Herbert Hoover High School Athletic Facilities Upgrades Project Final Environmental Impact Report
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- Gwenda Scott
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1 CEQA Findings of Fact (Public Resources Code CEQA Guidelines 15091) and Statement of Overriding Considerations (CEQA Guidelines 15093) for the Herbert Hoover High School Athletic Facilities Upgrades Project Final Environmental Impact Report SCH Number: prepared for the Facilities Planning and Construction Physical Plant Operations Annex 4860 Ruffner Street San Diego, CA January 2014 prepared by BRG Consulting, Inc. 304 Ivy Street San Diego, CA (619)
2 Table of Contents Table of Contents Chapter Page 1.0 INTRODUCTION Purpose of CEQA Findings; Terminology Purpose and Legal Authorities Environmental Impact Report Description of Proposed Project Project Objectives Environmental Setting Mitigation Monitoring Program Record of Proceedings FINDINGS OF SIGNIFICANT IMPACTS, REQUIRED MITIGATION MEASURES AND SUPPORTING FACTS Project-Level Impacts Determined to be Significant and Unmitigable Project-Level Impacts Determined to be Less Than Significant with Mitigation Cumulative Impacts Determined to be Significant and Unmitigable Cumulative Impacts Determined to be Significant and Mitigable EFFECTS FOUND NOT TO BE SIGNIFICANT FINDINGS REGARDING PROJECT ALTERNATIVES Analysis of Feasible Alternatives STATEMENT OF OVERRIDING CONSIDERATIONS...19 Final EIR i
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4 1.0 INTRODUCTION The Herbert Hoover High School Athletic Facilities Upgrades Project Final Environmental Impact Report (SCH No ) (hereafter Final EIR or FEIR ) has been prepared pursuant to the California Environmental Quality Act (CEQA) to address the potential environmental effects of the Herbert Hoover High School Athletic Facilities Upgrades Project and associated actions (hereafter Proposed Project ) and considered by the district in connection with its public consideration of requested approvals for the Proposed Project. The Final EIR also analyzed the environmental effects of a range of project alternatives as well. The Final EIR and its technical appendices (provided on a CD attached to the back cover of the Final EIR) are incorporated herein by reference as though fully set forth. While the full scope of the Proposed Project and associated approvals are more detailed in Section 1.4, the Proposed Project was developed within the existing Herbert Hoover High School campus. The proposed new school is located within the Kensington-Talmadge Community. 1.1 Purpose of CEQA Findings; Terminology CEQA Findings play an important role in the consideration of projects for which an EIR is prepared. Under Public Resources Code (PRC) and Guidelines below, where a Final EIR identifies one or more significant environmental effects, a project may not be approved until the public agency makes written findings supported by substantial evidence in the administrative record regarding each of the significant effects. In turn, the three possible findings specified in Guidelines are: (a) (1) Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect as identified in the Final EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR. (b) (c) (d) The findings required by subsection (a) shall be supported by substantial evidence in the record. The finding in subdivision (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subdivision (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. When making the findings required in subdivision (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures. Final EIR 1
5 (e) (f) The public agency shall specify the location and custodian of the documents or other materials, which constitute the record of the proceedings upon which its decision is based. A statement made pursuant to Section does not substitute for the findings required by this section. In turn, Guidelines 15092(b) provides that no agency shall approve a project for which an EIR was prepared unless either: (1) The project as approved would not have a significant effect on the environment, or (2) The agency has: (A) Eliminated or substantially lessened all significant effects on the environment where feasible as shown in the findings under Section 15091, and (B) Determined that any remaining significant effects on the environment found to be unavoidable under Section are acceptable due to overriding concerns as described in Section Based on the foregoing, the Guidelines do not provide a bright distinction between the meaning of avoid or substantially lessen. The applicable Guidelines are based on PRC 21081, which uses the phrase mitigate or avoid, and hence it is generally considered that to avoid is to include changes or alterations that result in the significant effect being reduced to below a level of significance. In contrast, the phrase substantially lessen is used to describe changes or alterations that materially reduce the significant effect, but not below a level of significance, thus, while mitigated, the effect remains significant. These Findings would distinguish, for the purposes of clarity, between effects that have been avoided (thereby reduced below a level of significance) and those that have been substantially lessened (and thus remain significant). In combination with the mitigation and monitoring program discussed in Section 1.7, the following Findings and Statement of Overriding Considerations are binding obligations of the project to implement all required mitigation measures. 1.2 Purpose and Legal Authorities The California Environmental Quality Act (hereafter CEQA ) was adopted in 1970 and is codified in California Public Resources Code et.seq. (hereafter PRC ). CEQA is an important environmental law applicable to most public agency decisions to carry out, authorize or approve projects that could have adverse effects on the environment. CEQA does not directly regulate project implementation or approvals through substantive standards or prohibitions, but rather CEQA generally requires only that agencies inform themselves about the potential environmental effects of a Proposed Project, carefully consider all pertinent environmental information effects of a Proposed Project, carefully consider all pertinent environmental information before they act, provide the public an opportunity to review and comment on any environmental issues, and include conditions or other requirements to avoid or reduce potential significant adverse effects of the project or action when feasible. Final EIR 2
