Inadequate criteria of significance (pages 107-8)

The first criterion presented states that a project would have significant land use impacts if it were to alter the type or intensity of land use on a proposed site, causing it to be incompatible with sourrounding land uses or the overall character of the surrounding neighborhoods.? The EIR suggests that the General Plan is source of this standard but no references are provided. The second criterion comes from the CEQA Guidelines Checklist (Appendix G).

Both of these criteria focus on the impacts of the project on adjacent land uses. While it is surely apropriate to include the nearby impacts, there also needs to be a criterion that addresses the citywide impacts of the Project. We would expect criteria concerning the Project's potential to implement General Plan policies. In fact, the Checklist in Appendix G includes a question about conflict with land use plans, policies, and regulations. However, criteria are notably absent from the section on Policy.

Additional Criterion Required: Include item IX b) from the Checklist (Appendix G) among the land use criteria of significance.

The project as described in the EIR is inconsistent with the city's General Plan, and the proposed General Plan amendments do not correct the inconsistencies.

The proposed Project is inconsistent with the General Plan, including the following goals and policies in the City's Housing Element:

"Provide Housing to Meet the City's Needs." (Housing Element, page 2-2) The Project will accomplish virtually the reverse of this goal. It will provide 500 units of housing affordable to above moderate income housing, when Alameda has already exceeded its need for that category. (Housing Element, page 7-10) In view of EBALDC’s proposal to preserve all 590 units as affordable very low, low and moderate income households, choosing the Project alternative is flatly inconsistent with Housing Element policy.

"Promote the conservation and rehabilitation of the City's existing housing stock." (Housing Element, page 2-2) The Project would visit the antithesis of this policy upon 590 units. In view of the proposal and analysis of EBALDC, the attempt to characterize the units as too dilapidated, is unsupported, especially since it is within the City's and Reuse Authority's power to arrest any dilapidation.

"[T]he City is committed to ensuring that for those areas where there will be a substantial change in land use designations, there will be a surplus of possible net housing supply over net housing demand of at least 360 units." (Housing Element, page 12-3) Instead of a surplus, the Project will create deficit of 59 units.

Not only is the Project inconsistent with the General Plan, but the proposed amendments in the EIR will not bring it into consistency. The proposed amendments specify that all of the 300 Coast Guard units built in 1991 will be affordable to very low income households. (B-2) However, the figures in the element for the incomes of the occupants of the housing are Navy income figures. (B-3) There is no support for attributing the units now transferred to the Coast Guard to the very low income category.

Additional Analysis Required: Reanalyze consistency with the Housing Element, and consider mitigating impacts with the LOCAL WORK FORCE ALTERNATIVE PROJECT that is part of these comments.

Inconsistency with General Plan Land Use Designation

The density of the residential units that Catellus proposes to build as part of this project does not appear to match the requirements of the Medium Density Residential designation that will apply to this component of the Project. A comparison of the proposed amendment to the General Plan Land Use (page 143) with the existing map (page 117) shows the City intends to retain the Medium Density Residential designation, except for the 5-acre park area.

Medium Density Residential requires a density ranging between 8.8 and 21.8 units per net acre. (Alameda General Plan, page 11). Catellus intends to put a maximum of 500 units on a section of an 87-acre residential site (comprised of 70 acres of East Housing and 24 acres of FISC property less the 5 acre public park).

This equates to a gross density of 5.7 units per acre. It we use the rule of thumb that 25% of the site will be needed for public space, residential lots will account for 65.3 acres, with a net density of 7.7 units per acre. If Catellus builds fewer than 500 units, the lack of compliance with General Plan standards would be even worse.

Correction Required: Identify the Project?s lack of conformance to General Plan density standards as a potential impact.

Invalid assumption that decreasing intensity of use is always beneficial (page 108)

Discussion of Land Use Impact 1 assumes that reductions in density are necessarily beneficial. This is not a valid assumption because reduced housing density would further reduce the number of housing units, worsening the lack of conformance with the General Plan and exacerbating the loss of housing units. Reducing the number of housing units would also exacerbate the imbalance between the Project?s jobs (4,600) and housing (539 units at most). and increases traffic and air pollution correspondingly. This is an issue because Catellus representatives have suggested to members of the public that they are likely to build fewer than 539 housing units.

Correction Required: Specify the minimum as well as maximum number of housing units and analyze mitigations accordingly.

