SD Stadium Reconstruction EIR – Public Comments Date Name NOP RECEIPTS 6/29 Jacob Armstrong 7/02 James Royle SCOPING COMMENTS 7/15-7/18 Dan McLellan 7/16 Jason Riggs 7/18 Debora Greene 7/19 Michael Beck 7/19 Cindy Moore 7/19 Don Wood 7/20 Jesse Arroyo 7/20 Douglas Carstens 7/20 Donna Frye 7/20 Jim Peugh 7/20 Gail Sevens 7/20-7/21 7/21 7/21 7/21 Jose Quinones Jody Ebsen Rob Hutsel Susan Baldwin Title/Agency # Submittals Format – Email, Attachment, Audio Chief Dev’t Review, Caltrans Chairperson Env’l Review Committee, SD County Archaeological Society 1 1 Attachment Attachment Sports writer, SD resident San Diego Stadium Coalition SD resident SD Director, Endangered Habitats League Chair, Serra Mesa Planning Group SD resident SD resident, former Chargers staff Chatten-Brown & Carstens, LLP SD resident 5 1 1 1 1 1 1 1 1 2 1 Email Email Attachment (Word doc) Attachment Email Email Email Attachment Attachment Audio (2 recordings) Attachment 3 1 1 1 Emails Email Email Attachment Env’l Program Manager, South Coast Region – Dept of Fish & Wildlife SD resident SD resident Executive Director, SD River Park Foundation Sr Regional Planner, SANDAG STATE OF TRANSPORTATION AND HOUSING AGENCY EDMUND G. BROWN, Jr.. Governor DEPARTMENT OF TRANSPORTATION DISTRICT 11, DIVISION OF PLANNING 4050 TAYLOR ST, ms. 240 SAN DIEGO, CA 92110 Serious drought. PHONE (619) 688?6960 Help save water! FAX (619) 688?4299 TTY 711 June 29, 2015 PM 6.81 Stadium Reconstruction Ms. Martha Blake City of San Diego 1222 First Avenue, San Diego, CA 92101 Dear Ms. Blake: The California Department of Transportation (Caltrans) has received the Notice of Preparation dated, June 22, 2015, for the Stadium Reconstruction Project located adjacent to the Interstate 15 (I- 15) at Friars Road. Caltrans has the following comments: Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the project referenced above. The mission of Caltrans is to provide a safe, sustainable, integrated and efficient transportation system to enhance California?s economy and livability. The Local Development-Intergovernmental Review (LD-IGR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities of infill, conservation, and efficient development. To ensure a safe, efficient, and reliable transportation system, we encourage early consultation and coordination with local jurisdictions and project proponents on all development projects that utilize the multi-modal transportation network. A traffic impact study (T18) is necessary to determine this proposed project?s near-term and long- term impacts to the State facilities existing and proposed and to propose appropriate mitigation measures. The study should use as a guideline the Caltrans Guide for the Preparation of Traffic Impact Studies. Minimum contents of the traf?c impact study are listed in Appendix of the T18 guide. All State?owned signalized intersections affected by this project should be analyzed using the intersecting lane vehicle (ILV) procedure from the Caltrans Highway Design Manual, Topic 406, page 400?21. The geographic area examined in the traffic study should include as a minimum all regionally significant arterial system segments and intersections, including State highway facilities where the project will add over 100 peak hour trips. State highway facilities that are experiencing noticeable delays should be analyzed in the scope of the traffic study for projects that add 50 to 100 peak hour trips. A focused analysis may be required for project trips assigned to a State highway facility that is experiencing significant delay, such as where traffic queues exceed ramp storage capacities. A focused analysis may also be necessary if there is an increased risk of a potential traffic accident. "Provide a safe. sustainable, integrated and efficieni transportation stolen: to enhance California '3 economy and livability Ms. Martha Blake June 29, 2015 Page 2 All freeway entrance and exit ramps where a proposed project will add a significant number of peak- hour trips that may cause any traffic queues to exceed storage capacities should be analyzed. If ramp metering is to occur, a ramp queue analysis for all nearby Caltrans metered on-ramps is required to identify the delay to motorists using the on-ramps and the storage necessary to accommodate the queuing. The effects of ramp metering should be analyzed in the traffic study. For metered freeway ramps, LOS does not apply. However, ramp meter delays above 15 minutes are considered excesswe. The data used in the TIS should not be more than 2 years old. Caltrans endeavors that any direct and cumulative impacts to the State Highway System be eliminated or reduced to a level of insignificance purSuant to the California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) standards. Mitigation measures to State facilities should be included in TIS. Mitigation identified in the traffic study, subsequent environmental documents, and mitigation monitoring reports, should be coordinated with Caltrans to identify and implement the apprOpriate mitigation. This includes the actual implementation and collection of any ?fair share? monies, as well as the appropriate timing of the mitigation. Mitigation improvements should be compatible with Caltrans concepts. Mitigation measures for proposed intersection modifications are subject to the Caltrans Intersection Control Evaluation (ICE) policy (Traffic Operation Policy Directive 13?02). Alternative intersection design(s) will need to be considered in accordance with the ICE policy; therefore, please refer to the policy for more information and requirements. The lead agency should monitor impacts to insure that roadway segments and intersections remain at an acceptable LOS. Should the LOS reach unacceptable levels, the lead agency should delay the issuance of building permits for any project until the appropriate impact mitigation is implemented. Mitigation conditioned as part of a local agency?s development approval for improvements to State facilities can be implemented either through a Cooperative Agreement between Caltrans and the lead agency, or by the project prOponent entering into an agreement directly with Caltrans for the mitigation. When that occurs, Caltrans will negotiate and execute a Traffic Mitigation Agreement. If you have any questions on the comments Caltrans has provided, please contact Roy Abboud of the Development Review Branch at (619) 688?6968. SinC://6 JACOB . Chief Development Review Branch ?Provide a safe, sustainable. integrated and e?icient transportation system to enhance Caly?ornia '3 economy and livability Environmental Review Committee 2 July 2015 To: Ms. Martha Blake Development Services Department City of San Diego 1222 First Avenue, Mail Station 501 San Diego, California 92101 Subject: Notice of Preparation of a Draft Environmental Impact Report Stadium Reconstruction Project Dear Ms. Blake: Thank you for the Notice of Preparation for the subject project, received by this Society last month. We are pleased to note the inclusion of historical resources in the list of subject areas to be addressed in the DEIR, and look forward to reviewing it during the upcoming public comment period. To that end, please include us in the distribution of the DEIR, and also provide us with a copy of the cultural resources technical report(s). SDCAS appreciates being included in the City's environmental review process for this project. Sincerely, ?mes W. Royle, Jr., ?jiri'ge?on Environmental Review Committee cc: SDCAS President File PO. BOX 81106 San Diego, CA 92138-1106 (858) 538-0935 Le shta Lynette Subject: FW. Stadium Reconstruction Prayert. Contaminated as" uctettanm Sent: Wednesday. Juy1 1 1 To: DSD Blake. Martha: Tomlinson. Tom: Bragado, Nancy Subject: Stadium Reconstruction Project Contaminated Dear San Diego City Officials: 1 recently had a conversation with Troy w. Salazar, the owner of Troy Dirt Paaephp). It was one of seveml conversations I have had with contractors to better understand the obstacles that would face a new stadium in Mission Valley. Mr. Salazar revealed that he had already conducted several core din samples on the site. He said, those samples revealed tens of thousands of cubic yards of contaminated dirt. Valley stadium Mr. Salazar was aware that there had been a clean up effort with regards to the known gas plume. However, he led me to believe that the dirt he had tested had not been cleaned up. He also made me feel that this would be a serious obstacle to construction. I talked with him about the expense of removing the din which I believe he estimated at over $500 per 16 cubic yards. Salazar arrived at this estimate based on the fact that closest location to deposit contaminated dirt is in Arizona. It would take at least 4 hours of driving time per trip, and there would be an additional disposal fee. 1 am requesting that this be fully investigated in the process of completing an EIR on the site. This should include obtaining the records that Troy Dirt has from the samples they took. The completed EIR should include tull disclosure of all contaminated dirt for the entire site which includes over 157 acres. It should also include a realistic estimate of what it will cost to clean up the contamination. and the time fmme tor completion. Thank you tor your hard work on this matter. Sincerely, Dan McLellan Le shin LGefle From: Dan McLelIan -- Sent: Thursday, July 16, m:22 PM To: DSD Blake. Martha; Tomlinson. Tom; aragado. Nancy Subject: Stadium Reconsirucllon Project: Road Infrastructure Improvements Dear San Diego City Officials: I have seven] environmental concerns regarding the EIR for a possible new stadium in Mission Valley. Previously I disclosed concerns aboul the high likelihood of the existence ofcontarninated din on the site. This letter is to inform you of my environmental concerns regarding road improvements. As a sports writer and stadium advocate. the Chargers granted me access to their secure website they setup to help guide CSAG to a successful plan. Through that website I discovered that the team identified 15 road related infrastructure needs for Mission Valley in their first stadium proposal in 2003. None of the known infrastructure needs were identified or specifically funded in the CSAG report. 16 known mad needs: I. Friars Road/SR 153 Interchange Roadway Ramp Improvements including improvements at Friars Road and Frazee Road Intersection 2. Friars Road/Interstate 15 Exchange. Roadway and Ramp Improvements 3. Friars Road/Qualcomm Way, Ramps and Intersection Improvements 4. Texas Street/Camino Del Rio South Intersection Improvements 5. Camino Del Rio South/Interstate 15 North bound improvements 6. Friars Road/Mission Center Road, Ramp and Intersection improvements 7. Rancho San Diego Road/ Ward Road, Intersection Signalization s. Friars Road/Mission Center Drive, Interchange Improvements 9. Interstate 8 Hook Ramps Westbound from Camino Del Rio South to near Interstate 805 lo.Camino Del Rio South to 4 lanes from Fenton Parkway/Mission Center Parkway to Interstate 205 ll.Camino Del Rio North to 4 lanes. from Fenton Parkway/Mission Center Parkway to Interstate 15 12. Mission Center Parkway Bridge over Interstate 3, widen to 4 lanes 13. Bridge over San Diego River at Fenton Parkway 14. South Development Road Connection offsite, west to Fenton Parkway 15. Western Development Road Connection, offsite to Northside Drive 16. Extend Murphy Canyon Road South to development area Several environmental concerns are presented with these known infrastructure needs. The EIR should address all of the following concerns:  How will traffic on a daily basses be impacted during infrastructure improvements?  Will infrastructure construction occur during game days while the stadium is being built? If so, how will that affect getting in and out of the stadium?  Will infrastructure improvements be made during the construction of a new stadium? If so, what impact will that have on the surrounding area?  How will the San Diego River be impacted by the construction of the bridge over it at Fenton Parkway? o This bridge has been planned for several years, but never completed due to environmental concerns. Do those same environmental concerns persist today and would prohibit the construction of this needed infrastructure?  Would construction of so much infrastructure create noise pollution that would disrupt the quality of life for homes and businesses in the community?  Would the construction of the infrastructure damage the air quality in the surrounding area?  Are there any other needed road infrastructure projects? o These 16 needed projects were identified over a decade ago. Since then, there has been a great deal of additional development in the surrounding area. Community leaders have voiced that development did not come with appropriate infrastructure improvements. Has development created other infrastructure needs?  Would the 8 and 15 freeways need to be expanded? o In an increase in population density in Mission Valley may have led to the need to expand the freeways. If expansion is needed, is it even possible based on existing available land?  What would be the total cost of all infrastructure improvements?  How would infrastructure costs be paid for?  What would be time frame for completion of all infrastructure projects?  What would the total environmental impact be for infrastructure improvements in Mission Valley versus the Chargers preferred site in the East Village of Downtown? Thank you again for your time. Sincerely, Dan McLellan 2 Le shin Lynette Subject: FW. Stadium Reconstruction Projett. Fill Dirt From: Dan McLella Sent: Friday. July 17, 2015 2:05 PM To: DSD Blake. Martha: Tomlinson. Tom: Bragado, Nancy Subject: Stadium Reconstruction Project Fill Dirt Dear San Diego City Officials: have seven] environmental concerns regarding the EIR for a possible new stadium in Mission Valley. Previously disclosed concerns about the high likelihood of the existence ofcontaminated dirt on the site and environmental concerns regarding road infrastructure improvements. This letter is to inform you of my environmental concerns regarding the excessive amount of fill dirt needed at the Mission Valley site. it has been widely reported that enough till din would need to be brought into Mission Valley to level the entire 157 acres off at Friars Road. This has been illustrated in not only the artwork the Chargers have provided for possible development but also by the mockrups Councilman Sherman released for his plan for developing Mission Valley that he shared with CSAG. Due to this public information it is not reasonable to complete an EIR on the Mission Valley site that does not include the impact of bringing in such a massive amount of fill dirt. I am not a mathematician but some rough estimates make me believe this could be in the millions of cubic yards of dirt. Fill dirt is delivered in trucks that haul 16 cubic yards at a time. If only one million cubic yards of fill dirt are required, that would mean 62,500 truckloads of dirt would be needed to complete the project. There are unknown variables when it comes to till dirt because the quality of the dirt and where the dirt is being obtained is difficult to predict for such a large project. Water is needed to compact fill dirt for The amount of water needed varies depending on the quality of dirt. California is currently suffering the impacts of one of the worst droughts in our state's history so it is imperative that water is used wisely. Residents and businesses have already been asked to make drastic cutbacks. it does not make sense to engage in a stadium project in Mission Valley that would require so much fill dirt if the Chargers preferred site in East Village of Downtown would demand far less water in the construction process. The following questions must be answered with regards to the use of fill dirt for the stadium project in Mission Valley:  How much fill dirt is needed to raise the entire property of to Friars Road level?  Where will the dirt be obtained?  What will the quality of the dirt be that will be used?  How much water will be needed to compact the soil? o How many truckloads of water is required to disperse the water? o What will be environmental impact of using so many individual truckloads of water? o How much traffic congestion with these water trucks create?  How many truck loads of dirt will be required? o What will be environmental impact of using so many individual truckloads? o How much traffic congestion would the dirt trucks create?  How will bringing in so much dirt affect the air quality for the surrounding area?  Will the numerous truckloads of dirt and water damage any roads due to the heavy nature of the vehicles? o If so, who is responsible for fixing the roads?  Can fill dirt be brought in stages of construction, or does the whole site need to be filled before construction can begin? o If the whole site needs to be filled before construction can begin, how can the Chargers use the existing stadium to play while the new stadium is being built? o If it can be done in stages, how will that impact parking?  What would the environmental impact be of relocating game day parking to an offsite location during construction to accommodate the need for fill dirt?  What would be total cost of the fill dirt and prepping it for construction?  How much fill dirt is needed at the Mission Valley site compared to the Chargers preferred site in the East Village of Downtown? o Would construction at the East Village site be more environmentally friendly because of the demand for significantly less fill dirt? I continue to appreciate your assistance. 2 Smcerely. Dan McLellan Le film: LGetle Subject: rw. Stadium Reconstruction Proyett. Parking Structure From: Dan McLelIan-- Sent: Friday. July 17. 2015 10:42 PM To: DSD alake. Martha; Tomlinson. Torn; aragado. Nancy Subject: Stadium Reconstruction Project Parking Structure Dear San Diego City Officials: This is my fourth letter addressing environmental concerns regarding the Elk for a possible new stadium in Mission Valley. Previously I discussed concerns about the high likelihood of the existence of contaminated din on the site. needed road infrastructure improvements. and environmental concerns with regards to fill dirt. This letter is to inform you of my environmental concerns regarding the 12,000 space parking structure CSAG proposed for the site. While not specifically environmentally related. it is important to start by addressing how underfunded this project was in the CSAG report. CSAG allocated only $144 million for what would be the largest parking structure in North America by 1,000 spaces. Currently the largest parking structure in North America is at the Detroit Airport and can service 11,000 cars at max capacity. Mr. Tomezak was the Assistant Construction Manager for Walker Parking Consultants on the Mickey and Friends gamge at Disneyland. He stated after two years of construction in 2001. the 10,250 space structure came in ahead of time and under budget in the neighborhood of $240 million facilities/). A 1994 Los Angeles Times article. written six years before construction began. established the accuracy of this number by saying the Disneyland garage was projected to cost $223 million (i7ele/news/mnelozss Qarkingrgarage). Keep in mind this article is over two decades old and costs tend to rise overtime. CSAG proposed a 12.000 space parking garage. because they chose Mission Valley for a new stadium over the Chargers preferred site of the East Village in Downtown where several private parking structures already exist. and public transit is more available and readily services a wider geographic area of San Diego. The Chargers and JMI Realty have put forth a multi-purpose venue that would include an expansion of the convention center. That proposal also includes additional parking. By not embracing that project for a new stadium, it means the stadium and convention center would be divided into separate projects. Financially it makes no sense to spend hundreds of millions on a parking garage in Mission Valley for a stadium, and then turn around and spend it again downtown to expand the convention center, when both facilities if built together would share parking. Loading zones, back of the house, and kitchens, are a few other areas where construction cost would not need to be duplicated in a joint use facility. This would add millions more in savings while diminishing a negative impact on the environment. When speaking with experts, I learned that the cost for the proposed garage in Mission Valley would be higher than Mickey and Friends because of poor access to Friars Road and the need for additional exit ramps to accommodate most drivers leaving at the same time. It also doesn’t make sense from an environmental perspective to separate the stadium from the convention center. Two major projects must have a much more significant environmental impact than one. Even if built, the 12,000 space parking garage that would be the largest in North America would still under serve a new stadium when considering Qualcomm currently has over 19,000 spots and is virtually land locked to pedestrian traffic. The trolley only serviced on average 15,202 patrons per Chargers game last season. If more than 7,000 parking spaces were taken away, additional mass transit to service the new stadium would need to be added and would take years to build and would be costly. The EIR for a new stadium in Mission Valley must answer all of the following questions with regards to the proposed parking garage:  How will a 12,000 space parking garage, the largest in North America, change the landscape?  Where would the parking structure be located on the site?  Is there any concerns that the close proximity to the San Diego River could flood the parking structure? o If flooding did occur, what would be the environmental impact of water running back into the river?  How long will it take to build? o The Mickey and Friends garage took over 8 years to plan and construct.  Where will fans park while the parking garage is being built? 2 What would the environmental impact be if a substantial amount of fans had to park offsite? What additional mass transit infrastructure will be provided to accommodate the loss ot' 7.00 parking spaces? 0 When will this additional mass transit be completed? 0 What will the cost be Io adding additional mass transit? How will neariy 12.000 vehicies 1eaving the same parking structure at rougth the same time affect traft'ic patterns? What wouid be the heaith risks to having the engines of neariy 12'000 vehicies running at the same time in a parking structure? How many levels will the parking structure have? How many levels will be below ground and how many will be above ground? 0 It shouid be noted that below ground parking is more expensive to construct. If there is beiow ground parking, what will the environmentai impact caused by below ground construction? What will the tota1 cost of the parking garage be inciuding getting through the entitiement phase and architecture design? What additionai infrastructure wouid be needed to accommodate poor access to Friars Road? What would the environmental benefits be of building the stadium at the Chargers preterred site in the East Vi11age of Downtown where there is more avaiiabie public transit and severai pubiic parking garages aiready exist? Thank you again for your heip. Sincerely, Dan McLellan Le shta LGette Subject: FW. Stadlum Reconstruction Plan Comparan alternatives is needed and benefetial From: Dan Sent: Saturday. July 1 1 i To: DSD Blake. Martha: Tomlinson. Tom: Brzgado, Nancy Subject: Stadium Reconslrucllon Plan: Comparing alternatives is needed and benelecizl Dear San Diego City Officials: My four previous letters addressed environmental concerns regarding the EIR for a possible new stadium in Mission Valley discussed the high likelihood of the existence of contaminated dirt on the site, needed road infrastructure improvements till dirt. and CSAG's proposal for a 12.000 space parking garage. This letter will discuss how important it is for the Elk to show alternatives to the stadium plan in Mission Valley. And how examining alternatives can be highly beneticial with regards to our effon to keep the Chargers. A new stadium at the Mi, 'on Valley site is not the best use of the property. Multiple alternative ideas have been publicly discussed. Community leaders have proposed a large central park. My personal belief is the best use of the land would be an SDSU campus expansion. It's my understanding that currently the political backing at the State level exists to make a campus expansion a reality. 1 fully suppon a new stadium being built that would keep the Chargers in San Diego. and consider myself an activist for that cause. in 2009. I broke the story for SanDiegocom that the Chargers had city officials and the focus for a new stadium had turned to downtown. Since then. I have built a strong relationship with the team and spent three seasons (2010712; as the Chargers beat writer for However, i believe the superior stadium plan is the one that the Chargers and JMI Realty proposed which would include a multieuse stadium and an expansion of the Convention Center in the East Village of Downtown. That plan solves three problems: . It builds a staterofrtheran stadium that would attract numerous other events to San Diego while locking the Chargers into staying in America's Finest City. . It adds roughly 240.000 square feet of elegant convention space that would secure Comichon to San Diego. and in the future invite many other large conventions that would bolster our economy. . It would free up the Mission Valley land for a much needed SDSU expansion. SDSU is currently built to capacity and has nowhere else to expand. A campus expansion would have a huge residual positive cultural and economic impact for San Diego. The CSAG plan. which fell significantly short. only attempted to deal with the stadium issue. It is time that San Diego's leadership think on a bigger scale. A downtown mulliruse stadium and convention center expansion provides the best vision forward for San Diego while also being more environmentally friendly than building two needed facilities separately. An EIR for the proposed stadium in Mission Valley must look at the environmental impact of all visions that have been publicly put forward for the land. I'm among many who are onrrecord stating this quickened EIR is a waste of money because it will not be legally defensible and bring the Chargers back to the negotiating table. There is away to prove myself and other critics wrong. This EIR will not be a waste of money if it determines it is more economical and better for the environment to go with the Chargers preferred location of downtown where two major projects can be combined into one. That conclusion would provide a reason to turn the focus to downtown for a new stadium and would likely buy more time with the NFL. This is because the city can go back to the NFL and say they did there due diligence with an expedited EIR and discovered the Chargers preferred site is in fact more advantageous for environmental and financial reasons. It would then be reasonable to ask for more time to engage the team in their preferred site. If that were to occur, I believe based on my discussions wilh Ihe Ieam Ihal the NFL would be forced to grant San Diego additional lime to resolve this critical issue. Sincerely, Dan McLellan Le shin LGefle From: Jason Riggs-- Sent: Thursday, July 16, 2015 11:25 AM To: Blake, Martha Subject: Public Comments on Scope ot EIR for Chargers Stadium in Mission Valley Martha Blake, Senior Planner City of San Diego Development Services Center 1222 First Avenue, MS 501 San Diego, CA 92101 Ms. Blake. 