6 The San Diego Unified School District (hereinafter referred to as district ) has codified environmental protection procedures implementing CEQA and the state administrative guidelines issued pursuant to CEQA. The district s consideration of Findings of Fact and a Statement of Overriding Considerations are key steps in the process of considering the approval of the Proposed Project while concurrently protecting and enhancing the environment. The applicable standards and scope of the district s responsibilities are detailed in the following excerpts from the State CEQA Guidelines (California Code of Regulations, Title 14, Chapter 3, et. seq.; hereafter Guidelines ). Guidelines Authority Provided by CEQA (a) (b) (c) (d) (e) CEQA is intended to be used in conjunction with discretionary powers granted to public agencies by other laws. CEQA does not grant an agency new powers independent of the powers granted to the agency by other laws. Where another law grants an agency discretionary powers, CEQA supplements those discretionary powers by authorizing the agency to use the discretionary powers to mitigate or avoid significant effects on the environment when it is feasible to do so with respect to projects subject to the powers of the agency. Prior to January 1, 1983, CEQA provided implied authority for an agency to use its discretionary powers to mitigate or avoid significant effects on the environment. Effective January 1, 1983, CEQA provides express authority to do so. The exercise of the discretionary powers may take forms that had not been expected before the enactment of CEQA, but the exercise must be within the scope of the power. The exercise of discretionary powers for environmental protection shall be consistent with express or implied limitations provided by other laws. Guidelines Authority to Mitigate Within the limitations described in Section 15040, (a) (b) (c) A lead agency for a project has authority to require feasible changes in any or all activities involved in the project in order to substantially lessen or avoid significant effects on the environment, consistent with applicable constitutional requirements such as the nexus and rough proportionality standards established by case law (Nollan v. California Coastal Commission (1987) 483 U.S. 825; Dolan v. City of Tigard, (1994) 512 U.S. 374; Ehrlich v. City of Culver City, (1996) 12 Cal. 4 th 854.). When a public agency acts as a responsible agency for a project, the agency shall have more limited authority than a lead agency. The responsible agency may require changes in a project to lessen or avoid only the effects, either direct or indirect, of that part of the project that the agency would be called on to carry out or approve. With respect to a project which includes housing development, a lead or responsible agency shall not reduce the proposed number of housing units as a mitigation measure or alternative to lessen a particular significant effect on the environment if that agency determines that there is another Final EIR 3
7 feasible, specific mitigation measure or alternative that would provide a comparable lessening of the significant effect. Guidelines Authority to Disapprove Projects A public agency may disapprove a project if necessary in order to avoid one or more significant effects on the environment that would occur if the project were approved as proposed. A lead agency has broader authority to disapprove a project than does a responsible agency. A responsible agency may refuse to approve a project in order to avoid direct or indirect environmental effects of that part of the project that the responsible agency would be called on to carry out or approve. For example, an air quality management district acting as a responsible agency would not have authority to disapprove a project for water pollution effects that were unrelated to the air quality aspects of the project regulated by the district. Guidelines Authority to Approve Projects Despite Significant Effects A public agency may approve a project even though the project would cause a significant effect on the environment if the agency makes a fully informed and publicly disclosed decision that: (a) (b) There is no feasible way to lessen or avoid the significant effect (see Section 15091); and Specifically identified expected benefits from the project outweigh the policy of reducing or avoiding significant environmental impacts of the project. (See Section 15093) Guidelines Certification of the Final EIR (a) Prior to approving a project the lead agency shall certify that: (1) The Final EIR has been completed in compliance with CEQA; (2) The Final EIR was presented to the decision-making body of the lead agency and that the decision-making body reviewed and considered the information contained in the Final EIR prior to approving the project; and (3) The Final EIR reflects the lead agency s independent judgment and analysis. (b) When an EIR is certified by a non-elected decision-making body within a local lead agency, that certification may be appealed to the local lead agency s elected decision-making body, if one exists. For example, certification of an EIR for a tentative subdivision map by a city s planning commission may be appealed to the city council. Each local lead agency shall provide for such appeals. Guidelines Findings The purpose of this resolution is to adopt the findings required by this CEQA Guideline section and the underlying California Public Resource Code (a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are: Final EIR 4
