gatos, Milpitas, Monte Sereno, Mountain View,
Palo Alto, San Jose, Santa Clara, Santa Clara Valley Water District, Saratoga, and Sunnyvale.
These text revisions represent text corrections and revised text descriptions. This text change
does not involve or identify any new significant impacts or “significant new information” that
would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
These comments do not address the adequacy of the Draft EIR analysis. No further response in
this EIR is required.
A-24: The commenter states they appreciate the opportunity to comment on the Envision Campbell 2040
General Plan and associated draft EIR.
This comment provides a conclusion statement for the comment and does not address the
adequacy of the Draft EIR, and no further response is required.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-21
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Final Environmental Impact Report – Campbell General Plan Update 2.0-27
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Response to Letter B: California
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Final Environmental Impact Report – Campbell General Plan Update 2.0-29
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2.0-30 Final Environmental Impact Report – Campbell General Plan Update
Response to Letter B: California Department of Fish and Wildlife (CDFW)
B-1: The commenter provides an introductory statement related to the CDFW review of Projects.
This comment is noted. This comment is introductory in nature and does not address the
adequacy of the Draft EIR, and no further response is required.
B-2: The commenter provides an introductory statement related to the ADFW Role as a trustee and
responsible agency.
This comment is noted. This comment is introductory in nature and does not address the
adequacy of the Draft EIR, and no further response is required.
B-3: The commenter provides a description and summary of the Proposed Project. The commenter states
that the Location of the project includes “All areas within the City of Campbell, Santa Clara County,
California”.
This comment in introductory in nature and does not address the adequacy of the Draft EIR, and
no further response is required.
B-4: The commenter states that the CDFW offers the comments and recommendations below to assist
the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant,
direct and indirect impacts on fish and wildlife (biological) resources. Additionally, the commenter states
the some of the recommendations provided in CDFW’s letter on the NOP were not incorporated in the
DEIR; therefore, CDFW is further addressing those recommendations below which should be
incorporated in the Final EIR.
This comment is noted. All comments received during the NOP review period are included in
Appendix A of the Draft EIR. This comment is introductory in nature and does not address the
adequacy of the Draft EIR, each CDFW comment on the DEIR are included below, and no further
response is required..
B-5: The Commenter references DEIR Figure 5.0-1 Existing General Plan Land Use Map, and Figure 2.0-2
Proposed Land Use Map, and Impact 3.4-4 on DEIR page 3.4-33. The commenter states: “The Existing
General Plan Land Use Map (Figure 5.0-1) clearly shows the furthest downstream reach of Los Gatos Creek
in the Project area designated as Open Space. The Open Space designation, in summary, is designated for
parks, groundwater recharge areas, creek corridors, and other areas where limited development, such
park facilities, trails, and utilities, could occur. Exhibit 1 to this letter is Figure 5.0-1 with emphasis added
to indicate the creek reach of concern. This Open Space designation is consistent with the proposed Project
Open Space Element Policies and Actions that include preservation, protection, and enhancement of
riparian areas (Policy 7.2, 7.5, 7.6 and Action 7.a, 7.h).
The Commenter references DEIR Impact 3.4-4, regarding movement of fish and wildlife species, Page 3.4-
33, states that “As shown in the proposed General Plan Land Use Map, Open Space land uses are found
adjacent to and along the complete stretch of Los Gatos Creek.”
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-31
However, the commenter states: “Proposed Land Use Map (Figure 2.0-2) shows that the lowest
downstream reach of Los Gatos Creek being designated as General Commercial. Exhibit 2 to this letter is
Figure 2.0-2 with emphasis added to indicate the creek reach of concern. In CDFW review and comparison
with aerial photographs, this General Commercial designation encompass the entire riparian corridor in
this creek reach (Exhibit 3). General Commercial designation could include construction of buildings and
high volumes of automobile or transit traffic. This General Commercial designation is not consistent with
the proposed Project Open Space Element Policies and Actions that include preservation, protection, and
enhancement of riparian areas (Policy 7.2, 7.5, 7.6 and Action 7.a, 7.h).”
The Commenter concludes the General Commercial designation may result in impacts that may
potentially substantially reduce the abundance and diversity of fish and wildlife species within the
riparian corrido and notes that It is especially important to preserve riparian corridors that are
surrounded by urban areas.
The City of Campbell appreciates the commenter’s concerns related to changes in land use
designations along Los Gatos Creek that would result in encroachment of commercial uses. The
City has taken a thoughtful and holistic approach to updates to the proposed land use map,
including protecting existing open space buffers along the creek corridor. The encroachment of
new commercial uses into the creek corridor referenced by the commenter was the result of an
inadvertent map change to the Land Use Map and is considered a mapping error. No changes to
these parcels are included as part of the General Plan Update and the Land Use Map has been
corrected accordingly to include the existing Open Space designation (OS) on the approximately
4.27 acres along the creek corridor as identified by the CDFW, consistent with the existing
designations along this area in question.
This comment is noted. Upon review of this portion of the DEIR, the City has made the following
changes (as represented on the following map) to the Land Use Map to correct a mapping error.
As such the proposed Land Use Map has been updater for clarity and correctness per CDFW
comments. Exhibit 2-1: shows the areas of concern identified by the CDFW, and corrected parcel
designations to be included on the Proposed Land Use Map. These revisions are shown in
strikethrough and underline format.
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Exhibit 2-1: Areas of Concern and Corrected OS Parcel Designations.
This change does not involve any new significant impacts or “significant new information” that
would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
Section 3.0 Errata presents all text changes warranted by comments, including this text update.
The City has included broad and extensive policies and actions in the General Plan to ensure the
protection of water resources throughout the planning area, and is committed to protecting
riparian corridors. Changes to the Lands Use Map represent the correction of a mapping error,
and no further response is required.
B-6 The Commenter references DEIR pg. 3.4-19 (Regulatory Setting) and states: “Page 3.4-19, discusses
California Fish and Game Code as only being applicable to predatory birds. However, Fish and Game Code
3503 and 3513 are applicable to all birds and birds listed within the Migratory Bird Treaty Act (see
Evidence impact would be significant section below).
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This comment is noted. Upon review of this portion of the DEIR, the City proposes to make the
following changes (shown in strikethrough and underline format). As such the regulatory setting
has been updater for clarity and correctness per CDFW comments and recommendations.
DEIR pg. 3.4-19 Fish and Game Code §3503, 3503.5, 3513, 3800 - Predatory Birds
The California Fish and Game Code provide protection for native birds, including their nests and
eggs (Sections 3503, 3513, and 3800). These regulations prohibit all forms of take, including
disturbance that causes nest abandonment and/or loss of reproductive effort. Raptors (i.e.,
eagles, falcons, hawks, and owls) are specifically protected under Fish and Game Code Section
3503.5. Additionally, Fish and Game Code 3503 and 3513 are applicable to all birds and birds
listed within the Migratory Bird Treaty Act.
Under the California Fish and Game Code, all predatory birds in the order Falconiformes or
Strigiformes in California, generally called “raptors,” are protected. The law indicates that it is
unlawful to take, posses, or destroy the nest or eggs of any such bird unless it is in accordance
with the code. Any activity that would cause a nest to be abandoned or cause a reduction or loss
in a reproductive effort is considered a take. This generally includes construction activities.
This section has been revised and updated to provide clarity and correct information related to
the regulatory setting. This change does not involve any new significant impacts or “significant
new information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. Section 3.0 Errata presents all text changes warranted by comments, including
this text update. The City appreciates these comments and looks forward to working with the
CDFW as future development projects are proposed. This comment does not address the
adequacy of the Draft EIR, and no further response is required.
The Commenter references DEIR pg. 3.4-23 (Impact Discussion) Impact 3.4-1 and states: “Impact 3.4-1
includes a list of significant impacts such as direct mortality due to removal of trees with active nests and
abandoned eggs or young and subsequent nest failure. Although the DEIR states that impacts to nesting
birds could occur, specific mitigation measures to avoid take are not included.
The commenter additionally states that:” “Take of nesting birds, birds in the orders Falconiformes or
Strigiformes, and migratory nongame bird as designated in the Migratory Bird Treaty Act is a violation of
Fish and Game Code (§ 3503, 3503.5, 3513). The measures proposed for sensitive and special-status spices
(Impact 3.4-1) include habitat protection in particular areas of the City, but do not address all Project
impact areas and the mitigation measures do not specifically mitigate for take of nesting birds, eggs, and
young under Fish and Game Code.”
The commenter recommends 2 Mitigation Measures be included to reduce this impact to a less than
significant level as described below:
Mitigation Measure #1: Nesting Bird Surveys
If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small
bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15
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for other raptors), a qualified biologist should conduct a minimum of two surveys for active nests of such
birds within 14 days prior to the beginning of Project construction, with a final survey conducted within
48 hours prior to construction. Surveys should be conducted in all potential bird-nesting locations
including grasslands, shrubs, and trees. However, species-specific survey protocols may be available and
should be followed. Appropriate minimum survey radii surrounding the work area are typically the
following: i) 250 feet for passerines; ii) 500 feet for small raptors such as accipiters; and iii) 1,000 feet for
larger raptors such as buteos. Surveys should be conducted at the appropriate times of day and during
appropriate nesting times.
Mitigation Measure #2: Active Nest Buffers
If the qualified biologist documents active nests within the Project area or in nearby surrounding areas,
an appropriate buffer between the nest and active construction should be established. The buffer should
be clearly marked and maintained until the young have fledged and are foraging independently. Prior to
construction, the qualified biologist should conduct baseline monitoring of the nest to characterize
“normal” bird behavior and establish a buffer distance which allows the birds to exhibit normal behavior.
The qualified biologist should monitor the nesting birds daily during construction activities and increase
the buffer if the birds show signs of unusual or distressed behavior (e.g., defensive flights and
vocalizations, standing up from a brooding position, and/or flying away from the nest). If buffer
establishment is not possible, the qualified biologist or construction foreman should have the authority to
cease all construction work in the area until the young have fledged and the nest is no longer active.
This comment is noted. The regulatory setting has been updater for clarity and correctness per
CDFW comments and recommendations.
As the commenter is aware, adoption of the General Plan Update and certification of the Final
EIR would not approve or otherwise entitle any development projects within Campbell, and no
habitat modifications are proposed or would be approved. The details of individual projects and
any potential site specific impacts are not know at this time and each would require a detailed
project specific review. The Draft EIR includes projections for buildout of the Land Use Map,
including future population levels, housing units, jobs, square footage of non-residential
development, etc. See Chapter 2.0 of the Draft EIR. In instances where the Draft EIR references
General Plan policies or actions that require project-level review of future development
applications, the policies and actions identify the performance-based standards that must be
used when analyzing future projects.
The General Plan includes a variety of policies and actions to protect local species, preserve
habitats, and discourage the removal of important habitats throughout the planning area.
Policies such as COS-4.5 seek to avoid the removal of large, mature trees that provide wildlife
habitat. Additionally, specific to the commenter’s concerns, the General Plan requires project
specific reviews to ensure all future projects are reviewed for impacts and that projects mitigate
these impacts to the greatest extent feasible. One such example is Action COS-7.c that states
“Where sensitive biological habitats have been identified on or immediately adjacent to a project
site, the project shall include appropriate mitigation measures identified by a qualified biologist,
which may include, but are not limited to the following:
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• Pre-construction surveys for species listed under the State or Federal Endangered Species Acts, or
species identified as special-status by the resource agencies, shall be conducted by a qualified
biologist;
• Construction barrier fencing shall be installed around sensitive resources and areas identified for
avoidance or protection, and to reduce potential soil compaction in sensitive areas; and
• Pre-Construction training of contractors and sub-contractors shall be conducted”
This represents a cohesive “Program Level” approach to ensuring that future development projects’
impacts are reduced to the greatest extent feasible through the implementation of performance-
based measures at the time an application for entitlement is submitted. Project-level mitigation
measures such as those required by Action COS-7c would ensure that all feasible mitigation measures
would be implemented related to project level impacts to biological habitats and their associated
species. The City is committed to protecting local species and conserving biological habitats
throughout the planning area. As future development project are proposed the City will consider the
applicability of mitigation measures, including those presented by the commenter.
The City has included broad and extensive policies and actions in the General Plan to ensure that
biological species and habitats are protected, and that future projects that include sensitive biological
habitats shall include appropriate mitigation measures identified by a qualified biologist. However
upon further review of the General Plan policies and actions, the City agrees that additional policy
guidance will provide for additional clarity for the enhancement of species and habitat protections
for nesting birds. The following changes (shown in strikethrough and underline format), include an
updated action (Action COS-7c), in order to provide more specificity and enforceability related to
future projects impacts to nesting birds.
DEIR Pg. 3.4-26, 3.4-29, and 3.4-32
COS-7.c Where sensitive biological habitats have been identified on or immediately adjacent to
a project site, the project shall include appropriate mitigation measures identified by a qualified
biologist, which may include, but are not limited to the following:
· Pre-construction surveys for species listed under the State or Federal Endangered Species
Acts, Migratory Bird Treaty Act, or species identified as special-status by the resource
agencies, shall be conducted by a qualified biologist;
· Provision of temporary or permanent buffers of adequate size (based on the specifics of
the protected species) to avoid nest abandonment by nesting migratory birds and raptors
associated with construction and site development activities.
· Construction barrier fencing shall be installed around sensitive resources and areas
identified for avoidance or protection, and to reduce potential soil compaction in sensitive
areas; and
· Pre-Construction training of contractors and sub-contractors shall be conducted by a
qualified biologist to identify and avoid protected species and habitat.
This updated General Plan action provides more specificity related to future projects’ potential
impacts to nesting birds. No new impacts, or increased impacts are identified or would be
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included from these comments or policy enhancements. The City appreciates these comments
and looks forward to working with the CDFW as future development projects are proposed. This
change does not involve any new significant impacts or “significant new information” that would
require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0
Errata presents all text changes warranted by comments, including this text update, and no
further response is required.
B-7: The commenter provides information related to Environmental Data and reporting requirements for
future surveys, and notes that the City must report any special-status species and natural communities
detected during Project surveys to the California Natural Diversity Database (CNDDB).
These comments are to note specific reporting requirements. The City appreciates these
comments and looks forward to working with the CDFW as future development projects are
proposed, and future surveys are conducted. No further response is required.
B-8: The commenter provides information related to Environmental Document Filing Fees and notes that
the payment of the environmental document filing fee is required in order for the underlying project
approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub.
Resources Code, § 21089).
These comments provide information specifically related to CDFW filing fees. The City
appreciates these comments and looks forward to working with the CDFW. No further response
is required.
B-9: The commenter provides a conclusion to the comment letter.
These comments provide contact related information and a conclusion to the letter. The City
appreciates comments from the CDFW. No further response is required.
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Response to Letter C: Santa Clara County Fire Department (SCCFD).
C-1: The Santa Clara County Fire Department (SCCFD) provided a comment letter that included updated
descriptions of Fire Protection Services within Campbell.
The City appreciates the comments and input provided by the SCCFD. The City has made text
revisions to include Santa Clara County Fire Department (SCCFD) consistent with SCCFD
comments. The changes (shown in strikethrough and underline format in Section 3.0 Errata)
include information provided by SCCFD related to fire protection services on DEIR Page 3.13-1 in
Section 3.13.1, Environmental Setting - Fire Protection Services.
DEIR Pg. 3.13-1 through 3.13-4 Section 3.13.1 Environmental Setting - Fire Protection Services.
The City of Campbell receives fire protection from the Santa Clara County Fire Department
(SCCFD).
The Santa Clara County Fire Department (SCCFD), which was formed in 1947, provides
suppression and dispatches emergency services for a 128.3-mile area. The SCCFD provides
firefighting personnel and emergency medical service (basic life support) to the residents and
businesses in Los Altos Hills, Los Altos, Cupertino, Saratoga, Monte Sereno, Campbell, and Los
Gatos. The Department also provides protection for the unincorporated areas adjacent to those
cities. The City of Campbell contracts service through the SCCFD, and the Campbell Police Chief
is responsible for SCCFD contracts.
The SCCFD maintains 15 fire stations, an administrative headquarters, a maintenance facility, five
other support facilities. The SCCFD offers fire resources and services that are divided into five
major sections: Fire Suppression and Rescue, Fire Investigation, Emergency Medical Services,
Special Operations Task Force / Haz-Mat, and Wildland Urban Interface.
The SCCFD operates two fire stations within the City of Campbell, as shown on Figure 3.13-1. Both
stations are City-owned facilities.
• Campbell Fire Station, at 123 Union Avenue, Campbell
• Sunnyoaks Fire Station / McCormack Training Center, at 485 West Sunnyoaks Avenue,
Campbell
Fire Suppression and Rescue
The Fire Suppression Department is configured into three districts. First-call equipment is
deployed to deliver initial fire attack and EMS services within 7 minutes. A standard first-alarm
assignment for structure fires consists of two engine companies, a ladder truck company, a
rescue or hazardous materials company and a Battalion Chief, for a total of 15 people. On
working fires, the response is increased to three engines companies, one ladder truck company,
a Hazmat and Breathing Support company, one rescue company, two Battalion Chiefs, a Safety
Officer, and a Duty Investigator, totaling 25 persons.
A second-alarm would add another two engine companies, one truck company, one rescue
company, and an additional Chief Officer; total staffing for two alarms is then 40 persons.
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Wildland-urban interface companies are trained and equipped to provide structure protection
and limited initial attack on wildland incidents.