1 am writing to provide my comments on the scope of the Draft Environmental impact Report for a new football stadium for the Chargers. 1 understand that the proposed project is the reconstruction of the Qualcomm Stadium in Mission Valley. While 1 agree that the Chargers may need a new stadium, 1 believe the EIR must look at alternatives to construction ofa new stadium at the existing Qualcomm site, including construction ofa stadium in the downtown East Village area. Given all the changes to Mission Valley since the stadium was constructed, the current site is just not appropriate for a largerscale, public development like a football stadium. 1 also want to add some additional thoughts as to what should be covered in any EIR for a stadium. First, as 1 noted above the EIR should analyze a wide range of alternatives relating to the site and the stadium. The EIR should analyze establishing a regional park at the Qualcomm site and putting the new stadium in the East Village. In my opinion, creating a new regional park here would be a major benefit to the community and would be a far superior use of the site than constructing a new stadium at the existing site. 1 would like to see a thorough and comprehensive analysis of the East Village alternative. Also the EIR must analyze what happens ifa portion of the property is used for other development. The use of a portion of the property for development has been widely discussed and must be analyzed. It would be an incomplete analysis of the project to ignore what future development will be at the Qualcomm site and the related environmental impacts, given all of the discussion about the future development, including discussion by the Mayor's task force and other City Council members. The community must have a full understanding of the potential environmental impacts of the entire project. it is clearly reasonably foreseeable that a portion of the property will be developed to raise money for the stadium. Second the site is contaminated and construction at the site could pose health risks to nearby residents, and the nearby river habitat as well as attendees. This issue must be thoroughly addressed in the EIR. 1 am aware that there has been extensive remediation at the site and the EIR should disclose the current status of the remediation and the City's position on the remediation. 1 recall that the City has sued Kinder Morgan to get them to clean up the mess they made, and il's still unclear whether the site is safe and what the impacts will be of construction at the site. 1 would like to understand the effecls ofconstruction ofa stadium at a site on the north side of the existing stadium. This is closer to the tank farm and 1 suspect the areas of contamination. 1 I am not an engineer, but common sense dictates that excavating dirt, constructing a new stadium on already contaminated land and demolishing the old stadium would impact these ongoing cleanup activities and could further increase the negative impacts by spreading the contamination further by exposing toxins into the air and water. The impacts of this on the river, the habitat and the community must be studied. A full health risk assessment is needed on this issue. We also need to understand what the effects will be of dewatering associated with any construction. What will happen to existing remediation activities and infrastructure? And it will be important to know the position of other regulatory agencies and Kinder Morgan, and what other approvals are needed. Although not an EIR issue, we need to understand the costs associated with all of this. Third, the Qualcomm site is close to the river and the EIR should disclose risks associated with flooding and liquefaction. I believe the current stadium is within a floodplain zone, which means that it could flood if a large storm comes through. Are the environmental impacts of a flood, including the contaminated water that would flow from the site, going to be analyzed in the environmental report? What happened if there is flooding during construction? What new infrastructure must be built to keep the site safe for flooding? Is new construction permitted in this area by the City’s rules and zoning and the FEMA standards, and would this affect species using the river? Because the current stadium is so close to a river and above a water table, it is in a liquefaction zone, so it will be greatly impacted by an earthquake. What will be the impacts of a stadium holding 70,000 people in a flood or liquefaction event? Fourth, traffic at the existing stadium, surrounding streets and freeways is awful and will only get worse. Not only will construction create a traffic nightmare, but after the stadium is completed, more events will occur, meaning even more traffic. We need a detailed traffic analysis of the construction traffic on our community and the effects of a stadium event occurring during construction, as well as the effect of holding more events at the new stadium. We also need to understand very clearly the construction traffic and related air quality, noise and health risk implications, both to residents living near the stadium as well as along major routes. If the construction is done at the same time of the existing stadium is operational, how will the impacts be handled? Is the environmental report going to analyze the negative impacts of more traffic and air quality in Mission Valley? Since there is only one entrance to the stadium, which is also bordered by the river, there is no way to improve these conditions. Fifth, the notice indicates that parking would be provided on the location of the existing stadium. Will it be structured parking or surface parking? If the current stadium remains operational while construction occurs, how will the Chargers make up for lost parking? What will happen to the land owned by the water department? If the water department land is not used, then how will the parking provided? The EIR should analyze an alternative of structured parking since it is not clear that the water department land will be available. And what will be the increased construction with a large parking structure? And how will it impact traffic flow? What about tailgating? The report must address how parking would be provided onsite if the demolition of Qualcomm is delayed. The report should address where attendees would park during construction of new stadium and demolition of old stadium, both of which will significantly limit available parking on the site. Will this spill into surrounding neighborhoods? The noise and air quality impacts of that should be analyzed. How will reduced on-site parking and increased reliance on off-site parking impact traffic patterns and non-stadium parking needs around the stadium? How will reduced on-site parking impact public transportation use? Also, the EIR should analyze tearing down Qualcomm first then constructing a new stadium within the same footprint. The Chargers could play in some interim location for 2 or 3 years. That should be analyzed and evaluated in the EIR. And one final consideration—cost is a major concern. We understand that the money to fund the City and County’s share of the stadium costs could be $500 million or more. This money is going to come from the City and County’s general fund. What cuts will be made by the City and County of services to the residents to pay for it, and what are the impacts of these cuts? Cuts in police, fire, parks, recreation, health care and other 2 essential services will have very significant environmental impacts. For example, if there are cuts to the parks maintenance budgets, what will be the environmental impacts to parks? If fire department budget is cut, what will be the impact on fire department resources to prevent large fires? This all should be analyzed. We need clarity as to how the City and County are going to spend $500 million or more of general fund revenues and what the impacts will be on the community. I look forward to the EIR including analysis of the issues set forth in this letter. Regards, Jason M. Riggs Chairman, San Diego Stadium Coalition This e-mail and any attachments contain AECOM confidential information that may be proprietary or privileged. If you receive this message in error or are not the intended recipient, you should not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any attachments or copies. 3 July 18, 2015 Debora Greene PO Box 7511 San Diego, CA 92167 City of San Diego Development Services Attn: Martha Blake, Senior Planner 1222 First Ave., MS501 San Diego, CA 92101 RE: Stadium Reconstruction Project in Mission Valley-Comments in response to Notice of Preparation of Draft Environmental Impact Report Dear Ms. Blake: I write to you as a concerned resident and taxpayer of San Diego. I am requesting the Draft Environmental Impact Report (DEIR) include an alternatives analysis for a San Diego River Park. The San Diego River is the southern boundary of this 166 acre site. The effects of redevelopment of this site will impact the San Diego River Park. The alternative analysis will meet the project goals of providing updated recreation facilities to enable San Diego to continue to host recreation events such as family entertainment events, concerts and meeting activities at the San Diego River Park. Thank you for your compliance. Sincerely, Debora Greene Le shin LGefle From: Cind-- Sent: Sunday July 1% 2015 a 23 AM To: DSD EAS Subject: Stadium Reconstruction Project The Serra Mesa Planning Group an 16, 2015 approved a "Mdtion to request to inciude the 52m Mesa Community [exciuding the airdiand area) to the Elk." Since the Stadium site is lacated adjacent td seria Mesa tne draft EIR should include a study otany and impacts to Serra Mesa. Cindy Maura cna'ii, Serra Mesa Planning Gmup inis ermaii and any ailachmenls caniain AECOM caniideniiai iNOYmaliUfl inai may be UV piiyiieged ii ydu receive inis message in mare Vim we intended Yecipiem you snouid noi retain fliswbule disciuse 01 use any at inis inimniaiidn and ydu snouid desnoy ine ermaii and any anachmenls 01 copies Lei htan, nette Sent: Sunday, July 19, 2015 4 00 PM To: oso EAS Subject: Initial scoping comments on proposed Oualcomm stadium replacement project EIR July 19,2015 To: San Diego City planning staff From: Don Wood Subject: Initial scoping comments on proposed Qualcomm stadium replacement project EIR lam a long time Chargers fan and hope that the team decides to stay in San Diego. Therefore is very important that the pending environmental impact report (EIR) the city is embarking on comply with the California Environmental Quality Act (CEQA) in all ways, and is not a factor that might slow down progress going forward. Note that CEQA requires that project EIRs address in detail all the direct and indirect cumulative impacts a clearly defined proposed project might have. What that means that before you can do an EIR on a proposed project, you need a very detailed project description, which covers all actions the city proposes to take to make the project work. It also means that all environmental impacts of all those city actions must be clearly described and all proposed mitigation actions be clearly spelled out. That means that all action the city proposes to take related to the project, including but not limited to the potential sale and development of any city property, including parcels around the existing stadium and the city owned sports arena building, must be clearly described It also means that a clear project budget forthe proposed project must be provided, showing all costs associated with the project itself and all proposed mitigation actions the city proposes to take related to the project. Without those elements, you don't have a project to do an EIR on under state law. Please ensure that these initial scoping comments get posted to the project record and 1 fully addressed in the upcoming EIR. Thank you, Don Wood Tm: armed and any arachmen's can'am AECOM conndenha' mrormahon mm may be or mueged rename we message error mars nm me mended rempxenl ,eu Show" nD' mam mswbule memos: or use any or (ms wrormamn and you Show deem, me ermafl and en, a'lachmen or copes HnstrATSLrncun ENonNGERED LeN o U st Dr or c . q. r r o r o Ec o s v s rrrt P n o re c tl o N A N D S usre.tN .q,sLt July 19,2015 MarthaBlake SeniorPlanner City of SanDiego DevelopmentServicesDepartment IZ?2FtstAvenue, MS 501 SanDego, CA 92101 Re: Notice of Prepantion, Qualcomm Stadium Reconstruction Proje'ct DearMs. Blake, The EndangeredHabitatsLeague(EHL) would like to offer the following cornmentson the subjectproject.For yow reference,EHL is a regionalconservationorganizationfocusedon biodiversityconservationand land use.We havebeenengagedon City of SanDiego land useand MSCPissuessince 1991. For this project NOP we highlight the following topic areasand concefns. l. Process,impact and alternatives an*lysis. It is our opinion that the project must be processedunderan EnvironmentalImpactReport.(The NOP seemsto indicatethat an EIR may not be necessarypendingreview of technicaldocuments.)Among other products,an EIR will providean importantanalysisof alternativesand cumulative impacts,critical for a project of this scopeandlocation.Importantissuessuchas the Mission Valley communitypark deficit and integrationwith the SanDiego River Fark shouldbe analyzed.This issuewasnot identified in the NOP Notice as needing additionalstudy,asit clear{ydoes. 2. Financing and scope.The questionof whethera stadiumis evena viable land useis a matterof public record. Not only havethe Chargerssignaledthat they arenot interested in this location,it seemsclearthat a stadiumproject cannotproceedwithout outside financing. Sinceearly April, at leastsomeCity of SanDiegoelectedofficials haveopined that financing a stadiumreconstructionwould requirepotentiallythousandsof residential and mixed-useunits to be developedon this City ownedsite. It is importantthat the public is awarethat a financing plan for the proposedstadiumproject would include significantimpacts:rcrossthe entiresuiteof CEQA impact issues.Failure to analyzethe (The tenn whole of the project is in violation d CEQA GuidelineSection15378: pvject refen to the wholc of an action that has thepotential,directly or ultimalely,to resuk in a phy$cal ehangeto the environment.This i.nehdasall phasesof a proiect thu are reasonabl!forpseeable,and all rplatedproiecn that are dbecilJ linlcedto the oroiect." We appreciateyour considerationof comments. 7ur tl,L(* f Michael Beck SanDiego Director I PHoNE213.804.2750 8424-A, S,qNreMosrca BLVD.,#592, Los ANcEres,CA,90069-4267 a wwv.EHLEAGUE.oRG FAx323.654.1931 CARSTENS LLP 2200 Paeific Coast Highway, Ste. 31 - Flesimil July 20, 2015 Martha Blake, Senior Planner City of San Diego Developmmt Services Center 1222 First Avenue, MS 501 San Diego, CA 92101 Re: Possible Stadium Reconstruction Project in Mission Valley Dear Ms. Blake, We write to express our concern about, and objections to, the process that appears to be taking shape for hasty approval of a football stadium and associated mixed use development in Mission Valley that would involve demolition of the historic Qualoomm Stadium (fonnaly San Diego Jack Murphy Stadium) The stadium, designed by Gary Allen, is one of the last remaining mid--omun'y multi-purpose stadiums lefi in the United States. Review of its fixture and potential re-use of the site should he informed by a thorough, legally adequate environmental review pursuant to the California Enviromnental Quality Act (CEQA). Our law firm has been involved in efforts to ensure CEQA is properly implemented in projects throughout the state, including in sports stadiums We helped oppose special exemptions for football stadium proposals in the Cities of Industry and Los Angeles (Farmers Field), and continue to be opposed to public agencies providing special treatment or unique processes for sports stadiums. We view the Mission Valley proposal as the latest in this string of poor policy decisions seeking qln'ck approval and avoidance of CEQA rather than proteaion of the virtmment and affected communities to the gates! extent possible and necessary We provide comments on the notice ofprepantion for an impact report for the potmtial project below. Given the extrunely limited infonnation provided in the NOP, we urge the City to reissue the with substantially more information as requested herein. 1. NOTICE OF PREPARATION PROCEDURAL REQUIREMENTS A. NOP Does Not Satisfy CEQA Requirements The failed to identify whether the project or an alternative was on list tablished pursuant to Government Code 65962.5. See Public Resources Code 210926. Pursuant to Section 659625"), the State Water Resources Control Board is directed to compile a list of, among others, the following: all underground storage tanks for which an unauthorized release report is filed pursuant to Section 25295 of the Health and Safay Code; and all cease and desist ordus issued tfier January 1, 1986, pursuant to Section 13301 ofthe Water Code, and all cleanup or abatement ordas issued after January 1, 1986, pursuant in Section 13304 of the Water Code, that concern the discharge of wastes that are hazardous materials. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 2 Here, the Qualcomm site or Kinder Morgan site next door may be on the applicable State Water Board lists. The factors leading to including a site on such lists are present, meaning there is a reasonable likelihood that the site has either been added to the list or the site was inadvertently omitted from the list. The purpose of the list—to notify the public as to the risks of developing projects on these types of contaminated sites—is present in this case and warrants notice in the NOP. B. NOP Does Not Properly Describe the Project The NOP failed to describe the need for voter approval, the use of public bond funding or the reasonably foreseeable adjacent development project, which the Citizens' Stadium Advisory Group (CSAG) report makes clear is an integral part of any funding plan. (See Attached CSAG Report). The NOP failed to identify where the stadium would be relocated on the property, stating only that the current stadium footprint would be rebuilt for parking. Changing the location would move the stadium closer to sensitive receptors located immediately northeast and northwest of the site, and, if moved south, closer to the San Diego River. The NOP fails to describe when the existing stadium will be demolished, stating only that the "Qualcomm stadium structure...would be subject to future demolition and parking would be constructed on the existing stadium site." The NOP fails to clarify how parking would be provided onsite if the demolition of Qualcomm is delayed, or whether the parking would be surface parking or a parking structure. If structured parking is foreseeable, the EIR must examine the construction impacts related to the structured parking. The NOP does not describe whether the Chargers would need to play temporarily in an offsite location while the new stadium is being constructed. The NOP does not describe the City's ongoing litigation involving soil and groundwater contamination from the adjacent Kinder Morgan property, which has contaminated the Qualcomm stadium site. Further, the NOP does not discuss whether relocating the new stadium to a different area of the site may impact ongoing monitoring and remediation activities. C. NOP Does Not Notify All Responsible Agencies The purpose of a NOP is to solicit not just comments from the public, but also guidance from other public agencies on the scope and content of the environmental information to be included in the EIR. Pub. Res. Code § 21080.4(a); 14 Cal. Code Regs. § 15375. The lead agency must send the NOP to all public agencies with authority over the project or resources affected by the project, including each responsible agency, trustee agency, each federal agency involved in funding or approving the project. Pub. Res. Code § 21080.4(a); CEQA Guidelines § 15082(a). There are a number of potentially responsible agencies: County of San Diego (County Bond offering), Regional Water Quality Control Board (401 certification), San Diego Air Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 3 Pollution Control District (air quality permits), San Diego County Regional Airport Authority (consistency determination), U.S. Army Corps of Engineers (404 permit), U.S. Fish and Wildlife Service (take permit) and California Department of Fish and Wildlife (SAA and take permit). It appears that the NOP was not sent to the San Diego County Regional Airport Authority, U.S. Army Corps of Engineers or U.S. Fish and Wildlife Service. II. PROJECT DESCRIPTION A. CEQA Requires EIR to Consider the "Whole of the Action" CEQA requires an analysis of the "whole of an action, which has the potential for physical impact on the environment." CEQA Guidelines, § 15037. The determination of the scope of a project is a question of law. See Communities for a Better Environment v. City of Richmond, 184 Cal. App. 4th 70, 83 (2010) (applying de novo review to question of project scope). In the seminal case of Laurel Heights Improvement Assn. v. Regents of University of California, 47 Cal. 3d 376 (1998), the California Supreme Court set aside an EIR for failing to analyze the impacts of the reasonably foreseeable multiphase project. That case involved a plan by the University of California to move its School of Pharmacy units to a new building, of which only about one-third was initially available. Id. at 393. The EIR acknowledged that the school would eventually occupy the remainder of the building, but the ER only discussed the environmental effects relating to the initial move. Id. at 396. The court concluded that the EIR should have analyzed both phases. Id. at 399. In so holding, the court announced the following test: "[Aln EIR must include an analysis of the environmental effects of future expansion or other action if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effects." Id. at 396. B. Mixed-Use Development of Site Is a Reasonably Foreseeable Consequence of the Stadium Project and Should Be Evaluated by the EIR Multiple reports and proposals closely link the need to include a mixed-use development (e.g., residences, commercial, hotel, etc.) with the new stadium to make it financially feasible for the Chargers without being an economic burden on the community (the "Mixed-Use Development"). A "stadium plus parking" project is substantially different from a "stadium and Mixed-Use Development" project. Even though no formal applications for the Mixed-Use Development have been proposed at this time, the following demonstrates that it is a reasonably foreseeable consequence of the stadium project and has been sufficiently described to allow meaningful analysis in the EIR. 1. Citizens' Stadium Advisory Group (CSAG) Report The Mayor of San Diego commissioned CSAG to study the feasibility of building a new Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 4 stadium in San Diego without taxpayer support. CSAG issued its findings in May 2015, a month before the NOP was issued. The close proximity of timing between the Report being issued and the NOP supports a conclusion that the CSAG Report provides a reasonable representation of the project scope. CSAG advised the City to include, as a key component of the project's fmancing, the $225 million sale of 75 acres of land surrounding the new stadium to a private developer for a mixed-use development. In addition to using the $225 million sale price as roughly 16% of the financing for the stadium development itself, "CSAG recommends [that] the tax revenue from the 75-acre development should pay for community benefits (including parks, additional parking, road and transit upgrades), and to help the City and County recoup its [sic] capital costs." CSAG Site Selection and Financing Plan at p. 2. CSAG estimates that the tax revenue would "conservatively yield $5.5 million annually, resulting in roughly $116 million in net present value." Id. at p. 15. It is unclear how the City would finance any of these aspects of the project without the revenue from the land-sale and mixed-use development. The Mixed-Use Development would include "3,300 housing units, 1 million square feet of commercial space, 175,000 square feet of retail space, and a 500-room hotel." Id. This issue should be fully addressed by the EIR. 2. Councilman Sherman's Proposal San Diego City Councilman Scott Sherman has also announced a development plan in conjunction with a new stadium, calling the mixed-use development a chance to create a new "catalyst for economic development . . . [that can] be an overall economic engine and amenity... in the City of San Diego."' 3. Relocating Stadium To Northeast Corner Of Site Removes a Key Obstacle for the Mixed Use Development Building the new stadium in the northeast or northwest corner of property removes a key obstacle to the future Mixed-Use Development project, meaning the EIR should analyze the reasonably foreseeable consequences. See California Unions for Reliable Energy v. Mojave Desert Air Quality Management District, 178 Cal. App. 4th 1225, 1241, 1242 (2009) (EIR failed to analyze not-yet-planned road paving project because air district's approval "was the first step in a process of obtaining governmental approval for such road paving"). A public agency's decision to authorize an activity that starts in motion a chain of events that will result in foreseeable impacts on the physical environment is treated as approval of a project subject to CEQA. See, e.g., San Lorenzo Valley Community Advocates for Responsible Educ. v. San Lorenzo Valley Unified Sch. Dist., 139 Cal. App. 4th 1356, 1379 (2006) (school consolidation is 1 See City of San Diego, Councilmember Sherman Releases Stadium Options, YOUTUBE (April 2, 2015), https://www.youtube.com/watch?v=P_td8p9vPXU. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 5 project on basis of potential traffic and parking impacts). 