8 (1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR. (b) (c) (d) (e) (f) The findings required by subsection (a) shall be supported by substantial evidence in the record. The finding in subsection (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subsection (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. When making the findings required in subsection (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes, which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures. The public agency shall specify the location and custodian of the documents or other materials, which constitute the record of the proceedings upon which its decision is based. A statement made pursuant to Section does not substitute for the findings required by this section. Guidelines Feasible Feasible means capable of being accomplished in a successful manner within a reasonable period of time taking into consideration economic, environmental, legal, social and technological factors. Feasibility must also be considered in the context of alternatives, which obtain most of the basic objectives of the Project, but would avoid and substantially lessen any significant effects of the Project. See Guideline (a). Guidelines Approval (a) (b) After considering the Final EIR and in conjunction with making findings under Section 15091, the lead agency may decide whether or how to approve or carry out the project. A public agency shall not decide to approve or carry out a project for which an EIR was prepared unless either: (1) The project as approved would not have a significant effect on the environment, or (2) The agency has: (A) Eliminated or substantially lessened all significant effects on the environment where feasible as shown in findings under Section 15091, and Final EIR 5
9 (B) Determined that any remaining significant effects on the environment found to be unavoidable under Section are acceptable due to overriding concerns as described in Section (c) With respect to a project, which includes housing development, the public agency shall not reduce the proposed number of housing units as a mitigation measure if it determines that there is another feasible mitigation measure available that would provide a comparable level of mitigation. 1.3 Environmental Impact Report Process Based on preliminary review of the Proposed Project, the district concluded that the Proposed Project could have a significant impact on the environment and that preparation of an environmental impact report was necessary. The district issued its Notice of Preparation ( NOP ) in accordance with CEQA, on April 19, The NOP was mailed to the state clearinghouse, county, city, and state and federal agencies, other public agencies, and various interested private organizations and individuals. A scoping meeting was held on May 8, A copy of the NOP and the written comments received in response to the NOP are included in Appendix A to the Final EIR. After consideration of the scoping meeting comments and other comments in response to the NOP process, the district identified that the Draft EIR should analyze the potential for environmental impacts associated with the following three substantive potential impact areas in the Environmental Analysis section: Aesthetics/Lighting Noise Transportation/Traffic/Parking Additionally, the Draft EIR was directed to include other CEQA substantive sections including Executive Summary, Project Description Location and Environmental Setting, Significant Effects of the Proposed Project, Effects Found Not to Be Significant, Project Alternatives, References, and Preparers Persons and Organizations Contacted. 1.4 Description of Proposed Project The district proposes the Herbert Hoover High School Athletic Facilities Upgrades Project within the Kensington-Talmdage Community of the City of San Diego. As part of the project, several bleachers were refurbished, replaced or added. For the home side stadium bleachers, there was a net loss of 1,394 seats (previous seating of 4,190 seats was reduced to 2,796 seats, including 30 wheelchair spaces). On the visitor stadium side bleachers, there was a net loss of 271 seats (previous seating of 1,445 seats was reduced to 1,174 seats, including 14 wheelchair spaces). The following describes the recent improvements that were completed to upgrade the athletic facility: Stadium Upgrades: Replaced existing home side bleachers; Final EIR 6
10 Replaced existing visitor side bleachers and installed a concrete masonry screen wall at bleachers and ramps; Replaced the existing press box with new press box and elevator for wheelchair access; Constructed a new 3,436 square foot athletic services building with new Breitbard Stadium sign; Installed new lighting for the football field (two 99 foot light standards on south side of football field and two 87 foot light standards on north side of football field). The field lighting is focused and directed at the field area during school events, including sporting events (i.e., football, soccer, track) that occur after dusk. The facility is cleaned and the field lights are extinguished (approximately at 10:00 P.M.); Installed an upgraded public announcement (PA system); Installed a new ornamental steel perimeter fence surrounding the football field; Installed stand-up snack tables; Salvaged and re-installed concrete base and plaque Arnold Margulis Memorial Track ; and, Constructed a concrete masonry wall (268 feet long, 11 feet high, with 12-foot return at each end) on the northern side of visitor bleachers (parallel to Monroe Avenue), which serves to visually screen the bleachers from the surrounding neighborhood. Note: Access to the football field is only available from the internal portion of the school campus through the eastern portion of the football field at the new athletic services building. The only spectator entrance to the campus is located on El Cajon Boulevard. Softball Field Upgrades: Replaced the existing tennis courts with a new softball field; Installed a new softball scoreboard; Constructed new accessible dugouts; Constructed new softball batting cages; and, Installed a new chain link perimeter fence with green windscreen. Baseball Field Upgrades: The existing bleachers (162 seats) were replaced to accommodate 356 seats including four wheelchair spaces; Replaced existing dugouts with new accessible dugouts; Constructed a new 15-foot wall with sign for Ted Williams Field ; Installed serpentine seating wall; Installed a new baseball scoreboard; Constructed a new maintenance equipment storage building; and, Installed a new chain link perimeter fence with green windscreen. Final EIR 7