A brush alarm for vegetation fires in wildland/urban interface areas consists of two engine
companies, a Type 3 engine and a Battalion Chief, totaling 9 persons.
Daily emergency response staffing consists of 70 career fire personnel on a 24-hour shift
assignment, operating 19 pieces of first-line apparatus, plus three 3 Battalion Chief command
vehicles, operating from 15 fire stations. In daily operations during declared "Fire Season,"
patrols function in tandem with ladder trucks during daytime hours. This means that during the
summer months, when the probability of a brush fire is high, the truck and patrol vehicle go out
on calls as a pair. This guarantees continuous coverage of the entire area served, should another
response be required during an alarm.
The SCCFD aims to control emergency incidents that threaten lives, property, and the environment.
The Department maintains the following three goals:
• Arrive at the scene of emergencies within five minutes of receipt of alarm, at least 90 percent
of the time.
• Maintain "Confined Space - Operational Level" training for all Department responders.
• Maintain "Rescue Systems I" certification for truck and rescue personnel.
The SCCFD has four first-call ladder trucks and one rescue vehicle, which employ specialized
equipment designed to carry out rescues such as traffic collisions and industrial accidents. All
emergency response personnel are trained in specialized rescue techniques. All apparatus carry
a compliment of rescue tools.
Fire Investigation
The Department is one of the few agencies in the Bay Area to staff full time fire investigator
positions, augmented by on-call personnel. Investigation of fires provides information on the
cause of local fire problems, which provides information to the local news media regarding fire
safety education.
Arson Investigation provides for the apprehension of arsonists who cause billions of dollars in
property damage, fraud and death each year. The Department also uses the AIRS program to
track arson registrants/suspects and compile fire statistics. With local police agencies, the Santa
Clara County Fire Investigation Unit track down many arson investigations, as they account for
about 25% of fires. The SCCFD places a strong emphasis on quelling arson fires.
Emergency Medical Services
The SCCFD provides first response Advanced Life Support (ALS) Paramedic level services to
Unincorporated Santa Clara County, Campbell, Cupertino, Los Altos, Los Altos Hills, Los Gatos,
Monte Sereno, and Saratoga. An Emergency Medical Services (EMS) Coordinator and a
Firefighter Engineer Paramedic, who report to the Battalion Chief of Operations, facilitate the
delivery of high quality, effective patient care. The District operates 19 fully equipped ALS fire
apparatus daily all staffed with a minimum of one Paramedic and two Emergency Medical
Technicians (EMT). The Department maintains a Santa Clara County EMS Multi-Casualty Incident
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(MCI) supply trailer for large-scale emergency medical incidents and is a participant in Master
Mutual Aid in the event of major disasters.
The Department’s EMS division is an active participant in the Santa Clara County EMS System,
participates in many of the EMS subcommittees, and sits as a representative on the EMS
subsection of the Santa Clara County Fire Chiefs Association. The State of California’s EMS
Authority has recognized the Department as a Continuing Education Provider for both
Paramedics and Emergency Medical Technicians.
The District is a participant in Santa Clara County's Electronic EMS patient care record (PCR)
system. The software is programmed to capture patient data upon receipt of a 911 call and
provides enhanced capabilities for monitoring and evaluating patient care. The Department is
committed to the protection of an individual's private patient healthcare information and
maintains a comprehensive Privacy Practices Policy.
Santa Clara County EMS has a contract with a third party ambulance transport provider for the
ground transport of all patients. The delivery of exceptional EMS in a partially rural area involves
the utilization of ALS helicopter service providers. The Department routinely works with the
various transport providers in order to rapidly transport critical patients from all locations to
definitive care. Some areas covered by the department are so remote that an ALS helicopter is
part of the initial EMS dispatch. The Department conducts extensive in-service training on a
routine basis to insure the most up to date EMS skills, procedures, and practices are implemented
and delivered to the citizens and visitors of Santa Clara County.
Special Operations Task Force / Haz-Mat
The mission of the SCCFD Special Operations Task Force is to improve emergency responses that
are outside the scope of typical emergency calls through advanced training, teaching, and
emergency responses in the district and adjoining agencies.
In addition to regular fire department training, all members are required to have the following:
• CSFM Fire Instructor 1A and 1B
• Confined Space Rescue
• Trench Rescue
• Low Angle Rescue
• Rescue Systems I and/or II
• CSTI Hazardous Materials Technician or Specialist
• Haz-Mat Safety Officer/All Risk
Continued training includes:
• Weekly Special Ops, multi company training
• Participation in the quarterly Hazardous Materials Countywide Refresher Training
• UASI Urban Shield Exercise/Competition and Participation (12 hours)
The SCCFD Special Operations Task Force may be deployed within the district when needed by
Incident Command request of the Special Operations Task Force. Haz-Mat 72 is also recognized
as an OES Type 1 resource for large WMD or large scale Haz-Mat events throughout the state.
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Some Santa Clara County Fire Department Special Operations Task Force (SOTF) members have
been attached to FEMA Task Force 3, local SWAT teams, or actively teach for private and public
agencies. Some member deployments and SOTF deployments include:
• Hurricane Katrina – rescue and Haz-Mat operations (2005)
• San Jose High Rise Rescue (2011)
• Santa Clara County City Six Flags Roller Coaster Rescue (2007)
• San Jose Downtown / AT&T- 1,300-gallon Diesel Spill (2010)
• Santa Clara City/ CHP- Bomb maker's facility (2013)
• Los Altos- PG&E House Explosion (2002)
• Suspicious Package/ Envelope diagnostics at Campbell PD, Moffett Field, Google, EBay,
Stanford and Apple (various years)
• Trench and steep terrain rescues (various years)
The City of Campbell receives fire protection from the Santa Clara County Fire Department
(SCCFD).
The Santa Clara County Fire Department (SCCFD), which was formed in 1947, provides
suppression and dispatches emergency services for a 128.3-mile area. The SCCFD provides fire
prevention, fire investigation, and all-hazard emergency services inclusive of structural and
wildland firefighting, rescue and advanced life support emergency medical services (EMS), and
special operations response to the residents and businesses in Los Altos Hills, Los Altos,
Cupertino, Saratoga, Monte Sereno, Campbell, and Los Gatos. The Department also provides
protection for the unincorporated areas adjacent to those cities. The City of Campbell contracts
service through the SCCFD, and the Campbell Police Chief is responsible for SCCFD contracts.
The SCCFD maintains 15 fire stations, an administrative headquarters, a maintenance facility, and
five other support facilities. Additionally, the SCCFD supplies executive leadership by contract to
the Santa Clara County Office of Emergency Management, and the Santa Clara County 9-1-1
Communications Department. The SCCFD offers fire resources and emergency services that are
divided into five major sections: Fire Suppression, Rescue and Emergency Medical Services, Fire
Investigation, Special Operations, and Wildland Urban Interface.
The SCCFD operates two fire stations within the City of Campbell, as shown on Figure 3.13-1.
Both stations are City-owned facilities.
• Campbell Fire Station, at 123 Union Avenue, Campbell
• Sunnyoaks Fire Station / McCormack Training Center, at 485 West Sunnyoaks Avenue,
Campbell
Fire Suppression and Rescue
Emergency response falls under the operations division. SCCFD’s fifteen fire stations are
configured into three battalions. First-call equipment is deployed to deliver initial fire attack and
EMS services for moderate and high-risk incidents with first unit arrival within 8 minutes. A
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standard first-alarm assignment for structure fires consists of two engine companies, a ladder
truck company or a rescue and a Battalion Chief, for a total of 11 people. On working fires, the
response is increased to three engines companies, one ladder truck company, a Hazmat and
Breathing Support company, one rescue company, two Battalion Chiefs, a Safety Officer, and a
Duty Investigator, total 25 persons.
A second-alarm would add another two engine companies, one truck company, one rescue
company, and an additional Chief Officer; total staffing for two alarms is then 40 persons.
Wildland-urban interface companies are trained and equipped to provide structure protection
and initial attack on wildland incidents.
A brush alarm for vegetation fires in wildland/urban interface areas consists of two Type 1 engine
companies, a Type 3 or Type 6 engine company, and a Battalion Chief, totaling 10 persons.
Daily emergency response staffing consists of 66 career fire personnel on a 24-hour shift
assignment, using 19 pieces of first-line apparatus, plus three Battalion Chief command vehicles,
and working from 15 fire stations.
The SCCFD aims to “improve survivability for victims of fire, hazardous materials release,
entrapment or other crisis incidents” (SCCFD, 2020):
• First unit arrival at structure fires, vegetation fires, and other crisis incidents in urban areas
in an average of 5:30 and under 7:50 ninety percent of the time.
• Contain structure fires to the room of origin at or above current, published, national average
percentage.
• Keep vegetation fires to three acres or less ninety percent of the time.
The SCCFD has three ladder trucks, three rescue vehicles, and one urban search and rescue
vehicle which employ specialized equipment designed to help personnel carry out technical
rescues such as traffic collisions and industrial accidents. All emergency response personnel are
trained in specialized rescue techniques. All SCCFD apparatus are equipped with a compliment
of rescue tools scaled to their local hazards.
Fire Investigation
The Department provides fire investigation services by means of specially trained fire prevention
division staff, whom are augmented by on-call personnel. The Department contracts with the
Campbell Police Department for criminal investigation services in conjunction with the arson
program, and in cooperation with other local law enforcement agencies. Conducting effective
fire investigations results in information on the origin and cause of fire incidents, finds local fire
problems, and supports prosecution of arsonists who nationwide cause billions of dollars in
property damage, fraud, injuries, and death each year. In turn this supplies information to the
SCCFD’s Community Education and Risk Reduction Services program to better identify
community risk and provide targeted fire safety education to the community.
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Emergency Medical Services
The SCCFD provides first response Advanced Life Support (ALS) Paramedic level services to
Campbell, Cupertino, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Saratoga, and
unincorporated areas of Santa Clara County. The EMS section, under the direction of the Deputy
Chief of Operations, facilitates the delivery of high quality, effective patient care. The section is
overseen by an Emergency Medical Services (EMS) Coordinator, who is a registered nurse, and a
Firefighter Paramedic. The Department uses 19 fully equipped ALS fire apparatus daily, all staffed
with a minimum of one Paramedic and two Emergency Medical Technicians (EMT). The
Department maintains a Santa Clara County EMS Multi-Casualty Incident (MCI) supply trailer for
large-scale emergency medical incidents and is a participant in Master Mutual Aid in the event
of major disasters.
The EMS section is an active participant in the Santa Clara County EMS System, takes part in many
of the EMS subcommittees, and sits as a representative on the EMS subsection of the Santa Clara
County Fire Chiefs Association. The State of California’s EMS Authority has recognized the
Department as a Continuing Education Provider for both Paramedics and EMTs.
The SCCFD is a participant in Santa Clara County's Electronic EMS patient care record (PCR)
system. The software is programmed to capture patient data upon receipt of a 911 call and
provides enhanced capabilities for monitoring and evaluating patient care. The Department is
committed to the protection of an individual's private patient healthcare information and
maintains a comprehensive Privacy Practices Policy.
Santa Clara County EMS has a contract with a third-party ambulance transport provider for the
ground transport of all patients. The delivery of exceptional EMS in a partially rural area involves
the utilization of ALS helicopter service providers. The SCCFD routinely works with the various
transport providers in order to rapidly transport critical patients from all locations to definitive
care. Some areas covered by the department are so remote that an ALS helicopter is part of the
initial EMS dispatch. The Department conducts extensive in-service training on a routine basis to
insure that most up to date EMS skills, procedures, and practices are implemented and delivered
to the citizens and visitors of Santa Clara County.
Special Operations Task Force / Haz-Mat
The mission of the SCCFD Special Operations Task Force is to improve emergency responses that
are outside the scope of typical emergency calls through advanced training, teaching, and
emergency responses in the district and adjoining agencies.
In addition to regular fire department training, Special Operations Task Force members are
required to have the following training:
• Incident command and fire instructor training
• Technician and/or specialist-level training for rope rescue, confined space, trench, and
structural collapse rescue incidents
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Hazardous Materials technician and/or specialist-level training with enhanced CBRNE
component
Continued training includes:
• Weekly task force training and multi company training
• Participation in quarterly hazardous materials and technical rescue training exercises with
countywide stakeholders.
The SCCFD Special Operations Task Force may be deployed to incidents based on incident scope
and dispatch protocols, or by request of the incident command. USAR 85 is certified by Cal-OES
Fire and Rescue Division as a Type-1 (Heavy) Urban Search and Rescue Company. Haz-Mat 72 is
also certified by Cal-OES Fire and Rescue Division as a Type 1 Hazardous Materials Response
Team. Each resource can be deployed statewide to significant natural or human-caused incidents
through the California Fire and Rescue mutual-aid system.
Several SCCFD Special Operations Task Force (SOTF) personnel are members of California Urban
Search and Rescue Task Force 3, one of 8 national urban search and rescue task forces here in
California, and a total of 28 such task forces nationwide. These task forces are deployed by FEMA
to provide urban search and rescue support for national-level disasters. Team members have
deployed to various hurricanes, floods, and earthquakes since SCCFD became a participating
agency after the events of September 11, 2001.
This text change provides background information related to fire emergency services serving Campbell
and does not involve any new significant impacts or “significant new information” that would require
recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. Section 3.0 Errata presents
all text changes warranted by these comments, including this text update.
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Response to Letter D: Tim Pasquinelli - CONSIGLIARE - CAMPBELL TECHNOLOGY PK
LLC
D-1: The Commenter requests that the Campbell Technology Park be zoned for a minimum density of
less than 25 units/ acre, which would accommodate 3-story townhomes.
These comments are noted. These comments are specifically related to desired development
standards and the zoning code. This request will be forwarded to the Planning Commission, and
City Council for review and consideration. This comment does not address the adequacy of the
Draft EIR, and no further response is required. No changes to the Draft EIR text are required.
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Response to Letter E: Vikki Essert
E-1: The Commenter provides an introduction to the comment letter.
This comment is introductory in nature and does not address the adequacy of the Draft EIR, and
no further response is required.
E-2: The Commenter requests that native landscaping language be added to specific policy guidance
related to landscaped parkways.
The General Plan Includes a variety of policies related to supporting native plantings and
landscaping and these General Plan Policies are applicable throughout the city including any
future landscaped parkways.
The City appreciates the comments and input provided by the commenter. These comments
provide input related to various goals, policies, and actions in the General Plan and do not
address the adequacy of the Draft EIR analysis. These comments have been forwarded to the
Planning Commission and City Council for consideration. No further response in this EIR is
required.
E-3: The Commenter references the Hamilton Area Precise Plan, the importance of safe infrastructure,
and the potential for reduced LOS.
These comments provide input related to various future improvements and the Hamilton Area
Precise Plan and do not address the adequacy of the Draft EIR analysis. The City appreciates the
comments and input provided by the commenter. These comments have been forwarded to the
Planning Commission and City Council for consideration. No further response in this EIR is
required.
E-4: The Commenter stated that the city should pursue new ways of determining density and intensity of
development, and that the city should support affordable housing goals.
The General Plan uses standard density and intensity calculation consistent with other area
jurisdictions and industry standards. Residential Density as stated in the General Plan Guidelines
is “applied differently from one jurisdiction to another, residential population density can best be
expressed as the relationship between two factors: the number of dwellings per acre and the
number of residents per dwelling.” The General Plan uses this industry standard to provide
consistence and clarity.
These comments provide input related to various opportunities for improvements and issues
facing Campbell and the need to support affordable housing objectives. The City appreciates the
comments and input provided by the commenter. These comments do not address the adequacy
of the Draft EIR analysis. These comments have been forwarded to the Planning Commission and
City Council for consideration. No further response in this EIR is required.
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Response to Letter F: Julie Schaer, WVCWA and Vishakha Atre, SCVURPPP
F-1: The Commenter provides a variety of suggested changes to the General Plan policy document related
to incorporating Green Stormwater Infrastructure (GSI) language.
The City appreciates the comments and input provided by the commenter. The City has reviewed
these comments and has made various revisions to the General Plan Policy Document to include
updated language related to GSI. This comment specifically addressed General Plan policy
language and does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. These comments have been forwarded to the Planning Commission and City
Council for consideration. No further response in this EIR is required.
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Response to Letter G: Liz Gibbons
G-1: The Commenter requests the DEIR correct references to PGE as the power supplier to Campbell and
notes that PGE provides gas, transmission and distribution only. Silicon Valley Clean Energy provides
electric power generation to 95% of Campbell residents and businesses. The Greenstart power is 100%
carbon free and 50% renewable; Greenprime is 100% carbon free and 100% renewable.
As stated on DEIR Pg. 3.7-25 the City of Campbell is also a member agency of the Silicon Valley
Clean Energy (SVCE). In late 2016, the Campbell City Council voted to enroll the City’s municipal
electricity accounts in Silicon Valley Clean Energy’s optional GreenPrime program starting April
2017. The electricity to run City-owned facilities, parks, and streetlights, comes from 100%
renewable sources like wind and solar. The SVCE program is also available to Campbell residents
and business.
The Silicon Valley Clean Energy program buys and/or generate power, but PG&E continues to
deliver grid electricity over existing power lines, maintain the lines and provide customer service.
Programs such as the Silicon Valley Clean Energy put renewable sources of electricity into the
grid.
The City appreciates the comments and input provided by the commenter. The City has reviewed
these comments and has made revisions to the DEIR related to adding additional information
relating to the SVCE program. The City proposes to make the following changes to the DEIR to
add additional references and information related to Silicon Valley Clean Energy on DEIR Page
3.7-37. (shown in strikethrough and underline format).