4. Mixed-Use Development Would Substantially Impact the Environment According to the CSAG report, the development would include "a low- to mid-rise mixed-use village concept consisting of 3,300 housing units, 1 million square feet of commercial space, 175,000 square feet of retail space, and a 500-room hotel."2 In addition, the CSAG report also contemplates the restoration and enhancement of a 31-acre San Diego River Park on land that is now part of the stadium site, including the addition of walking and bike paths. Even if the Mixed-Use Development ultimately involves a different use configuration than that identified by CSAG, the CSAG report nonetheless provides a reasonably foreseeable framework for analyzing environmental impacts associated with the stadium project. Including the Mixed-Use Development in the EIR would affect a number of resource areas, including, but not limited to: traffic and Transportation (substantially adding to already major congestion and traffic impacts); parking (reducing onsite parking options and increasing parking demand); noise (onsite sensitive receptors impacted by the stadium and freeway traffic, while adding to overall project noise levels); air quality (increasing overall air emissions and locating sensitive receptors onsite); water supply (need to identify water supply for additional residential and commercial demand); health risks (onsite sensitive receptors impacted by the stadium emissions and freeway traffic); hazardous waste (exposing onsite sensitive receptors to ongoing contamination risks); aesthetics; and construction impacts. C. Accurate Description of Construction Equipment and Truck Trips Must Be Provided To Properly Evaluate Demolition and Construction Activities To complete demolition and construction activities within the rapid schedule necessary to meet NFL timelines, construction of the new stadium and demolition of the old stadium would likely need to be done concurrently, or at least with the potential for significant overlap. Unless the City is willing to accept a condition that the construction and demolition cannot overlap, then the EIR must analyze worst case assumptions of concurrent construction/demolition activities. An accurate construction fleet mix and schedule of activities must be provided to allow a detailed evaluation of construction/demolition impacts, including health risks, air quality, traffic, parking and noise impacts. The construction/demolition phase will require numerous offsite truck trips. Given the highly congested traffic environment around the stadium and the limited access routes, a critical environmental concern will be how offsite truck trips will impact the community. As a result, the EIR must accurately describe the expected truck routes, the volumes of trucks and the 2 CSAG Report, p. 15 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 6 frequency of trucking activities to give the public a meaningful opportunity to evaluate project impacts, including related to traffic, noise, air pollution, health risks and environmental justice concerns. D. Temporary Use of Offsite Stadium The Chargers may need to play temporarily in an offsite stadium while the new stadium is being constructed, which must be fully analyzed in the EIR, including traffic, noise, parking and air quality impacts. If a temporary location is not used, how will parking and traffic be impacted if the new stadium is under construction while the Chargers continue to use the existing stadium? E. Changes to the Stadium Location, Frequency of Events, and Nature of Events Are Critical to Understanding Operational Impacts The proposed stadium would not merely replace the existing Qualcomm stadium. The EIR must fully describe and evaluate the operational impacts from these changes, including the following. Location change: According to the NOP, parking would be built on the current stadium site, so the new stadium will be located elsewhere on the property. Based on the CSAG report, the stadium would make room for the Mixed-Use Development. Given the proximity to sensitive receptors on the east and west side of the property (200 feet or less from the property boundary), changing the stadium location will result in important environmental consequences, including changes to localized air quality impacts, health risks, noise and aesthetics, which must be analyzed in the EIR. Frequency of Events: According to the CSAG report, the frequency of events would increase at the new stadium, which would host a year-round source of activities. Increasing the frequency of events would significantly impact the community and environment, even if the impacts from any given event do not change. See Berkeley Keep Jets Over the Bay Commission v. Board of Port Commissioners, 91 Cal. App. 4th 1344 (2001) (EIR failed to analyze how increasing the frequency of night flights would adversely affect residents). The EIR should include the number of events for past representative years and provide a list of the projected number of events for the future. Environmental impacts related to the expected scope of events must be analyzed. Nature of Events: The CSAG report identified a range of events that could be held at the new stadium. Events other than NFL games have the potential to create different impacts, such as increased noise effects, which should be evaluated in the EIR. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 7 III. ENVIRONMENTAL IMPACTS A. Significant Impacts to Qualcomm Stadium and Other Cultural Resources Must be Analyzed and Mitigated. Qualcomm Stadium satisfies the requirements for designation of a historical resource under CEQA. Under Public Resources Code § 21084.1: "For purposes of this section, an historical resource is a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources. Historical resources included in a local register of historical resources, as defined in subdivision (k) of Section 5020.1, or deemed significant pursuant to criteria set forth in subdivision (g) of Section 5024.1, are presumed to be historically or culturally significant for purposes of this section, unless the preponderance of the evidence demonstrates that the resource is not historically or culturally significant." According to CEQA Guidelines § 1504.5: "Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 4852) including the following: (A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or (D) Has yielded, or may be likely to yield, information important in prehistory or history." Qualcomm Stadium (formerly San Diego Jack Murphy Stadium) has been recognized for historic attributes. Its demolition should be evaluated as a potentially significant adverse impact to a major cultural landmark. The Mission Valley Community Plan called the stadium "probably the most distinct landmark in Mission Valley," with an "award-winning design" that has "made it a community landmark." (p. 167.) It has played host to the Super Bowl three times, in 1988, 1998, and 2003, as well as the World Series in 1984 and 1998 and the Major League All-Star Game in 1978 and 1992. It is one of only three stadiums in history to have hosted all three events. The Save Our Heritage Organisation (SOHO) has emphasized the significance of the stadium. Designed by Gary Allen, it is one of the last remaining mid-century multi-purpose stadiums left in the United States. A classic example of the Brutalist architectural school, it Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 8 possesses "innovative design features which include pre-cast concrete, pre-wired light towers, and spiral concrete pedestrian ramps," which led to the stadium's receipt of the American Institute of Architects Honor award in 1969 for outstanding design. This marked the first time in history that a San Diego design firm had received a national honor. 3 Additionally, the project site is in an area of high sensitivity for archaeological resources. For example, the EIR for nearby Quarry Falls notes that "the project site is located in an area of high sensitivity for cultural resources, and earth-moving activities would have the potential to affect unknown resources located within the undisturbed areas of the project site." B. Quantitative Studies Are Needed to Establish "Baseline" Conditions Mere projections of baseline information are insufficient for baseline analysis. Fairview Neighbors v. County of Ventura, (1999) 70 Cal. App. 4th 238; Save Our Peninsula Committee v. Monterey Bd. of Supervisors, (2001) 87 Cal. App. 4th 99 [CEQA "requires that the preparers of the EIR conduct the investigation and obtain documentation to support a determination of preexisting conditions."]). Further, County of Amador v. El Dorado County Water Agency (1999) 76 Cal. App. 4th 931 states that recitation of raw data without explanation of how such levels were derived or maintained "does not provide an adequate description of the existing environment." Citizens for East Shore Parks v. State Lands Commission, (2011) 202 Cal. App. 4th 549 held the proper baseline for analysis of environmental impacts is "what [is] actually happening," not what might happen or should be happening. Traffic: The City is required to conduct traffic studies of existing conditions on game days. The City must present actual data on traffic counts and not mere projections. This is especially important because the NFL is increasingly scheduling games on days other than Sunday, which will impact rush hour traffic. In 2015, the Chargers have two scheduled preseason games at Qualcomm, one on Thursday and one on Saturday. During the regular season, two Monday night games are scheduled to be held at Qualcomm.5 Air Quality/Health Risks/GHG: To evaluate emissions from onsite activities and stadium-related traffic (onsite and offsite) requires the City to have actual game day trip counts to ascertain impacts on air quality, health risks and greenhouse gas emissions. For ambient air quality impacts and health risks from toxic air contaminants, it is important to identify current emissions sources to evaluate impacts with moving the stadium closer to nearby residents. Cultural and Historical Resources: The City must determine whether Qualcomm stadium is an historical resource for purposes of CEQA, as well as the potential to impact underground cultural resources if the site is moved (with related excavation). As such, the City must complete 3 4 5 SOHO has identified the stadium as an important historical resource. See http://www.sohosandiego.org/endangered/me12007/stadium.htmCity of San Diego, Quarry Falls Project Program EIR, July 2008 Update, p. 6. http://espn.go.cominfliteamischedule/ iname/sd/san-diego-chargers. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 9 an historical evaluation of the stadium and study the probability of impact to underground resources based on historical and paleontological activities in the area. Hazardous Wastes: The City must fully evaluate and describe the current status of the monitoring and remediation activities associated with the Kinder Morgan soil and groundwater contamination, including the location of any monitoring or extraction wells that could be impacted by changing the stadium location. In addition, the City must evaluate the current level of contamination on the Qualcomm property and the potential for contamination to worsen as the water table rises (with Kinder Morgan reducing extraction activities) to assess the impact of project-related site changes and excavation. Noise: (lame-day traffic counts in the vicinity of the stadium are also necessary to determine noise impacts to the neighborhoods nearest to the proposed stadium. Both preseason games and three regular season games are night games and have the potential elevate ambient noise in the surrounding neighborhoods during night hours. It is also important to obtain noise readings from the stadium's current location to understand the impact of moving the stadium closer to nearby residents. Without this type of baseline data, the City cannot properly establish the environmental setting and its analysis is not based on substantial evidence. C. Impacts to Sensitive Receptors The proposed project is close to a number of sensitive receptors that will be adversely affected by project construction, demolition and operations. There are multiple residential areas immediately surrounding the site. On the east side, an adjacent residential development is approximately 185 feet from the property line. Similarly, on the west side, residences are located within several hundred feet of the property line or less. The San Diego campus of the University of Redlands is also about half a mile west of the stadium. Additionally, at least two hotels or motels are located proximate to the stadium: Motel 6 (4380 Alvarado Canyon Rd.), and San Diego Marriott Mission Valley (8757 Rio San Diego Dr.). There are at least three daycare centers within approximately half a mile of the stadium complex, including the YMCA Childcare Resource Service, the Children's Home Society, and Gethsemane Christian Preschool. The Office of Environmental Health Hazard Assessment (OEHHA) developed the California Communities Environmental Health Screening Tool: CalEnviroScreen Version 2.0 (CalEnviroScreen 2.0), as a screening methodology to identify California communities that are disproportionately burdened by multiple sources of pollution. Ca1EPA has used the tool to designate California communities as disadvantaged pursuant to Senate Bill 535. 6 A search on 6 See Office of Environmental Health Hazard and Assessment, CalEnviroScreen Version 2.0, http://oehha.ca.goviej/ces2.html. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 10 CalEnviroScreen 2.0 reveals several disproportionately burdened communities near the Project Site, the closest being 1.2 miles away. (See Exhibit A attached hereto.) As shown in Exhibit A, residential communities surround the project and are listed as a having a higher percentage "Pollution Burden." CalEnviroScreen 2.0 identifies communities with higher "Pollution Burdens" based on various characteristics related to local pollution risks, such as ozone levels, particulate matter concentrations, and proximity to hazardous materials. Based on a CalEnviroScreen report for the area surrounding the Qualcomm property, communities to the east, west and south are identified as having a high Pollution Burden (see attached CalEnviroScreen Report For Area Near Qualcomm Site). A number of communities with a high Pollution Burden are also located along possible transportation routes that could be impacted by the project. Accordingly, the EIR should analyze impacts to potential disadvantaged communities that may be impacted by the stadium project. The San Diego River immediately south of the project is important to plants and animals and to recreational users of the river. The San Diego River should be considered a location for recreational users and other sensitive receptors. D. Traffic, Transportation and Parking Overburdened roadways, congested freeways and inadequate transportation infrastructure in the Mission Valley area will be significantly impacted by years of construction/demolition traffic and increased frequency of stadium events. The Mission Valley Community Plan identified major traffic and transportation deficiencies in the Mission Valley area including the following: (1) "Many streets are under-designed and route an excessive number of cars on streets that were never intended for such volumes," and "the transportation system for Mission Valley falls far short of the ideal. "7 (2) The major streets in the area are not built to major street standards at this time and are experiencing congestion, especially during the peak-hour periods. This congestion is both a function of incomplete or undersigned major streets, and the congestion on the freeways during peak hours causing backup onto the surface street system."8 (3) Existing problems would be exacerbated by the stadium project, which is located on Friars Road, the primary arterial through Mission Valley, upon which other traffic flow in the area relies. The Mission Valley Community Plan highlights that when 7 8 Mission Valley Community Plan at p. 71 (emphasis added). Id. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 11 the existing stadium is used, it "overloads Friars Road," "overburden[ing] the surface street system" and plans to increase seating in the stadium and to hold additional events there will "generate even more traffic in the future." The segment of Friars road directly outside the stadium (from Mission Village Drive to Mission Gorge Road) has been identified as a high congestion area.9 A Caltrans report identified "unacceptable" traffic and congestion in Mission Valley. According to the 1-8 Transportation Concept Summary for San Diego County, the 1-8 corridor "currently experiences congestion and operates at unacceptable levels of service during the morning and afternoon peak hours" throughout the Mission Valley area. Caltrans found that "[t]he present transportation system in Mission Valley has inadequate capacity," and that "it will be unable to handle future local circulation and regional transportation needs."1° Caltrans identified a need for "[a] significantly upgraded surface street system in Mission Valley," which "is needed to reduce reliance on 1-8 for travel within Mission Valley. This will require overcoming a problematic "lack of any uniformity" to the street system in Mission Valley, where "[m]any streets are under-designed and transport an excessive number of cars on streets that were never intended for such volumes." There is also "an inordinate amount of out of direction travel."11 Gridlock and congestion are well known problems in Mission Valley. See: http://www.voiceofsandiego.org/growth-housing/mission-valley-keeps-getting-more-roads-andmore-traffic/ ("Any San Diegan knows Mission Valley at rush hour is a gridlocked mess.") These traffic infrastructural impacts must be considered in the context of a region that is rapidly developing and adding further stress to the strained street system. The population of the area around the stadium is expected to more than double from 33,000 to 75,000. 1. Analysis of Impacts to Critical Intersections and Major Arteries The EIR must consider a wide range of different event activities to fully evaluate the impacts of the project, including, but not limited to: Saturday day games, Sunday day games, weekday evening games, weekday evening non-game events, and weekend non-game events. The City of San Diego Environmental Analysis Section has established specific criteria to determine if a traffic impact at an intersection, roadway segment, or freeway is considered significant. Both project specific and cumulative project impacts can be significant impacts. These include: -If any intersection or roadway segment affected by a project would operate at LOS E or 9 10 Id. at p. 72 (emphasis added). Interstate-8 San Diego County Transportation Concept Summary, June 2012, pp. 1-2 (emphasis added). 11 Id. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 12 F under either direct or cumulative conditions and the project exceeds specified increases in delay or intersection capacity utilization or volume-to-capacity ratios; -If a project would add a substantial amount of traffic to a congested freeway segment, interchange, or ramp; -If a project would increase traffic hazards to motor vehicles, bicyclists, or pedestrians due to proposed non-standard design features (e.g., poor sight distance, proposed driveway onto an access-restricted roadway; -If a project would result in a substantial restriction in access to publicly or privately owned land; -If any facility affected by a project would degrade from an acceptable level of service (LOS D or better) to an unacceptable level of service (LOS E or worse). As a result of these criteria, it appears reasonably possible that the stadium project would cause significant traffic impacts. The segment of 1-8 most immediately proximate to the stadium—the segment between 1-805 and 1-15—receives a Level of Service (LOS) rating of F, a failing rating. In fact, every highway segment for at least four miles in either direction of the stadium (encompassing most of the highway's length within the City of San Diego) currently receives a LOS F rating.12 As revealed by the Mission Valley Community Plan and the Quarry Falls EIR, there are a number of heavily impacted intersections in the area of influence that would be adversely affected by the project's construction and operational traffic. Traffic flow analysis will be necessary at key intersections and highway on- and off-ramps (including differentiated analysis of peak morning and afternoon traffic hours), as well as of the anticipated effects of construction and operation of the new facility on those intersections. At a minimum, the following points of traffic concern should be modeled and evaluated in the EIR's transportation analysis (for both construction and operational impacts) under a variety of scenarios (weekend games, weekday games, non-game events such as concerts, etc.): - 1-15 north from Friars Road, south from 1-8, north from 1-805; - 1-805 north and south from 1-8, north from highway 163, south from highway 15, south from highway 94; - 1-8 east and west from 1-15, east and west from 1-8, west from highway 163, west from 1-5, east from College Avenue, east from highway 125; - 1-5 north and south from 1-8, south from highway 163, south from highway 94; 12 Id. at p. 4. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 13 - Friars Road from Mission Gorge Road to Ulric Street; -Mission Village Drive from Friars Road to Gramercy Drive; - Camino Del Rio N and Camino Del Rio S from Fairmount Avenue to Qualcomm Way; - San Diego Mission Road from Friars Road to Twain Road; - Fenton Parkway (and Fenton Marketplace); Northside Drive; - Mission Gorge Road from Fairmount Avenue to Princess View Drive; - Fairmount Avenue from Mission Gorge Road to Aldine Drive; - I-15 exits 7, 7A, 7B, and 6B; - 1-805 exits 17 and 17B; - 1-8 exits 6A, 6B, 7, 7A, 7B, and 8; - Friars Road intersections with Mission Gorge Road, San Diego Mission Road, Mission Village Drive, Northside Drive, Fenton Parkway, Qualcomm Way, and Mission Center Road; - San Diego Mission Road with Mission Gorge Road; - Camino Del Rio N and Camino Del Rio S with Fairmount Avenue; -Impacts to ingress to and egress from major nearby residences and public and private facilities, including nearby residential communities, Fenton Marketplace, and Kaiser Foundation Hospital. 2. Farmers Field EIR Identified Numerous Transportation Impacts The Farmers Field EIR provides an example of the type of traffic impacts that may be associated with the stadium project. The Farmers Field EIR identified numerous significant traffic impacts (see attached table). Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 14 3. Analysis of Impacts to Mass Transit, Bikeways, and Pedestrians The City's light rail Green Line passes by and stops at the stadium. Mass transit analysis of the impacts of construction and operation of the facility on the intensity of use of the Green Line and other interconnected transit lines must he conducted, The City's bus lines numbered 18, 235, 60, 13, and 14 all pass within a short distance of the stadium. Mass transit analysis of the impacts of construction and operation of the facility on the intensity of use of these bus lines and other interconnected transit lines must be conducted. The City has three classifications for bikeways: Class I (Bike Path or Trail), Class II (Bike Lane), and Class III (Bike Route). Analysis must consider the impacts of construction and operation of the facility on all three classes of bikeways in the area. The impacts of construction and operation of the facility on pedestrian traffic must also be considered, including pedestrian access from various bus stops for the lines discussed above. 4. Parking The NOP indicates that parking would be provided on the location of the existing stadium. Will this be surface parking or a parking structure? The EIR must address how parking would be provided onsite if the demolition of Qualcomm is delayed. The EIR should address where attendees would park during construction of a new stadium and demolition of the old stadium, both of which will significantly limit available parking on the site. How will reduced on-site parking and increased reliance on off-site parking impact traffic patterns and non-stadium parking needs around the stadium? How will reduced on-site parking impact public transportation use? How will sufficient capacity be ensured? Given that the southern portion of the property may be used for a Mixed Use Development, that would mean there is not sufficient land for surface parking on site. That would require either a parking structure or off-site parking, both of which options should be fully analyzed in the EIR. Also, given that the southerly portion is owned by the water department, the EIR should analyze what the possible environmental effects will be if the water department property is not available for stadium uses. Given that the water department is required to receive market value for the use of its property, the EIR must analyze the entirely possible circumstance that this portion of the property cannot be used for stadium uses (either a stadium or parking). E. Air Quality 1. Scope of Analysis Air Quality impacts should be analyzed under a variety of scenarios, including: Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 15 construction of new stadium; demolition of existing stadium; concurrent construction and demolition; concurrent construction/demolition and operations (if applicable); Mixed-Use Development (overlapping with construction/demolition, if applicable). Air quality impact analysis of operations should include both operational emissions on a daily basis and also on an annual basis, as identified by the City of San Diego significance thresholds. The annual analysis will account for increased frequency of events and resultant emissions. The increased frequency of events can cause a significant noise impact even if any particular single event does not change. 2. Regional Emissions The stadium project has the potential to emit significant air emissions that exceed applicable thresholds. These emissions could be individually and cumulatively considerable. 3. Localized Emissions The EIR must analyze localized and ambient air quality impacts for all criteria pollutants from project construction and operations. The City of San Diego CEQA Thresholds state that a project may cause a significant impact if it "[e]xpose[s] sensitive receptors to substantial pollutant concentrations including air toxics such as diesel particulates."13 Thus, the EIR should consider localized impacts associated with criteria pollutants (not limited to carbon monoxide), as well as toxic air contaminants. Further, the San Diego CEQA Thresholds state that an EIR should "[a]pply AAQS as the threshold where accepted methodology exists when the project involves a sensitive receptor or if the potential exists for a significant cumulative air quality impact." The SCAQMD Localized Significance Thresholds establish a proven, accepted methodology for evaluating localized health risks based on criteria pollutant concentrations and the Ambient Air Quality Standards (AAQS), both for concentration and operational emissions." Substantial evidence demonstrates that localized concentrations of criteria pollutants can result in significant health impacts, based on both short-term and long-term exposure. Given the size and intensity of the construction activities that likely would be required, construction of a new stadium may result in significant air quality impacts, given the standards established by the San Diego APCD and City of San Diego. For example, there may be significant impacts related to VOC, CO, and NOx during construction, and other projects of this size have resulted in significant air quality impacts. (See, e.g., Farmers Field EIR [finding air quality impacts of new football stadium in Downtown LA had significant and unmitigable 13 City of San Diego CEQA Thresholds, p. 7. httn://www.aqmd.gov/home/regulations/ceua/air-auality-analysis-handbook/localizedsignificance-thresholds. 