11 Overall School Campus: Repaired existing city-owned sidewalks that surround the school for ADA compliance; and, Installed new landscaping. Existing and Proposed Parking: The Herbert Hoover High School campus currently has a total of 167 parking spaces. As a result of the Proposed Project, the number of parking spaces on the campus will increase by 56 to 223. Lot A (total spaces 87): o o Existing - 51 spaces Proposed 36 spaces, this lot is proposed as part of the project to be reconfigured to maximize the number of spaces and circulation. Lot B (total spaces 14): o Existing- 14 spaces. No changes proposed. Lot C (total spaces 71): o Existing 71. No changes proposed. Lot D (total spaces 41) o Existing - 31 o Proposed - 10 spaces added to maximize the number of spaces and circulation. Maintenance Storage Building 10 new spaces proposed. Athletic Facilities Operations Events conducted within the athletic stadium that previously were possible only during the daylight hours or with temporary lights would be able to occur in the evening with field lighting. These events include football, boys and girls soccer, and track and field. The District anticipates that approximately 15 evening events would occur with implementation of the proposed project. The District notes that due to routine practices and the potential for unforeseen events, such as playoff games, a few more events may occur. No lights are proposed on the upgraded baseball field; therefore, only daytime baseball or softball games would occur. The school currently has an event plan that includes traffic and crowd control measures (Appendix D3 of this EIR), which is implemented during the evening stadium events, as determined necessary by school officials. The expected highest capacity lighted use of the stadium would be from an evening football game. It is anticipated that of the approximately 15 evening events, six (6) of those events are expected to be home evening football games. Access/Transportation Access to the football field is only available from the internal portion of the school campus through the southeastern portion of the football field at the new athletic services building. The only spectator entrance to the campus is located on El Cajon Boulevard. When temporary parking is opened on the ball field, cars will access the area via the Norwood Street reference, but no pedestrian access will be permitted at this entrance. Final EIR 8
12 1.5 Project Objectives The following objectives describe the underlying purpose of the project and provide a basis of identification of a reasonable range of alternatives evaluated in this EIR: To operate an upgraded athletic facility at Herbert Hoover High School to be equal with other schools in the California Interscholastic Federation (CIF) conference that are able to conduct evening events; To limit the academic time disturbances for students by providing additional evening hours for practice and events; To provide an opportunity for more people (parents and students) to attend the games; To allow Herbert Hoover High School teams to be able to play evening games at their home field rather than using an off-campus facility; To improve school spirit for the student body; and, To construct a safer facility for fans attending the game as well as be Americans with Disabilities Act (ADA) compliant. 1.6 Environmental Setting The site of the athletic facilities upgrades is located on the campus of Herbert Hoover High School at 4474 El Cajon Boulevard in San Diego, California. The school site is approximately 24.6 acres in size and is owned by the district. The site is bounded by Monroe Avenue and residences to the north; 46 th Street, single-family and multi-family residential, and commercial to the east; El Cajon Boulevard to the south; and, Highland Avenue, single-family and multi-family residential to the west. More specifically, the project site is located on the northern and northeastern portions of the Herbert Hoover High School campus, and is currently developed with the recently upgraded athletic facility. The athletic facility area of the school is bounded by classroom buildings to the south and residential units to the north, west, and east. The project site is located in a built-out urban area and is surrounded by residential and commercial uses. The project site is bounded by residences and Monroe Avenue on the north; 46 th Street, single-family and multi-family residential, and commercial to the east; El Cajon Boulevard and commercial to the south; and, Highland Avenue, single-family and multi-family residential to the west. 1.7 Mitigation Monitoring Program Pursuant to PRC , the district has also adopted a detailed mitigation and monitoring program prepared by the EIR consultant under the direction of the district. The program is designed to assure that all mitigation measures as hereafter required are in fact implemented on a timely basis as the Project progresses through its development, construction, and operational phases. Final EIR 9