DEIR Page 3.7-37: For example, PG&E is responsible for the mix of energy resources used to
provide electricity for its customers, and it is in the process of implementing the Statewide
Renewable Portfolio Standard (RPS) to increase the proportion of renewable energy (e.g. solar
and wind) within its energy portfolio. However, community choice programs such as the Silicon
Valley Clean Energy provide power generation for Campbell residents and businesses by
supplying grid power with renewable and carbon free choices and include the following tier
structures: Greenstart power 100% carbon free and 50% renewable, and Greenprime 100%
carbon free and 100% renewable.
This comment does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. Section 3.0 Errata presents all text changes warranted by comments, including
this text update.
G-2: The commenter requests that the City please clarify the term “action”. Is it the city’s responsibility
or the developer/homeowner? Who pays for the action items? When are they applicable?
DEIR Page 2.0-10 described Goals, Policies, and Actions. “An action is an implementation
measure, procedure, technique, or specific program to be undertaken by the City to help achieve
a specified goal or implement an adopted policy. The City must take additional steps to
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implement each action in the General Plan. An action is something that can and will be
completed.
In some instances, an action may be implemented by a developer or homeowner, in other
instances, an action may be implemented by the City. This comment is related to the General
Plan. No changes to the Draft EIR text are required.
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Response to Letter H: Stacie Wolny
H-1: The Commenter provides an introduction to the letter and references a variety of opportunities to
improve the city.
This comment is noted. This comment is introductory in nature and does not involve or identify
any new significant impacts or “significant new information” that would require recirculation of
the Draft EIR pursuant to CEQA Guidelines Section 15088.5. The City appreciates the comments
and input provided by the commenter. These comments have been forwarded to the Planning
Commission and City Council for consideration. No further response in this EIR is required.
H-2: The Commenter references Table ES‐1and notes that none of the alternatives make our environment
significantly better.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-3: the commenter references Table 2.0‐1: and states concerns about, and the importance of, open
space.
As descried Under Response B-5 map errors have been corrected to include Open Space along
the creek corridor in the northern portion of the city. This results in the addition of approximately
4.27 acres of OS along this corridor. Additionally, along Union Ave (APN 412-28-049) the city has
re-designated 1.26 acres of HDR to OS land uses.
One 2.17 acre parcel within the city (APN 404-07-033) that currently includes water district
utilities facilities has been redesigned from OS to MDR to support housing objectives.
Additionally, one Pacific Gas and Electric utility parcel (APN 288-01-022) has be re designated
from OS to I (Institutional) to be consistent with onsite utility uses.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-4: The Commenter references Table 2.0‐3. and references it as “delusional endless growth”.
This comment is noted. DEIR Table 2.0‐3 includes “Potential New Growth In Planning Area Over
Existing Conditions”. The Table assumes a 2040 buildout year. This comment does not involve or
identify any new significant impacts or “significant new information” that would require
recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. The City appreciates
the comments and input provided by the commenter. These comments have been forwarded to
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the Planning Commission and City Council for consideration. No further response in this EIR is
required.
H-5: The Commenter references Impact 3.1‐4 and disagrees that creating more light pollution is "less
than significant" and notes that it is never actually dark here because of existing light pollution.
EIRs address a Project’s impact potential as it relates to the existing environmental condition. As
described in DEIR Impact 3.1‐4, nighttime lighting impacts would be most severe in areas that do
not currently experience high levels of nighttime lighting. Increased nighttime lighting can reduce
visibility of the night sky, resulting in fewer stars being visible and generally detracting from the
quality of life in Campbell.
Future development would be required to be consistent with the General Plan, as well as lighting
and design requirements in the Campbell Municipal Code. The proposed General Plan contains
policies and actions related to the regulation and reduction of daytime glare and nighttime
lighting.
For example, Policy CD-2.7 calls for the City to reduce the use of highly-reflective and/or
transparent building materials in order to reduce the potential for bird strikes and other harm to
wildlife. Policy CD-2.8 calls for reduced lighting and transparent, reflective, and/or other
elements hazardous to birds in non-building structures such as art, bridges, fencing and sound
barriers, and antennae. Policy CD-2.9 requires that lighting and fixtures be integrated with the
design and layout of a project and that they provide a desirable level of security and illumination
without creating glare and overflow on adjacent properties or excessive artificial light at night
(light pollution). Additionally, Action COS- 7.h calls on the City to coordinate with the California
Department of Fish and Wildlife, Santa Clara County, the Santa Clara County Water District, and
local watershed protection groups to identify standards to reduce impacts between urban
development and riparian corridors, including lighting restrictions.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-6: The Commenter references DEIR Impact 3.10‐4: and notes that affordable housing should be a
priority in Campbell.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. It is also noted that the City’s Housing Element provides a comprehensive
approach to the provision of affordable housing in Campbell. No further response in this EIR is
required.
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H-7: The Commenter references DEIR Section 3.1 and Impact 4.1: and notes that Campbell doesn't have
any notable character, and notes that the city should support natural landscapes and recommends
several resources to improve the quality of the city.
The Conservation and Open Space Element addresses conservation topics including:
development and use of natural resources, open space, parks and recreational facilities, riparian
environments, native plant and animal species, soils, cultural/historical resources, air quality, and
alternative energy. It also details objectives and measures for preserving open space for natural
resources and the managed production of resources. Additionally, as stated in Policy COS-7.4 it
is the City’s intention to conserve existing native trees and vegetation where possible, and
integrate regionally native plant species into development and infrastructure projects where
appropriate.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-8: The Commenter references DEIR Page 3.1‐4 "The city’s open space, parks and public facilities,
especially multi‐use pathways and trails, are major contributors to the physical connection of Campbell
and provide linkages between residences, schools and commercial and employment centers." And askes:
What about wildlife linkages?
The City of Campbell has prepared the General Plan to include policies and actions intended to
protect movement corridors from adverse effects associated with future development and
improvement projects. Specifically, Action COS-7.h calls on the City to coordinate with the
California Department of Fish and Wildlife, Santa Clara County, the Santa Clara County Water
District, and local watershed protection groups to identify potentially impacted aquatic habitat
within Campbell and to develop riparian management guidelines to be implemented by
development, recreation, and other projects adjacent to creeks, streams, and other waterways.
Efforts should result in standards to reduce impacts between urban development and riparian
corridors, including lighting restrictions, pollution controls, noise reduction, and other measures
deemed appropriate to preserve and enhance the biological function of habitat.
As described under DEIR Impact 3.4-4: Campbell contains numerous aquatic habitats that may
be used for movement of wildlife. As noted in Impact 3.4-2, the following aquatic resources are
found in the Planning Area: San Tomas Aquinas Creek, Smith Creek, and Los Gatos Creek. While
flowing through Campbell, the San Tomas Aquinas Creek and Smith Creek are surrounded by
urban development. Portions of the Los Gatos Creek extend along the east side of the Los Gatos
Creek County Park, which contains riparian vegetation along the creek banks. The Los Gatos
Creek and Los Gatos Creek Trail (found in the Los Gatos Creek County Park) enables wildlife
movement; however, there are no large areas of native habitat.
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As shown in the proposed General Plan Land Use Map, Open Space land uses are found adjacent
to and along the complete stretch of Los Gatos Creek. In addition, the proposed Land Use Map
proposes targeted Open Space land uses along San Tomas Aquinas Creek. The areas designated
for urban uses by the proposed Land Use Map near both creeks are generally developed with
urban uses currently. The Los Gatos Creek County Park and Campbell Park are both designated
as Open Space. These areas would continue to be used by wildlife as movement corridors.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-9: The Commenter references DEIR Page 3.1‐5 and recommends the City reduce all of the "landscape
lighting, security lighting, and streetlights that contribute to light pollution.”
As described under Response H-5, future development would be required to be consistent with
the General Plan, as well as lighting and design requirements in the Campbell Municipal Code.
The proposed General Plan contains policies and actions related to the regulation and reduction
of daytime glare and nighttime lighting.
For example, Policy CD-2.7 calls for the City to reduce the use of highly-reflective and/or
transparent building materials in order to reduce the potential for bird strikes and other harm to
wildlife. Policy CD-2.8 calls for reduced lighting and transparent, reflective, and/or other
elements hazardous to birds in non-building structures such as art, bridges, fencing and sound
barriers, and antennae. Policy CD-2.9 requires that lighting and fixtures be integrated with the
design and layout of a project and that they provide a desirable level of security and illumination
without creating glare and overflow on adjacent properties or excessive artificial light at night
(light pollution). Additionally, Action COS- 7.h calls on the City to coordinate with the California
Department of Fish and Wildlife, Santa Clara County, the Santa Clara County Water District, and
local watershed protection groups to identify standards to reduce impacts between urban
development and riparian corridors, including lighting restrictions.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-10: The Commenter references DEIR Page 3.1‐7 and notes “The Streetscape Standards require Chinese
Pistache (Pistacia chinensis) as street trees for the section of Winchester Boulevard within the Plan Area.”
the commenter further states support for local native vegetation, and request that the city update
streetscape standards.
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This comment is noted. This comment specifically addressed “Streetscape Standards” and does
not involve or identify any new significant impacts or “significant new information” that would
require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. The City
appreciates the comments and input provided by the commenter. These comments have been
forwarded to the Planning Commission and City Council for consideration. No further response
in this EIR is required.
H-11: The Commenter references DEIR Impact 4.4: and concludes the main reason that this is less than
cumulatively considerable is because most of the natural habitats have already been destroyed.
The commenter correctly identifies Impact 4.4: and its impact conclusion. This comment is noted.
This comment does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. The City appreciates the comments and input provided by the commenter.
These comments have been forwarded to the Planning Commission and City Council for
consideration. No further response in this EIR is required.
H-12: The Commenter references general comments on a variety of Community Design Element Policies
and provides input on a variety of topics.
This comment is noted. This comment specifically addressed the General Plan Policy document
does not involve or identify any new significant impacts or “significant new information” that
would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. The
City appreciates the comments and input provided by the commenter. These comments have
been forwarded to the Planning Commission and City Council for consideration. No further
response in this EIR is required.
H-13: The Commenter references Cultural Resources section 3.5 of the DEIR, and states support for
consultation with local tribes.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-14: The Commenter references “Greenhouse Gas Emissions, Climate Change & Energy” (Section 3.7)
of the DEIR and encourages the city to include guidance and programs to that support GHG reduction
strategies including CAPs ,solar installations etc.
As described throughout the Conservation and open space Element the City has included a variety of
policies and actions that promote GHG reduction strategies as identified by the commenter. This
includes calling for the preparation of a climate action plan (CAP), as well as a variety of green building
techniques, including energy efficient standards and the promotion of renewable and alternative
energy. Below is a list of several policies and actions that may be of interest to the commenter:
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• Policy COS-10.2: Align the City’s local GHG reduction targets with the statewide GHG reduction
targets of Assembly Bill 32, and align the City’s GHG reduction goal with the statewide GHG
reduction goal of Executive Order S-03-05.
• Policy COS-10.9: Coordinate with Santa Clara County and nearby cities to implement regional
GHG reduction plans and consolidate efforts to reduce GHGs throughout the county.
• Action COS-10.c: Prepare a Climate Action Plan that establishes GHG reduction targets that are
consistent with Statewide GHG reduction goals, and includes an implementation program to
achieve the reduction targets. Periodically review and update the Plan as necessary to achieve
the GHG reduction targets specified in the Plan.
• Policy COS-8.1: Require all development projects to comply with the mandatory energy
efficiency requirements of the California Green Building Standards Code (CALGreen) and
Building and Energy Efficiency Standards.
• Policy COS-8.2: Support and encourage the implementation of innovative and green building
best management practices including, but not limited to, sustainable site planning, solar
opportunities, LEED certification for new development, the local adoption of Reach Codes, and
incorporation of net zero energy development standards in the California Code of Regulations
(CCR), Title 24, if feasible.
• Policy COS-8.3: Promote City operations as a model for energy efficiency and green building
and install, as feasible, energy-efficient lighting, appliances, and alternative-energy
infrastructure in City facilities.
This comment is noted. This comment does not involve or identify any new significant impacts or
“significant new information” that would require recirculation of the Draft EIR pursuant to CEQA
Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council for
consideration. No further response in this EIR is required.
H-15: The Commenter notes that climate change may impact future water supplies.
As described in the Draft EIR’s water supply assessment (WSA) (Appendix B of the DEIR), based
on Valley Water’s water supply plans and Urban Water Management Plan projections, Valley
Water expects to be able to meet the needs of the service area through at least 2045 for average
and single-dry years without a call for water use reductions. The impact of this project is not
consequential and Valley Water has the capacity to serve this project through buildout based on
current water supply capacity and Valley Water’s proposed water supply projects.
Additionally Action CSF-3.c requires the City to regularly review and update the City’s water
conservation measures to be consistent with current best management practices for water
conservation, considering measures recommended by the State Department of Water
Resources, the California Urban Water Conservation Council, and the Bay Area Water Supply and
Conservation Agency.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
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commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-16: The Commenter references DEIR Page 3.9‐15 Chapter 9.146 of the Campbell Municipal Code
(Water Efficient Landscape Regulations), notes many of the requirements, and questions if objectives are
being achieved.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-17: The Commenter references DEIR Page 3.9‐21‐22: and states that new developments should not be
creating runoff and pollutants similar to existing conditions.
As described on DEIR Pg. 3.9-32-33 the General Plan sets policies and actions for build-out of the
City, but it does not envision or authorize any specific development project. Because of this, the
site-specific details of potential future development projects are currently unknown and analysis
of potential project specific impacts of such projects is not feasible and would be speculative.
Each future development project must include detailed project specific drainage studies that
assess the drainage characteristics and flood risks so that an appropriate SWMP can be prepared
to control storm water runoff, both during and after construction. The SWMP will ultimately
include project specific best management measures that are designed to allow for natural
recharge and infiltration of stormwater.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-18: The Commenter references DEIR Table 3.9‐3: Santa Clara Subbasin Managed Recharge Facility
Summary, and states that a portion of our groundwater comes from the State Water Project (SWP) and
Central Valley Project (CVP). The commenter disagrees that the potential impact is "less than significant"
as we are “already stealing water from elsewhere in the state to recharge our aquifers and sate our
excessive water use”.
The SCVWD’s managed recharge systems in the Santa Clara Subbasin are summarized in Table
3.9-3.
As described on DEIR Pg. 3.9-22-29 the SCVWD’s managed recharge programs uses both runoff
captured in local reservoirs and imported water delivered by the raw water conveyance system
to recharge groundwater through more than 390 acres of recharge ponds and over 90 miles of
local creeks.
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The SCVWD actively monitors groundwater elevations to evaluate current groundwater
conditions and land subsidence, optimize recharge efforts, access groundwater storage, and
support groundwater management efforts. According to the July 2020 Groundwater Condition
Report, the Santa Clara Valley Groundwater Basin’s groundwater storage is above average and
the June 2020 groundwater levels Santa Clara Plain Well (06S01W24H015) were slightly below
the 5-year average. Overall, the 2020 managed recharge to date for the Santa Clara Plain is
22,300 AF while the 2020 groundwater pumping to date is 29,500 AF.
The Sustainable Groundwater Management Act (SGMA) defines sustainable yield as the
maximum quantity of water, calculated over a base period representative of long-term
conditions in the basin and including any temporary surplus, that can be withdrawn annually
from a groundwater supply without causing an undesirable result. According to the 2016
Groundwater Management Plan, the annual Santa Clara Plain pumping should not exceed
200,000 AF. However, the District does not manage to a particular value for sustainable yield,
but instead manages groundwater to maintain sustainable conditions through annual operations
and long‐term water supply planning.
The City of Campbell General Plan included a variety of policies and actions to support water
conservation throughout the planning area. Additionally, all future development is required to
demonstrate adequate water supplies, consistent with General Plan Action CSF-3.1, which
requires projects to demonstrate proof of adequate water supply (e.g., that existing services are
adequate to accommodate the increased demand, or improvements to the capacity of the
system to meet increased demand will be made prior to project implementation) and that
potential cumulative impacts to water users and the environment will be addressed.
This comment is noted. This comment does not involve or identify any new significant impacts
or “significant new information” that would require recirculation of the Draft EIR pursuant to
CEQA Guidelines Section 15088.5. The City appreciates the comments and input provided by the
commenter. These comments have been forwarded to the Planning Commission and City Council
for consideration. No further response in this EIR is required.
H-19: The Commenter references DEIR Table 3.10‐5: and notes the Regional Housing Needs Allocation
(RHNA) and disagrees with the RHNA allocations.
This comment is noted. The City does not set the RHNA. Each city, town, and county is assigned
a number as part of the Regional Housing Needs Assessment or “RHNA”. The total number of
new homes the Bay Area needs to build is determined by the California Department of Housing
and Community Development, or HCD, and distributed at the local level by the regional planning
agency which, for the City of Campbell, is the Association of Bay Area Governments (ABAG).
This comment does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. The City appreciates the comments and input provided by the commenter.
These comments have been forwarded to the Planning Commission and City Council for
consideration. No further response in this EIR is required.
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H-20: The Commenter references a variety of topics and issues within the Noise Chapter (3.12) of the
DEIR and included the following questions and concerns. The commenter asks if shifting weather patterns
are considered in noise molding.