14 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 16 impacts during construction even with the incorporation of all feasible mitigation measures].) Due to the increased capacity of the proposed stadium and the proposed adjacent development, the operation of the project may result in potentially cumulative impacts to air quality from increased vehicle trips. Because the stadium's location has not been identified, the EIR should include worst case assumptions about its location. 4. The Farmers Field EIR Identified Numerous Air Quality Impacts The Farmers Field EIR provides an example of the type of air quality impacts that may be associated with the stadium project. The Farmers Field EIR identified air quality impacts at a regional and localized level (see attached table). F. Health Risks 1. A Health Risk Assessment (HRA) Must Be Completed Based on Revised OEHHA Guidance The Office of Environmental Health Hazard Assessment (OEHHA) adopted a new version of the Air Toxics Hot Spots Program Guidance Manual for the Preparation of Risk Assessments (Guidance Manual).15 As discussed in Section 8.2.10 of the Guidance Manual, "[t]he local air pollution control districts sometimes use the risk assessment guidelines for the Hot Spots program in permitting decisions for short-term projects such as construction or waste site remediation." Construction impacts must be analyzed with an HRA. Agency guidance indicates that new OEHHA methodology will substantially increase the estimated significance of toxic air contaminants. Because the new OEHHA methodology includes a number of conservative assumptions about potential impacts to infants and children, short term construction emissions could lead to significant HRA results. For example, SCAQMD staff estimate that a six-month construction project for a typical one-acre office project could cause a significant HRA impact.16 The proposed stadium could be located within 185 feet of sensitive receptors, including residents on the west and east side of the property (or potentially closer, depending on the nature of the reasonably foreseeable Mixed-Use Development). Modeling estimates must be completed at the following locations: residences located adjacent to the site on the west and east side; the nearest location to the south where recreationists or walkers use the San Diego River. 15 See http://www.oehha.ca.gov/air/hot s_pots/hotspots2015.html. See SCAQMD Staff presentation, Potential Impacts of New OEHHA Risk Guidelines on SCAQMD Programs, Agenda Item 8b, http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2014/may-specsess-8b.pdf. 16 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 17 Operational impacts must be analyzed with an BRA. Moving the stadium closer to sensitive receptors could increase the potential for significant health risks. The HRA should include emissions from at least the following sources: (a) Idling trucks; (b) Trucks with refrigerated units; (c) Charbroiling facilities at stadium restaurants; (d) Tailgating activities (including charbroiling); (e) Idling cars and RV units while tailgating; (f) Fireworks; (g) Cooling towers; (h) Emergency Diesel Generators (i) Other stadium and related sources Because the stadium's location has not been identified, the EIR should include worst case assumptions about its location. 2. Health Risks to Sensitive Receptors at Key Offsite Intersections and Roadways Should Be Evaluated The EIR should analyze health risk impacts at congested intersections. The analysis should not be limited to carbon monoxide emissions, but rather should include ambient concentrations of criteria pollutants (which can cause localized health impacts from vehicle emissions) and toxic air contaminants. 3. Asthma Impacts From Construction Emissions and Project-Related Traffic Should Be Quantified and Mitigated Numerous studies have identified asthma impacts associated with diesel particulate matter exposure. The EIR should analyze the impact of such exposure from construction and operations on nearby residences, including offsite traffic. 4. Mixed-Use Development The EIR should prepare an HRA and evaluate asthma risks to future residences Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 18 associated with the reasonably foreseeable Mixed-Use Development. The EIR should evaluate impacts of siting residences within close proximity of a major freeway based on the reasonably foreseeable Mixed-Use Development based on guidance from CARB. 5. Soil vapor intrusion risks Soil vapor intrusion risks from residual site contamination should be analyzed. 6. Air conditioning and air filter units The EIR should evaluate installing air conditioning and air filter units on impacted residences, schools and other sensitive receptors where local air emissions will cause significant health effects from on-site or off-site emissions. See Los Angeles Unified School Dist. v. City of Los Angeles, 58 Cal. App. 4th 1019, 1030 (1997) (EIR deficient for failing to evaluate whether air conditioning or filters would mitigate significant localized air quality impacts). G. Noise 1. Scope of Noise Analysis The EIR should conservatively assume that noise impacts from demolition and construction will occur simultaneously. To evaluate worst case noise impacts, the EIR should assume demolition and construction activities occur simultaneously unless the City commits to staging construction activities to ensure that there is no overlap. The location of stadium is critical to noise assessment. Unless the DEIR identifies a specific location for the stadium footprint, the EIR must analyze multiple "worst case" scenarios of locating the stadium near the east, west and south boundaries to determine the impact on sensitive receptors. The EIR must apply appropriate noise standards. Noise analysis must include onsite noise and offsite traffic noise. According to City of San Diego CEQA Significance Thresholds, Interior and Exterior Noise Impacts from Traffic Generated Noise, Table K-2, traffic from the project will be significant if it causes noise levels at sensitive receptors (residents, schools, hospitals, etc.) to exceed 45 dBA interior or 65 dBA exterior. For transportation-related noise, impacts should be considered significant if projectgenerated traffic results in increases in ambient noise levels that generate a noise level of 60 dBA CNEL or greater at noise-sensitive receptors, based on the City of San Diego General Plan Noise Level Compatibility Standards for multifamily residences." For roadways that currently generate 17 See San Diego Marriott Marquis & Marina Facilities Improvement & Port Master Plan Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 19 a noise level of 60 dBA CNEL or greater, an increase in ambient noise level of more than 3 dBA CNEL would generally be considered a significant impact. Accordingly, the EIR should consider transportation related impacts. Increasing the frequency of events can be significant impact under CEQA even if single event noise does not increase. The increased frequency of events can cause a significant noise impact even if any particular single event does not change. (Berkeley Keep Jets Over the Bay Commission v. Board of Port Commissioners, 91 Cal. App. 4th 1344 (2001) [EIR failed to analyze how increasing the frequency of night flights would adversely affect residents].) Thus, the EIR must consider how the increased frequency of events at the stadium will adversely impact the environment, including noise-related impacts. Incremental increases in noise-impacted areas should be evaluated for significance. Increases in noise less than 3 dba should be considered cumulatively significant in areas already heavily impacted by noise, such as the areas around Qualcomm Stadium. (Los Angeles Unified School Dist. v. City of Los Angeles, 58 Cal. App. 4th 1019, 1025 (1997) [EIR found insufficient where existing ambient noise level of 72.1 dBA already exceeded the recommended maximum of 70 dBA and would only increase by another 2.8 — 3.3 dBA at build-out, an increase the EIR considered insignificant because the EIR only applied a strict change in dBA threshold without considering whether the project-related impact would be significant for impacted sensitive receptors "in light of the serious nature of the traffic noise problem already existing around the schools"].) 2. Construction and Other Types of Noise Must be Considered. Construction Equipment - According to the City of San Diego Municipal Code, § 59.5.0404, construction noise is limited to 7:00 am-7:00 pm, Monday through Saturday (except holidays). Further, per Section 59.5.0404(b), "it shall be unlawful for any person, including The City of San Diego, to conduct any construction activity so as to cause, at or beyond the property lines of any property zoned residential, an average sound level greater than 75 decibels during the 12—hour period from 7:00 a.m. to 7:00 p.m." The proposed project construction has the potential to significantly impact a number of sensitive receptors from onsite construction and demolition activities and from offsite traffic noise. There are multiple residential areas immediately surrounding the site. On the east side, an adjacent residential development is approximately 185 feet from the property line. Similarly, on the west side, residences are located within several hundred feet of the property line. Construction noise, including demolition, grading, foundation-laying, pile-driving, and construction traffic are all likely, individually and cumulatively, to constitute significant and substantial noise pollution affecting sensitive receptors. This was true for the Convention Center Amendment Project, Draft Environmental Impact Report, SCH #2010091012, September 2011, p. 4.9-11. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 20 Phase III, which required substantial mitigation measures.18 Additionally, the construction of the new 49ers stadium (which does not involve demolition or the transportation of the demolished materials), was expected to generate the following average noise levels (measured at 50 feet): ground clearing (83-84 dBA), excavation (88-89 dBA), foundation-laying (77-88 dBA), building and construction (79-87 dBA), and finishing work (84-89 dBA). Even at 700 feet, the nearest residences were expected to be subjected to an average noise range of 54-66 (with a maximum of 71) dBA, exclusive of background noise. Fireworks- Impacts from fireworks at the stadium should be analyzed. Construction Traffic- The EIR must analyze traffic-related noise impacts onsite, at entrance/exit points, and at major intersections along the truck haul routes, including all intersections where traffic impacts are potentially significant. Use of Explosives - The Candlestick park demolition considered the use of explosives for demolition given the difficulty of demolishing the stadium using mechanical techniques. Here, the City should assume that explosives may be used based on the Candlestick precedent and model noise impacts associated with explosives. Specific locations where explosives may be used and noise impact zones should be analyzed in the EIR. Helicopters -The possible use of helicopters for construction should be analyzed in the EIR, including flight routes, helicopter type and noise contours. 3. Operational Noise Proximity to sensitive receptors, like residential areas, will impact this calculation. An interior CNEL of 45 dB is set by the State of California Noise Insulation Standards for multiple family dwellings, hotel and motel rooms. Residential units are located directly across 1-15 from the stadium complex and already have to deal with substantial ambient noise from the highway. The project proposal may move the new stadium much closer to the residences. This proximity would have impacts during both the construction and operation phases of the new project. Stadium events, such as sporting events and concerts, will also generate significant noise. For example, outdoor activities and events at the Convention Center were found to have the potential to create significant noise impacts, which required mitigation activities.19 The sound system for the stadium, including the distribution of speakers, as well as cheering crowds, added traffic, fireworks, etc. must all be factored into the calculations. Based on other recent stadium projects, the EIR should also consider: (a) Even before games begin, ambient noise from tailgating in the parking lot; at San Diego Convention Center Phase III Expansion and Expansion Hotel Project & Port Master Plan Amendment Final Environmental Impact Report (Sept. 2012), at p. 3-62. 19 San Diego Convention Center Phase III FEIR at pp. 3-63, 3-66. 18 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 21 Candlestick Park, these noise levels reached 57-61 dBA at the monitoring station 1,350 feet from the edge of the stadium (but reached 75 dBA at roughly 300 feet, with the average around 57-63 dBA); tailgating activities had a significant impact on nearby residents.2° (b) When spectators exited Candlestick Park, ambient noise rose to 63 dBA at the 1,350-foot monitoring station.21 (c) During a game at Candlestick Park, maximum noise levels ranged from 95-103 dBA, and the average was roughly 78-92 dBA. Use of the PA system in the stadium created ambient noise at 1,350 feet of about 56 dBA, cheering ranged from 52-65 dBA, and the national anthem and fireworks generated a sound of 6162 dBA (at 1,450 feet—closer data is unavailable for these). This was also a significant impact. By contrast, the Padre Gardens Apartments would be only a few hundred feet from the new stadium, and would already have significant ambient noise from I-15.22 (d) At Candlestick Park, non-NFL sporting events were almost identical in the noise levels generated and also qualified as significant impacts on nearby residents. 23 (e) Concert events would generate an average noise level of 95 dBA, measured 100 feet from the speakers. Noise levels were comparable to, or slightly lower than maximum crowd noise at an NFL event, and constituted a significant impact on residents.24 Additionally, the EIR for Phase III of the Convention Center project noted that HVAC and other air-handling systems, loading and unloading activities, and other stationary and recurring on-site activities also contribute significantly to noise pollution.25 Ground-borne vibrations caused by vehicle circulation within the proposed parking facilities, on-site delivery truck activity, and added ofd site traffic, as well as stationary on-site mechanical equipment, like air handling units, condenser units, cooling towers, exhaust air fans, and electrical power generators could cause noise impacts. Therefore, these activities should be analyzed in the EIR. 4. Noise Impacts on Wildlife. The FIR should consider noise impacts to sensitive wildlife, which may require 20 The 49ers Stadium Project, City of Santa Clara, Draft EIR (July 2009), Sec. 4.10.1.4, p. 241. 21 22 23 24 25 Id. Id. Id. at pp. 246-48. Id. at pp. 248. San Diego Convention Center Phase III FEIR at pp. 3-63. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 22 mitigation measures. Notably, impacts to certain avian species during their breeding season may create the need for mitigation, depending on whether or not the project is occupied by the California gnatcatcher, least Bell's vireo, southern willow flycatcher, least tern, cactus wren, tricolored blackbird or western snowy plover, and whether or not noise levels from the project, including construction during the breeding season of these species would exceed 60 dB(A) or existing ambient noise level if above 60 dB(A). 5. Mixed-Use Development Noise Impacts The EIR should analyze noise impacts to future residences associated with the reasonably foreseeable Mixed-Use Development. 6. Farmers Field EIR Identified Numerous Noise Impacts The Farmers Field EIR provides an example of the type of noise impacts that may be associated with the stadium project. The Farmers Field EIR identified significant noise impacts (see attached table). Notably, the proposed project appears to have more sensitive receptors in close proximity to the project site than the Farmers Field project. H. Water Resources 1. The Proposed Development May Fall Within U.S. Army Corps' Jurisdiction Based on Newly Issued Rules The EPA and U.S. Army Corps of Engineers have recently issued new rules clarifying the scope of the "Waters of the United States," which establishes the scope of federal jurisdiction over certain bodies of water pursuant to the Clean Water Act. The San Diego River, which runs directly to the south of the stadium, is a jurisdictional water. The ponds within the river-course approximately half a mile to the east of the stadium appear to also qualify. The new rule also establishes that any water within the 100-year floodplain or within 4,000 feet of the high water mark of such a body of water may fall within federal jurisdiction. The stadium site falls within the 100-year floodplain of the river. The EIR should include a wetlands delineation and analysis of whether the stadium project would directly or indirectly impact any waters of the United States, and determine whether an Army Corps permit is required. Impacts from construction and operation of the new stadium that lead to contamination of the San Diego River or any of its tributaries could also be subject to regulation under the Clean Water Act. Furthermore, construction of the new stadium may substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of the river and floodplain. Further, the project may degrade water quality if it interferes with existing Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 23 remediation activities. I. Aesthetics 1. Light Pollution Use of the new stadium's bright lights on an increased number of evenings throughout the year would contribute additional light pollution to the area, and would particularly impact nearby residential areas to the east of the site. Light from additional car headlights resulting from both construction trucks and, once the project is completed, from extra year-round events and increased stadium capacity would also impact nearby residences. The Farmers Field EIR notes that "New nighttime light sources have the potential to increase ambient nighttime illumination levels and result in spillover of light onto adjacent properties. These effects have the potential to interfere with certain functions including vision, sleep, privacy, and general enjoyment of the natural nighttime condition."26 Residential and some commercial uses are among the most adversely impacted. For the residential units, the increased proximity and frequency of lights could be a major issue. Beyond light pollution from artificial lights, glare (during both daytime and nighttime hours) from the reflection of sunlight or artificial light off of highly polished surfaces, such as window glass or reflective materials (including cars parked in the parking lot). Analysis should include potential impacts on glare-sensitive uses, which include light-sensitive uses and transportation corridors (i.e. nearby residential units and nearby roadways, including Friars Road, 1-15, and possibly 1-8), and should consider the impacts on glare of moving the stadium closer to sensitive residential receptors. 2. Visual Impacts The stadium project, including the demolition, subsequent construction, and new stadium, would be visible from at least the following locations, which should be analyzed in the EIR: (i) from Friars Road, the major arterial passing to the north of the site; (ii) from 1-8, passing to the south of the stadium, across the river, 1-15, directly to the east of the stadium, and 1-805, half a mile west of the stadium; (iii) from residential units to the east of the stadium, across 1-15; (iv) and from residences, businesses, and roadways on the northern and southern slopes of Mission Valley, as well as from residences and public parkland on the northern and southern ridgelines of the Mission Valley canyon in Serra Mesa (to the north) and in Kensington and along N. Mountain View Drive (to the south). City of Los Angeles, Convention and Event Center [Farmers Field] Project Draft EIR, April 5, 2012, p. IV.D.2.-1. 26 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 24 The existing stadium has an award-winning design and has become a cultural institution in the region. The stadium "dominates the view from almost any vantage point in the eastern portion of the Valley." (MVCP, at 167). Replacing this with a different structure could negatively impact the aesthetic integrity of the site. By moving the stadium closer to the residences to the east of the site, the stadium may also impact the ability of those residences to receive afternoon light. For example, the Farmers Field EIR considers shadowing issues at each solstice and equinox, and places particular emphasis on the impacts to residences. See Farmers Field Draft EIR at p. IV.D.1-1-1-37. J. Hazardous Waste and Materials 1. Background to contamination issues with the site. The EIR must fully describe how the stadium project will affect ongoing monitoring and remediation associated with the Kinder Morgan site contamination. Kinder Morgan's Mission Valley Terminal (MVT) is an aboveground storage tank (AST) facility located to the northeast of Qualcomm Stadium. Petroleum products currently or historically stored at the MVT include leaded and unleaded gasoline, gasoline additives, jet fuel, diesel, ethanol and transmix. Petroleum hydrocarbons released from MVT have migrated in the subsurface and contaminated the soil and groundwater underlying the Qualcomm stadium site, triggering remediation and monitoring obligations under the authority of the San Diego Regional Water Quality Control Board to protect the environment and human health. Constructing the stadium project would likely complicate and possibly exacerbate future remediation of the Qualcomm stadium site while potentially creating new risks to future onsite sensitive receptors. Moreover, the stadium project may trigger the need for additional Regional Board approvals to manage and remediate the contamination. The Regional Board issued a Cleanup and Abatement Order (CAO) to address MVT's contamination in 1992 (CAO No. 92-01). Since 1992, the Regional Board has issued seven addenda to the CAO, including Addendum 5 in 2005. Addendum 5 requires Kinder Morgan to remediate contamination at the Qualcomm stadium site. Kinder Morgan implemented a remediation response consisting of soil vapor extraction (SVE) coupled with localized dewatering in two areas of the stadium site. Kinder Morgan completed remediation of the primary site on December 2010 and the secondary site in December 2013. Kinder Morgan ceased active remediation on the stadium site in the first quarter of 2014 and submitted a report in March 2014 to the Regional Board that concluded: "by the end of 2013, the selected remedial strategy had removed LNAPL [Light Non-Aqueous Phase Liquid] from the [secondary] LNAPL zone to the extent technically practicable." Kinder Morgan ceased monitoring on the stadium site following the Regional Board's approval in January 2015. However, the Regional Board required monitoring to resume in April 2015.27 27 Regional Board Response to Kinder Morgan Request for Suspension of Groundwater Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 25 2. There Continues to be Ongoing Uncertainty About the Contamination Risk. While remediation efforts may have reduced contamination at the Qualcomm stadium site since the CAO was issued, significant concerns remain that once groundwater levels stabilize onsite, monitoring will show that the Qualcomm stadium site remains impacted by contamination. As explained by the City in a March 2015 letter to the Regional Board "there is still considerable concern that the full effects of the release will impact this [the City's groundwater resources] for some time, and that mitigation and restoration of the resource is far from over."28 For instance, the most recent data suggests that levels of tert-butyl alcohol (TBA) and benzene are rebounding in the LNAPL zone at the stadium site.29 The rising water table can cause "smearing" in the LNAPL zone, essentially dislodging latent contamination in soils at the stadium site. Following receipt of the City's analysis, the Regional Board, on April 3, 2015, required Kinder Morgan to resume groundwater monitoring "to determine if groundwater cleanup levels have been achieved in accordance with [the CAO]" following groundwater level stabilization.3° Kinder Morgan's proposed monitoring plan, submitted on April 14, 2015, indicated that approximately 20 wells have had TBA, benzene, or MTBE concentrations above state response levels in the last year.31 Monitoring may trigger additional remediation requirements. The EIR should fully disclose the current status of the ongoing cleanup and monitoring activities, as well as analyze potential impacts to the site contamination from the project. Given the City's written position on the nature and scope of contamination, the EIR must analyze the potential for pulling of contamination from off-site locations with further dewatering associated with the new stadium construction. 3. Stadium Construction May Exacerbate Risks. Ongoing testing following groundwater level stabilization may demonstrate continuing contamination risks. In the event monitoring demonstrates the need for additional active remediation, any contemplated redevelopment at the stadium site would require consultation with Kinder Morgan and the Regional Board. If the stadium has had the potential to impact remediation or monitoring activities (likely given the scale of development work and extensive well network on the stadium site), the City may need to work with Kinder Morgan and the Regional Board to amend the CAO and associated work plans. Timing for amending the Monitoring and Reporting Requirements (Apr. 3, 2015). See City of San Diego March 25, 2015 Letter to David Gibson, Executive Officer California Regional Water Quality Control Board re Evaluation Report of Remediation for Kinder Morgan's Mission Valley Terminal Off-Site Release. 29 Post-Remediation Groundwater Quality, Mission Valley Aquifer, at 33 (Mar. 25, 2015). 