13 1.8 Record of Proceedings For all purposes of CEQA compliance, including these Findings of Fact and Statement of Overriding Considerations, the administrative record of all district proceedings and decisions regarding the environmental analysis of the Proposed Project shall include but are not limited to the following: The Draft and Final EIR for the Proposed Project, together with all appendices and technical reports referred to therein, whether separately bound or not, or on a CD; All reports, letters, applications, memoranda, maps or other planning and engineering documents prepared by the district, environmental consultant, or others presented to or before the Board of Education as determined by the district; All letters, reports or other documents submitted to the district by members of the public or public agencies in connection with the district s environmental analysis on the Proposed Project; All minutes of any public workshops, meetings or hearings, including the scoping meeting, and any recorded or verbatim transcripts/videotapes thereof; Any letters, reports or other documents or other evidence submitted into the record at any public workshops, meetings or hearings; and, Matters of common general knowledge to the district, which they may consider, including applicable state or local laws, and ordinances and policies. Documents or other materials which constitute the record of proceedings upon which these Findings are made are located at: San Diego Unified School District Facilities Planning and Construction Physical Plant Operations Annex 4860 Ruffner Street San Diego, CA FINDINGS OF SIGNIFICANT IMPACTS, REQUIRED MITIGATION MEASURES AND SUPPORTING FACTS The district, having reviewed and considered the information contained in the EIR, finds pursuant to Public Resources Code 21081(a)(1) and Guidelines 15091(a)(1) that changes or alterations have been required in, or incorporated into, the Project which would mitigate, avoid, or substantially lessen to below a level of significance the following potential significant environmental effects identified in the EIR. Final EIR 10
14 2.1 Project-Level Impacts Determined to be Significant and Unmitigable Noise A. Operational Noise Levels 1. Impact. The Proposed Project s operational noise levels would consist of PA system announcements, band music, and crowd cheering. Noise events at the proposed stadium that would utilize the PA system, have band music, or crowd cheering could reach up to just over 65 dba at the existing residences near the project site. This would exceed the City s noise standards for residential uses of 50 dba from 7:00 AM and 7:00 PM, 45 dba between 7:00 PM and 10:00 PM, and 40 dba after 10 PM. The estimate of 65.4 dba at nearby residences is considered a worst-case scenario, as depicted in the analysis results, the noise levels would range between 50 and 65 dba. Exceedance of the City s standards would occur only periodically as there would be limited number of events at the proposed stadium. Further, noise levels would be intermittent and variable depending on the size of the crowd and number of PA system announcements. As identified in Section 1.3 of the Final EIR, the Proposed Project incorporates a number of design features to minimize the effect of project-generated noise on neighboring properties to the extent feasible. 2. Finding. Specific economic, legal, social, technological, or other considerations make any potential mitigation infeasible. 3. Mitigation Measure. The PA System would be designed to minimize the impact of the stadium noise to the degree feasible, as described as follows with MM N-1: N-1 As part of the design of the PA system proposed to be installed at the athletic field, the district shall ensure that the PA system is either directional in nature (i.e., the ability to direct the majority of its sound away from the property line install a 4-channel amplifier system; or, have the ability to be adjusted to a minimum of db during evening hours to preclude the presence of noise impacts to offsite sensitive receptor areas during these quieter hours. The implementation of Mitigation Measure N-1 in combination with the Proposed Project s sound-reducing design features, will reduce noise levels at nearby sensitive receptors to the degree feasible. Nevertheless, attaining the City s noise standard is likely not feasible for larger events. In order to attain the City s noise standard, the stadium would need to be further away from the existing residents, which is not feasible due to the existing structures surrounding the field. Another optional mitigation measure option is to construct a noise attenuation wall that would be longer than the length of the bleachers. 4. Factual Support and Rationale. The existing installed noise reduction design features of the project, have helped reduce noise levels at nearby sensitive receptors. As part of the operation of the PA system Final EIR 11
15 the District shall implement Mitigation Measure N-1, which ensures that the PA system is either directional in nature (i.e., the ability to direct the majority of the sound away from the property line); install a 4-channel amplifier system; or, have the ability to be adjusted to a minimum of db during evening hours to reduce noise impacts to offsite sensitive receptor areas during these quieter hours. The speakers installed on the stadium light poles have adjustable coverage patterns and have been adjusted to fit the minimal area of coverage to maximize the sound levels for the audience and minimize the bleed over noise into the residential areas. The speakers are directional and have shrouds that channel noise output away from offsite receptors. The visitor seating, closest to the residences, has been constructed with a solid wall on the back of the bleachers to minimize noise. As discussed in the EIR, the recent noise measurements taken were based on the use of the existing PA system that has been installed with these noise reducing design features. In an effort to further reduce the noise impacts, other mitigation measures were considered. A mitigation measure to construct a solid wall that extends from the ground up to a point 6 feet above the top row of the bleachers that extends around the perimeter of the stadium was analyzed. The wall would need to be at least 30-feet tall and the PA speakers located on the light poles, which are currently at a height of 45 feet, would need to be lowered to 25 feet on the light poles. As depicted on Figure 2.1-3, the wall would be constructed along the entire north, east, and west perimeter of the stadium. Figure depicts a visual simulation of the 30-foot wall barrier at the corner of Monroe Avenue and Highland Avenue. The wall would be constructed with the same concrete material as the wall that exists on the site along Monroe Avenue. The primary purpose of the barrier is to preclude residential receptors from a direct line-of-sight to the top of the bleachers