As described on DEIR Pg. 3.12-5, the FHWA Highway Traffic Noise Prediction Model (FHWA-RD
77-108) was used to develop Ldn (24-hour average) noise contours for all highways and major
roadways in the Planning Area. The model is based upon the CALVENO noise emission factors for
automobiles, medium trucks, and heavy trucks, with consideration given to vehicle volume,
speed, roadway configuration, distance to the receiver and the acoustical characteristics of the
site. The FHWA Model predicts hourly Leq values for free-flowing traffic conditions and is
generally considered to be accurate within 1.5 dB. To predict Ldn values, it is necessary to
determine the hourly distribution of traffic for a typical 24-hour period.
Existing traffic volumes were obtained from the traffic modeling performed for the General Plan
study area. Day/night traffic distributions were based upon continuous hourly noise
measurement data. Heavy truck counts were also provided by the traffic engineer. Using these
data sources and the FHWA traffic noise prediction methodology, traffic noise levels were
calculated for existing conditions. Table 3.12-2 shows the results of this analysis.
Traffic noise levels are predicted at the sensitive receptors located at the closest typical setback
distance along each project-area roadway segments. In some locations sensitive receptors may
be located at distances which vary from the assumed calculation distance and may experience
shielding from intervening barriers or sound walls. However, the traffic noise analysis is believed
to be representative of the majority of sensitive receptors located closest to the project-area
roadway segments analyzed in this report.
The FHWA Model contains the following modeling components:
• Five standard vehicle types, as well as user-defined vehicles.
• Constant-flow and interrupted-flow traffic.
• Effects of different pavement types and graded roadways.
• Sound-level computations based on a one-third octave-band database and one-third
octave-band algorithms.
• Graphically interactive noise barrier design optimization.
• Attenuation over/through rows of buildings and dense vegetation.
• Multiple diffraction analyses.
• Parallel barrier analyses.
• Contour analyses.
As such, wind is not specifically identified in the FHWA modeling components. However, these
components are supported by a scientifically founded and experimentally calibrated acoustic
computation methodology and a new flexible database. The database is made up of more than
6,000 individual vehicle pass-by events, measured at 40 sites across the country. It is the primary
building block around which the acoustic algorithms are structured.
2.0 COMMENTS ON DRAFT EIR AND RESPONSES
2.0-78 Final Environmental Impact Report – Campbell General Plan Update
Additionally, during the community noise level survey, actual noise measurement would include
all existing conditions that impact noise. The community noise survey was conducted to
document ambient noise levels at various locations throughout the City. Short-term noise
measurements were conducted at six locations throughout the City on June 28-29, 2022. In
addition, four continuous 24-hour noise monitoring sites were also conducted to record day-
night statistical noise level trends. The data collected included the hourly average (Leq), median
(L50), and the maximum level (Lmax) during the measurement period. Noise monitoring sites
and the measured noise levels at each site are summarized in DEIR Table 3.12-6 and Table 3.12-
7. DEIR Figure 3.12-1 shows the locations of the noise monitoring sites.
H-21: The Commenter references a variety of topics and issues within the Noise Chapter (3.12) of the
DEIR and included the following questions and concerns: The commenter asks if lawn mowers and leaf
blowers figure into these noise thresholds, and supports the restriction and use of such tools.
The General Plan Noise Element does not specifically regulate the use of lawn mowers and leaf
blowers and there is not adopted threshold specifically for the use of these items. However, as
stated in Policy N-1.16 non-transportation related noise from site specific noise sources must
comply with the standards shown in Table N-2.
Additionally the General Plan includes several policies and actions aimed at reducing noise from
sources mentioned by the commenter. These include:
Action N-1.d, which calls for the City to update Section 21.16.070 – (Noise) of the Campbell
Municipal Code to include detailed standards and procedures for dealing with community noise
complaints and corresponding enforcement and remediation activities. The standards should
address, at a minimum:
o Criteria for determining if the alleged noise-generating activities are in violation of the
City’s adopted noise standards; and
o Procedures and protocols to ensure that the nuisance noise, or noise-generating
activity, ceases.
Action N-1.f considers requiring the phased elimination of the use of gas-powered leaf blowers
within the City.
Action N-1.j Explores and considers rebate, incentive, and educational opportunities to reduce
community noise, while providing co-benefits of community health and environmental
stewardship. Programs could include electric lawn and garden equipment upgrade programs,
dual pane/noise rated window upgrades, and HVAC system upgrades which coincide with energy
reduction, community health, and sustainability objectives identified by the General Plan and
any future Climate Action Plan.
This comment does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. The City appreciates the comments and input provided by the commenter.
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Campbell General Plan Update 2.0-79
These comments have been forwarded to the Planning Commission and City Council for
consideration. No further response in this EIR is required.
H-22: The Commenter referenced General Plan Strategy CNR‐10.1i: Vehicle Noise Reduction: and
supports further vehicle regulations to reduce noise.
This comment specifically addresses the General Plan’s policy guidance and does not involve or
identify any new significant impacts or “significant new information” that would require
recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. The City appreciates
the comments and input provided by the commenter. These comments have been forwarded to
the Planning Commission and City Council for consideration. No further response in this EIR is
required.
H-23: The Commenter references DEIR Table 3.12‐8 and disagrees with the noise thresholds.
Noise thresholds have been developed and compared using industry standards. Specially,
threshold’s identified in DEIR Table 3.12-8 are from the Federal Interagency Committee on Noise
(FICON). Based on Table 3.12-8 data, an increase in the traffic noise level of 1.5 dB or more would
be significant where the pre-project noise level exceeds 65 dB Ldn. Extending this concept to
higher noise levels, an increase in the traffic noise level of 1.5 dB or more may be significant
where the pre-project traffic noise level exceeds 75 dB Ldn. The rationale for the Table 3.12-8
criteria is that, as ambient noise levels increase, a smaller increase in noise resulting from a
project is sufficient to cause annoyance.
These transportation noise thresholds of significance shown in Table 3.12-8 are established by
the proposed General Plan via Policy N-1.8. Additionally, all DEIR Noise thresholds are described
in detail on DEIR Pg. 3.12-14 through 3.12-17.
This comment does not involve or identify any new significant impacts or “significant new
information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines
Section 15088.5. The City appreciates the comments and input provided by the commenter.
These comments have been forwarded to the Planning Commission and City Council for
consideration. No further response in this EIR is required.
ERRATA 3.0
Final Environmental Impact Report – Campbell General Plan Update 3.0-1
This chapter includes minor edits to the EIR. These modifications resulted from responses to
comments received during the Draft EIR public review period, as well as City initiated changes to
add additional clarity and to reflect minor cleanup items on the General Plan Land Use Map.
Revisions herein do not result in new significant environmental impacts, do not constitute significant
new information, and do not alter the conclusions of the environmental analysis that would warrant
recirculation of the Draft EIR pursuant to State CEQA Guidelines Section 15088.5. Changes are
provided in revision marks with underline for new text and strike out for deleted text.
3.1 REVISIONS TO THE DRAFT EIR
Since circulation of the Draft EIR, the City of Campbell has been working to refine the Land Use Map
consistent with housing goals and HCD guidance to support regional housing objectives, identify and
refine housing opportunity sites, and to cleanup any mapping errors or text changes. Since
circulation of the Draft EIR, a few minor Land Use Map “cleanups” have been made and a few parcels
have changed based on feedback from HCD on the City’s Housing Element. All Land Use Map changes
that have been made since the DEIR was circulated for public review are included in the updated
Figure LU-1 of the Campbell General Plan, as well as Figure 2.0-2 in the DEIR Project description. The
updated Land Use Map is shown below in the updated Figure 2.0-2, and specific changes made since
circulation of the DEIR are included below in FEIR Figure 3.0-1 (Land Use Map updated since
publication of the DEIR). As shown in Figure 3.0-1, changes include the addition of Open Space (OS)
along the riparian corridor in the northern portion of the Planning Area to correct a mapping error,
updates to three parcels to reflect existing institutional type uses, and an update to one parcel from
Neighborhood Commercial to Commercial Corridor Mixed Use to support housing objectives. The
map revisions would not alter the overall buildout growth projections analyzed in the DEIR. These
map revisions herein do not result in new significant environmental impacts, do not constitute
significant new information, and do not alter the conclusions of the environmental analysis that
would warrant recirculation of the Draft EIR pursuant to State CEQA Guidelines Section 15088.5.
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CITY OF CAMPBELLGENERAL PLAN UPDATE
Figure 3.0-1: Map Updates
Following DEIR Publication
LosGatosCreekSanTom asAquinasCr eekLosGatosC r e e kLosGatosCreekSources: City of Campbell; Santa Clara County. Map date: March 14, 2023.
0 2,0001,000
Feet
Planning Areas
Campbell City Boundary
Other Incorporated Areas
Planning Overlays
Site Specific Overlay - Max. Developable GrossAcres for Residential Uses as Indicated
Residential Uses
Low Density Residential (<4.5 Units/Gr. Acre)
Low Density Residential (<5.5 Units/Gr. Acre)
Low Density Residential (<7.5 Units/Gr. Acre)
Low-Medium Density Residential(8-16 Units/Gr. Acre)Medium Density Residential(18-25 Units/Gr. Acre)Medium-High Density Residential(26-33 Units/Gr. Acre)
Mobile Home Park (8-16 Units/Gr. Acre)
Commercial/Office Uses
Neighborhood Commercial
General Commercial
Professional Office
Industrial Uses
Light Industrial
Research & Development
Mixed Uses
General Commercial/Light Industrial
Professional Office Mixed-Use(8-16 Units/Gr. Acre)Neighborhood Commercial Mixed-Use(18-25 Units/Gr. Acre)Medium-High Density Mixed-Use(26-33 Units/Gr. Acre)Central Business Mixed-Use(26-33 Units/Gr. Acre)
General Commercial Mixed-Use(26-33 Units/Gr. Acre)High Density Mixed-Use(34-45 Units/Gr. Acre)Commercial Corridor Mixed-Use(45-60 Units/Gr. Acre)Transit-Oriented Mixed-Use(57-75 Units/Gr. Acre)
Public/Recreational Uses
Public Facilities
Open Space
From Neighborhood Commercialto Commercial Corridor Mixed-Use
LMDR to ILMDR to IFrom Low-Medium Density Residentialto Institutional
Corrected:From General Commercialto Open Space
From High Density Mixed-Useto Neighborhood Commercial(former Denny's)
From High Density Mixed-Useto Neighborhood Commercial(Social Security Offices/Jack in the Box)
From Transit-Oriented Mixed-Useto Public Facilities(First St. Parking Garage)
From High Density Mixed-Useto General Commercial Mixed-Use(Campbell Industrial Park)
From Medium-High Density Mixed Useto High Density Mixed-Use(Campbell Technology Park)
From Medium-High Density Mixed Useto Research & Development(Campbell Technology Park)
From General Commercialto General Commercial Mixed-Use
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Final Environmental Impact Report – Campbell General Plan Update 3.0-3
EXECUTIVE SUMMARY
Changes were made to the following pages of the Draft EIR:
DEIR Pg. ES-2 San Jose Water Company (Valley Water)
1.0 INTRODUCTION
Changes were made to the following pages of the Draft EIR:
DEIR Pg. 1.0-5
• Santa Clara Valley Water District (Valley Water)
DEIR Pg. 1.0-10 San Jose Water Company (Valley Water)
2.0 PROJECT DESCRIPTION
Changes were made to the following Figure of the Draft EIR:
DEIR Figure 2.0-2 (Proposed Land Use Map)
See Figure 3.0-1, above, for changes to the Proposed Land Use Map
3.1 AESTHETICS AND VISUAL RESOURCES
Changes were made to the following pages of the Draft EIR:
DEIR Pg. 3.1-16 Santa Clara County Valley Water District
DEIR Pg. 3.1-17 Santa Clara County Valley Water District
3.2 AGRICULTURAL AND FOREST RESOURCES
No changes were made to Section 3.2 of the DEIR.
3.3 AIR QUALITY
No changes were made to Section 3.3 of the DEIR.
3.4 BIOLOGICAL RESOURCES
Changes were made to the following pages of the Draft EIR:
DEIR Pg. 3.4-26, 3.4-29, and 3.4-32:
COS-7.c Where sensitive biological habitats have been identified on or immediately
adjacent to a project site, the project shall include appropriate mitigation measures
identified by a qualified biologist, which may include, but are not limited to the following:
3.0 ERRATA
3.0-4 Final Environmental Impact Report – Campbell General Plan Update
· Pre-construction surveys for species listed under the State or Federal
Endangered Species Acts, Migratory Bird Treaty Act, or species identified as
special-status by the resource agencies, shall be conducted by a qualified biologist;
· Provision of temporary or permanent buffers of adequate size (based on the
specifics of the protected species) to avoid nest abandonment by nesting migratory
birds and raptors associated with construction and site development activities.
· Construction barrier fencing shall be installed around sensitive resources and
areas identified for avoidance or protection, and to reduce potential soil
compaction in sensitive areas; and
· Pre-Construction training of contractors and sub-contractors shall be
conducted by a qualified biologist to identify and avoid protected species and
habitat.
DEIR pg. 3.4-19 Fish and Game Code §3503, 3503.5, 3513, 3800 - Predatory Birds
The California Fish and Game Code provide protection for native birds, including their nests
and eggs (Sections 3503, 3513, and 3800). These regulations prohibit all forms of take,
including disturbance that causes nest abandonment and/or loss of reproductive effort.
Raptors (i.e., eagles, falcons, hawks, and owls) are specifically protected under Fish and
Game Code Section 3503.5. Additionally, Fish and Game Code 3503 and 3513 are applicable
to all birds and birds listed within the Migratory Bird Treaty Act.
Under the California Fish and Game Code, all predatory birds in the order Falconiformes or
Strigiformes in California, generally called “raptors,” are protected. The law indicates that it
is unlawful to take, posses, or destroy the nest or eggs of any such bird unless it is in
accordance with the code. Any activity that would cause a nest to be abandoned or cause a
reduction or loss in a reproductive effort is considered a take. This generally includes
construction activities.
DEIR Pg. 3.4-21 Santa Clara County Valley Water District
DEIR Pg. 3.4-22 The SCVWD Water Resources Protection Collaborative issued Guidelines and
Standards for Land Use Near Streams:
DEIR Pg. 3.4-22 The SCVWD Valley Water owns much of the land where the Los Gatos Creek
Trail located in the southeast corner of Campbell and would be a responsible agency if any
future projects would result in work within its title fee property. “Responsible agencies” are
public agencies that carry out or approve a project for which a lead agency is conducting
CEQA review; responsible agencies are all agencies other than the lead agency with
discretionary approval power over the project. In the case of the proposed project, a permit
from the SCVWD would be required for any work that occurs within the Los Gatos Creek
trail corridor.
DEIR Pg. 3.4-27 Santa Clara County Valley Water District
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Final Environmental Impact Report – Campbell General Plan Update 3.0-5
DEIR Pg. 3.4-27 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for
Land Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-30 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for
Land Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-30 Santa Clara County Valley Water District
DEIR Pg. 3.4-32 Santa Clara County Valley Water District
DEIR Pg. 3.4-32 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for
Land Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-36 Santa Clara County Valley Water District
DEIR Pg. 3.4-36 COS-7.i Adopt an ordinance incorporating the Guidelines and Standards for
Land Use Near Streams into the Zoning Code.
DEIR Pg. 3.4-37 Santa Clara County Valley Water District
3.5 CULTURAL AND TRIBAL RESOURCES
No changes were made to Section 3.5 of the DEIR.
3.6 GEOLOGY
No changes were made to Section 3.6 of the DEIR.
3.7 GREENHOUSE GAS, CLIMATE CHANGE AND ENERGY
Changes were made to the following pages of the Draft EIR:
DEIR Page 3.7-37: For example, PG&E is responsible for the mix of energy resources used
to provide electricity for its customers, and it is in the process of implementing the
Statewide Renewable Portfolio Standard (RPS) to increase the proportion of renewable
energy (e.g. solar and wind) within its energy portfolio. However, community choice
programs such as the Silicon Valley Clean Energy provide power generation for Campbell
residents and businesses by supplying grid power with renewable and carbon free choices
and include the following tier structures: Greenstart power 100% carbon free and 50%
renewable, and Greenprime 100% carbon free and 100% renewable.
3.8 HAZARDS AND HAZARDOUS MATERIALS
No changes were made to Section 3.8 of the DEIR.
3.9 HYDROLOGY AND WATER QUALITY
Changes were made to the following pages of the Draft EIR:
3.0 ERRATA
3.0-6 Final Environmental Impact Report – Campbell General Plan Update
DEIR Pg. 3.9-1 The San Jose Water Company (Valley Water)
DEIR Pg. 3.9-3. Two Several creeks are located within the City’s Planning Area: Los Gatos
Creek. and San Tomas Aquino Creek, and Smith Creek.
DEIR Pg. 3.9-4 river creek
DEIR Pg. 3.9.-7.
Vasona Dam and reservoir is located on Los Gatos Creek within the town of Los Gatos. The
Vasona Lake Dam and Reservoir is one of six original reservoirs approved by the voters in
1934. The reservoir capacity is 495 acre-feet. The surface area is 57 acres. The dam was
completed in 1935 and new gates were installed in 1997. The dam inundation area is shown
below in Exhibit 3.9-1. As shown the inundation area impacts the SR 85 Roadway in the
southernmost portion of the Planning Area.
Exhibit 3.9-1: Vasona Dam inundation Area:
DEIR Pg. 3.9-16
Santa Clara and Llagas Subbasins 2016 2021 Groundwater Management Plan
The 2016 2021 Groundwater Management Plan (GWMP) for the Santa Clara and Llagas
Subbasins describes the SCVWD's comprehensive groundwater management framework,
including existing and potential actions to achieve basin sustainability goals and ensure
continued sustainable groundwater management.
