Criterion of Significance for Police and Fire (pages 350 and 352)

The EIR uses the Checklist (Appendix G) as the source for a significance criterion for Police and Fire Services. The standard is far too insensitive for the Proposed Project because it fails to recognize degradation of the environment that could occur as the result of this Project to the services levels throughout the City of Alameda – reductions in public service levels that will cause deterioration of the City’s physical plant and potential damage to private property.

The Catellus project is likely to cause a large reduction in police and fire services for Alameda neighborhoods because the project?s property taxes will not be used to pay for police and fire services that the project will need. This is an unusual condition, even for a project in a redevelopment area where normally only a portion of the property tax is diverted. Since 100% of property taxes assessed on the Project will be considered tax increment, 100% of the taxes will not be available to pay for City services.

Unlike other new development, the Catellus Project will not contribute property tax revenues that can be used to pay for the city services that the development will need. These services typically include Police, Fire, Ambulance, street lighting, libraries, park and landscape maintenance, and street maintenance. None of the property taxes paid by the Catellus Project will be available to meet these needs because The Catellus Project sits in two redevelopment areas, which means that Catellus property taxes will pay redevelopment costs for the next 30 years instead of paying for services.

Nonetheless, the City will clearly have to provide the 215 acres of the Catellus project with services. What happens to service levels in the rest of the City when their property taxes must be stretched to pay for the Catellus Project?. Since Proposition 13 makes it almost impossible to raise taxes to cover the cost of new services, the City will have to spread its existing budget thinner ? that is cut services overall in order to extend services to the Catellus Project. It is not clear whether this will mean that response time for Police, Fire, and Paramedic service calls will be slower, whether street light bulbs will be replaced less often, whether maintenance will be reduced on parks and libraries and roads.

Unfortunately the EIR, which is obligated to analyzed such impacts, dismisses them without examination. The EIR claims that if a new police or fire station is not needed, the problem is not a significant one. However, the EIR acknowledges that the Project will cause a 2% increase in calls for service ? very likely an underestimate. Then the EIR states that the police force will need to be increased by some unspecified number, gives no indication of the cost of adding uniformed personnel, and gives no hint about where the funds to pay the new officers would come from.

Let us suppose the one additional patrol beat will be needed to protect the residents, businesses, visitors to the waterfront promenade, neighborhood parks, etc. That would require about five officers to provide 24-hour coverage. The cost of putting an officer on the street is about $150,000; five will add on the order of $750,000 to the Police budget every year (and go up over time) if new police are hired. It they are not, service will decrease elsewhere.

To cut the budgets of other departments to pay for the new police that will be needed, could result in serious physical deterioration to City facilities, since maintenance is usually the first function to suffer when there is a budget crunch.

The City attempted to devise another plan to cover the cost of services out of the sale proceeds that Catellus will pay for the property. However, the BRAC legislation that provides for a no-cost Economic Development Conveyance of the property from the Navy to the City requires the sale proceeds to be used to pay for infrastructure and marketing.

Additional Analysis Required: Analyze the level of services that the Project will need. Estimate impacts of the City?s budget of providing these services and devise mitigations to prevent deterioration of the City?s physical plant.

Cumulative Public Service Impacts

The impacts of providing the Catellus Project with services even though they are not contributing property taxes will be compounded by redevelopment of Alameda Point, since the same condition will prevail. In the case of Alameda Point, a new first station will be needed.

Additional Analysis Required: Estimate the combined impacts of providing public safety and physical maintenance services to the Catellus Project and to Alameda Point without the availability of property taxes.

Solid Waste and Recycling

The EIR acknowledges (Impact PUB-2, page 365) that disposal of demolition debris will cause the City to be out of compliance with AB939 and Measure D. The EIR concludes that this impact cannot be mitigated; however, no serious mitigations are proposed. The EIR discusses possibilities for deconstruction (page 363) but the mitigations do not even mention, must less require the developer to use such programs.

The mitigations proposed (PUB-2a and b) are vague and carefully worded to avoid causing the developer any expense. (The City of Alameda, the Project sponsor and the demolition subcontractor shall work with organizations able to provide funding and technical assistance for managing and financing the demolition, recycling and reuse project.?) A plan will have to be prepared but it is not required to meet any performance standard.

For materials that are not recyclable, no mitigations to reduce the amount of debris are proposed. Conserving the East Housing stock is an obvious approach to reducing the burden on the landfill.

Additional Mitigation Required: Consider the LOCAL WORK FORCE ALTERNATIVE PROJECT as a mitigation of the solid waste impacts.

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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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