and the PA system. The wall barrier would reduce the noise levels from the stadium by approximately 5-10 dba. The wall barrier would not be effective at receptors with views of the bleachers or views of field activity. The noise attenuation provided by the noise barrier behind the bleachers is not sufficient to reduce the noise impact during football games to a less than significant level; football games would continue to substantially increase hourly average noise levels, exceeding the City's noise standards by up to dba Leq as compared to the proposed project which exceeds the City s noise standards by 5-20 dba Leq. Therefore, this method cannot achieve the noise reduction required to meet the hourly average noise threshold and would not substantially reduce the noise impact from football games. Further, based on preliminary cost estimates, the wall barrier would cost approximately $1.5 Million and in order for the District to be able to maintain the existing emergency access gates, solid gates would need to be installed along the wall. Due to the high cost to construct the wall, minimal noise decrease of 5-10 dba, and the inability to reduce the impact to a level less than significant, this mitigation measure has been determined to be infeasible. Another mitigation measure that was considered, which would fully mitigate the noise impacts, would be to enclose the stadium with walls and a roof, similar to a dome. It is anticipated than an enclosed facility of such nature would reduce the noise levels by 20 dba and the events would comply with the City noise standards. However, the cost to construct a dome facility would be several times more expensive than Final EIR 12
16 installing the 30 foot wall. Due to the high cost to construct a dome, this mitigation measure has been determined to be infeasible. As discussed in Section 4.0 below, several alternatives to the project were considered that would reduce the noise impact, one of which is to lower the stadium below grade. As discussed below, this alternative is considered to be infeasible. Therefore, no feasible mitigation measures, except for the existing design features and Mitigation Measure N-1 as described above, are available to mitigate this impact. Therefore, the impact is reduced to the extent feasible, but not mitigated to a level less than significant. As such, a significant and unavoidable noise impact is identified with the implementation of the proposed project. 2.2 Project-Level Impacts Determined to be Less Than Significant with Mitigation Aesthetics/Lighting A. Near-Term Lighting Impacts 1. Impact. As identified in Section of the EIR, implementation of the Proposed Project would result less than significant temporary aesthetics/lighting impacts to nearby sensitive receptors. The Taxpayers for Accountable School Bond Spending submitted an independent lighting study as a comment letter in response to the Draft EIR (dated November 18, 2013 and provided as Comment Letter C in the Final EIR). Within the independent lighting study, a comment was made eluding that the trees planted would not mitigate lighting impacts for several years until the trees reached maturity. The District acknowledges and agrees that trees are an effective mitigation tool for lighting impacts. Furthermore, given that all lighting elements would be extinguished by 10:00 pm, it is highly unlikely that Project lighting elements would result in sleep deprivation-related impacts to a substantial number of people. Although the District finds that impacts to nearby sensitive receptors would be less than significant (as concluded in the EIR), in an effort to be conservative, the District has agreed to provide Mitigation Measure A-1 in order to reduce lighting effects on nearby sensitive receptors during pre-curfew hours. 2. Finding. The landscaping installed by the Project, at maturation, would substantially reduce the amount of ambient lighting levels affecting homes along Highland Avenue and Monroe Avenue. To reduce temporary lighting impacts, which may occur prior to landscape maturation, Mitigation Measure A- 1 shall be implemented in order to lessen such near-term effects. 3. Mitigation Measures. A-1 The District shall make a written offer to provide and install light blocking blinds or shades to nearby homeowners with a direct or indirect line of site from bedroom windows to the football Final EIR 13
17 field and/or associated lighting elements and that are calculated by the LISA to be affected by Project-related lighting levels by more than 0.79 footcandles. Light blocking blinds or shades shall only be required to be offered for bedroom windows. The light blocking shades or blinds shall be certified by the manufacturer as blocking at least 90% of all incoming light. The following homes shall be offered light-blocking shades or blinds for bedroom windows: 4452, 4462, 4466, 4474, 4482, and 4486 Highland Avenue; 4448 and 4490 Monroe Street; and th Street The written offer shall specify a time period in which the homeowner must accept or decline the offer and if no response is received by the District, the District shall assume that the offer has been declined. The District will pay for the cost of installation of the blinds, upon proof that the work has been completed. 4. Factual Support and Rationale. Implementation of the above mitigation measure would lessen potential near-term lighting effects, which may occur at homes along Highland Avenue and Monroe Avenue prior to landscape maturation. In addition, the landscaping installed by the Project, at maturation, would substantially reduce the amount of ambient lighting levels affecting homes along Highland Avenue and Monroe Avenue; therefore, a less than significant aesthetics/lighting impact would result from implementation of the Proposed Project. 