30 Regional Board Response to Kinder Morgan Request for Suspension of Groundwater Monitoring and Reporting Requirements at 1 (Apr. 3, 2015). 31 Request for Revision of the Monitoring and Reporting Program at 2 (Apr. 14, 2015). 28 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 26 CAO/work plans could range significantly and should be analyzed in the EIR. 4. City Liability If Environmental Contamination Worsens If the City moved forward with construction and demolition without Regional Board approval, it potentially could put itself at risk of being named a responsible party at the stadium site for exacerbating or accelerating the migration of contamination. Exacerbation or acceleration of migration during construction could also subject the City to owner/operator liability under federal law. See Kaiser Aluminum & Chemical Corp. v. Catellus Development Corp., 976 F.2d 1338 (9th Cir. 1992). 5. The City Should Evaluate the Impact of Dewatering. Environmental risks due to discharging water from construction dewatering must be analyzed. In the event the significant excavation required for a new stadium and/or Mixed-Use Development requires extensive construction dewatering (which we view as likely given the current dewatering at the Stadium itself), it is foreseeable that the City will need to obtain a NPDES permit from the Regional Board to discharge dewatered groundwater encountered during construction. While under most circumstances construction dewatering can be covered by a Regional Board issued "General Permit," given the quality of groundwater in the area (specifically the high naturally occurring Total Dissolved Solids (TDS)), it is reasonably foreseeable that the Regional Board may require a Time Schedule Order (TSO) prior to discharge. Prior to approving a TSO, the Regional Board must provide the public the opportunity to review and comment on the approval. See, e.g., Cal. Water Code § 13167.5(a)(4) (providing for notice and comment prior to adoption of any a "time schedule order" pursuant to Water Code § 13300) and an aggrieved party can petition the State Board for review. See Water Code § 13320(a). If the State Board denies review, or a party does not prevail on the merits before the Board, an aggrieved party may file a petition for a writ of mandamus with the Superior Court requesting review of the State Board or Regional Board decision. Water Code § 13330(a). Timing for the review and processing of a TSO can range significantly based on the nature of the request and Regional Board staff resources. In a relevant example, it took approximately four months after the public notice and nine months after the notice of violation necessitating its issuance for the Regional Board to adopt a TSO for the MVT discharge.32 In general, a Regional Board can take as few as three months to over a year to process and adopt a TSO. In the event a party challenges an issued TSO via writ of mandamus, like any litigation, proceedings may take a year or more before resolution. The necessity of a TSO appears to be reasonably foreseeable, and should be analyzed in the EIR because the Regional Board issued Kinder Morgan's MVT facility a TSO in 2011 after 32 See Regional Board Time Schedule Order No. R9-2011-0052. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 27 determining that naturally occurring TDS had the reasonable potential to cause a violation the water quality objectives established in the Water Quality Control Plan for the San Diego Basin.33 6. Hazardous materials from demolition The existing stadium was built in 1967 and, therefore, its demolition could result in the disturbance and transportation of hazardous materials, including asbestos, which must be fully analyzed in the EIR. A complete analysis of the presence of hazardous materials in the existing stadium must be provided. 7. Ongoing Litigation Involving the Kinder Morgan Contamination The City of San Diego is involved with ongoing litigation involving the Kinder Morgan Contamination, which must be thoroughly discussed and analyzed in the EIR.34 — The City alleged that Kinder Morgan's slow progress in remediation and abatement entitled the City to damages under a variety of claims. The City additionally alleged that Kinder Morgan had continued to contaminate the site and had permitted additional leaks and discharge of chemicals. K. Hydrology The property is located within the 100-year floodplain. Impacts related to flooding should be evaluated in the EIR. Will flood control infrastructure be required to protect the site from flooding, and if so, what are the implications for other issues areas (biological resources, visual resources, etc.)? (See attached FEMA map.) L. Biological Resources Take of species listed under the federal Endangered Species Act as threatened or endangered is only authorized if the person first receives an incidental take permit from the USFWS, either through the Section 7 consultation process (if another federal agency has discretionary authority over the project) or the Section 10 process (requiring approval of a Habitat Conservation Plan). Construction and demolition activities for the project may disturb habitat along the San Diego River. Based on a U.S. Fish and Wildlife Service (USFWS) online database search, a project near the Qualcomm site and related portion of the San Diego River has the potential to impact over 50 species managed or regulated by the USFWS, including endangered species such as the Coastal California Gnatcatcher, Least Bell's Vireo, Southwestern Willow Flycatcher and Western Snowy Plover." 33 See id. See City of San Diego v. Kinder Morgan Energy Partners (District Court Case No. 07CV-1883 W) (Court of Appeals Docket #13-55297). 35 See attached results from the USFWS database search, available at 34 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 28 Under Fish and Game Code § 1600 et seq., a Lake and Streambed Alteration Agreement is required if an activity may substantially adversely affect existing fish or wildlife resources and the activity will: substantially divert or obstruct the natural flow of any river, stream or lake; substantially change or use any material from the bed, channel or bank of any river, stream, or lake; or deposit debris, waste or other materials that could pass into any river, stream or lake. Section 2081 of the Fish and Game Code allows the California Department of Fish and Wildlife (CDFW) to issue incidental take permits for species listed under the California Endangered Species Act. For species listed under both the federal and state Endangered Species Acts, CDFW may issue a consistency determination under Section 2080.1. Here, CDFW's authority is generally similar to, but broader than, the USFWS' and Army Corps' authority under statutes described above. Therefore, if the project impacts to the San Diego River or endangered species would require federal approval, then CDFW approval would also be triggered. Even if federal approval is not required, it is possible that impacts to statelisted species or waters of the state could obligate the need for CDFW approval. M. Greenhouse Gases The project's construction and operations would result in new GHG emissions that need to be evaluated for significance. GHG emissions, including those generated by the new trips to and from stadium events, need to be evaluated for significance. GHG emissions from construction need to be evaluated for significance as well. The Project would generate both direct and indirect GHG emissions via the following emissions sources, including: 1. Construction: Emissions associated with dust control (water), construction debris disposal, and construction-related equipment and vehicular activity; 2. Transportation: Emissions associated with Project-generated vehicular operations; 3. Building Operations: Emissions associated with space heating and cooling, water heating, and lighting; 4. Water: Emissions associated with energy used to pump, convey, treat, deliver, and re-treat water; and 5. Solid Waste: Emissions associated with waste streams (embodied energy of materials).trips, energy use, water use, construction. http://ecos.fws.gov/ipac/projectNTOJ7C5JHRCLBCXGHKSWRKOTHM/overview. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 29 The proposed project would generate and contribute to cumulative increases in sources of GHGs. N. Geology and Soils A detailed analysis of whether the project would expose people or structures to substantial adverse effects including death as a result of seismic related ground failure, including liquefaction, should be analyzed in the EIR, including considering the following. San Diego's Seismic Safety Study indicates that there is a high potential for liquefaction at the property. This means that the property is at a moderate to high risk of hazard.36 The Seismic Safety Study also outlines the required geotechnical studies for different categories of development. A stadium would fall into Group 3, which includes "places normally attracting large concentrations of people." Based on the hazard category, relative risk, and building type, a stadium project would have to conduct a soil investigation and a geologic investigation prior to receiving planning and development permit approval.37 The Seismic Safety Study concludes that developments will require a geotechnical investigation prior to development. All buildings within the high potential liquefaction area require the completion of a geotechnical investigation prior to receiving building permit approval.38 0. Land Use The project must be evaluated for consistency with land use regulations, under CEQA. The zoning code for the current zone in which the stadium is located, MVPD-MV-CV, states that "no building or improvement, or portion thereof, shall be erected, constructed, converted, established, altered or enlarged, nor shall any premises be used except for one or more of the uses listed for applicable zones in Table 1514-03J." (SDMC § 1514.0305(b).) In turn, Table 1514-03J does not list "stadium" or any use that could be construed as permitting a stadium. While Table 131-05B indicates that stadiums are permitted in the CV zone, Section 131.0520 states that the uses permitted under Section 131-05B "may be further limited by... (3) The presence of environmentally sensitive lands, pursuant to Chapter 14, Article 3, Division 1 (Environmentally Sensitive Lands Regulations); or (4) Any other applicable provision of the San Diego Municipal Code." The property is both located within environmentally sensitive land (floodplain) and in a zone (MVPDMC- CV) that limits further uses otherwise permitted in the CV zone. Stadiums are not permitted in floodplains. 36 37 38 San Diego Seismic Safety Study Map, Grid Tiles 21 and 26. San Diego Seismic Safety Study Map, Sheet 2. San Diego Seismic Safety Study Map, Sheet 3. Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 30 As discussed below, the project may require a consistency determination by the San Diego County Regional Airport Authority. Further, the Project could impact on San Diego River Park Master Plan (http://www.sandiego.gov/plaiming/programs/parkplanning/pdf/sdriverparkpdf/sdrp_master_plan full.pdf), which should be analyzed in the EIR. IV. A REASONABLE RANGE OF ALTERNATIVES MUST BE ANALYZED A reasonable range of alternatives must be addressed, Besides the no project alternative, these could potentially include a downtown stadium such as JMI Realty's proposed joint stadium/convention center east of Petco Park (http://www.sandiego.gov/real-estateassets/pdVstadium/jinifacilitystudy2014.pdf) The range should also include remodeling/refurbishing the existing stadium instead of building a new stadium. This would reduce construction impacts and keep the stadium in the center of property to reduce impacts on surrounding sensitive receptors. This would require a temporary location for the Chargers to play while the existing stadium is demolished and a new stadium is constructed at the same location. It would also have reduced impacts on ongoing remediation efforts. The alternatives should include a reduced stadium size, or a stadium for a soccer team in lieu of a football stadium. The City should evaluate a domed stadium option to reduce noise impacts. The City must also evaluate reasonably foreseeable permutations of the Mixed-Use Development. Because the NOP does not identify where the stadium would be located, the EIR should fully analyze impacts associated with locating the stadium on different possible areas of the property. And the EIR must examine the possibility of a large parking structure to accommodate the stadium parking requirements. Finally, while preservation of the historic stadium would be ideal, alternatives could include creation of a public park and expansion of San Diego River Park. (http://www.voiceofsandiego.org/topics/opinion/mission-valley-needs-more-of-what-it-doesnthave-no-more-of-what-it-does/.) V. ADDITIONAL GOVERNMENTAL APPROVALS WOULD BE NECESSARY Based on a preliminary assessment, it is reasonable to assume that discretionary approvals may be required from one or more of the following responsible agencies that may have approval authority over the stadium, which must be analyzed in the EIR. County of San Diego — CEQA applies to "[a]ctivities financed in whole or in part by a governmental agency." (CEQA Guidelines § 15002(b).) A governmental bond offering that helps fund a specific development project that will change the physical environment constitutes a "project" under CEQA because it is lamn activity undertaken by a person which is supported, in whole or in part, through contracts, grants, subsidies, loans, or other forms of assistance from one or more public agencies." Pub. Res. Code § 21065(b); CEQA Guidelines § 15378(a)(2). Where the Legislature has intended to exempt certain bond financing from CEQA, it has Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 31 expressly done so. Here, because the County of San Diego bond offering would result in governmental funding of the stadium project, and the stadium would result in changes to the physical environment, the bond offering constitutes a project under CEQA, obligating the need for environmental review. Because the County bond offering would help fund the stadium project, the County must satisfy CEQA before issuing the bonds. If the City ElR does not fully describe the project (such as by failing to include the reasonably foreseeable Mixed-Use Development), then the County would be obligated to complete its own CEQA review prior to the bond offering. Regional Water Quality Control Board — To approve site contamination or water discharge measures. If a Clean Water Act Section 404 permit is required, the Regional Board would need to issue a Section 401 certification. The Regional Board or State Water Resources Control Board must issue a Section 401 certification if a Section 404 permit is required under the Clean Water Act. San Diego Air Pollution Control District — Operation of the proposed stadium may trigger the need for SDAPCD permits for stationary sources onsite, such as emergency diesel generators. The SDAPCD does not publicly list what permits are held by Qualcomm Stadium. However, other stadium facilities in southern California require permits for emergency diesel generators, charbroiling facilities and air conditioning units. In addition, demolition of the current stadium may require obtaining pre-approval for an asbestos removal plan. (See SDAPCD Rules 361.145, 361.150.) San Diego County Regional Airport Authority-- According to the Montgomery Field Airport Land Use Compatibility Plan map, the Qualcomm Stadium site is within the Montgomery Field Airport Influence Area, Review Area 2. The San Diego Municipal Code § 132.1550(c)(4) requires: "Prior to approval of development within the Airport Land Use Compatibility Overlay Zone, the applicant shall obtain a consistency determination from the SDCRAA for the following types of development:. . . (4) Development that includes a rezone or approval of a land use plan." Here, the stadium proposal and/or the adjacent development project may require a General Plan or zoning amendment, potentially triggering the need for a consistency review. According to the Montgomery Field Airport Land Use Compatibility Plan, Section 2.6.2(a)(2), development within Review Area 2 requires a consistency review in the following cases: (1) Any object which has received a final notice of determination from the FAA that the project will constitute a hazard or obstruction to air navigation, to the extent applicable. (2) Any proposed object in an area of terrain penetration to airspace surfaces which has a height greater than 35 feet above ground level. (3) Any project having the potential to create electrical or visual hazards to aircraft in flight, including: electrical interference with radio communications or navigational signals; lighting which could be mistaken for airport lighting; glare or bright lights (including laser lights) in the eyes of pilots or aircraft using the Airport; certain colors of neon lights- especially red and white- that can interfere with night vision goggles; and impaired Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 32 visibility near the Airport. The local agency should coordinate with the airport operator in making this determination. (4) Any project having the potential to cause an increase in the attraction of birds or other wildlife that can be hazardous to aircraft operations in the vicinity of the Airport. The local agency should coordinate with the airport operator in making this decision. If the San Diego Regional Airport Authority determines that the development is inconsistent with the airport land use plan, the project would have to be revised to ensure consistency or the City of San Diego could overrule the Regional Airport Authority after holding two public hearings and making certain findings. See San Diego Municipal Code § 132.1555. Notification to the Federal Aviation Administration is also required if the stadium would include heights over 200 feet above ground level. U.S. Army Corps of Engineers — Under Section 404 of the Clean Water Act, the U.S. Army Corps of Engineers regulates the discharge of dredged or fill material into waters of the United States, including wetlands. On May 27, 2015, the Environmental Protection Agency and Army Corps co-released the final version of a rule clarifying what constitutes waters of the United States, including tributaries, adjacent waters, wetlands and other waters with a significant nexus to waters of the United States. Here, if the stadium proposal and/or the adjacent development project would directly or indirectly result in fill of the San Diego River, a Section 404 permit may be required. If an individual permit is required, NEPA would be triggered. U.S. Fish and Wildlife Service — Take of species listed under the federal Endangered Species Act as threatened or endangered is only authorized if the person first receives an incidental take permit from the USFWS, either through the Section 7 consultation process (if another federal agency has discretionary authority over the project) or the Section 10 process (requiring approval of a Habitat Conservation Plan). Based on a USFWS online database search, a project near the Qualcomm site and related portion of the San Diego River has the potential to impact over 50 resources managed or regulated by the USFWS, including endangered species such as the Coastal California Gnatcatcher, Least Bell's Vireo, Southwestern Willow Flycatcher and Western Snowy Plover. See http://ecos.fws.gov/ipac/project/VT0J7C5JHRCLBCXGHKSWRKOTHM/overview. Here, given the presence of listed species in the general project area, it is reasonable to conclude that the stadium project and/or adjacent development have some potential to impact listed species, in which case, approval from the USFWS would be required. California Department of Fish and Wildlife (CDFW) — Under Fish and Game Code § 1600 et seq., a Lake and Streambed Alteration Agreement is required if an activity may substantially adversely affect existing fish or wildlife resources and the activity will: substantially divert or obstruct the natural flow of any river, stream or lake; substantially change or use any material from the bed, channel or bank of any river, stream, or lake; or deposit debris, waste or other materials that could pass into any river, stream or lake. Section 2081 of the Fish and Game Code allows CDFW to issue incidental take permits under certain circumstances for species listed under the California Endangered Species Act. For species listed under both the federal and state Endangered Species Acts, CDFW may issue a consistency determination under Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 33 Section 2080.1. Here, CDFW's authority is generally similar to, but broader than, the USFWS' and Army Corps' authority under statutes described above. Therefore, if project impacts to the San Diego River or endangered species would require federal approval, then CDFW approval would also be triggered. Even if federal approval is not required, it is possible that impacts to state-listed species or waters of the state could obligate the need for CDFW approval. National Historic Preservation Act — Where federal discretionary agency approval is required, the federal agency must satisfy the Section 106 consultation process under the National Historic Preservation Act. VI. ADEQUATE TIME FOR PUBLIC REVIEW AND COMMUNITY ENGAGEMENT MUST BE PROVIDED. Given the complexity of demolishing the existing stadium, constructing a new stadium and planning for a potential future Mixed Use Development, the City should give the public more than the minimum period of public review and comment on the Draft EIR. The minimum period will not allow adequate time to review all the technical information and, if necessary, to prepare different analyzes for the City to consider. Given the high number of sensitive receptors that will be affected by this project, and the potential for communities with a high pollution burden to be impacted, the City should complete additional scoping meetings and EIR workshops to facilitate community outreach and awareness. Given the high percentage of Spanish speakers in San Diego, all materials must be made available in Spanish as well as English. CONCLUSION We strongly urge you to conduct adequate environmental review pursuant to CEQA before making any decisions that profoundly affect the future of Mission Valley. The Supreme Court's admonition regarding adequate environmental review must be heeded: The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. The EIR's function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been taken into account. (Laurel Heights I, supra, 47 Cal.3d at pp. 391-392, 253 Cal.Rptr. 426, 764 P.2d 278.) For the EIR to serve these goals it must present information in such a manner that the foreseeable impacts of pursuing the project can actually be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Ca1.4th 412, 449-50. Before the City decides to move forward with a football stadium in Mission Valley, it should develop a full understanding of the environmental consequences of Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 34 such a decision, examine potential alternatives that could avoid the negative consequences, and ensure that those consequences are taken into account in any decisions made. We reserve the right to provide further comments. We believe that the NOP should be reissued given the paucity of information provided for in the original NOP. We hereby request notice of all further proceedings pursuant to Public Resources Code section 21092.2. Thank you for your attention and consideration. Sincerely, Douglas Carstens Enclosures Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 35 Exhibit A Potentially Disproportionately Burdened Communities 35 Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 36 CalEnviroSerren 2.0 results Highest Scores (91 - 100%) 81 - 90% 71 - 80% 61 - 70% 51 - 60% 41 - 50% 31 - 40% 29 - 30% 11 - 20% 12 miles Lowest Scores (Bottom 10%) High pollution, low population ti USFAC Reen.. .". DeDie go II • i v San Diane Intl Almon I. Eel, HERE, DoLorrnfr internap USGS, MEP/NASA, NGA: USDA, EPA Martha Blake, Senior Planner City of San Diego Development Services Center July 20, 2015 Page 37 Coliwisteleiw Miami CalenviroScreen 2.0 _ *6.FL—cm. CalEnvIroScreen 2.0 Pollution Burden Scores CAIEnvirokrean Pallulioe Elunlin .tens Oyer eli CalEnviroScreen scores are c air Waled from Pie scores for two broad groups of indicators: Pollution Burden and Population Characteristics. This map shows only the combined Pollution Bur den moil es. The 12 indicators that make up the Pollution Burden are: bk al ay. .11.621:est Pd on 51 5. „4.0;, b b hi . b 71 • Malec Owe litlimailly../1WartickislPie2 Si hceettanirsultaticodesm inaliesereart reseleseces Pingo* Ifse resiceNueuram Wares • Trafteliamsas • • • • WA 41 -5e.. 21 • 3.7. 11 • 20`.. 1 IV. 'Laves! Penur.on Bairn stares! firounigiveler • Marko Vii11124111100 facings . • 111141101dWistrIleilie • SOW lesseleSimsaedraseisies These indecalct s are described in detail in the CalErwiroSarean report To !spier* [he map, zoom to a location or type an address in the search bar. Carotin:Screen 2.0 fiE 0 CalEmdroBerimn PopulaUen Charschnistict acorns ▪ St -10611.4Hz&11. 110t1 I MIA ▪ B1- ▪ -dlr. lb 81- 101. CalEnvIroScreen 2.0 Ito Population Characteristics Scores Over all CalEavloScreen scores are calculated horn the scores for two broad groups of indleatOrS: Pollution Burden and Populanon Characteristics. This map shows Only the combined Population Characteristics scores. The seven Indicators that make up the Pollution Burden are. ▪ 51.80'. 41- 50.31 •• 21_50•. 11 1 • 101.11.060bi Populat.36 Durazlenslas SWIMS! Gookann sane AmiCalltratierdraderka • AelereememersesenieeraNisits • Law tieth Wasiak-6nm inaleureaeualmeiamate • Unsuisliciselauen • Boone • Unerrialeareent These indicators are described in detail In tne careiiroureentspon To explore the map. roam toe location or type an address in the search bar .1•EPI Ain, ell Hier 1"7 1111/r / .1 .. 