DEIR Pg. 3.9-17 SVCWP WVCWP
3.10 LAND USE PLANNING AND POPULATION/HOUSING
No changes were made to Section 3.10 of the DEIR.
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Final Environmental Impact Report – Campbell General Plan Update 3.0-7
3.11 MINERAL RESOURCES
No changes were made to Section 3.11 of the DEIR.
3.12 NOISE
No changes were made to Section 3.13 of the DEIR.
3.13 PUBLIC SERVICES AND RECREATION
Changes were made to the following pages of the Draft EIR:
DEIR Pg. 3.13-10 The Hacienda Percolation Ponds Camden Ponds
DEIR Pg. 3.13-1 through 3.13-4 Section 3.13.1 Environmental Setting - Fire Protection
Services.
The City of Campbell receives fire protection from the Santa Clara County Fire Department
(SCCFD).
The Santa Clara County Fire Department (SCCFD), which was formed in 1947, provides
suppression and dispatches emergency services for a 128.3-mile area. The SCCFD provides
firefighting personnel and emergency medical service (basic life support) to the residents
and businesses in Los Altos Hills, Los Altos, Cupertino, Saratoga, Monte Sereno, Campbell,
and Los Gatos. The Department also provides protection for the unincorporated areas
adjacent to those cities. The City of Campbell contracts service through the SCCFD, and the
Campbell Police Chief is responsible for SCCFD contracts.
The SCCFD maintains 15 fire stations, an administrative headquarters, a maintenance
facility, five other support facilities. The SCCFD offers fire resources and services that are
divided into five major sections: Fire Suppression and Rescue, Fire Investigation, Emergency
Medical Services, Special Operations Task Force / Haz-Mat, and Wildland Urban Interface.
The SCCFD operates two fire stations within the City of Campbell, as shown on Figure 3.13-
1. Both stations are City-owned facilities.
• Campbell Fire Station, at 123 Union Avenue, Campbell
• Sunnyoaks Fire Station / McCormack Training Center, at 485 West Sunnyoaks Avenue,
Campbell
Fire Suppression and Rescue
The Fire Suppression Department is configured into three districts. First-call equipment is
deployed to deliver initial fire attack and EMS services within 7 minutes. A standard first-
alarm assignment for structure fires consists of two engine companies, a ladder truck
company, a rescue or hazardous materials company and a Battalion Chief, for a total of 15
people. On working fires, the response is increased to three engines companies, one ladder
truck company, a Hazmat and Breathing Support company, one rescue company, two
Battalion Chiefs, a Safety Officer, and a Duty Investigator, totaling 25 persons.
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3.0-8 Final Environmental Impact Report – Campbell General Plan Update
A second-alarm would add another two engine companies, one truck company, one rescue
company, and an additional Chief Officer; total staffing for two alarms is then 40 persons.
Wildland-urban interface companies are trained and equipped to provide structure
protection and limited initial attack on wildland incidents.
A brush alarm for vegetation fires in wildland/urban interface areas consists of two engine
companies, a Type 3 engine and a Battalion Chief, totaling 9 persons.
Daily emergency response staffing consists of 70 career fire personnel on a 24-hour shift
assignment, operating 19 pieces of first-line apparatus, plus three 3 Battalion Chief
command vehicles, operating from 15 fire stations. In daily operations during declared "Fire
Season," patrols function in tandem with ladder trucks during daytime hours. This means
that during the summer months, when the probability of a brush fire is high, the truck and
patrol vehicle go out on calls as a pair. This guarantees continuous coverage of the entire
area served, should another response be required during an alarm.
The SCCFD aims to control emergency incidents that threaten lives, property, and the
environment. The Department maintains the following three goals:
• Arrive at the scene of emergencies within five minutes of receipt of alarm, at least
90 percent of the time.
• Maintain "Confined Space - Operational Level" training for all Department
responders.
• Maintain "Rescue Systems I" certification for truck and rescue personnel.
The SCCFD has four first-call ladder trucks and one rescue vehicle, which employ specialized
equipment designed to carry out rescues such as traffic collisions and industrial accidents.
All emergency response personnel are trained in specialized rescue techniques. All
apparatus carry a compliment of rescue tools.
Fire Investigation
The Department is one of the few agencies in the Bay Area to staff full time fire investigator
positions, augmented by on-call personnel. Investigation of fires provides information on
the cause of local fire problems, which provides information to the local news media
regarding fire safety education.
Arson Investigation provides for the apprehension of arsonists who cause billions of dollars
in property damage, fraud and death each year. The Department also uses the AIRS program
to track arson registrants/suspects and compile fire statistics. With local police agencies, the
Santa Clara County Fire Investigation Unit track down many arson investigations, as they
account for about 25% of fires. The SCCFD places a strong emphasis on quelling arson fires.
Emergency Medical Services
The SCCFD provides first response Advanced Life Support (ALS) Paramedic level services to
Unincorporated Santa Clara County, Campbell, Cupertino, Los Altos, Los Altos Hills, Los
Gatos, Monte Sereno, and Saratoga. An Emergency Medical Services (EMS) Coordinator and
a Firefighter Engineer Paramedic, who report to the Battalion Chief of Operations, facilitate
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Final Environmental Impact Report – Campbell General Plan Update 3.0-9
the delivery of high quality, effective patient care. The District operates 19 fully equipped
ALS fire apparatus daily all staffed with a minimum of one Paramedic and two Emergency
Medical Technicians (EMT). The Department maintains a Santa Clara County EMS Multi-
Casualty Incident (MCI) supply trailer for large-scale emergency medical incidents and is a
participant in Master Mutual Aid in the event of major disasters.
The Department’s EMS division is an active participant in the Santa Clara County EMS
System, participates in many of the EMS subcommittees, and sits as a representative on the
EMS subsection of the Santa Clara County Fire Chiefs Association. The State of California’s
EMS Authority has recognized the Department as a Continuing Education Provider for both
Paramedics and Emergency Medical Technicians.
The District is a participant in Santa Clara County's Electronic EMS patient care record (PCR)
system. The software is programmed to capture patient data upon receipt of a 911 call and
provides enhanced capabilities for monitoring and evaluating patient care. The Department
is committed to the protection of an individual's private patient healthcare information and
maintains a comprehensive Privacy Practices Policy.
Santa Clara County EMS has a contract with a third party ambulance transport provider for
the ground transport of all patients. The delivery of exceptional EMS in a partially rural area
involves the utilization of ALS helicopter service providers. The Department routinely works
with the various transport providers in order to rapidly transport critical patients from all
locations to definitive care. Some areas covered by the department are so remote that an
ALS helicopter is part of the initial EMS dispatch. The Department conducts extensive in-
service training on a routine basis to insure the most up to date EMS skills, procedures, and
practices are implemented and delivered to the citizens and visitors of Santa Clara County.
Special Operations Task Force / Haz-Mat
The mission of the SCCFD Special Operations Task Force is to improve emergency responses
that are outside the scope of typical emergency calls through advanced training, teaching,
and emergency responses in the district and adjoining agencies.
In addition to regular fire department training, all members are required to have the
following:
• CSFM Fire Instructor 1A and 1B
• Confined Space Rescue
• Trench Rescue
• Low Angle Rescue
• Rescue Systems I and/or II
• CSTI Hazardous Materials Technician or Specialist
• Haz-Mat Safety Officer/All Risk
Continued training includes:
• Weekly Special Ops, multi company training
• Participation in the quarterly Hazardous Materials Countywide Refresher Training
• UASI Urban Shield Exercise/Competition and Participation (12 hours)
3.0 ERRATA
3.0-10 Final Environmental Impact Report – Campbell General Plan Update
The SCCFD Special Operations Task Force may be deployed within the district when needed
by Incident Command request of the Special Operations Task Force. Haz-Mat 72 is also
recognized as an OES Type 1 resource for large WMD or large scale Haz-Mat events
throughout the state.
Some Santa Clara County Fire Department Special Operations Task Force (SOTF) members
have been attached to FEMA Task Force 3, local SWAT teams, or actively teach for private
and public agencies. Some member deployments and SOTF deployments include:
• Hurricane Katrina – rescue and Haz-Mat operations (2005)
• San Jose High Rise Rescue (2011)
• Santa Clara County City Six Flags Roller Coaster Rescue (2007)
• San Jose Downtown / AT&T- 1,300-gallon Diesel Spill (2010)
• Santa Clara City/ CHP- Bomb maker's facility (2013)
• Los Altos- PG&E House Explosion (2002)
• Suspicious Package/ Envelope diagnostics at Campbell PD, Moffett Field, Google, EBay,
Stanford and Apple (various years)
• Trench and steep terrain rescues (various years)
The City of Campbell receives fire protection from the Santa Clara County Fire Department
(SCCFD).
The Santa Clara County Fire Department (SCCFD), which was formed in 1947, provides
suppression and dispatches emergency services for a 128.3-mile area. The SCCFD provides
fire prevention, fire investigation, and all-hazard emergency services inclusive of structural
and wildland firefighting, rescue and advanced life support emergency medical services
(EMS), and special operations response to the residents and businesses in Los Altos Hills, Los
Altos, Cupertino, Saratoga, Monte Sereno, Campbell, and Los Gatos. The Department also
provides protection for the unincorporated areas adjacent to those cities. The City of
Campbell contracts service through the SCCFD, and the Campbell Police Chief is responsible
for SCCFD contracts.
The SCCFD maintains 15 fire stations, an administrative headquarters, a maintenance
facility, and five other support facilities. Additionally, the SCCFD supplies executive
leadership by contract to the Santa Clara County Office of Emergency Management, and the
Santa Clara County 9-1-1 Communications Department. The SCCFD offers fire resources and
emergency services that are divided into five major sections: Fire Suppression, Rescue and
Emergency Medical Services, Fire Investigation, Special Operations, and Wildland Urban
Interface.
The SCCFD operates two fire stations within the City of Campbell, as shown on Figure 3.13-
1. Both stations are City-owned facilities.
• Campbell Fire Station, at 123 Union Avenue, Campbell
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Final Environmental Impact Report – Campbell General Plan Update 3.0-11
• Sunnyoaks Fire Station / McCormack Training Center, at 485 West Sunnyoaks Avenue,
Campbell
Fire Suppression and Rescue
Emergency response falls under the operations division. SCCFD’s fifteen fire stations are
configured into three battalions. First-call equipment is deployed to deliver initial fire attack
and EMS services for moderate and high-risk incidents with first unit arrival within 8
minutes. A standard first-alarm assignment for structure fires consists of two engine
companies, a ladder truck company or a rescue and a Battalion Chief, for a total of 11
people. On working fires, the response is increased to three engines companies, one ladder
truck company, a Hazmat and Breathing Support company, one rescue company, two
Battalion Chiefs, a Safety Officer, and a Duty Investigator, total 25 persons.
A second-alarm would add another two engine companies, one truck company, one rescue
company, and an additional Chief Officer; total staffing for two alarms is then 40 persons.
Wildland-urban interface companies are trained and equipped to provide structure
protection and initial attack on wildland incidents.
A brush alarm for vegetation fires in wildland/urban interface areas consists of two Type 1
engine companies, a Type 3 or Type 6 engine company, and a Battalion Chief, totaling 10
persons.
Daily emergency response staffing consists of 66 career fire personnel on a 24-hour shift
assignment, using 19 pieces of first-line apparatus, plus three Battalion Chief command
vehicles, and working from 15 fire stations.
The SCCFD aims to “improve survivability for victims of fire, hazardous materials release,
entrapment or other crisis incidents” (SCCFD, 2020):
• First unit arrival at structure fires, vegetation fires, and other crisis incidents in urban
areas in an average of 5:30 and under 7:50 ninety percent of the time.
• Contain structure fires to the room of origin at or above current, published, national
average percentage.
• Keep vegetation fires to three acres or less ninety percent of the time.
The SCCFD has three ladder trucks, three rescue vehicles, and one urban search and rescue
vehicle which employ specialized equipment designed to help personnel carry out technical
rescues such as traffic collisions and industrial accidents. All emergency response personnel
are trained in specialized rescue techniques. All SCCFD apparatus are equipped with a
compliment of rescue tools scaled to their local hazards.
Fire Investigation
The Department provides fire investigation services by means of specially trained fire
prevention division staff, whom are augmented by on-call personnel. The Department
3.0 ERRATA
3.0-12 Final Environmental Impact Report – Campbell General Plan Update
contracts with the Campbell Police Department for criminal investigation services in
conjunction with the arson program, and in cooperation with other local law enforcement
agencies. Conducting effective fire investigations results in information on the origin and
cause of fire incidents, finds local fire problems, and supports prosecution of arsonists who
nationwide cause billions of dollars in property damage, fraud, injuries, and death each year.
In turn this supplies information to the SCCFD’s Community Education and Risk Reduction
Services program to better identify community risk and provide targeted fire safety
education to the community.
Emergency Medical Services
The SCCFD provides first response Advanced Life Support (ALS) Paramedic level services to
Campbell, Cupertino, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Saratoga, and
unincorporated areas of Santa Clara County. The EMS section, under the direction of the
Deputy Chief of Operations, facilitates the delivery of high quality, effective patient care.
The section is overseen by an Emergency Medical Services (EMS) Coordinator, who is a
registered nurse, and a Firefighter Paramedic. The Department uses 19 fully equipped ALS
fire apparatus daily, all staffed with a minimum of one Paramedic and two Emergency
Medical Technicians (EMT). The Department maintains a Santa Clara County EMS Multi-
Casualty Incident (MCI) supply trailer for large-scale emergency medical incidents and is a
participant in Master Mutual Aid in the event of major disasters.
The EMS section is an active participant in the Santa Clara County EMS System, takes part in
many of the EMS subcommittees, and sits as a representative on the EMS subsection of the
Santa Clara County Fire Chiefs Association. The State of California’s EMS Authority has
recognized the Department as a Continuing Education Provider for both Paramedics and
EMTs.
The SCCFD is a participant in Santa Clara County's Electronic EMS patient care record (PCR)
system. The software is programmed to capture patient data upon receipt of a 911 call and
provides enhanced capabilities for monitoring and evaluating patient care. The Department
is committed to the protection of an individual's private patient healthcare information and
maintains a comprehensive Privacy Practices Policy.
Santa Clara County EMS has a contract with a third-party ambulance transport provider for
the ground transport of all patients. The delivery of exceptional EMS in a partially rural area
involves the utilization of ALS helicopter service providers. The SCCFD routinely works with
the various transport providers in order to rapidly transport critical patients from all
locations to definitive care. Some areas covered by the department are so remote that an
ALS helicopter is part of the initial EMS dispatch. The Department conducts extensive in-
service training on a routine basis to insure that most up to date EMS skills, procedures, and
practices are implemented and delivered to the citizens and visitors of Santa Clara County.
ERRATA 3.0
Final Environmental Impact Report – Campbell General Plan Update 3.0-13
Special Operations Task Force / Haz-Mat
The mission of the SCCFD Special Operations Task Force is to improve emergency responses
that are outside the scope of typical emergency calls through advanced training, teaching,
and emergency responses in the district and adjoining agencies.
In addition to regular fire department training, Special Operations Task Force members are
required to have the following training:
• Incident command and fire instructor training
• Technician and/or specialist-level training for rope rescue, confined space, trench,
and structural collapse rescue incidents
Hazardous Materials technician and/or specialist-level training with enhanced CBRNE
component
Continued training includes:
• Weekly task force training and multi company training
• Participation in quarterly hazardous materials and technical rescue training exercises
with countywide stakeholders.
The SCCFD Special Operations Task Force may be deployed to incidents based on incident
scope and dispatch protocols, or by request of the incident command. USAR 85 is certified
by Cal-OES Fire and Rescue Division as a Type-1 (Heavy) Urban Search and Rescue Company.
Haz-Mat 72 is also certified by Cal-OES Fire and Rescue Division as a Type 1 Hazardous
Materials Response Team. Each resource can be deployed statewide to significant natural
or human-caused incidents through the California Fire and Rescue mutual-aid system.
Several SCCFD Special Operations Task Force (SOTF) personnel are members of California
Urban Search and Rescue Task Force 3, one of 8 national urban search and rescue task forces
here in California, and a total of 28 such task forces nationwide. These task forces are
deployed by FEMA to provide urban search and rescue support for national-level disasters.
Team members have deployed to various hurricanes, floods, and earthquakes since SCCFD
became a participating agency after the events of September 11, 2001.
3.14 CIRCULATION
No changes were made to Section 3.14 of the DEIR.
3.15 UTILITIES AND SERVICE SYSTEMS
Changes were made to the following pages of the Draft EIR:
DEIR Pg. 3.15-1 The San Jose Water Company (Valley Water)
3.0 ERRATA
3.0-14 Final Environmental Impact Report – Campbell General Plan Update
DEIR Page 3.15-14 Santa Clara Valley Water District Water Supply and Infrastructure
Master Plan 2040
DEIR Page 3.15-14 The SCVWD’s 2012 Water Supply and Infrastructure Master Plan 2040
DEIR Pg. 3.15-28 river creek
DEIR Page 3.15-28: The Safe, Clean Water and Natural Flood Protection Program, has the
following 6 priorities:
Priority A: Ensure a Safe, Reliable Water Supply
Priority B: Reduce Toxins, Hazards, and Contaminants in our Waterways
Priority C: Protect our Water Supply and Dams from Earthquakes and Other Natural
Disasters
Priority D: Restore Wildlife Habitat and Provide Open Space
Priority E: Provide Flood Protection to Homes, Businesses, Schools, Streets, and
Highways
Priority F: Support Public Health and Public Safety for Our Community
The Clean, Safe Creeks and Natural Flood Protection (CSC) Plan was approved by
Santa Clara County voters in November 2000 to create a countywide special parcel
tax to accomplish the following four goals:
• 100-year flood protection for homes, schools, businesses, and transportation;
• Clean, safe water in Santa Clara County creeks and bays;
• Healthy creek and bay ecosystems; and
• Trails, parks, and open space along waterways.