2.3 Cumulative Impacts Determined to be Significant and Unmitigable The City of San Diego engineering staff provided information on five cumulative projects in the vicinity of the project, which include Crawford High School Athletic Facilities Upgrades Project, Centerpoint (mixeduse project), YMCA, City Heights Square, and Kensington Terrace (mixed-use project). Any past projects are considered baseline and were included in the analysis under the existing conditions, baseline data. The proposed project would result in a significant and unavoidable noise impact for the operation of the facility during an event that would utilize the PA system, the band, and have crowd cheering, such as a football game. The proposed project would not result in a traffic noise impact. Due to the distance from the project site and the varying use of the cumulative projects, it is not anticipated that the proposed project in conjunction with the cumulative project would result in cumulatively greater noise impact. However, because there is no feasible mitigation to fully mitigate the operational noise impact for the proposed project, the proposed project in conjunction with the cumulative projects identified within the surrounding area would result in a cumulatively significant and unavoidable operational noise impact. Therefore, significant and unmitigable cumulative impacts for the Proposed Project would be the same as the direct impacts for the project (see Section 2.1 above). Final EIR 14
18 2.4 Cumulative Impacts Determined to be Significant and Mitigable The City of San Diego engineering staff provided information on five cumulative projects in the vicinity of the project, which include Crawford High School Athletic Facilities Upgrades Project, Centerpoint (mixeduse project), YMCA, City Heights Square, and Kensington Terrace (mixed-use project). Any past projects are considered baseline and were included in the analysis under the existing conditions, baseline data. As discussed in Section 2.2 above, the Proposed Project would result in a significant and mitigable temporary lighting impact. However, due to the distance from the project site and the varying use of the cumulative projects, it is not anticipated that the proposed project in conjunction with the cumulative project would result in cumulatively greater lighting impact. Therefore, significant and mitigable cumulative impacts for the Proposed Project would be the same as the direct impacts for the project (see Section 2.2 above. 3.0 EFFECTS FOUND NOT TO BE SIGNIFICANT The district finds, based on the substantial evidence appearing in Chapters 3.0 of the EIR that the following impacts would not be significant: aesthetics/lighting, transportation/traffic/parking, agricultural and forest resources, air quality, biological resources, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology/water quality, land use and planning, mineral resources, population and housing, public services, recreation, utilities and service systems. 4.0 FINDINGS REGARDING PROJECT ALTERNATIVES Pursuant to CEQA Guidelines (a), EIRs must describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. The EIR considers a reasonable range of alternatives. The alternatives to the Project are evaluated in Chapter 4.0 of the EIR in terms of their ability to meet the basic objectives of the Project, and eliminate or further reduce its significant environmental effects. Based on these parameters, the following alternatives are considered: (1) No Project/No Evening Football Games Alternative, (2) Alternative 1 Proposed Project with Operational Limitations, and (3) Alternative 2 Proposed Project with Stadium Below Grade. Final EIR 15
19 4.1 Alternatives Considered but Rejected Alternative Site Location This alternative considered the relocation of the Proposed Project. However, due to the built-out condition of the school site and the surrounding neighborhood and the lack of space to accommodate the proposed athletic facilities that would be accessible to students at Herbert Hoover High School, no feasible alternative sites were identified. In addition, the campus is completely developed and it is not feasible to move the stadium further south away from the surrounding residential community. As such, an alternative providing the components of the Proposed Project on an alternative site is rejected No Night Events/No Lighting Alternative The No Night Games/No Lighting Alternative is the same as the Proposed Project, with the exception that there would be no night lighting at the athletic stadium. All of the other athletic upgrades, including the increase in stadium capacity, would occur under this alternative. As a result, future football events could not occur during non-daylight hours and would continue to occur in the afternoon. As discussed in Chapter 1.0 of this EIR, two of the project objectives are to operate an upgraded athletic facility at Herbert Hoover High School to be equal with other schools in the conference that are able to conduct evening events and to provide an opportunity for more people (parents and students) to attend the games. Because this alternative would be in direct conflict with these two objectives, it is considered but rejected. As discussed in Section 2.3 of this EIR, the estimated noise levels generated by the stadium could reach 50.7 to 65.4 dba at the existing residences near the project site, which exceeds the City s noise limits during evening hours. The impact associated with noise exceeding the evening threshold would be avoided under this alternative. However, noise generated from the PA announcer combined with the crowd and band noise would still exceed the daytime thresholds. As a result implementation of this alternative would not avoid the impact associated with noise levels that exceed the daytime standards Limit Use of the Athletic Stadium This alternative would limit the use of the upgraded stadium as proposed under the Proposed Project alternative, but would limit the use of the athletic stadium. Evening stadium events that draw spectators and require operation of the PA would not be permitted. The stadium would only be available for evening operational uses that do not draw spectators nor require the use of a PA system. Similar to the No Night Game/No Lighting Alternative, this alternative would not avoid the impacts associated with noise because a game utilizing the PA system combined with crowd cheering and band use would exceed daytime standards. Furthermore, this alternative would conflict with two of the objectives of the project as identified in Chapter 1.0 of this EIR, including the objectives to operate an upgraded athletic facility at Herbert Hoover High School to be equal with other schools in the conference that are able to conduct evening events and to Final EIR 16