37 . SA Site Selectiun??an?' Financing Plan for a New Stadium in San Di?gu May 13.2015 CITIZENS' STADIUM ADVISORY GROUP May 18, 2015 The Honorable Kevin L. Faulconer Mayor, City of San Diego 202 C Street San Diego, CA 92101 Dear Mayor Faulconer: It is our honor to submit our report entitled, "Site Selection & Financing Plan for a New MultiUse Stadium in San Diego." On January 30, 2015, you announced the creation of the Citizens' Stadium Advisory Group (CSAG). You directed us to do two things: Select one of two proposed sites, and develop a fair and workable financing plan for a new multi-use stadium in San Diego. Faced with this unprecedented task and pressure from competing stadium dynamics in Los Angeles, CSAG has successfully met its goals. We did so in 108 days, or four months before our original deadline. We worked collaboratively with all stakeholders, reviewed an enormous amount of data from the past 12 years, hosted a public forum, interviewed dozens of industry experts and civic leaders and maintained an objective and independent eye toward solving one of the region's largest public policy issues. As a result of our collaboration, we are pleased to present our plan as a blueprint for initiating negotiations with the San Diego Chargers. The attached report answers the two issues you asked us to resolve. A path to a new state-ofthe-art stadium now exists in San Diego. We propose a stadium that is modern and efficient, occupying a smaller footprint than the existing stadium, and creating new opportunities and experiences for San Diegans and tourists. We selected the site that works financially for all parties involved. It meets the time constraints presented by the Chargers, and gives the City an opportunity to create an iconic place showcasing a restored and enhanced San Diego River Park and a new walkable entertainment and residential village linked to mass transit that is the new paradigm for smart urban planning and design. Along with presenting this exciting vision, our plan spells out a list of important recommendations we believe are needed to complete the work we have started. It also addresses the concerns we have heard from the Chargers and the NFL, and reflects the dynamics of San Diego. The most important element — the financing plan — reflects a balanced and shared approach that works for the team, the City, the County and taxpayers. It also ensures a new level of financial competitiveness for the franchise without unduly burdening taxpayers. Your leadership and our work created momentum that Chargers' fans have built upon. We believe San Diego's mega-region, home to more than 10 million people, is ready to support a new multi-use stadium where the Chargers can thrive, and San Diegans can enjoy a wide range of entertainment and event activities as suggested in our report. 1 CITIZENS' STADIUM ADVISORY GROUP Thank you for selecting us to serve you in addressing this critical civic matter. We wish you, the City Council, the County of San Diego, and the broader mega-region, the best of luck as you embark on the next phase of this effort. We stand ready to provide further assistance if needed. Sincerely, Adam kay Chairman I0(54"?rt/ Doug Barnhart r,Ocksal,tc Walt Ekard /Jason Hughes Rod Dammeyer an-hhge Aimee Faucett Mary Lydon Co-Chairman d"-i)d4 essie Knig H Jim Steeg CITIZENS' STADIUM ADVISORY GROUP Site Selection and Financing Plan for a New Multi-Use Stadium in San Diego CONTENTS 1 Executive Summary 3 Summary of CSAG's Work 4 Site Selection 4 Mission Valley 5 Support for Mission Valley 6 Downtown 7 7 8 San Diego Stadium Assessment LA Threat Surfaces San Diego Responds 10 Costs 12 Financing 13 Chargers/NFL 13 City/County 13 PSLs 13 Chargers Rent 14 Rent From SDSU & Bowl Games 14 Developer Purchase 14 Ticket Surcharge 14 Chargers Parking & Surcharge 14 Additional Funding Sources 15 15 Non-Stadium Financing Enhanced Infrastructure Financing District (EIFD) 16 Revenue Opportunities: Chargers 17 Revenue Opportunities: City/County 18 Revenue Streams 19 Next Steps 20 Final Recommendations 20 Recommended terms for negotiations with the Chargers 20 Recommendations for the JPA 21 Endnotes APPENDIX 24 Citizens' Stadium Advisory Group— Bios 27 Key Dates 28 Design Narrative 35 National Stadium Assessment CSAG Executive Summary San Diego Mayor Kevin L. Faulconer announced the formation of the Citizens' Stadium Advisory Group (CSAG) on January 30, 2015, to chart a workable path to building a new multi-use stadium in San Diego that protects taxpayers and creates a win-win solution for the Chargers and San Diego. The committee is composed of nine civic leaders with experience developing large-scale projects and financing plans. CSAG's Plan at a Glance: •No tax increases. •No increases to the City's General Fund. •Does not rely on development to pay for the stadium, parking or stadium-related infrastructure. Mayor Faulconer asked the committee to do two things: 1.Select the existing Mission Valley site or the Downtown site for a new multi-use stadium. 2.Develop a financing plan to pay for the facility. "It's time for us, as a community, to come together to decide the future of the Chargers in San Diego," Mayor Faulconer said at the time. "This independent group will give San Diegans the first real plan. These expert volunteers will explore all possibilities to finance the project, with the clear direction from me that it must be a good and fair deal for San Diego taxpayers."' CSAG completed its work in 108 days, or four months before its original deadline, and two days ahead of the accelerated deadline the committee agreed to early in the process. CSAG concluded a new multi-use stadium in Mission Valley is the most viable option, and would cost approximately $1.1 billion, excluding land. To pay for the facility, CSAG outlines revenue streams that exceed $1.4 billion without increasing taxes. CSAG's plan lays out a clear and workable path to a new multi-use stadium in San Diego that is fair for everyone, including taxpayers. In addition to breaking down costs and funding sources, this report explains how the Chargers, the City and County would recoup its investments. CSAG's financing plan is the first of its kind in San Diego and represents an important break from the past. After years of little progress, due to the collapse of the real estate market, the Great Recession and other issues, CSAG's plan should immediately jump-start negotiations. The City, the County and the Chargers will need to work together to fill in the framework CSAG created. When the Chargers met with CSAG this past February, the team outlined what it called "guiding principles" that CSAG's financing plan should meet.2 The committee had made these assumptions prior to meeting with the Chargers and is confident its plan: Avoids a two-thirds vote of the electorate (because it does not include a tax increase). - Will gain the support of the Mayor and a strong majority of the City Council. - Recognizes the economic realities of our local marketplace and the NFL. Does not require "perfectly controlled laboratory conditions" to succeed. The mega-region San Diego anchors includes more than 10 million people, many of whom have decided keeping the Chargers is a priority. This report should signal to the team that it is time to focus on remaining in San Diego. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 I 1 GSAG For many reasons, including a commitment by the City and County to work with the team to resolve this issue, more progress has been made in the last 4 months than the last 12 years, when the Chargers first introduced plans for a new stadium. For the first time in a long time, a fair and workable plan is on the table, one that provides the Chargers with a clear path to remain in San Diego, which is what the team has repeatedly said it wants. Based on its research, experience, and meetings with numerous stadium builders and architects, the Citizens' Stadium Advisory Group has concluded a new multi-use stadium at the team's existing Mission Valley location would cost approximately $1.3 billion including land. This estimate includes: - $950 million for the stadium. - $204 million for structured parking and stadium-related infrastructure. • $180 million (the value of 60 acres of land from the City). The cost drops to $1.1 billion when the land value is backed out, and is based on construction starting no later than 2018. To pay for the proposed stadium, parking, stadium-related infrastructure and operations and maintenance, CSAG's financing plan includes 60 acres of land from the City of San Diego valued at $180 million, and more than a dozen funding sources that exceed $1.4 billion, including: $300 million from the Chargers $173 million in bondable construction capital from the team's rent. • $200 million from the NFL. • $121 million from the County of San Diego. • $121 million from the City of San Diego. • $225 million from the sale of 75 acres of land. •More than $100 million from fans, who would contribute through the purchase of Personal Seat Licenses (PSLs), and ticket and parking surcharges. CSAG's financing plan does not rely on tax revenues from development to pay for the stadium, structured parking or stadium-related infrastructure. Moreover, it does not include any new City general fund dollars. In addition to the stadium, structured parking and stadium-related infrastructure, CSAG's report outlines' million in estimated future infrastructure costs that wo. be necessary for the housing, shops, restaurants, and related development that could be built near the stadium. To cover these costs, CSAG recommends revenue streams that include $116 million from an Enhanced Infrastructure Financing District (EIFD), and $40 million from Transient Occupancy Tax (TOT) gained from the construction of a new hotel. CSAG recommends the following for the existing 166-acre Mission Valley site: • 60 acres of City-owned land be used for the new stadium, parking and a fan plaza. •31 acres be carved out to expand a restored and enhanced San Diego River Park. • 75 acres be sold to a developer. CSAG recommends the tax revenue from the 75-acre development should pay for community benefits (including parks, additional parking, road and transit upgrades), and to help the City and County recoup its capital costs. Under CSAG's stadium proposal, the Chargers would earn many millions of dollars more a year, and the City and the County also stand to benefit. It has been an honor for CSAG to have played a role in jump-starting this process. The committee looks forward to a successful outcome that keeps the Chargers in San Diego, playing NFL football in a new state-of-the-art multi-use stadium that also hosts San Diego State University, the Holiday and Poinsettia Bowls, and numerous events that benefit our mega-region. CSAG's financing plan exceeds anticipated costs: $1.48 31.E 11 $1.113* 1.011 Stadium Cost CSAG Financing Plan *Not including land from the City valued at 3.180 million. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 12 Summary of CSAG's Work CSAG Summary of CSAG's Work Building a fair and workable financing plan to serve as the blueprint for negotiations began with research, and it was research that drove CSAG's decisions. In less than four months, CSAG met with Chargers' representatives, NFL executives, fan groups (including Save Our Bolts, Bolt Pride, and the San Diego Stadium Coalition), Chargers alumni, and other stakeholders, including representatives with the County of San Diego, San Diego State University, and the San Diego Bowl Game Association. The committee also met with labor groups and developers, as well as stadium architects, including New York-based MEIS and Dallas-based HKS Architects. At CSAG's request, MEIS designed artist renderings of a new multi-use stadium in Mission Valley. Stadium design veteran Dan Meis, FAIA, is the Founder and Managing Principal at MEIS. He was the lead designer for the Staples Center in Los Angeles and two existing NFL stadiums—Paul Brown Stadium in Cincinnati and Lincoln Financial Field in Philadelphia. MEIS currently is working on renovations at Paul Brown Stadium and designing a new 60,000-seat soccer stadium in Rome, Italy called "Stadio Della Roma" that includes a mixed-use entertainment village similar to "LA Live" at Staples Center. HKS Architects designed AT&T Stadium in Dallas and Lucas Oil Stadium in Indianapolis. HKS also is designing the stadium under construction in Minneapolis, Minnesota for the Vikings, as well as the proposed NFL stadium planned for Inglewood, California. CSAG also consulted with Clark Construction Group, one of three companies that built Petco Park, home of the San Diego Padres; AECOM, which designed numerous sports stadiums, including CenturyLink Field, home to the Seattle Seahawks; Turner Construction Company, which constructed Levi's Stadium, home to the San Francisco 49ers; and numerous investors interested in financing a new stadium in San Diego. CSAG was self-funded. It received no contributions from outside the ninemember group and no funding from the City of San Diego. It paid for all of its expenses, including a public forum it hosted, and for the services of a communications professional. The committee did receive a tremendous amount of support and information, including new plans and designs, from San Diego's business community, which was instrumental to CSAG's work The City Attorney was the only individual who declined an invitation to meet privately with the committee, and recommended that CSAG not meet with the consultants the City and County retained to vet CSAG's financial report. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 3 o ne Selection GSM Site Selection Given the accelerated timeline the NFL and the Chargers established, the Mission Valley site emerged as the only option that leads to a ribbon cutting ceremony at a new stadium before the end of the decade. Mission Valley The current Mission Valley site, home to Qualcomm Stadium, holds a great deal of appeal from a financial standpoint due to the fact that the City and the City's Water Department own the land. The land, which is already zoned for a stadium, fast tracks the region's ability to retain the Chargers, with estimates the site could be shovel-ready by 2017 and built within 30 to 36 months. The proposed stadium CSAG recommends includes a modern and efficient design and a smaller footprint than the existing stadium, and the area around it has tremendous potential. It includes plans to restore and enhance the San Diego River Park. Improvements could include opening the river to walking and biking paths, transforming a grossly underutilized Mission Valley site into an iconic destination recognized around the world. The path to a new multi-use venue in San Diego exists largely With an existing trolley stop at the stadium, the site is transit-friendly and offers better parking and tailgating opportunities than the Downtown location CS A 1because of Mission Valley. analyzed. It is two trolley stops away from San Diego State University, treat strong partnership opportunities with a university that hosts its football games at Qualcomm Stadium. With 166 acres, the Mission Valley site is expected to become a year-round destination for fans, residents and tourists that could include a sports museum, an entertainment district, a river park, and other attractions people want to visit. There also is room r 143 to grow because the City owns 45 adjacent acres. The site is expected to generate tax revenues to pay for public facilities that provide community benefits including, but not limited to, parking and transit facilities, parks and infrastructure upgrades. The revenues also would generate income for the City and County to help recoup its capital investments. It is estimated the development would include a hotel, meaning TOT funds would be available. Once all phases are complete, the developed property, excluding thc\ stadium, could be worth $3 to $4 billion based on CSAG's research. A proposed San Diego River Park sketch drafted by Rick Engineering. • .16,4"t ' • Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 14 CSAG Support for Mission Valley The potential of the existing Mission Valley location has not been lost on the Chargers. Over the years, the team has aggressively campaigned for the site. "Redeveloping the site makes a lot of sense," the Chargers wrote in 2003. "The site can be transformed from an empty parking lot into a unique and vibrant new community that rivals the best in the world." The team added: "One hundred acres of asphalt surrounds Qualcomm stadium. For 350 days a year, this parking lot remains largely unused. The Chargers' concept turns it into a vibrant village with parks, condominiums and shops. Putting homes on transportation corridors is a top priority for this region. The Chargers' concept embraces that notion and envisions affordable and market rate homes with an easy walk to the trolley station, which, by the way, is built specifically to handle the large crowds generated by a stadium." In October 2013, U-T San Diego columnist Nick Canepa wrote: "The drawing board for a new stadium in Mission Valley never was taken down. So the Chargers are going back to it."3 The Mission Valley site is home to Qualcomm Stadium. The Chargers are quoted in Mr. Canepa's column as saying: "The Qualcomm site drawing board always was there. Now that the economic and housing issues have improved, redeveloping the Qualcomm site is something we're discussing with our development partner (Colony Capital) as something of interest. A major international company, which I can't name now, also is interested in partnering with us for stadium naming rights. The site is perfect for private development, for building an urban village."' This past February, when the Chargers met with the CSAG, the team described its site preference as "agnostic" and said it would be happy with a workable plan for either Mission Valley or Downtown. In an interview last month, the Chargers said: "If you can finance the stadium in a way that is acceptable to the public and the Chargers, then it doesn't matter where it is. People are going to come to the games, no matter where they are."' CSAG agrees financing a new multi-use stadium plays the most important role in the reality of its implementation, and Mission Valley is a key driver behind the fair and workable financing plan CSAG developed. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18.2015 1 5 CSAG Downtown If one were to move the proposed Mission Valley stadium Downtown, where the City does not own any land for a stadium, it would increase hard costs by at least a quarter billion dollars. The City would have to buy multiple parcels of land and pay to relocate and clean a large bus yard, a process expected to take up to 7 years. CSAG recognizes Downtown, at first glance, is an appealing location for a new stadium, but a close examination of the site reveals numerous problems that make it unworkable. Multiple parcels would have to be purchased, which could lead to eminent domain issues and years of litigation, on top of uncertain real estate costs. "It's hard to assemble even 20 acres downtown...and the land east of Petco is both expensive and already occupied," the Chargers said in 2009.6 In April 2014, the Chargers were quoted extensively in a U-T San Diego story about the team's renewed optimism fc stadium at either location—Mission Valley or Downtow,... That story is headlined: "Chargers eye 2016 ballot measure,"12 and was published months after Rams owner Stan Kroenke purchased land for his proposed stadium in Los Angeles. The article says "a working scenario would see a roughly $1 billion stadium proposal go before voters in the November 2016 Presidential General Election. The Spanos family and investment partners would put up roughly $400 million and seek a $200 million loan from the NFL."" The Chargers are quoted as saying: "We hope that our ongoing meetings with the Mayor's staff will result in another proposal that can work for the city, the Chargers, and ultimately, the voters."14 CSAG told the Chargers and the NFL that if the team was set on Downtown the committee would work to make it happen if the Chargers bought the land needed for a new stadium and extended its lease at Qualcomm Stadium. Relocating the Metropolitan Transit System's (MTS) bus yard is one of the difficult and expensive steps that would be required to try and piece together enough land for a Downtown stadium. In a February 2015 letter to CSAG Chairman Adam Day, MTS CEO Paul Jablonski said the relocation would take five to seven years and cost up to $150 million.' For CSAG, the Downtown plan eventually became a non-starter because it relies on a tax increase of at least $600 million' that would require support from two-thirds of the voters. Numerous polls have shown San Diego voters would soundly reject such a tax increase.9 The Chargers have proposed the City sell the Qualcomm and Sport Arena sites to a developer in order to raise money to purchase land Downtown.i° The selloff would require a public vote, the outcome of which is far from certain. Additionally, a SurveyUSA poll taken in January 2015 found San Diegans prefer the existing Mission Valley site over Downtown by a margin greater than 2 to 1." Other problems regarding the Downtown site include: lack of developable land; extremely limited tailgating options; issues with nearby residents; and complications surrounding the purchase of Tailgate Park land from the California Department of Finance. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 6 San Diego Stadium Assessment CSAG San Diego Stadium Assessment The Chargers are supported by a fiercely loyal fan base, and the team has an organic reach that is easy to see, especially on gamedays. The Chargers bring San Diegans together. Save our Bolts Against the backdrop of the stadium tug-of-war with Los Angeles, ongoing contract issues with the team's franchise quarterback, one playoff appearance in the last five years, and a 2015 decision by the league to lift TV blackouts, one would not expect an uptick in season ticket sales. But fans are rallying around the Chargers. "Based on new season-ticket sales and season-ticket renewal numbers, we are approximately 4,500 season tickets ahead of last year's pace," the team said in early May.15 So why has a stadium solution not surfaced until now? Why is this time different? The stadium issue in San Diego has been around for more than a decade. The Chargers first introduced a plan for a new stadium 12 years ago, following a letter the team sent to Mayor Dick Murphy in 2002 expressing concerns about its viability in the existing facility. The team's stadium pursuits included several concepts at numerous sites, including Mission Valley and Downtown. It is not accurate to suggest any one person, group, or issue thwarted the team's efforts. Multiple factors played a role, including the infamous "ticket guarantee" between the City and the Chargers, which cost San Diego taxpayers tens of millions of dollars and was not lifted until the 2004 season. This adversely affected the political climate for a new stadium at City Hall. City leaders then faced a $2 billion pension deficit that nearly bankrupted the City.16 The pension crisis was resolved, but the real estate collapse hit San Diego hard, as did the Great Recession. LA Threat Surfaces In the latter half of 2014, speculation about the Chargers potentially moving to Los Angeles began.17 The rumors became reality in February 2015, less than a month after Mayor Faulconer announced the formation of CSAG and his pledge to resolve San Diego's stadium issue. The mayor shared these messages during his first State of the City. At the time, he was in office 10 months. On February 20th of this year, the Chargers announced plans for a joint stadium with the Oakland Raiders in Carson, California. The news came as a surprise to everyone in San Diego. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 7 San Diego Stadium Assessment CSAG According to NFL bylaws, any team that wants to relocate needs the support of two-thirds of the league's owners, or 24 of 32 NFL franchises.18 The owners NI to know what has been done to build a new stadium in the existing market, what's being planned, and whether that market can sustain a franchise well into the future. Faced with multiple proposals by NFL teams interested in moving to Los Angeles, the league formed the "Committee on Los Angeles Opportunities" earlier this year. The committee is made up of six NFL owners tasked with analyzing stadium plans from existing markets and for L.A. League executives have told CSAG that members of its group and City representatives would likely be invited to present to the Committee on Los Angeles Opportunities this summer. The Chargers have not filed for relocation with the league, but the team has said it would be forced to do so if either the St. Louis Rams or the Oakland Raiders file for relocation.'9 Rams owner Stan Kroenke is proposing a privately funded stadium in Inglewood, California that would be capable of housing two home teams. The Chargers have not released the financing plan for Carson but have said the stadium would be privately financed and based primarily on a record number of sales of PSLs. The team also has said its financing plan would remain viable if the Raiders work out a deal to remain in Oakland.2° rr. 6.1111.11IF DV TIE DIIIKFFIC4 0.4110 " San Diego Responds In San Diego, the Chargers met with CSAG in February, and joined an April meeting with members of CSAG and NFL Executive Vice President Eric Grubman. The Chargers also built a website for CSAG and stocked it primarily with public information. While unsettling to many Chargers' fans, the efforts to bring NFL football back to L.A. galvanized San Diego. The past became the past, San Diego dug in, and a massive regional effort surfaced. The hashtag #SaveOurBolts become ubiquitous. Rallies were held. Sports talk radio lit up. News coverage of the stadium issue moved from random to constant, and from the sports page to the front page. San Diego is engaged, and the timing could not be better. The political will exists to see this project through, and the City and County are on solid financial footing. Those reasons, and others, make this time different. Numerous people and organizations deserve credit, including former Chargers and fan groups who represent tens of thousands of people, many of whom have donated time and money to keep the Chargers in San Diego. The team has been here for 54 years, and CSAG and many others want to ensure the San Diego Chargers are a member of the NFL family indefinitely. One of CSAG's goals was to present a plan that would improve the Chargers' finances. The team has been open about its struggles to remain competitive teams who earn more money largely because they play in newer stadiums dial generate more revenue than Qualcomm Stadium, which was built 48 years ago. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 18 San Diego Stadium Assessment CSAG The Chargers have said they want to share in the costs of a new municipally-owned stadium in San Diego. The team, however, does not want the public's share to rely on development because of the time it would take for those revenues to be realized. Mr. Grubman relayed a similar message when he met with CSAG, encouraging the committee to eliminate the risk if its financing plan included mixed-use development. CSAG agrees there are better and faster approaches to financing a stadium, which is why its plan does not rely on tax revenues from development to pay for the stadium. The committee, however, was careful not to limit potential options while crafting its financing plan. It heard from numerous developers and private investors who want to fund all or part of the Mission Valley project. CSAG referred these requests to the City The landscape in San Diego is essentially risk-free. This is the team's home, and a plan now exists to keep them here—in a world-class region. "The San Diego region is thriving and growing," according to an April 11 commentary in U-T San Diego written by members of the Strategic Roundtable, 32 retired executives and longtime San Diego civic leaders. "San Diego has the highest percentage of 18-35 year olds in the United States, and has three strong economic drivers — innovation, military, tourism — that are growing jobs across the county." "Chargers fans come to San Diego from the surrounding mega-region, which includes Tijuana (population 3 million), south Orange County (population 3 million) and parts of Riverside (population 2 million). Combined, we draw fans from a population of more than 10 million people. We have an economically sustainable region that will continue to support the NFL, including future Super Bowls, as much as it has for the past 54 years."2' America's 8th largest city, San Diego is home to 1.3 million residents, and San Diego County is home to 3.3 million residents. The County's population grew by 41,000 in 2013; only three other counties across the United States added more residents that year.22 Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 9 Costs CSAG Costs How much would the new municipally-owned stadium cost? In determining the probable cost of a new stadium in Mission Valley, CSAG noted that since 2009 no NFL stadium project has cost less than $1 billion. CSAG researched the cost of recently constructed stadiums and reviewed the following estimates for stadium construction: Two estimates from Clark Construction Group for construction of two Los Angeles stadiums that were not built. An estimate from Turner Construction Company for a stadium on the existing Mission Valley site. An estimate by CB Urban Development and Rider Levett Bucknall for a stadium on the existing Mission Valley site.23 A stadium-only estimate prepared by Cumming Construction to evaluate the feasibility of a combined Convention Center/Stadium facility. The Mission Valley Stadium Private Financing Proposal prepared by the San Diego Stadium Cooperative Coalition. In evaluating the above information, CSAG had to make adjustments for estimate inclusions and exclusions to determine the most likely probable cost for a new stadium, including parking and related stadium infrastructure costs. Assuming the stadium will contain approximately 1,650,000 square-feet of gross area and 65,000 seats, with room for 72,000 seats for Super Bowls and College Football Championship Games, the probable cost of a new facility — including land, parking and stadium-related infrastructure — is estimated at $1.33 billion. With the land backed out, the cost drops to $1.15 billion and is based on a construction start no later than 2018. It is worth noting that the six most recent NFL stadiums opened or under construction "would cost an average of $1.5 billion dollars if constructed in Southern California," according to a report released in April, 2015 by the National University System for Policy Research!- The average includes four extremely high-end stadiums in San Francisco, Atlanta, New York and Dallas, each of which includes extravagant expenses covered by the team and not the public. While the probable cost estimate of the proposed stadium in San Diego is lower than the $1.5 billion average cost of the most recent premium NFL stadiums, a downward adjustment was made since the proposed stadium would be open air as opposed to covered. Additionally, transit facilities and other infrastructure that would be necessary to support a 65,000-seat stadium are already in place in Mission Valley. The proposed San Diego stadium MEIS designed CSAG at the Mission Valley site includes a "canopy, not a roof, to shade much of the seating bowl, and ensure a home field advantage by keeping crowd noise close to the field. MEIS and other architects who have designed NFL stadiums told CSAG a stadium in Mission Valley would very likely be constructed to take advantage of San Diego's wonderful year-round climate, meaning it would include ample design features that lower construction and operational costs, and let in natural breezes and sunlight. There are roof options for the City, County and Chargers to consider, but CSAG recommends that a roof not be included because it would add roughly $150 million to the project with negative returns anticipated for the investment. The project as proposed would include land valued at $180 million ($3 million an acre for 60 acres) from the City of San Diego, $204 million in stadium-related infrastructure and parking, and $950 million for the stadium itself. The cost is all-inclusive and covers design, construction, permits, contingency, testing, inspection and financing also uses a Design-Build delivery system to ensure relit.. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May18, 2015 110 Costs CSAG cost containment. CSAG recommends that the stadium be an open-air multi-use facility in comparable quality and amenities as other recent outdoor NFL The projected $204 million of infrastructure includes $144 million for a 12,000-vehicle parking structure and $60 million in stadium-related infrastructure costs, including entry/ exit improvements, and general site preparation such as utilities, earthwork and tailgate facilities. CSAG received two estimates for infrastructure costs.2526 After accounting for structured parking and stadium-related infrastructure, which is paid for in the core financing plan, there was an additional $144 million in future infrastructure costs for community amenities to support ancillary development, including general site preparation, utilities, earthwork, sidewalks, lighting, traffic enhancements, and parking. CSAG envisions these costs being paid by using an EIFD (a new statewide tool to help finance needed infrastructure and development projects) and TOT on a new 500-room hotel. By using these tools, the value of the 75 acres of land to be sold by the City will be increased, providing additional revenues to fund the stadium and further minimizing the impact to the City's General Fund. "The canopy would not only enhance the fan experience, but also would contribute to the stadium's state-of-the-art TV broadcast capabilities by reducing glare and shadows and providing for optimal distribution of field lighting and stadium audio," said stadium design veteran, Dan Meis. Conceptual renderings by MEIS showing the exterior (above) and interior (middle) of the new stadium. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May IS, 2015 111 Financing CSAG Financing Paying for the new $1.33 billion* municipallyowned stadium and operations and maintenance CSAG recommends the following funding sources to pay for the stadium ($950M), structured parking, and stadiumrelated infrastructure ($204M), or $1.15 billion in costs. CSAG assembled more than $1.4 billion in funding recommendations. Determining the public-private split of the costs is one of the issues that will be resolved during upcoming negotiations between the Chargers, the City and the County, Chargers $300M NFL $200M City Stadium Fund $121M** ($7M/year over 30 years***) County Stadium Fund $121M** ($7M/year over 30 years***) Personal Seat Licenses (PSLs) $60M ($120M total split evenly with Chargers) Chargers Rent $173M ($10M per season) or 30 years*** SDSU Annual Rent $21.6M ($1.25M/year) over 30 years*** Bowl Games Rent $21.6M ($1.25M/year) over 30 years* Developer Purchase (sale of 75 acres at $3 million an acre) $225M Ticket Surcharge $84.7M ($4.75M/year) over 30 years*** Chargers Parking & Surcharge $26M ($1.5M/year) over 30 years*** Additional funding sources stadium $50M over 30 years*** is expected to generate Total mmended Revenues S th Billion *Includes City land valued at $180 million. **No new taxes. ***Net Present Value based upon 4% discount rate over 30 years. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 112 Financing Chargers/NFL Twelve years ago, the Chargers offered to pay $200 million, or half the cost of a new stadium in Mission Valley. Since that time, due to inflation and significant design changes, stadium costs have soared. Based on CSAG's analysis and information from the Chargers, CSAG believes the Chargers can contribute $300 million, backfilled by new and increased revenues explained on page 16 of this report. The NFL has said the league would be willing to contribute $200 million to build a new stadium in San Diego. City/County CSAG discussed the recommended funding sources with City and County leaders. The City currently pays approximately $10 million a year to operate Qualcomm Stadium, including $4.8 million in annual debt service for Qualcomm. The total remaining debt service is $52 million and set to expire in 2026.27 CSAG has outlined more than $1.4 billion in funding sources to pay for a new stadium costing roughly $1.1 billion excluding land, and therefore recommends the City retire 100 percent of its Qualcomm stadium debt before the new stadium opens. With proper third-party management, the expectation is the new stadium would break even, at a minimum, therefore the City would no longer be required to subsidize the operations of the stadium as it currently does. Additionally, with the Qualcomm Stadium debt paid off, the City would not need to spend millions of dollars a year to retire that obligation. CSAG recommends that a portion ($7 million a year) of the City's savings be used to contribute toward financing the new stadium. The County's stadium sub-committee has assured CSAG it would partner with the City on financing, which is why CSAG recommends the County also contribute a minimum of $7 million a year, or a lump sum payment of at least $121 million. PSLs While some have questioned San Diego's ability to sell a substantial amount of PSLs, the National University System Institute for Policy Research suggests that "San Diegans would likely support between $100 and $150 million in PSLs."" CSAG In April, Mr. Grubman, the NFL's Executive Vice President, suggested to CSAG a figure of $150 million for PSL sales in San Diego, with half going to the Chargers as part of the team's financial contribution for the new stadium. CSAG estimates $120 million in PSLs would be sold, half of which would help fund the public's share of the stadium. The other half would help the Chargers backfill its share of construction costs. The Minnesota Vikings expect to sell $125 million in PSLs for a new stadium scheduled to open next year.29 Chargers Rent The Chargers current rental agreement with the City of San Diego states that the team must pay "$2.5 million for each Regular Football Season beginning with the 2004 Regular Football Season; $3 million for each Regular Football Season beginning with the 2014 Regular Football Season through and including the 2016 Regular Football Season; and, $4 million for each Regular Football Season through and including the 2020 Regular Football Season,"3° when the lease is set to expire. "The team's property taxes, some parking revenues, and the City's suite at Qualcomm" all count against what the Chargers pay, bringing the total to approximately $1 million a year. Additionally, "the Chargers annual payment due to the City gets eaten away by a series of rent credits, which drastically reduces the team's bill. The City also pays the team each year as part of a settlement to a 2006 American with Disabilities Act lawsuit at Qualcomm."31 Rents across the league range and some are tied to concessions, parking and other revenue, so it is difficult to do an apples to apples comparison. The San Francisco 49ers are at the high end, paying $24.5 million annually in rent." In Minneapolis, the Vikings will be responsible for $13 million in annual stadium costs at the stadium under construction, with $8.5 earmarked as rent, which climbs 3 percent a year until reaching $20 million in Year 30.3' Based on comparable stadium costs and rent payments, CSAG recommends the Chargers pay rent of $1 million a game, or $10 million a year in Year One, with 3% annual increases for 30 years. One million dollars per game is less than 10 percent of the expected gross revenues the team would earn on game days in the new stadium. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 113 Financing CSAG Rent From SDSU & Bowl Games Chargers Parking & Surcharge San Diego State University's (SDSU) current contract with the City of San Diego expires after the last game of the 2018 season. Retaining SDSU as a tenant in the new facility would be both beneficial for the City, in helping to recoup costs, and for the University, providing SDSU's Division 1 football program with a premier state-of-the-art space to showcase its football team. Based on a 12,000 parking-space structure and 10 games a season, with an average of $25 a spot, parking for Chargers games would generate $3 million a year in addition to $360,000 annually from a surcharge of $3 per vehicle. CSAG recommends $1.5 million of this annual revenue be bonded against for construction costs. Additional Funding Sources CSAG recommends that an annual rent of $1.25 million for 30 years ($21.6M) is charged to SDSU. Similarly, CSAG recommends that an annual rent of $1.25 million for 30 years 421.64 is charged to the San Diego Bowl Game Association. CSAG met with officials from SDSU and the San Diego Bowl Game Association on several occasions, and they assured CSAG they want to be a part of San Diego's stadium solution. Ultimately, contributions from SDSU and the San Diego Bowl Game Association will be based on negotiations or market rate lease agreements and cover access to signage, premium areas, suites, locker rooms, etc. during their games/events. CSAG has identified other revenue opportunities that have been used to pay for the cost of new NFL stadiums. It anticipates these sources would be able to raise and/or contribute in excess of $50 million over a 30-year period. Among these items are the sale of seats from Qualcomm Stadium; sales of bricks and/or other recognition elements in the new stadium; naming rights within the stadium (not including suite or club level seating); capital contributions from concession vendors; and infrastructure support from sponsor participation, including non-alcoholic pouring rights, alcohol vendor support, and telecommunication companies support of services including Wi-Fi. CSAG also researched the option to pursue "crowd fund' and believes there is an ability to raise funds similar to approach the Green Bay Packers successfully used.35 Developer Purchase The local development community supports CSAG's estimate that 75 acres of the stadium site could be sold for $3 million an acre for a total of $225 million.34 Ticket Surcharge CSAG recommends a surcharge of $5 be placed on Chargers tickets (roughly 650,000 attendees a year). CSAG also recommends a ticket surcharge of $2 for all other events at the stadium (roughly 750,000 attendees a year). Other NFL stadiums, including AT&T Stadium, CenturyLink Field, and Lucas Oil Stadium, charge as much as 10 percent in ticket surcharges. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 14 Non-Stadium Financing CSAG Non-Stadium Financing Financing future infrastructure costs and creating revenue streams to help the City and County recoup capital costs and pay for operations and maintenance. The committee settled on the following funding sources to cover future non-stadium related infrastructure costs ($144 million), and provide longterm revenue streams for the City and County. Enhanced Infrastructure Financing District (EIFD) $116M for 30 years or $5.5M annually Transient Occupancy Tax (TOT) — 500-room hotel • • Non-Chargers event parking and surcharge • Concessions from Non-Chargers events $40M for 30 years or $2.3M a year (10.5% TOT, 500-room hotel) $3M a year .......... $1M a year Enhanced Infrastructure Financing District (EIFD) Through the creation of an EIFD, CSAG believes the City and County, working with planners and developers, can ensure long-term revenue streams are opened from the 75 acres of land CSAG is recommending the City sell to a developer. These revenues would pay for public facilities that provide community benefits including, but not limited to, parking and transit facilities, parks, and infrastructure upgrades. The revenues also would generate income for the City and County to help recoup its capital investments. Based on a low- to mid-rise mixed-use village concept consisting of 3,300 housing units, 1 million square feet of commercial space, 175,000 square feet of retail space, and a 500-room hotel, the tax increment available at market stabilization would conservatively yield $5.5 million annually, resulting in roughly $116 million in net present value based on a 30-year term and a 4% discount rate.36 Real estate markets change and CSAG realizes what makes sense today may not be what is best several years down the road when site development is in full swing. CSAG would encourage government leaders and planners to be flexible, in order to ensure the development maximizes land value, generates sufficient tax revenues to cover capital investments, and ensures the community's needs are met. Transient Occupancy Tax (TOT) TOT is a fee accrued as a portion of the total booking cost from a hotel or motel room. It is estimated that a 500-room hotel could be built as part of a future mixed-use development adjacent to the stadium. Based on market comparisons of Mission Valley hotels with an Average Daily Rate of $159, and assuming an occupancy rate of 75%, a 10.5% TOT rate would yield $2.3 million per year, with a net present value over 30 years of roughly $40 million. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego May 18, 2015 115 Revelaue Otmununiti es: Chargers CSAG Revenue Opportunities: Chargers Revenue streams at the new stadium for the Chargers Recouping the Chargers' construction costs through new and enhanced revenue streams. Stadium naming rights $135M to $165M (over 20 years)* Naming rights at existing stadium while new stadium is under construction $15M (over 3 years) Personal Seat Licenses (PSLs) $60A. Other $25M annually *Net Present Value based upon 4% discount rate. Naming rights at the new stadium in Mission Valley are expected to range between $10 million and $12 million a year, according to CSAG's research. In addition to naming rights and PSLs, CSAG identified approximately $25 million in annual increases in team revenues from the use of a new stadium from the following sources: • Increased general admission tickets pricing Increased concession sales at Chargers' games • Increased premiums charged for club and special seating • Increased premium charged for suite seating • Ability to secure a premium suite waiver for 10 years • Increased merchandise sales • Increased signage and advertising • Naming rights to club and suite levels • Revenue from hosting a small number of events other than Chargers games Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 16 Revenue Oppon unities: CIN .0 unry CSAG Revenue Opportunities: City/County Opportunities at new stadium for the City and the County Other than a small number of events hosted by the Chargers, the proposed multi-use stadium is expected to operate on a year-round basis and host in excess of 200 events, from Super Bowls to corporate events, generating revenue for the City and County for operations and maintenance costs. It is acknowledged that the NFL is provided all revenue streams and a rent-free facility for a Super Bowl, and therefore no direct revenue can be attributed to that event. The playing field at the new stadium should accommodate the needs of professional football as the home field for the San Diego Chargers and NFL events, including the Super Bowl and Pro Bowl. The field also should accommodate collegiate football as the home field for the San Diego State University Aztecs, as well as the Holiday Bowl and Poinsettia Bowl. The facility also should accommodate the San Diego regional California Interscholastic Federation (CIF) High School football playoffs and championships. Additional field sport uses should be accommodated, including soccer, rugby, and lacrosse. The floor area should be able to accommodate large outdoor events, including motor sports, concerts, music festivals, and monster truck jams. When HKS Architects met with CSAG, it said AT&T Stadium in suburban Dallas, which HKS designed, has become a revenue-generating machine. A little more than half of the stadium's revenues, HKS said, are generated from 3-day rodeos, rock concerts, and other events besides Dallas Cowboy games. MEIS rendering. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 117 GSM- Revenue Streams In San Diego, the stadium would be expected to host: College Football Championships International Soccer/MLS Expansion Opening kickoff game for NCAA/ season Special in-season collegiate games Monster Truck Jams Motocross/Supercross Concerts Private events'. Bar Mitzvahs; weddings; corporate events; proms; reunions Bars; breweries; restaurants open 365 days a year Music festivals RFP for rideshare company (Uber/ Lyft) to have game-day pickup/drop off zone in front of the stadium. CIF championships Tours of facility Film showings Movie, TV and Commercial shoots Broadcast NFL draft and away games Religious events Rodeos/Bull riding Events held at San Diego River Park Rugby D Rec Leagues D Youth sports » Concerts Bowling • Mountain Dew Tour/X Games • Dog Shows MMA, WWE, Boxing 5Ks,10Ks NCAA Championship Lacrosse • Fantasy sports drafts • Graduation ceremonies L College Football Championships I ,; liCertS Other map sporting elk like MLS soccer, Motocross, and boxing. 10k runs, graduations and other family events. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 18 Next Steps CSAG Next Steps Based on CSAG's extensive review process and thorough analysis of the issues at hand, it recommends negotiations between the City, County and the Chargers commence immediately. In addition, the outside financial experts retained by the City and County should simultaneously begin vetting CSAG's financing recommendations; work to determine the best way to complete the financing and retire the $52 million debt the City owes on Qualcomm Stadium before the new stadium opens; and take the City and County portion of the financing plan to the bond market once terms are agreed to. The City and County also should begin soliciting proposals from investors and developers to purchase the 75 acres at the Mission Valley site, as well as stadium architects and builders. Further, CSAG recommends that a Joint Powers Authority (JPA) be formed between the County and City to oversee development and ownership of the stadium. The City and County also should open negotiations with San Diego State University and the San Diego Bowl Game Association with the goal of securing long-term lease agreements for each organization. The City and County should request an opportunity to present San Diego's stadium plan to the Committee on Los Angeles Opportunities, and NFL Executive Vice President Eric Grubman. This meeting should be held well in advance of the NFL owners meeting in October 2015. Following the negotiations, the Chargers should launch and fund a citizens' initiative, like the team did this year in Carson, with the goal of gathering enough verified signatures and securing a City Council vote prior to the NFL owners meeting. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 119 rmai ort Jou, CSAG Final Recommendations Recommended terms for negotiations with the Chargers 1. The Chargers should sign a 30-year lease with the WA, and enter into a non-relocation agreement with the JPA. 2. The City and County should create a capital improvement fund for future maintenance and facility upgrades. 3. The City, County and Chargers should share the costs of operations and maintenance. These costs will rise over time so payments should be indexed to inflation. 4. The Chargers should assume the financial risks for naming rights. The team should also cover all construction overages and premium add-ons. 5. The City, County and Chargers should agree to draft a cooperative parking agreement with the owners of office towers in Mission Valley with parking lots that are largely vacant on nights and weekends. The idea would be for fans to park in these large office lots and receive a shuttle ride to and from Chargers games and other events. This service could continue to operate after stadium parking is constructed. It would give fans ample tailgating opportunities and thin out traffic around the stadium. Recommendations for the IPA 1. Explore parking options on the south side of the San Diego River to create additional parking and tailgating opportunities. 2. Work with State lawmakers on any environmental compliance issues that surface while also working with regional, state and federal agencies to secure any and all grants for transit, road/freeway work, and parks. 3. Hire a private stadium management company with a proven track record to manage the facility. For reasons outlined in this report, a path to a new multi-use stadium in San Diego exists. A collaborative effort is needed to build on the momentum San Diegans have created. CSAG would encourage everyone to put San Diego first. if we do, we will achieve greatness, and our new stadium will be a constant reminder of what we can achieve together. Special thanks to CSAG's spokesman, Tony Manolatos with Apex Strategies. Additional special thanks to reproHAUS for printing the report and to MEIS for creating the stadium renderings. The printing and renderings were done pro-bona. APEX strategies axpexstrat.com reproHAUS reprohaus.net MEIS meisarchitects.com Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 120 Endnotes CSAG Endnotes Links are active when viewed in Adobe Acrobat. 1. Mayor Kevin Faulconer. "Faulconer taps civic leaders, stadium and financial experts to develop plan to keep Chargers in San Diego." Press Release. 30 January, 2015. . 2. Fabiani, Mark. "Remarks to the Mayor's Stadium Task Force." 16 February, 2015. . 3. Canepa, Nick. "Qualcomm site still a new stadium option." U-T San Diego. 16 October, 2013. . 4. Canepa, Nick. "Qualcomm site still a new stadium option: U-T San Diego. 16 October, 2013. . 5. Fabiani, Mark. Interview by Scott Kaplan and Billy Ray Smith of the Mighty 1090 AM radio. "Mark Fabiani: we are eager to see CSAG's Plan...We've been cooperative" Mighty 1090. Web. 17 April, 2015. . 7. Jablonki, Paul C. Metropolitan Transit System letter to Adam Day. 20 February, 2015. . 8. JMl Real Estate. Presentation to CSAG. 3 March. 2015. . 9. Bauder, Don. "Poll: San Diegans do not want to subsidize a stadium." The San Diego Reader. 1 September, 2014. . 12. Walker, Mark. "Chargers eye 2016 ballot measure." U-T San Diego. 19 April, 2014. dittp://www.utsandiego.com/news/2014/apr/19/ chargers-eye-2016-stadium-ballot-measure/>. 13. Walker, Mark. "Chargers eye 2016 ballot measure." U-T San Diego. 19 April, 2014. . 14. Walker, Mark. "Chargers eye 2016 ballot measure." U-T San Diego. 19 April, 2014. . 15. Kaplan, Daniel. "Ticket Sales Mixed for NFL Teams Looking at LA Market." St. Louis Business Journal. Web. 5 May, 2015. . 