DEIR Page 3.15-32 The West Valley Clean Water Program (WVCWP) was established in 1994
as a collaborative effort between the smaller west valley communities (Campbell, Monte
Sereno, Saratoga, and Los Gatos) to implement stormwater pollution control and
management efforts. The WVCWP goal is to reduce pollutants in storm drain discharges,
comply with MRP regulations and requirements, and maximize the effectiveness of
pollution prevention efforts. The Santa Clara Valley Water District (SCVWD) administers an
Urban Runoff Management Plan to reduce stormwater pollution, which includes the
following specific actions:
• Municipal controls such as storm drain stenciling, storm drain operation and
maintenance (O&M), street sweeping, street/public facilities maintenance, and illegal
discharge response.
ERRATA 3.0
Final Environmental Impact Report – Campbell General Plan Update 3.0-15
• Construction and development measures including on-site inspections, grading and
erosion controls, and educating developers.
• Commercial and industrial facility inspections to prevent wastes from discharging into
the storm drain system.
Public education activities to increase awareness and change behavior.
By agreement with the participating cities and towns, the WVSD collects an additional
surcharge from residences and commercial properties to fund the WVCWP. The SCVWD
complies with the requirements of the MRP for urban runoff pollution control.
The West Valley Clean Water Program Authority (Authority) serves as the Stormwater
Pollution Prevention Authority for the cities of Campbell, Monte Sereno, Saratoga, and the
Town of Los Gatos. The Authority was created to maximize the effectiveness, efficiency, and
cost-benefit of collective stormwater pollution prevention efforts of the four West Valley
communities. The Authority was formally established in February 2018 but has been
operating as a collaborative stormwater management program since 1992.
The Authority’s member agencies must comply with the NPDES stormwater permit, which
mandates certain activities including maintenance of the stormwater drain system.
The Authority develops an annual work plan to fulfill the requirements of its MRP and to
reduce the amount of pollutants discharged in urban runoff. The plan is a comprehensive
program that is designed to reduce the discharge of pollutants to the maximum extent
practicable and encompasses best practices for the following operational areas:
• Construction Site Stormwater Runoff Control
• Commercial Facilities
• Illicit Discharge Detection and Elimination
• Industrial Facilities
• Municipal Operations/Pollution Prevention and Good Housekeeping
• Post Construction Storm Water Management
• Public Education
• Public Participation
The Authority also participates in the Santa Clara Valley Urban Runoff Program (Program).
The Program is an association of thirteen cities and towns in Santa Clara Valley, the County
of Santa Clara, and the Santa Clara Valley Water District that share a common permit to
discharge stormwater to South San Francisco Bay. Member agencies include Campbell,
County of Santa Clara, Cupertino, Los Altos, Los Altos Hills, Los Gatos, Milpitas, Monte
Sereno, Mountain View, Palo Alto, San Jose, Santa Clara, Santa Clara Valley Water District,
Saratoga, and Sunnyvale.
3.0 ERRATA
3.0-16 Final Environmental Impact Report – Campbell General Plan Update
3.16 WILDFIRE
No changes were made to Section 3.15 of the DEIR.
4.0 CUMULATIVE/OTHER CEQA-REQUIRED TOPICS
No changes were made to Section 4.0 of the DEIR.
5.0 ALTERNATIVES
No changes were made to Chapter 5.0 of the DEIR.
6.0 REPORT PREPARERS
No changes were made to Chapter 6.0 of the DEIR.
7.0 REFERENCES
The following references are added to Section 7.0 of the DEIR:
Regional Water Quality Control Board (RWQCB) Municipal Regional Stormwater NPDES
Permit. May 11, 2022 (Order No. R2-2022-0018, NPDES Permit No. CAS612008)
Santa Clara Valley Water District Water Supply Master Plan 2040. November 2019.
Available At:
https://www.valleywater.org/sites/default/files/Water%20Supply%20Master%20Plan%20
2040
Envision Campbell General Plan and Housing Element Update
FINDINGS OF FACT AND STATEMENT OF
OVERRIDING CONSIDERATIONS
FOR THE
ENVISION CAMPBELL GENERAL PLAN AND HOUSING
ELEMENT UPDATE
MARCH 2023
Prepared for:
City of Campbell
City Hall 70 N. First St.
Campbell, CA 95008
Prepared by:
De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
www.denovoplanning.com
D e N o v o P l a n n i n g G r o u p
A L a n d U s e P l a n n i n g , D e s i g n , a n d E n v i r o n m e n t a l F i r m
FINDINGS OF FACT AND STATEMENT
OF OVERRIDING CONSIDERATIONS
FOR THE
ENVISION CAMPBELL GENERAL PLAN AND HOUSING ELEMENT
UPDATE
MARCH 2023
Prepared for:
City of Campbell
City Hall 70 N. First St.
Campbell, CA 95008
Prepared by:
De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
www.denovoplanning.com
TABLE OF CONTENTS TOC
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding
Considerations TOC-1
FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS
Section Page Number
I. Introduction .................................................................................................................................. 1
II. General Findings and Overview .................................................................................................... 2
III. Findings and Recommendations Regarding Significant and Unavoidable Impacts .................... 4
IV. Findings and Recommendations Regarding Less than Significant Impacts, Less Than
Cumulatively Considerable, or Have No Impact ............................................................................. 11
V. Project Alternatives .................................................................................................................... 19
VI. Statements of Overriding Consideration .................................................................................. 25
VII. Conclusion ................................................................................................................................ 27
TOC TABLE OF CONTENTS
TOC-2 Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding
Considerations
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Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 1 of 27
FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS
FOR THE
ENVISION CAMPBELL GENERAL PLAN AND HOUSING ELEMENT UPDATE
REQUIRED UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
(Public Resources Code, Section 21000 et seq)
I. INTRODUCTION
The California Environmental Quality Act (CEQA) requires the City of Campbell (City), as
the CEQA lead agency to: 1) make written findings when it approves a project for which an
environmental impact report (EIR) was certified, and 2) identify overriding considerations for
significant and unavoidable impacts identified in the EIR.
These findings explain how the City, as the lead agency, approached the significant and
potentially significant impacts identified in the environmental impact report (EIR) prepared for
the General Plan Update (General Plan, or Project). The statement of overriding considerations
identifies economic, social, technological, and other benefits of the Project that override any
significant environmental impacts that would result from the Project.
As required under CEQA, the Final EIR describes the Project, adverse environmental
impacts of the Project, and mitigation measures and alternatives that would substantially
reduce or avoid those impacts. The information and conclusions contained in the EIR reflect the
City’s independent judgment regarding the potential adverse environmental impacts of the
Project.
The Final EIR (which includes the Draft EIR, comments on the Draft EIR, responses to
comments on the Draft EIR, and any revisions to the Draft EIR) for the Project, examined several
alternatives to the Project that were not chosen as part of the approved Project (the No Project
Alternative, Modified Project Alternative, and the Corridor Enhancements Alternative).
The Findings of Fact and Statement of Overriding Considerations set forth below
(“Findings”) are presented for adoption by the City Council (Council) as the City’s findings under
the California Environmental Quality Act (“CEQA”) (Public Resources Code, §21000 et seq.) and
the CEQA Guidelines (California Code of Regulations, Title 14, § 15000 et seq.) relating to the
Project. The Findings provide the written analysis and conclusions of this Council regarding the
Project’s environmental impacts, mitigation measures, alternatives to the Project, and the
overriding considerations, which in this Council’s view, justify approval of the Campbell General
Plan, despite its environmental effects.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 2 of 27
II. GENERAL FINDINGS AND OVERVIEW
A. Project Background
In 2016, the City of Campbell embarked on multi-year process to update the City’s
General Plan. The General Plan is the overarching policy document that guides land use,
housing, transportation, infrastructure, community design, and other policy decisions. State law
requires every city and county in California to prepare and maintain a general plan planning
document. The General Plan is the City’s “constitution” or “blueprint” for future development
of the city, and provides the policy guidance for achieving the community’s vision. In 2021, the
City initiated an update to the Housing Element. The Housing Element is updated every eight
years to take into account the changing needs of the community and to comply with state law.
The Housing Element includes a Housing Sites Inventory that shows the locations where
housing can be built and is supported by goals, policies, and strategies aimed at meeting the
community’s housing needs.
As part of the General Plan Update process, a General Plan Existing Conditions Report
was prepared to establish a baseline of existing conditions in the city.
The updated Campbell General Plan includes a framework of goals, policies, and actions
that will guide the community toward its common vision. The General Plan is supported with a
variety of maps, including a Land Use Map and Circulation Diagram.
B. Procedural Background
The City of Campbell circulated a Notice of Preparation (NOP) of an EIR for the proposed
Project on March 23, 2022 to trustee and responsible agencies, the State Clearinghouse, and
the public. A scoping meeting was held on April 12, 2022 at the City of Campbell City Hall. Public
comments on the NOP related to the EIR were presented or submitted during the scoping
meeting. During the 30-day public review period for the NOP, which ended on April 25, 2022,
nine written comment letters were received on the NOP. The NOP and all comments received
on the NOP are presented in Appendix A of the DEIR. Concerns raised in response to the NOP
were considered during preparation of the Draft EIR.
Campbell published a public Notice of Availability (NOA) for the Draft EIR on September
12, 2022, inviting comment from the general public, agencies, organizations, and other
interested parties. The NOA was filed with the State Clearinghouse (SCH# 2022030566) and
was published in the Santa Clara County Clerk’s office and the Mercury News, pursuant to the
public noticing requirements of CEQA. The Draft EIR was available for public review from
September 12, 2022, through October 28, 2022. The Public Draft General Plan was also
available for public review and comment during this time period.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 3 of 27
The Draft EIR contains a description of the Project, description of the environmental
setting, identification of Project impacts, and mitigation/minimization measures for impacts, as
well as an analysis of Project alternatives, identification of significant irreversible environmental
changes, growth-inducing impacts, and cumulative impacts. The Draft EIR identifies issues
determined to have no impact or a less than significant impact, and provides detailed analysis
of potentially significant and significant impacts. Comments received in response to the NOP
were considered in preparing the analysis in the Draft EIR.
The City received eight comment letters regarding the General Plan and Draft EIR from
public agencies, organizations and members of the public during the public comment period. In
accordance with CEQA Guidelines Section 15088, a Final EIR was prepared that responded to
the written comments received, as required by CEQA. The Final EIR document and the Draft
EIR, as amended by the Final EIR, constitute the Final EIR.
C. Record of Proceedings and Custodian of Record
For purposes of CEQA and the findings set forth herein, the record of proceedings for
the City’s findings and determinations consists of the following documents and testimony, at a
minimum:
• The NOP, comments received on the NOP, Notice of Availability, and all other public
notices issued by the City in relation to the Campbell General Plan Update EIR.
• The Campbell General Plan Update Final EIR, including comment letters and technical
materials cited in the document.
• All non-draft and/or non-confidential reports and memoranda prepared by the City of
Campbell and consultants in relation to the EIR.
• Minutes of the discussions regarding the Project and/or Project components at public
hearings held by the City.
• Staff reports associated with Planning Commission and City Council meetings on the
Project.
• Those categories of materials identified in Public Resources Code Section 21167.6.
The City Clerk is the custodian of the administrative record. The documents and materials that
constitute the administrative record are available for review at the City of Campbell Office of
the City Clerk at 70 N 1st St, Campbell, CA 95008
D. Consideration of the Environmental Impact Report
In adopting these Findings, this Council finds that the Final EIR was presented to this
Council, the decision-making body of the lead agency, which reviewed and considered the
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 4 of 27
information in the Final EIR prior to approving the Campbell General Plan. By these findings,
this City Council ratifies, adopts, and incorporates the analysis, explanation, findings, responses
to comments, and conclusions of the Final EIR. The City Council finds that the Final EIR was
completed in compliance with the California Environmental Quality Act. The Final EIR
represents the independent judgment and analysis of the City.
E. Severability
If any term, provision, or portion of these Findings or the application of these Findings
to a particular situation is held by a court to be invalid, void, or unenforceable, the remaining
provisions of these Findings, or their application to other actions related to the Campbell
General Plan, shall continue in full force and effect unless amended or modified by the City.
III. FINDINGS AND RECOMMENDATIONS REGARDING SIGNIFICANT AND UNAVOIDABLE
IMPACTS
A. Air Quality
1. General Plan implementation would expose sensitive receptors to substantial
pollutant concentrations (EIR Impact 3.3-3)
(a) Potential Impact. The potential for the Project to result in the exposure
of sensitive receptors to substantial pollutant concentrations is discussed
at pages 3.3-34 through 3.3-37 of the Draft EIR.
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Effects of Mitigation and Remaining Impacts. As described on
pages 3.3-34 through 3.2-37 of the Draft EIR, the Project includes
numerous policies and programs aimed to limit exposure to TAC
and PM concentrations within the city. These include policies
which help explicitly minimize conflicts between land uses
including promoting the establishment of adequate buffers
between industrial and residential land uses, project
requirements to reduce impacts caused by TAC’s by implementing
best practices recommended by the California Attorney General’s
Office, and restrictions on the use of roadways in close proximity
to sensitive receptors. However, the proposed General Plan would
allow for the development of future projects, the specific
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 5 of 27
characteristics of which cannot be known at this time. Individual
projects could have an impact that could exceed the applicable
TAC thresholds. the General Plan includes policies and actions to
limit impacts including: Policy COS-10.3 that requires
discretionary projects involving sensitive receptors proposed
within 500 feet of State Route 17 or State Route 85 to require an
analysis of mobile source toxic air contaminant health risks and, if
necessary, incorporate appropriate mitigation measures to reduce
health risks to the greatest extent feasible. In addition, General
Plan Action COS-10.f requires development projects to maintain
adequate buffering or other mitigation of all potential air
pollutant sources, including commercial and industrial emissions.
Additionally, future developments would be evaluated through
the CEQA process or BAAQMD permit process.
In the event that future individual projects may result in exposure
to TACs by sensitive receptors, these future projects would be
required to analyze TAC impacts on an individual project level, per
BAAQMD requirements, and in accordance with California Office
of Environmental Health Hazard Assessment (OEHHA) guidance.
However, since the full nature of future project impacts is not
fully known at this time, this is a potentially significant impact and
is considered significant and unavoidable impact of the Project as
individual projects could have an impact that could exceed the
applicable TAC thresholds.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
remaining significant adverse impact of the Project associated
with expose to substantial pollutant concentrations.
B. Greenhouse Gases, Climate Change and Energy
1. Project implementation could generate greenhouse gas emissions that could
have a significant impact on the environment and could conflict with an
applicable plan, policy, or regulation adopted for the purpose of reducing the
emissions of greenhouse gases (EIR Impact 3.7-1)
(a) Potential Impact. The potential for the Project to generate GHG
emissions that could have a significant impact on the environment and/or
conflict with an applicable plan, policy, or regulation is discussed at pages
3.7-22 through 3.7-35 of the Draft EIR.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 6 of 27
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Effects of Mitigation and Remaining Impacts As described on
pages 3.7-22 through 3.7-35 of the Draft EIR, the Project includes
policies and actions that would reduce the severity of this impact
to the extent feasible, including numerous goals, policies and
implementation actions which would further the State’s
fundamental GHG reduction goals and reduce energy usage,
promote renewable and/or alternative energy sources, and
encourage pedestrian/bicycle modes of transportation.
Additionally, through adoption of General Plan Action COS-10.c
the City is required to prepare a Climate Action Plan that
establishes GHG reduction targets that are consistent with
Statewide GHG reduction goals, and includes an implementation
program to achieve the reduction targets. This action also
requires the City to periodically review and update the Plan as
necessary to achieve the GHG reduction targets specified in the
Plan.
However, even with implementation of the goals, policies, and
actions contained in the proposed General Plan, there is no
guarantee that the General Plan alone would be sufficient to limit
GHGs consistent with California’s long-term climate goal of
achieving carbon neutrality by 2045. This would represent a
significant and unavoidable impact of the Project.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
remaining significant adverse impact of the Project associated
with GHG emissions and impacts.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 7 of 27
C. Transportation and Circulation
1. General Plan implementation may conflict with a program, plan, ordinance or
policy addressing the circulation system, including transit, roadway, bicycle and
pedestrian facilities (EIR Impact 3.14-1)
(a) Potential Impact. The potential for the Project to conflict with a
program, plan, policy, or ordinance addressing the circulation system is
discussed at page 3.14-36 through 3.14- 47 of the Draft EIR.