20 provide an opportunity for more people (parents and students) to attend the games. Because this alternative would be in direct conflict with these objectives, it is considered but rejected. 4.2 Analysis of Feasible Alternatives The range of reasonable alternatives considered by the decision makers are: No Project/No Evening Football Games Alternative Alternative 1 Proposed Project with Operational Limitations Alternative 2 Proposed Project with Stadium Below Grade No Project/No Evening Football Games Alternative Description of Alternative: No Project/No Evening Football Game Alternative assumes that the athletic improvements, specifically the PA system would not be used. In addition, this alternative would not allow an evening football game to occur that would draw a crowd to the facility and allow the band to operate during a game. By eliminating the PA system, the crowd, and the band, noise levels generated by these sources would be avoided. Finding: The No Project/No Evening Football Games Alternative is not feasible. It will not meet any of the six project objectives. Factual Support and Rationale: The No Project/No Evening Football Game Alternative would avoid the significant and unavoidable noise impacts associated with the Proposed Project. However, the No Project/ No Evening Football Game Alternative would not meet any of the objectives of the project as identified in Chapter 1.0 of this EIR and is, therefore, not recommended for selection and implementation Alternative 1 Proposed Project with Operational Limitations Description of Alternative: Alternative 1 allows the use of the new lights and PA system, but includes additional operational limitations that may substantially reduce impacts related to noise. Alternative 1 would include the following operational limitations: Limit ticket sales, which would limit the number of people attending the event and ultimately reduce the crowd noise at night, but would not reduce the noise related to the PA system and band, which put the noise above the City s noise threshold; Limit the number of football games at the stadium per year (less than six games per year); and, Eliminate the use of or strictly limit the size of the musical band during a game. Finding: The Alternative 1 Proposed Project with Operational Limitations is not feasible. It does not meet three of the project objectives and would reduce but not fully mitigate the noise impacts. Final EIR 17
21 Factual Support and Rationale: Alternative 1 would result in similar environmental impacts as the proposed project, but the noise impact resulting from evening events may be reduced; however, it is unlikely that the noise could be reduced to below the City s evening noise threshold at most residential units. In addition, Alternative 1 would not meet a significant portion of the project objectives described above. More specifically limiting the ticket sales and the number of football games would not meet the project objectives related to constructing an athletic facility to be equal with other schools in the California Interscholastic Federation (CIF) conference that are able to conduct evening events, because the use of the facility would be limited and the school would not allowed to operate their facility like other school s in the district are able to operate their facilities. In addition, these operational limitations would not meet the objective of the project to provide an opportunity for more people (parents and students) to attend the games, because events would be limited. The operational limitation for the elimination of the band would not meet the project objective to construct an athletic facility to e equal with other schools in the California Interscholastic Federation (CIF) conference that are able to conduct evening events, including with the use of the band. Therefore, Alternative 1 would not allow operational practices equal to other schools in the conference that are able to conduct evening events and would not limit the opportunity for more people (parents and students) to attend the games. For these reasons this alternative is infeasible Alternative 2 Proposed Project with Stadium Below Grade Description of Alternative: Alternative 2 includes reconstructing the stadium below grade to be at a lower elevation than existing, to reduce noise levels. Lowering the elevation of the stadium approximately 25 feet below the current grade would place the top of the visitor bleachers at the existing elevation of the field, and the playing field would be approximately 25 feet lower in a "bowl". The PA system would also need to be lowered to current grade elevations. Calculations were made to determine the noise reduction provided by depressing the field below grade. Because of the proximity of residential receptors, and the height of the average noise source, assumed to be 15 feet above the field and track base elevation, depressing the field 25 feet could break the line-of-sight from the bleachers and reduce noise levels by approximately 5 dba (Ldn Consulting, 2013). The noise levels during a football game would exceed the City's noise standards by up to 15 dba Leq. This method cannot achieve the noise reduction required to meet the hourly average noise threshold and reduce the impact from football games to a less than significant level. Depressing the stadium 25 feet, in combination with the construction of an 8-foot noise barrier around the perimeter of the stadium was also analyzed. The lowering of the stadium and the 8-foot noise barrier should achieve approximately 10 dba of noise reduction (Ldn Consulting, 2013). However, this additional 5 dba of noise reduction would still not reduce football event noise levels to a less than significant level. The Final EIR 18
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