Potential conflict between USCG Housing and office/R&D area (page 110)

The EIR states that "The R&D buildings proposed nearest to the USCG Housing would be one to two stories surrounded by landscaped parking areas." No analysis is provided in chapter IV-J of the traffic safety, noise or air pollution impacts of locating up to 2,800 parking spaces adjacent to existing residential uses for families with children.

Additional Information Required: Analyze potential conflicts between commercial parking and family housing as adjacent uses.

No analysis of land use impacts of Tinker Avenue extension

The EIR states that Tinker Avenue "would create a boundary" between USCG and East Housing. This "boundary," would divide the Main Street Neighborhood Area contemplated in the Reuse Plan as a continuous, integrated residential area. A 10 foot planting strip would “minimize the impact of traffic noise” on East Housing (page 67), but there would not be a comparable buffer for USCG Housing, an equally sensitive (though less affluent) receptor. The EIR fails to consider the noise impacts on USCG Housing or on the proposed new school of the Tinker extension. The maximum 30-minute allowable daytime noise level for these sensitive receptors is 55 dBA; Tinker Avenue is projected to generate 65.1 dBA, a significant increase over the existing average noise level of 59.9 and median of 51.6

There is a similar lack of analysis of air quality impacts of the Tinker Avenue extension.

Additional Information Required: Analyze land use conflicts of the Tinker extension. Include analysis of noise and air pollution on the Coast Guard Housing and on the proposed school site.

No analysis of land use impacts of Mitchell-Mosley Connection

A 10 foot wide landscaped area is planned to buffer the street from office parking areas, but nothing is apparently planned to buffer the USCG Housing from this new arterial. (page 68) There is no analysis of noise or air pollution impacts.

Additional Information Required: Analyze land use conflicts of the Mitchell-Mosely extension. Include analysis of noise and air pollution on the Coast Guard Housing.

Demolition of East Housing is inconsistent with Housing Policy A-1, that promotes the "conservation and rehabilitation of the City's existing housing stock."

One argument presented in the EIR (page 134) for ignoring this policy is that the units contain lead based paint and asbestos. However, virtually all housing units constructed before 1976 contain lead based paint. Policies in favor of conservation would be meaningless if the presence of lead based paint meant that they should be demolished. There are acceptable techniques for sealing or removing lead based paint.

Similarly the presence of asbestos, especially in non-friable form, does not justify demolition of housing. Asbestos can be sealed so that it does not present a hazard. And seismic retrofitting is a standard component of housing rehabilitation. (See EBALDC comments for greater detail.)

The City's argument that East Housing units have deteriorated from lack of maintenance is particularly unconvincing since that City was in a position to provide the necessary maintenance.

Neighborhood Continuity Page 108, last paragraph:

The EIR states "At the southern boundary, the introduction of new residential uses and an improved streetscape along Atlantic Avenue would create a greater sense of neighborhood continuity." This statement is factually inaccurate. The removal of the 590 units of existing multi-family workforce housing affordable to the low and moderate economic families in the existing neighborhood on the south side of Atlantic Avenue, their replacement with $500,000 single family housing, installation of a 10 foot noise wall to protect those high income families, and provision of a 10-15 foot landscaped area only on the north side of Atlantic Avenue would all serve to divide the existing neighborhood along physical and socio-economic lines. The proposal to relocate Woodstock school from the south side of Atlantic Avenue into the center of the proposed Catellus neighborhood will likely lead to further tension between existing and future residents. There is no factual basis to conclude that the proposed project will increase neighborhood continuity.

Correction Required: Correct erroneous conclusion or provide analysis supporting this point of view.

Local Residents Employed at Project Page 160-161

The EIR states that the Project will generate 4,600 employees, which will create demand for new housing in Alameda. The EIR states on page 161 that the traffic model calculations assume 11% of evening trips are local with 80% of those being home-based work trips, so 9% of the employees will seek housing in Alameda. However, Figure IV.H-3 on page 265 shows that 36% of the PM trips generated by the project site have a destination in Alameda. There appears to be a serious discrepancy between the traffic calculations and the housing calculations. If 36% of the 4600 jobholders seek housing in Alameda, the need for housing would increase by 1600 units, or 5% of the City?s housing stock. This would create strong inflationary pressures of housing costs.

Clarification/Correction Required: Explain the apparent discrepancy in numbers and make corrections as necessary.

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Cover Letter - Project Alternative - Analysis Failures - Deferred Mitigations
Report Organization - Land Use - Population and Housing - Traffic - Air Quality
Public Services - Noise - Drainage and Hydrology - Hazards

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