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Effects of Mitigation and Remaining Impacts As described on
page 3.14-36 through 3.13-47 of the Draft EIR, the Project
includes policies and actions that would reduce the severity of this
impact to the extent feasible. The General Plan Update includes
policies and actions that help make the circulation system,
including transit, bicycle, and pedestrian facilities, consistent with
applicable programs, plans, policies, and ordinances and address
the needs of growth accommodated by the proposed General
Plan. The proposed Project includes an updated Housing Element
that was developed primarily in response to the Regional Housing
Needs Allocation, or “RHNA”, allocated to the City of Campbell
(via ABAG) to comply with California State planning law. The
Housing Element portion of the General Plan addresses the City’s
obligations and programs for the provision of its fair share of
housing in California. The proposed Project would guide future
residential growth consistent with Campbell’s RHNA obligations
and would create opportunities to address the jobs/housing
imbalance by providing a range of high-quality housing options
and creating opportunities for affordable housing to be
constructed. However, due to the fact that the General Plan
identifies residential and employment growth in excess of the
projections for Campbell contained in Plan Bay Area 2040, the
proposed Project is in conflict with the projections contained in
the relevant RTP/SCS, thus the impact is considered significant
and unavoidable. The Campbell growth projections contained in
Plan Bay Area 2040 were derived by ABAG from Campbell’s
existing General Plan. Campbell is required to provide for
adequate housing sites to meet its State-issued RHNA numbers,
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 8 of 27
which necessitates that the City update its Land Use Map to
provide for additional housing and growth potential in Campbell.
This update to the Campbell Land Use Map, and the associated
increase in growth potential is what is triggering this significant
and unavoidable impact.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
remaining significant adverse impact of the Project associated
with a conflict with a program, plan, policy, or ordinance
addressing the circulation system, including transit, bicycle, and
pedestrian facilities.
2. General Plan implementation would conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (a) (EIR Impact 3.14-2)
(a) Potential Impact. The potential for the Project to result in VMT impacts
is discussed at pages 3.14-47 through 3.14-56 of the Draft EIR.
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Effects of Mitigation and Remaining Impacts As described on
pages 3.14-47 through 3.14-56 of the Draft EIR, the Project
includes policies and actions that would reduce the severity of this
impact to the extent feasible. The City of Campbell’s proposed
General Plan includes a comprehensive approach to reducing VMT
through the implementation of numerous policies and actions,
and through the establishment of a Land Use Map that prioritizes
higher density development near transit stations. However, in
order to reduce VMT to a less than significant level, the City must
rely on additional assistance from regional and state-level
agencies to affect major changes in driving patterns and behaviors
throughout the greater Bay Area region. The biggest effects of
VMT mitigation actions (and resultant emissions reductions)
derive from statewide or region-wide policies that increase the
cost, or reduce the convenience, of using vehicles. The City of
Campbell cannot effectively or practically implement statewide or
region-wide policies, other than to be supportive of and
complimentary to these efforts in the City’s General Plan, which
the City has done, as described above. There are no additional
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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feasible mitigation strategies available to the City to reduce this
impact to a less than significant level. Therefore, implementation
of the proposed Project would result in a VMT impact that would
be considered significant-and-unavoidable.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
remaining significant adverse impact of the Project associated
with transportation VMT impacts.
D. Cumulative Impacts
1. Cumulative impacts related to greenhouse gases, climate change, and energy
(EIR Impact 4.7)
(a) Potential Impact. The potential for the Project to result in a considerable
contribution to the cumulative impact related to greenhouse gases,
climate change, and energy is discussed at pages 4.0-10 and 4.0-11 of the
Draft EIR.
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Mitigation and Remaining Impacts. As described on pages 4.0-10
and 4.0-11 of the Draft EIR, the Project includes policies and
actions that would reduce the severity of this impact to the extent
feasible. However, even with implementation of adopted policies
and actions, the General Plan has the potential to considerably
contribute to an impact related to greenhouse gases, and climate
change goals. No feasible mitigation is available to fully reduce
the cumulative effect, or to mitigate the contribution to a less-
than-significant level as there is no guarantee that
implementation of the General Plan Update would ensure that
the City of Campbell would be consistent with California’s long-
term climate goal of achieving carbon neutrality by 2045. This
would represent a cumulatively considerable contribution by the
Project to the significant and unavoidable cumulative impact.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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remaining significant adverse impact of the Project associated
with cumulative impacts to greenhouse gases, climate change,
and energy.
2. Cumulative impacts on the transportation network (EIR Impact 4.14)
(a) Potential Impact. The potential for the Project to result in a considerable
contribution to the cumulative impacts on the transportation network is
discussed at pages 4.0-16 and 4.0-17 of the Draft EIR.
(b) Mitigation Measures. Minimized to the greatest extent feasible through
General Plan Policies and Actions. No feasible mitigation is available.
(c) Findings. Based upon the EIR and the entire record before this Council,
this Council finds that:
(1) Mitigation and Remaining Impacts. As described on pages 4.0-16
and 4.0-17 of the Draft EIR, the proposed Project includes an
updated Housing Element that was developed primarily in
response to the Regional Housing Needs Allocation, or “RHNA”,
allocated to the City of Campbell (via ABAG) to comply with
California State planning law. The Housing Element portion of the
General Plan addresses the City’s obligations and programs for
the provision of its fair share of housing in California. The
proposed Project would guide future residential growth
consistent with Campbell’s RHNA obligations and would create
opportunities to address the jobs/housing imbalance by providing
a range of high-quality housing options and creating opportunities
for affordable housing to be constructed. However, due to the
fact that the General Plan projects residential and employment
growth in excess of the projections for Campbell contained in Plan
Bay Area 2040, the proposed Project is in conflict with the
projections contained in the relevant RTP/SCS, thus the impact is
considered significant and unavoidable. The Campbell growth
projections contained in Plan Bay Area 2040 were derived by
ABAG from Campbell’s existing General Plan. Campbell is required
to provide for adequate housing sites to meet its State-issued
RHNA numbers, which necessitates that the City update its Land
Use Map to provide for additional housing and growth potential in
Campbell. The Project includes policies and actions that would
reduce the severity of this impact to the extent feasible. However,
it may not be feasible to mitigate this impact to a less-than-
significant level in all instances as the General Plan would result in
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the increase of household and employment population by more
than what is currently projected by ABAG. This would represent a
cumulatively considerable contribution by the Project to the
significant and unavoidable cumulative impact.
(2) Overriding Considerations. The environmental, economic, social
and other benefits of the Project, as stated more fully in the
Statement of Overriding Considerations in Section VI, override any
remaining significant adverse impact of the Project associated
with cumulative impacts on the transportation network.
IV. FINDINGS AND RECOMMENDATIONS REGARDING THOSE IMPACTS WHICH ARE
LESS THAN SIGNIFICANT, LESS THAN CUMULATIVELY CONSIDERABLE, OR HAVE
NO IMPACT
A. Specific impacts within the following categories of environmental effects were
found to be less than significant as set forth in more detail in the Draft EIR.
1. Aesthetics and Visual Resources: The following specific impacts were
found to be less than significant:
a. Impact 3.1-1: General Plan implementation would not have a
substantial adverse effect on a scenic vista
b. Impact 3.1-2: General Plan implementation would not substantially
damage scenic resources, including, but not limited to, trees, rock
outcroppings, and historic buildings, within a State scenic highway
c. Impact 3.1-3: General Plan implementation would not, in a non-
urbanized area, substantially degrade the existing visual character
or quality of public views of the site and its surroundings, or in an
urbanized area, conflict with applicable zoning and other
regulations governing scenic quality
d. Impact 3.1-4: General Plan implementation could result in the
creation of new sources of nighttime lighting and daytime glare
2. Agricultural and Forest Resources: The following specific impacts were
found to have no impact:
a. Impact 3.2-1: General Plan implementation would result in the
conversion of farmlands, including Prime Farmland and Unique
Farmland, to non-agricultural use
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b. Impact 3.2-2: General Plan implementation would not result in
conflicts with existing zoning for agricultural use, or a Williamson
Act contract
c. Impact 3.2-3: Result in the loss of forest land or conversion of forest
land to non-forest use
d. Impact 3.2-4: General Plan implementation would not involve other
changes in the existing environment which, due to their location or
nature, could result in conversion of Farmland, to non-agricultural
use or conversion of forest land to non-forest use
3. Air Quality: The following specific impacts were found to be less than
significant:
a. Impact 3.3-1: General Plan implementation would not conflict with
or obstruct implementation of the applicable air quality plan
b. Impact 3.3-2: General Plan implementation could result in a
cumulatively considerable net increase of any criteria pollutant for
which the project region is nonattainment under an applicable
federal or state ambient air quality standard
c. Impact 3.3-4: General Plan implementation would not result in
other emissions (such as those leading to odors adversely affecting
a substantial number of people)
4. Biological Resources: The following specific impacts were found to be
less than significant:
a. Impact 3.4-1: General Plan implementation could have a substantial
adverse effect, either directly or through habitat modifications, on
any species identified as a candidate, sensitive, or special status
species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife
Service
b. Impact 3.4-2: General Plan implementation could have a substantial
adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, regulations
or by the California Department of Fish and Wildlife or U.S. Fish and
Wildlife Service
c. Impact 3.4-3: General Plan implementation could have a substantial
adverse effect on state or federally protected wetlands (including,
but not limited to, marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other means
d. Impact 3.4-4: General Plan implementation would not interfere
substantially with the movement of any native resident or
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migratory fish or wildlife species or with established native resident
or migratory wildlife corridors, or impede the use of native wildlife
nursery sites
e. Impact 3.4-5: The General Plan would not conflict with any local
policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance
f. Impact 3.4-6: General Plan implementation would not conflict with
the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or
State habitat conservation plan
5. Cultural Resources: The following specific impacts were found to be less
than significant:
a. Impact 3.5-1: General Plan implementation could cause a
substantial adverse change in the significance of a historical or
archaeological resource pursuant to Section15064.5
b. Impact 3.5-2: Implementation of the General Plan could lead to the
disturbance of any human remains
c. Impact 3.5-3: Cause a substantial adverse change in the significance
of a tribal cultural resource, defined in Public Resources Code
Section 21074, and that is: Listed or eligible for listing in the
California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources Code Section
5020.1(k), or a resource determined by the lead agency
6. Geology, and Soils: The following specific impacts were found to be less
than significant, or to have no impact:
a. Impact 3.6-1: General Plan implementation has the potential to
expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving rupture of a
known earthquake fault, strong seismic ground shaking, seismic-
related ground failure, including liquefaction, or landslides
b. Impact 3.6-2: General Plan implementation has the potential to
result in substantial soil erosion or the loss of topsoil
c. Impact 3.6-3: General Plan implementation has the potential to
result in development located on a geologic unit or soil that is
unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse
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d. Impact 3.6-4: General Plan implementation has the potential to
result in development on expansive soil, as defined in Table 18-1-B
of the Uniform Building Code (1994), creating substantial direct or
indirect risks to life or property
e. Impact 3.6-5: General Plan implementation does not have the
potential to have soils incapable of adequately supporting the use
of septic tanks or alternative waste water disposal systems where
sewers are not available for the disposal of waste water
f. Impact 3.6-6: General Plan implementation has the potential to
directly or indirectly destroy a unique paleontological resource or
site or unique geologic feature
7. Greenhouse Gases Climate Change and Energy: The following specific
impacts were found to be less than significant:
a. Impact 3.7-2: Project implementation has the potential to result in a
significant impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, or conflict with or obstruct a
state or local plan for renewable energy or energy efficiency
8. Hazards and Hazardous Materials: The following specific impacts were
found to be less than significant:
a. Impact 3.8-1: General Plan implementation has the potential to
create a significant hazard to the public or the environment through
the routine transport, use, or disposal of hazardous materials, or
through reasonably foreseeable upset and accident conditions
involving the release of hazardous materials into the environment
b. Impact 3.8-2: General Plan implementation has the potential to
emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within one-quarter mile of an
existing or proposed school
c. Impact 3.8-3: General Plan implementation has the potential to
have projects located on a site which is included on a list of
hazardous materials sites compiled pursuant to Government Code
Section 65962.5
d. Impact 3.8-4: General Plan implementation is not located within an
airport land use plan, two miles of a public airport or public use
airport, and would not result in a safety hazard for people residing
or working in the project area
e. Impact 3.8-5: General Plan implementation has the potential to
impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan
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f. Impact 3.8-6: General Plan implementation has the potential to
expose people or structures to a significant risk of loss, injury or
death involving wildland fires
9. Hydrology and Water Quality: The following specific impacts were found
to be less than significant:
a. Impact 3.9-1: General Plan implementation could violate water
quality standards or waste discharge requirements or otherwise
substantially degrade water quality or obstruct implementation of a
water quality control plan
b. Impact 3.9-2: General Plan implementation could result in the
depletion of groundwater supplies or interfere substantially with
groundwater recharge or conflict with a groundwater management
plan
c. Impact 3.9-3: General Plan implementation could alter the existing
drainage pattern in a manner which would result in substantial
erosion, siltation, flooding, impeded flows, or polluted runoff
d. Impact 3.9-4: General Plan implementation would not release
pollutants due to project inundation by flood hazard, tsunami, or
seiche
10. Land Use Population and Housing: The following specific impacts were
found to be less than significant:
a. Impact 3.10-1: General Plan implementation would not physically
divide an established community
b. Impact 3.10-2: General Plan implementation would not cause a
significant environmental impact due to a conflict with any land use
plan, policy, or regulation adopted for the purpose of avoiding or
mitigating an environmental effect
c. Impact 3.10-3: General Plan implementation would not induce
substantial unplanned population growth in an area, either directly
(for example, by proposing new homes and businesses) or indirectly
(for example, through extension of roads or other infrastructure)
d. Impact 3.10-4: General Plan implementation would not displace
substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere
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11. Mineral Resources: The following specific impacts were found to have
no impact:
a. Impact 3.11-1: General Plan implementation would not result in the
loss of availability of a known mineral resource that would be of
value to the region and the residents of the state
b. Impact 3.11-2: General Plan implementation would not result in the
loss of availability of a locally-important mineral resource recovery
site delineated on a local general plan, specific plan or other land
use plan
12. Noise: The following specific impacts were found to be less than
significant:
a. Impact 3.12-1: General Plan implementation may result in exposure
to significant traffic noise sources
b. Impact 3.12-2: General Plan implementation may result in exposure
to excessive railroad noise sources
c. Impact 3.12-3: Implementation of the General Plan could result in
the generation of excessive stationary noise sources
d. Impact 3.12-4: General Plan implementation may result in an
increase in construction noise sources
e. Impact 3.12-5: General Plan implementation may result in
construction vibration
f. Impact 3.12-6: General Plan implementation may result in exposure
to groundborne vibration
13. Public Services and Recreation: The following specific impacts were
found to be less than significant:
a. Impact 3.13-1: General Plan implementation could result in adverse
physical impacts on the environment associated with the need for
new governmental facilities or the need for new or physically
altered governmental facilities, the construction of which could
cause significant environmental impacts and the provision of public
services
b. Impact 3.13-2: General Plan implementation may result in adverse
physical impacts associated with the deterioration of existing parks
and recreation facilities or the construction of new parks and
recreation facilities
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14. Transpiration and Circulation: The following specific impacts were found
to be less than significant:
a. Impact 3.14-3: General Plan implementation would not
substantially increase hazards due to a geometric design feature or
incompatible use
b. Impact 3.14-4: General Plan implementation would not result in
inadequate emergency access
15. Utilities and Service Systems: The following specific impact was found to
be less than significant:
a. Impact 3.15-1: General Plan implementation would result in
sufficient water supplies available to serve the City and reasonably
foreseeable future development during normal, dry and multiple
dry years
b. Impact 3.15-2: General Plan implementation may require or result
in the construction of new water treatment facilities or expansion
of existing facilities, the construction of which could cause
significant environmental effects
c. Impact 3.15-3: General Plan implementation has the potential to
result in a determination by the wastewater treatment provider
which serves or may serve the Project that it has adequate capacity
to serve the project’s projected demand in addition to the
provider’s existing commitments
d. Impact 3.15-4: General Plan implementation may require or result
in the relocation or construction of new or expanded wastewater
facilities, the construction or relocation of which could cause
significant environmental effects
e. Impact 3.15-5: General Plan implementation may require or result
in the relocation or construction of new or expanded storm water
drainage facilities, the construction or relocation of which could
cause significant environmental effects
f. Impact 3.15-6: General Plan implementation would comply with
federal, state, and local management and reduction statutes and
regulations related to solid waste, and would not generate solid
waste in excess of State or local standards, or in excess of the
capacity of local infrastructure, or otherwise impair the attainment
of solid waste reduction goals
16. Wildfires: The following specific impact was found to have no impact:
a. Impact 3.16-1: General Plan implementation would not have a
significant impact related to wildfire risks associated with lands in or
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near State Responsibility Areas or lands classified as very high fire
hazard severity zones
B. The Project was found to have a less than cumulatively considerable contribution
to specific impacts within the following categories of environmental effects as
set forth in more detail in the Draft EIR.
1. Impact 4.1: Cumulative degradation of the existing visual character of the
region
2. Impact 4.2: Cumulative impact to agricultural lands and resources
3. Impact 4.3: Cumulative impact on the region's air quality
4. Impact 4.4: Cumulative loss of biological resources, including habitats
and special status species
5. Impact 4.5: Cumulative impacts on known and undiscovered cultural
resources
6. Impact 4.6: Cumulative impacts related to geology and soils
7. Impact 4.8: Cumulative impacts related to hazardous materials and
human health risks
8. Impact 4.9: Cumulative impacts related to hydrology and water quality
9. Impact 4.10: Cumulative impacts related to local land use, population,
and housing
10. Impact 4.11: Cumulative impacts related to mineral resources
11. Impact 4.12: Cumulative impacts related to noise
12. Impact 4.13: Cumulative impacts to public services and recreation
13. Impact 4.15: Cumulative impacts related to utilities
14. Impact 4.16: Cumulative impact related to wildfire
15. Impact 4.17: Irreversible and adverse effects
C. The above impacts are less than significant or less than cumulatively considerable
for one of the following reasons:
1. The EIR determined that the impact is less than significant for the Project.
2. The EIR determined that the Project would have a less than cumulatively
considerable contribution to the cumulative impact.
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V. PROJECT ALTERNATIVES
A. Identification of Project Objectives
An EIR is required to identify a “range of potential alternatives to the Project [which]
shall include those that could feasibly accomplish most of the basic purposes of the
Project and could avoid or substantially lessen one of more of the significant effects.”
Chapter 2.0 of the Draft EIR identifies the Project’s goals and objectives. The Project
objectives include:
• Reflect the current goals and vision expressed by city residents,
businesses, decision-makers, and other stakeholders;
• Address issues and concerns identified by city residents, businesses,
decision-makers, and other stakeholders;
• Capitalize on Campbell’s location within the Silicon Valley to provide high
tech jobs that enable Campbell to be a live/work community while
maintaining Campbell’s small town community identity;
• Protect and enhance Campbell community character, and sense of
community;
• Ensure Campbell remains a safe, vibrant, and family-friendly community;
• Proactively plan for and accommodate local and regional growth in a
balanced and sustainable manner, with an emphasis on maintaining
Campbell’s unique character;
• Provide a range of high-quality housing options, including housing
resources and programs that comply with State Planning Law;
• Attract and retain businesses and industries that provide high-quality and
high-paying jobs;
• Continue to maintain and improve multimodal transportation
opportunities;
• Maintain strong fiscal sustainability and continue to provide efficient and
adequate public services;
• Support and enhance Campbell’s small business community to sustain a
vibrant city with a strong downtown core and community identity;
• Emphasize sustainability and environmental stewardship in future
planning decisions
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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• Address new requirements of State law;
• Address emerging transportation, housing, and employment trends;
• Promote alternative transportation and community connectivity; and
• Encourage mixed use corridors that promote vibrant commercial and
residential areas.
B. Alternatives Analysis in EIR
1. Alternative 1: No Project Alternative
The No Project Alternative is discussed on pages 5.0-3 through 5.0-6, and pages 5.0-10
through 5.0-22 of the Draft EIR.
Under Alternative 1, the City would not adopt the General Plan Update. The existing
Campbell General Plan would continue to be implemented and no changes to the
General Plan, including the Land Use Map, Circulation Diagram, goals, policies, or
actions would occur. Subsequent projects, such as amending the Municipal Code
(including the zoning map), would not occur. The Existing General Plan Land Use Map is
shown on DEIR Figure 5.0-1.
Under Alternative 1, the City would continue to implement the existing General Plan
and no changes would be made to address updated General Plan Guidelines, or the
requirements of State law. Since adoption of the existing General Plan, State legislation
has been passed requiring the City to address new safety and circulation requirements
in the General Plan and to further address greenhouse gas emissions. Additionally, the
City currently has an obligation to update and adopt its Housing Element to meet the
latest RHNA requirements, and receive new State certification. The existing General Plan
does not conform to state requirements regarding planning for future housing growth.
Additionally, The General Plan goals, policies, and actions, as well as the Land Use Map,
would not be updated to address the vision and concerns of the City’s residents,
property owners, decision-makers, and other stakeholders that actively participated in
the visioning and goal and policy development process.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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a. Findings: The No Project Alternative is rejected as an alternative because
it would not achieve the Project’s objectives.
b. Explanation: This alternative would not realize the benefits of the
Project and fails to achieve some of the Project objectives. Alternative 1
fails to meet several of the basic Project Objective as no changes would
be made to address updated General Plan Guidelines, or the
requirements of State law. Since adoption of the existing General Plan,
State legislation has been passed requiring the City to address new safety
and circulation requirements in their General Plan, and to further address
greenhouse gas emissions. Additionally, the City currently has an
obligation to update and adopt its Housing Element, and receive new
State certification. The existing General Plan does not conform to state
requirements regarding planning for future housing growth.
2. Alternative 2: Modified Project Alternative
The Modified Project Alternative is discussed on pages 5.0-3 through 5.0-22 of the Draft
EIR.
Under Alternative 2, the City would adopt the updated General Plan policy document,
but would retain the existing land use map. This alternative would result in the same
growth as the existing General Plan Alternative 1, but would implement the updated
goals, policies, and actions found in the General Plan Update. This Alternative would
result in less residential growth than the proposed Project or Alternative 3.
a. Findings: The Modified Project Alternative is rejected as an alternative because
it would not achieve the Project’s objectives.
b. Explanation: This alternative would achieve some of the Project objectives. Like
the Proposed Project, Alternative 2 reflects the current goals and vision
expressed by city residents, businesses, decision-makers, and other
stakeholders; through the updated policy document, and addresses new
requirements of State law, including climate resiliency planning, complete
streets, etc. Alternative 2 meets most Project Objectives. However, without the
updated Land Use Map, Alternative 2 provides less high-quality housing options;
and does not meet the General Plan’s Objectives to provide a range of high-
quality housing options, including housing resources and programs that comply
with State Planning Law. Based on the updated RHNA, the City must plan for at
least 2,977 new housing units between 2023 and 2031. This alternative identifies
a buildout of 1,640 additional units by 2040 and would not provide for the
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amount of housing that has been identified by the RHNA. Thus, Alternative 2 fails
to meet several Project Objectives as it retains the existing Land Use Map and
designations and does not implement the new land uses that are central to
meeting the proposed Project’s Objectives.
3. Alternative 3: Corridor Enhancements Alternative
The Corridor Enhancements (Alternative 3) is discussed on pages 5.0-3 through 5.0-22 of
the Draft EIR.
Alternative 3 is a residential and employment growth-oriented option, which identifies
the Bascom and Hamilton corridors for mixed use development, revitalization, and
appropriate transitions from the more intense urban development densities located
adjacent to Campbell in the City of San Jose. This alternative also promotes and
encourages additional high tech and office uses within the Research and Development
land use designation. This alternative would allow for more residential and employment
growth than the existing General Plan and Alternative 2. DEIR Figure 5.0-2 depicts the
Land Use Map proposed for Alternative 3. This alternative was developed as part of the
City’s review of potential growth strategies and land use changes during development of
the Preferred Land Use Map.
Alternative 3 would allow for more residential and employment growth than the
existing General Plan and Alternative 2, but would result in less residential growth than
the proposed General Plan. Alternative 3 would result in increased housing when
compared to the existing General Plan, but at a lower rate than the proposed Project.
Potential job growth under this alternative would be increased when compared to the
proposed General Plan. This alternative focuses additional mixed-use commercial and
residential development along key city corridors, and near surrounding future
development anticipated in San Jose’s Urban Village Plans. This alternative provided the
most nonresidential square footage and the most jobs when compared to all other
alternatives. This alternative was reviewed and considered by the General Plan Advisory
Committee (GPAC) during development of the General Plan Update. This alternative
was also presented to the community during a series of public workshops conducted
during the General Plan Update process.
DEIR Figure 5.0-2 depicts the Land Use Map proposed for Alternative 3. Alternative 3 is
characterized by the following features. These features are also noted graphically on
Figure 5.0-3:
• Create an extension of Campbell’s Downtown Central Commercial land use designation
along Hamilton and Bascom Avenues to provide enhanced and revitalized shopping,
services, entertainment, and office uses within mixed-use residential areas that are
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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pedestrian oriented. The maximum allowed FAR in these areas would be increased to
1.25, consistent with the City’s Central Commercial Zoning designation. Residential uses
would be allowed on the upper floors of new development, at densities up to 27
dwelling units per gross acre. Implementation of this alternative would necessitate
revisions to the zoning code to establish new zoning districts for these corridors, and/or
the development of one or more Area Plans for the Hamilton and Bascom corridors.
• Provide for additional multi-family housing opportunities that create transitional
residential densities to serve as a buffer between established single-family residential
neighborhoods in Campbell and the recently-adopted San Jose Urban Villages to the
north and east of Campbell, which allow for residential densities that are significantly
higher than the densities allowed within Campbell. This alternative would also provide
for additional housing opportunities within close proximity to existing and future
services and retail uses located along the Bascom and Hamilton corridors.
• Retain the Existing Research and Development (R&D) General Plan Land Use
Designation, and Update the General Plan R&D land use description to reflect the desire
for R&D uses to promote high tech jobs and industries. Create an action item in the
General Plan to establish a new zoning district (research and development) that
promotes high tech uses, or the development of an area plan to guide future
development within areas designated R&D. The maximum allowed FAR in areas
designated R&D would be increased to 1.0 in order to provide additional employment
opportunities.
a. Findings: The Corridor Enhancements Alternative is rejected as an
alternative because it would not achieve the Project’s objectives.
b. Explanation: Alternative 3 would satisfy most Project Objectives as it
would adopt the updated policy document as well as the updated Land
Use Map. This alternative would update the land use map to allow more
mixed use residential areas along key corridors and would allow for more
growth that would be allowed under Alternatives 1 and 2 but
substantially less overall housing development than the proposed
Project. Although Alternative 3 meets most Project Objectives, without
the updated Land Use descriptions and new mixed use and higher density
designations, Alternative 3 provides less high-quality housing options;
and does not meet the General Plan’s Objectives to provide a range of
high-quality housing options, including housing resources and programs
that comply with State Planning Law. As described previously, the City
must plan for at least 2,977 new housing units between 2023 and 2031.
Although this alternative identifies a maximum buildout of 3,268 units by
2040 this alternative would not be anticipated to provide for the amount
of housing that has been identified by ABAG over the next 8 years as
many sites would require substantial re-development of existing parcels
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
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and lot consolidation, and would not be anticipated to provide the type
of development levels over the shorter 8-year Housing Element planning
period. Additionally, without the updated land uses and land use
development standards that allow for higher density ranges the City’s
ability to ensure the RHNA for the extremely low and low income
categories could not be met. Thus, Alternative 3 fails to meet the Project
Objective to meet all housing needs as it does not implement the new
higher density land uses identified during the Land Use and Housing
Element update to ensure regional housing needs are met which is
central to meeting the proposed Project’s Objectives of meeting housing
needs and complying with State law.
CEQA requires that an environmentally superior alternative be identified among the
alternatives that are analyzed in the EIR. If the No Project Alternative is the
environmentally superior alternative, an EIR must also identify an environmentally
superior alternative among the other alternatives (CEQA Guidelines Section
15126.6(e)(2)). The environmentally superior alternative is that alternative with the
least adverse environmental impacts when compared to the proposed Project.
As discussed in Chapter 5.0 of the Draft EIR and summarized in Table 5.0-4 of the Draft
EIR, the proposed Project is the environmentally superior alternative. All of the
alternatives fail to reduce any significant and unavoidable impacts to a less than
significant level. Throughout the preparation of the General Plan Update, the City
Council, Planning Commission, and GPAC all expressed a desire and commitment to
ensuring that the General Plan not only reflect the community’s values and priorities,
but also serve as a self-mitigating document and avoid significant environmental
impacts to the greatest extent feasible. To that end, the proposed General Plan includes
a full range of feasible minimization policies and actions to reduce potential impacts to
the greatest extent possible. The General Plan Update provides for high density mixed-
use areas consistent with transit oriented development principles. It should be noted
that other impacts that were identified as less than significant throughout the Draft EIR
such as noise and aesthetics may be slightly increased when comparing the proposed
Project to alternatives with less overall development potential, however this would not
outweigh the overall benefit of the proposed Project’s Land Use Map and updated
policy guidance’s ability to reduce significant impacts to the greatest extent feasible
when compared to all other alternatives.
Overall, the proposed General Plan is the environmentally superior alternative as it is
the most effective in terms of overall reductions of the most significant impacts
compared to all other alternatives. As such, it is the environmentally superior
alternative.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 25 of 27
VI. STATEMENTS OF OVERRIDING CONSIDERATIONS
Pursuant to CEQA Section 21081(b) and the CEQA Guidelines Section 15093, the City of
Campbell has balanced the benefits of the proposed General Plan against the following
unavoidable adverse impacts associated with the proposed General Plan and has included all
feasible mitigation measures as policies and action items within the General Plan. Campbell has
also examined alternatives to the proposed Project, and has determined that adoption and
implementation of the proposed General Plan is the most desirable, feasible, and appropriate
action. The other alternatives are rejected as infeasible, failed to meet Project objectives, were
not able to reduce any significant impacts to a less than significant levels, or increased the
severity on significant impacts based on consideration of the relevant factors discussed in
Chapter 5.0 of the Draft EIR.
A. Significant Unavoidable Impacts
Based on the information and analysis set forth in the EIR and reiterated in Section III of
these Findings, implementation of the proposed General Plan would result in the following
Project-specific significant impacts related to: air quality, GHG, and transportation and
circulation. These impacts are identified below:
• Impact 3.3-3: General Plan implementation would expose sensitive receptors to
substantial pollutant concentrations (Significant and Unavoidable)
• Impact 3.7-1: Project implementation could generate greenhouse gas emissions that
could have a significant impact on the environment and could conflict with an applicable
plan, policy, or regulation adopted for the purpose of reducing the emissions of
greenhouse gases (Significant and Unavoidable)
• Impact 3.14-1: General Plan implementation may conflict with a program, plan,
ordinance or policy addressing the circulation system, including transit, roadway, bicycle
and pedestrian facilities (Significant and Unavoidable)
• Impact 3.14-2: General Plan implementation would result in a significant VMT impact or
be inconsistent with CEQA Guidelines section 15064.3, subdivision (a) (Significant and
Unavoidable)
• Impact 4.7: Cumulative impacts related to greenhouse gases, climate change, and
energy (Considerable Contribution and Significant and Unavoidable)
• Impact 4.14: Cumulative impacts on the transportation network (Considerable
Contribution and Significant and Unavoidable)
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 26 of 27
B. Benefits of the Proposed General Plan/Overriding Considerations
The City of Campbell has (i) independently reviewed the information in the EIR and the
record of proceedings; (ii) made a reasonable and good faith effort to eliminate or substantially
lessen the impacts resulting from the proposed General Plan to the extent feasible by including
policies and actions in the General Plan that effectively minimize or reduce potential
environmental impacts to the greatest extent feasible; and (iii) balanced the Project’s benefits
against the Project’s significant unavoidable impacts.
Adoption and implementation of the Campbell General Plan would provide the
following economic, social, legal, and other considerable benefits:
1. The General Plan promotes compact and environmentally-sustainable development
through goals and policies that balance the need for adequate infrastructure,
housing, and economic vitality with the need for resource management,
environmental protection, and preservation of quality of life for Campbell residents.
2. The General Plan provides a land use map and policy document that account for
existing development, physical constraints, economic development, and
incompatible uses, and assigns densities and use types accordingly to enhance the
safety, livability, and economic vitality of Campbell.
3. The General Plan improves mobility options through the development of a multi-
modal transportation network that enhances connectivity, supports community
development patterns, promotes public and alternative transportation methods,
and supports the goals of adopted regional transportation plans.
4. The General Plan directs the preservation and environmental stewardship of the
vast array of natural, cultural and historic resources that uniquely define the
character and ecological importance of the City and greater region.
5. The General Plan addresses adverse environmental effects associated with climate
change by facilitating sustainable development, promoting energy efficiency, and
promoting development that reduces greenhouse gas emissions.
6. The General Plan enhances the local economy and provides opportunities for future
jobs and business development growth by promoting increased FARs that support
redevelopment opportunities and uses consistent with market demands, while
promoting community character objectives.
7. The General Plan is the product of a comprehensive public planning effort driven by
members of the public, the General Plan Advisory Committee, the Planning
Commission and the City Council through a series of public meetings, hearings and
workshops that resulted in a thoughtful balance of community, housing, economic,
and environmental interests.
Campbell General Plan Update CEQA Findings of Fact/Statement of Overriding Considerations
Page 27 of 27
VII. CONCLUSION
After balancing the specific economic, legal, social, technological, and other benefits of
the proposed Project, the Council finds that the unavoidable adverse environmental impacts
identified may be considered “acceptable” due to the specific considerations listed above which
outweigh the unavoidable, adverse environmental impacts of the proposed Project.
The Campbell City Council has considered information contained in the EIR prepared for
the proposed General Plan as well as the public testimony and record of proceedings in which
the Project was considered. Recognizing that significant unavoidable air quality, GHG, and
transportation and circulation impacts may result from implementation of the proposed
General Plan, the Council finds that the benefits of the General Plan and overriding
considerations outweigh the adverse effects of the Project. Having included all feasible
mitigation measures as policies and actions in the General Plan, and recognized all unavoidable
significant impacts, the Council hereby finds that each of the separate benefits of the proposed
General Plan, as stated herein, is determined to be unto itself an overriding consideration,
independent of other benefits, that warrants adoption of the proposed General Plan and
outweighs and overrides its unavoidable significant effects, and thereby justifies the adoption
of the proposed General Plan.
Based on the foregoing findings and the information contained in the record, the
Council hereby determines that:
1. All significant effects on the environment due to implementation of the
proposed General Plan have been eliminated or substantially lessened where
feasible;
2. There are no feasible alternatives to the proposed General Plan which would
fully mitigate or substantially lessen the impacts to a less than significant level;
and
3. Any remaining significant effects on the environment found to be unavoidable
are acceptable due to the factors described in the Statement of Overriding
Considerations above.