16. "Pension troubles: A timeline." U-T San Diego. Web. 2009. dittp:// legacy.utsandiego.com/news/metro/pension/pensiontimeline.html >. 17. Togerson, Derek. "Carson Mayor on Chargers Stadium Site: "It's Contaminated Land." NBC San Diego. Web. 5 May, 2015. . 18. "Constitution and Bylaws." National Football League. 1 February, 1970 (2006 Rev.). . 19. Fabiani, Mark. Interview with Fox Sports San Diego. "Fabiani: You can survive (in San Diego) if you had a modern stadium deal." Fox Sports San Diego. Web. 23 April, 2015. . 20. M. Cavanaugh, et al. "Fabiani says Chargers not optimistic about Mission Valley." KPBS. 16 March, 2015. Web. . 23. Black. Charles. "San Diego Convention Center Phase III expansion report on development options." CB Urban Development. • Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 121 Endnotes 24. News and Notes: New Chargers Stadium likely to Cost More Than $700 Million." National University System for Policy Research. 7 April, 2015. . 25. Rice, Jeff. San Diego Stadium Cooperative Coalition. Presentation to CSAG. 21 April, 2015. . CSAG 35. Brennan, Matthew. Crowdfunding a loan for the new San Diego stadium. 12 May, 2015. . 36. Rice, Jeff. San Diego Stadium Cooperative Coalition. Presentation to CSAG. 21 April, 2015. . 26. A collaborative team from Urban Land Institute San Diego Tijuana District Council and the American Institute of Architects San Diego Chapter. Report to CSAG. 21 April, 2015. . and . 27. Lewis, Mary. Electronic Communication to Stephen Puetz. 23 January, 2015. San Diego Real Estate Assets. Web. . 28. "News and Notes: New Chargers Stadium likely to Cost More Than $700 Million." National University System for Policy Research. 7 April, 2015. . 29. Vikings.com, New Stadium Q&A, January 2015. 30. "1.5(b)(i) Payments to the City - Regular Football Season." Supplement Number Eight to the 1995 Agreement for Partial Use and Occupancy of San Diego Jack Murphy Stadium between Chargers Football Company, LLC And The City of San Diego. P.19 . 31. Dillon, Liam. "Fact Check: The City Pays the Chargers to Play at Qualcomm Stadium," Voice of San Diego. February 20, 2015. . 33. "8 Details you need to know about the new Vikings stadium agreement." Minnesota Vikings. Web. 8 October, 2013. . 34. Winckel, Borre. Building Industry Association of San Diego County letter to Whom It May Concern. 4 May, 2015. . Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 22 .m D. D. An Citizens' Stadium Advisory Li o..r;, —Bios CSAG Citizens' Stadium Advisory Group— Bios The Citizens' Stadium Advisory Group includes a Fortune 500 executive, a revered local government leader, a California State University Trustee, a former NFL and Chargers senior executive, and experts in the areas of finance, land use, real estate and construction of municipal stadiums. Meet the members of this well-rounded group: CITIZENS STADIUM ADVISORY GROUP liCSAG CITIZENS' STADIUM ADVISORY GROUP Doug Barnhart Chairman of Barnhart-Reese Construction Douglas E. Barnhart is a long-time resident of San Diego ant' civic and business leader. He is a San Diego County Plannin6 Commissioner and a past member of the Qualcomm Stadium Advisory Board. He has served as a board member for the Greater San Diego Chamber of Commerce, San Diego International Sports Council and past San Diego Super Bowl Committees. Mr. Barnhart's construction companies built, or helped build, many San Diego landmarks, including Petco Park, San Diego Lindbergh Field Terminal 2, the Douglas and Nancy Barnhart Cancer Center at Sharp Chula Vista, Tony Gwynn Stadium at San Diego State University, the SDSU Gateway/KPBS, dozens of K-12 schools, and the San Diego Chargers Training Facility and Offices. Rod Dammeyer Private Equity Investor Rod Dammeyer is chairman of CAC, a private company offering capital investment and management advisory services. He is a member of the boards of directors of Stericycle, Inc., and Quidel Corporation, in addition to being a trustee of Invesco Funds. A graduate of Kent State University, Mr. Dammeyer began his business career with Arthur Andersen & Co. where he became partner and chairman of its advisory council. He subsequently served as executive vice president and chief financial officer of two multi-billion dollar conglomerates, Northwest Industries, Inc. and Household International, Inc. From 1985 to 1995, he was CEO of Itel Corporation, which merged into Anixter International, a multibillion dollar wiring products value added reseller, in addition to serving as managing partner of Equity Group Corporate Investments until 2000. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 24 GSAG Adam Day California State University Trustee ePAssistant Tribal Manager of Sycuan Adam Day is a veteran public administration executive with extensive experience managing the efficient delivery of municipal services, government relations, community outreach, coalition development, and multi-million dollar charitable and media campaigns. Mr. Day is a California State University Trustee and directs government, public and community relations on behalf of the Sycuan Tribe and their affiliated business entities. Mr. Day brings nearly 12 years of experience at the County of San Diego as chief of staff and deputy chief of staff to various members of the Board of Supervisors. He played a significant role in shaping public policy at the local, state and federal levels on matters such as welfare reform, criminal justice, regional transportation planning and land use. He has served on dozens of boards and committees, including the Del Mar Fair Board appointed by Governors Arnold Schwarzenegger and Jerry Brown, the San Diego County Planning Commission and Century Club of San Diego. r Walt Ekard Former San Diego County CAO &former City of San Diego COO Walter F. Ekard is the former Chief Administrative Officer for the County of San Diego and former Chief Operating Officer for the City of San Diego. As the chief executive for the fifth largest county in the United States, Mr. Ekard managed a workforce of over 16,000 employees and an annual budget of $5 billion. Mr. Ekard was the Board of Supervisors' "first and only choice" for the job because of his experience and strong leadership skills. A native of San Diego County, Mr. Ekard received his Bachelor of Arts degree from San Diego State University and a Juris Doctor degree from the University of San Diego School of Law. Aimee Faucett COO of the San Diego Regional Chamber Aimee Faucett has served the communities of San Diego for 18 years while working in the legislative and executive branches of the City of San Diego and voluntarily serves on several nonprofit boards. Today she holds the position of Executive Vice President/Chief Operating Officer for the San Diego Regional Chamber. Prior to joining the San Diego Regional Chamber, Mrs. Faucett was the Deputy Chief of Staff to former Mayor Jerry Sanders and also served as Chief of Staff to former San Diego City Councilmembers Kevin L Faulconer and Jim Madaffer. Mrs. Faucett's community service includes serving on the board of directors for the Jacobs Cushman San Diego Food Bank, the American Red Cross San Diego/Imperial Counties Chapter and San Diego State Alumni Association. She is a graduate of San Diego State University and holds a bachelor's degree in Public Administration and is a recipient of the San Diego Business Journal's 2014 "Women Who Mean Business" Award. Jason Hughes President and CEO of Hughes.Marino Jason Hughes is President and CEO of the largest tenant representation company in San Diego and one of the premier commercial real estate companies in Southern California. Mr. Hughes has been a fixture in San Diego's commercial real estate industry for 26 years, and was appointed as Special Assistant for Real Estate Services to the City of San Diego in 2013. Mr. Hughes represents approximately three quarters of all corporate tenants downtown, and has negotiated some of the largest tenant lease, purchase and development transactions in the region. Over the years, Mr. Hughes has transacted leases and purchases for tens of millions of square feet, including a dozen downtown high-rise office building purchase and sale transactions, two downtown high-rise residential tower purchases, a development of a new office tower and one large hotel transaction. Jessie Knight Executive Vice President of Sempra Energy, Chairman of the Board of SDGe!E Jessie J. Knight is board chairman of San Diego Gas & Electric Co. (SDG&E); chairman of Southern California Gas Co. (SoCalGas), an affiliate of SDG&E; and executive vice president of external affairs for Sempra Energy. Before joining Sempra Energy in 2006, Mr. Knight served for seven years as president and chief executive officer of the San Diego Regional Chamber of Commerce. Mary Lydon Executive Director of the Urban Land Institute - San Diego-Tijuana Mary Lydon is an expert in smart growth, • 'L land-use planning, real estate markets, community and stakeholder participation and economic development strategies. She has worked with private-sector developers, public-sector agencies and nonprofit organizations. Ms. Lydon is a former Planning Commissioner for the City of San Diego and has held other ab. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 25 t.itizerLs Mad Adv (1!;:7.,_ Bins CSAG leadership roles on several nonprofit boards over her career. Ms. Lydon attended Harvard University's Kennedy School of Government and completed the Executive Leadership Program in 2010. She also holds a bachelor's degree from the University of Wisconsin, Madison. ULI is an international nonprofit organization focused on research and education. ULI's focus is in developing leaders in the responsible use of land and promoting the creation of sustainable thriving communities worldwide. ULI is a member-based organization with 35,000 members globally. Jim Steeg Former NFL Executive and Chargers Executive Vice President Jim Steeg is a former National Football League executive and Chargers Executive Vice President who is credited with growing the Super Bowl from a championship football game into a four-day extravaganza. He has 36 years of experience with the NFL, 26 of those in charge of Super Bowls, where he worked in 70 major stadiums in the United States and around the world. Mr. Steeg's unique experience is marked by working successfully with the multiple constituencies involved in special events and sports management. He has developed a broad range of expertise in dealing with civic, financial and real estate leaders; business, government, college and professional sports, and entertainment; stadium architects; urban planners; traffic and transportation; police; security; and the media. Tony Manolatos CSAG's Spokesman Tony Manolatos is an experienced strategist specializing in media relations, crisis communications, community engagement, coalition building, government affairs and public policy. Manolatos has more than 15 years' experience, including a unique blend of public policy, politics and journalism, which shapes the planning of effective and creative strategies. Manolatos owns and operates Apex Strategies, a San Diego-based public affairs firm that services public agencies and officials, businesses, non-profits, and others. Prior to starting Apex Strategies, Manolatos served as a deputy chief of staff and communications director to Councilman Kevin Faulconer. Before that he worked as an investigative reporter at the San Diego Union-Tribune, capping an award winning journalism career that spanned more than a decade. Site Selection and Financing Han for New Multi-Use Stadium in San Diego I May 111, 2015 126 Key Dates GSAG Key Dates December 14, 2014: San Diego Mayor Kevin L. Faulconer writes NFL Commissioner Roger Goodell, requesting an opportunity to discuss the stadium issue in San Diego. January 14, 2015: During State of the City, Mayor Faulconer announces stadium issue will be resolved on his watch. January 30, 2015: Mayor Faulconer announces formation of Citizens' Stadium Advisory Group (CSAG). February 22, 2015: Chargers owner Dean Spanos and Mayor Faulconer meet and agree to move up CSAG's deadline to 90 days. March 2, 2015: CSAG holds public forum at Qualcomm Stadium that draws about 3,000 people, March 12, 2015: CSAG selects Mission Valley site over Downtown. March 19, 2015: CSAG chair Adam Day and member Aimee Faucett testify to the City Council's Economic Development Committee about the committee's progress and next steps. March 2015: Members of CSAG meet with the architects who designed AT&T stadium, Lucas Oil stadium, and are designing the stadium under construction in Minneapolis, as well as the one planned for Inglewood. CSAG members also meet with builder who built Levi's Stadium, and investors interested in funding a new stadium in San Diego. March 2015: CSAG members Mary Lydon, Jim Steeg and Jessie Knight assemble a team of designers and land use experts to look deeper into the development of Mission Valley and a new Chargers Stadium. Representatives with the San Diego River Park Foundation and Mission Valley Planning Group are a part of this team. March 2015 — Apri12015: CSAG meets with fan groups, including Save Our Bolts and Bolt Pride, Chargers alumni, and other stakeholders, including representatives with the County of San Diego and San Diego State University. The committee also meets with developers interested in the 166-acre Mission Valley site. March 26, 2015: Mayor Faulconer, City Attorney Jan Goldsmith, San Diego County Supervisors Dianne Jacob and Ron Roberts, and City Councilmembers Myrtle Cole and Scott Sherman announce a partnership between the City and County to work collaboratively and share consultant costs (up to $500,000) for a potential new stadium for the Chargers. The County Board of Supervisors and City Council each have since unanimously approved this expense. April 6, 2015: CSAG speaks with NFL Executive Vice President Eric Grubman in advance of his visit to San Diego on Apri114. Apri11.4, 2015: Mr. Grubman and Mark Fabiani met with CSAG's Adam Day, Jason Hughes, Jessie Knight, Walt Ekard, and Tony Manolatos in downtown San Diego. Mr. Grubman said CSAG and/or the City will be given the opportunity to present to the "Committee on Los Angeles Opportunities" made up of six NFL owners. That meeting will likely occur sometime this summer. April 20, 2015: City and County finalize contracts with investment firm, outside attorneys, and financial advisor to represent City/ County during negotiations with Chargers. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 127 Design Narrative CSAG Design Narrative Stadium has a 'California convertible' feel By Dan Meis San Diego's sunny and mild climate provided us with the opportunity to design a multi-purpose, state-of-the-art stadium that would be both unique in the NFL and a home field to the San Diego Chargers unmatched by any other stadium on the planet in its ability to be completely evocative of the environment of which it is born. The temperate climate allowed us to design a building that is far more open in nature. Concourses, club areas, lobbies—areas that are traditionally enclosed and electronically heated or cooled—can in this climate often be open air, or significantly less weather protected than in a northern climate. The ability to forego the facade wrapping that most stadiums of this size require reduces both the capital and operating cost of the venue, while enhancing the fan experience by providing a truly unique-to-SDiego venue. MEIS renderings. The natural landscape of San Diego became a critical part of the architecture with the integration of native species of trees and flowers providing a natural tie to the site. The defining design feature of the proposed stadium is a sun canopy we have dubbed "the Helios". Helios, the personification of the sun in Greek mythology, here is a fabric canopy employed specifically to shade the seating bowl from the San Diego sun while maintaining an open-to-the-sky, "California convertible" feel. The form of the canopy is derived from a sophisticated computer simulation of the sun angles throughout the seasons at this specific geographic location. The canopy provides an added benefit in acoustical enhancement, capturing crowd noise, and allowing for sound and lighting distribution, ensuring a raucous home-field advantage and state-of-the-art broadcast conditions. The steel, fabric, and cable structure MEIS designed are instantly evocative of the masts and rigging of the sailboats so identified with the San Diego lifestyle. The design is at once simple and instantly iconic. The shape of the seating bowl reflects the desired sideline orientation of the majority of seating and the best site lines in the NFL. Regular capacity of 65,000 seats is easily expanded to 72,000 for Super Bowls and other major events through the addition of temporary end zone seating sections. This design allows for one of the most cost-effective stadiums of its size in the world while providing a uniquely San Diego experience and an instantly recognizable, iconic addition to the region. Dan Meis is the founder and managing principal at MEIS, a New York-based stadium architecture and design firm. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 28 Design Narrative CSAG PAGES FROM MEIS REFERENCE PRESENTATION: SAN DIEGO CHARMS Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 129 t CSAG PAGES FROM MEIS REFERENCE PRESENTATION: SAN DIEGO CHARGERS NAUTICAL INSPIRED STRUCTURE MtI SAN DIEGO CHARGERS SOLAR PATH .f SUN SHADING DIAGRAM FOR CANOPY DESIGN Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 130 Design Narrative CSAG PAGES FROM MEIS REFERENCE PRESENTATION: SAN DIEGO CHARMS OPEN AIR CONCOURSES MEIS Site Selection and Financing Plan for New Multi-Use Stadium in San Diego J May 18, 2015 131 CSAG PAGES FROM MEIS REFERENCE PRESENTATION: SAN DIEGO CHARGERS VISUAL CONNECTION & VIEWS DOT MEIS Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 132 Uesivn Narrailt“ CSAG PAGES FROM MEIS REFERENCE PRESENTATION: Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 133 Design Narrative CSAG PAGES FROM MEIS REFERENCE PRESENTATION: SAN DIN O CHARGERS EllWL MULTI-USA _ SOCCER Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 134 CSAG National Stadium Assessment In developing a fair and workable financing plan to jump-start negotiations between the City, County and Chargers, CSAG examined financing plans for several NFL stadiums, zeroing in on seven projects for the purposes of this report. Four of the seven stadiums opened within the last 10 years—Lucas Oil Stadium in Indianapolis, AT&T Stadium in Dallas, MetLife Stadium in New York, and Levi's Stadium in Santa Clara. Two others are under construction, one in Minnesota and the other in Atlanta. And one, in St. Louis, was recently proposed. CSAG received cost assessments from the NFL in April 20151 for six of the stadiums, and relied on a recent news report' highlighting the proposed stadium in St. Louis. Stadium . Year Opened Total ant rStadium Lona Sivport 07,:i Intnzttrurnire) Minnesota Stadium Proposed: 2017 . . Proposed. 2016 Estimated - $1.4 Billion , . Estimated - $1.07 Billion Levi's Stadium 2014 $1.3 Billion MetLife Stadium 2010 $1.6 Billion AT&T Stadium 2009 $1.3 Billion Lucas Oil Stadium 2008 $720 Million St. Louis Proposed n/a Estimated - $1 Billion Atlanta Proposed The financing models used to pay for the stadiums relied on a mix of public and privately financed bonds, paid back through revenue accrued from PSLs, tenant rental agreements, concessions, TOT, and naming rights, among other locationspecific sources of revenue. 1 2 "Publicly-available news articles." Young, Virginia. "Study: State would see payoff from building stadium for Rams." St. Louis Today. Web. March 9, 2015. cht-tp://www.stltoday.cominews/local/govt-and-politics/study-state-wouldsee-payoff-from-building-stadium-for-rams/article_2edfa1b8-7025-5b4e-9078-bblddb554da1. html>. Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May18, 2015 135 CSAG MINNESOTA The Minnesota Vikings stadium will require a public contribution of approximately "$498 million in State appropriation bonds backed by proceeds from State authorized non-sports charitable gaming ($348 million) and City of Minneapolis Convention Center taxes ($150 million).3 Private contribution is estimated to be approximately $574 million.' Bonds are expected to be paid through PSLs, the license which entitles a season ticket holder to maintain exclusive rights over their seat(s), to average $2,500.5 While the "Vikings will have the exclusive right to sell and profit from a pair of naming-rights deals for the new stadium and adjacent fan plaza,"6 as well as revenue accrued from advertising and concessions, the team will be asked to pay rent starting at $8.5 million. The team's annual rent is expected to grow at a rate of "three percent a year until reaching $20 million in the Year 30. Additionally, the team must put $1.5 million into a capital improvement account in Year One; that gradually rises to $3.5 million by the 30th year." During non-football days, the stadium is expected to be used for concerts, political conventions, fantasy football events and amateur sports games. ATLANTA Atlanta's stadium is expected to be backed by a public contribution of "$200 million in City of Atlanta bonds backed by a 2.75% County hotel tax,"" and a private contribution of $835 million.' "Additional hotel-motel tax money will go to the Falcons to help offset costs of maintaining and operating the stadium.'" The remaining $1 billion will be paid through a combination of the team ($800 million), the NFL ($200 million) and PSLs. "The Falcons also intend to recour some of their contribution through naming rights and other sponsorships." All stadium revenue will be retained by the Falcons; however, the team must "pay the Georgia World Congress Center Authority $2.5 million in annual rent, escalating 3 percent per year," for 25 years.'2 It is important to note that the team must cover all operational costs and capital maintenance expenses, which can be offset by excess TOT revenue. 3 "Publicly-available news articles." 4 "Publicly-available news articles." 5 "8 Details You Need to Know About the New Vikings Stadium Agreement" Associated Press. October 8, 2013.. 8 "Publicly-available news articles." 9 "Publicly-available news articles." 10 Tucker, Tim. "Comparing Braves, Falcons stadium deals." The Atlanta Journal-Constitution. November 14, 2013. . 12 Tucker, Tim. 'Comparing Braves, Falcons stadium deals." The Atlanta Journal-Constitution.' November14, 2013. . Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 36 GSAG DALLAS AT&T Stadium, located in Arlington, a suburb approximately 20 miles outside of Dallas, incorporates a public contribution of $465 million, $325 million of which stems from "City of Arlington bonds; annual debt service backed by a 0.5% sales tax increase, 2% hotel tax increase, and 5% car rental tax increase."" Admission and parking taxes will make up $115 million with an additional $25 million County contribution. A private contribution from the Cowboys of $835 million paid for the majority of the project. INDIANAPOLIS Lucas Oil Stadium received a public contribution of "620 million in State bonds; annual debt service backed by increase in restaurant tax (1% to 2%), and other possible sources including hotel tax, car rental tax, admission tax, and ticket tax."14 Private funding was provided at $100 million. HKS Architects designed Lucas Oil stadium and met with CSAG members, sharing with the committee that among the NFL's 32 teams, the Indianapolis Colts ranked 27th in league-wide revenues prior to the construction of the new stadium. Following the construction of Lucas Oil Stadium, according to HKS, the team rose to 11th. NEW YORK MetLife stadium is unique in that it is 100% privately financed, however some public funds were spent on infrastructure upgrades totaling $250 million." The Jets and Giants shared the $16 billion stadium price tag16, and split the naming rights revenue for 25 years, worth $17 million to $20 million annually? SANTA CLARA Levi's Stadium, home to the San Francisco 49ers, was constructed with a public contribution of $114 million, and private contribution of $1.2 billion. Public funding came from a $40 million Redevelopment Authority investment, $35 million from a City of Santa Clara Community Facilities District (CFD) hotel tax, and $37 million City of Santa Clara offsite project funding." The 49ers will receive "$220 million over 11 years for the naming rights to Levi's Stadium."~9 13 "Publicly-available news articles." 14 "Publicly-available news articles." 15 "Publicly-available news articles." 16 "NFL Teams Sold an Average of 48,200 Personal Seat Licenses Last Season." Sports Business Daily. September 8, 2011. . 17 Sandomir, Richard. "Giants-Jets Home Now MetLife Stadium." The New York Times. August 23, 2011. . 18 "Publicly-available news articles." 19 Bien, Louis. "49ers' Levi Stadium the 3rd-biggest naming rights deal in American sports." SB Nation. May 8, 2013. . Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May18, 2015 137 National Stadium A3w55-n21,1. CSAG ST. LOUIS (PROPOSED STADIUM) With efforts to move the Rams to Los Angeles, the St. Louis Stadium Task Fo has proposed a 90-acre, 64,000-seat stadium, without a roof. While few details have been released, it is estimated that "the new stadium would cost nearly $1 billion, with as much as $405 million paid by taxpayers."2° These costs would largely "come from extending payments that now go to pay off debt on the Edward Jones Dome. Of that, the state pays $12 million a year."" Some expect the stadium to bring in approximately "$50 million in tax credits from the Missouri Development Finance Board and the state's Brownfield program, which covers the cost of cleaning up contaminated sites."22 20 Young, Virginia. "Study: State would see payoff from building stadium for Rams." St. Louis Today. Web. March 9, 2015. . 21 Young, Virginia. "Study: State would see payoff from building stadium for Rams.' St. Louis Today. Web. March 9, 2015. . 22 Young, Virginia. 'Study: State would see payoff from building stadium for Rams." St. Louis Web. March 9, 2015. . Site Selection and Financing Plan for New Multi-Use Stadium in San Diego I May 18, 2015 1 38 Farmers Field DEIR Summary of Significant Air Quality, Noise and Transportation Impacts AIR QUALITY SIGNIFICANT IMPACTS CONSTRUCTION EMISSIONS IMPACT DESCRIPTION OPERATIONAL EMISSIONS IMPACT DESCRIPTION Regional Daily Construction Emissions VOC • Project will exceed the SCAQMD daily significance threshold of 75 pounds per day during architectural coatings applications. • n/a CO • Project will exceed the SCAQMD daily significance threshold of 550 pounds per day during heavy construction equipment use. • n/a NOx • Project will exceed the SCAQMD daily significance threshold of 100 pounds per day during heavy construction equipment use. • n/a NOx • Project will exceed the applicable screeninglevel LST of 66 pounds per day. • n/a PM10 • Project will exceed the applicable screeninglevel LST of 53 pounds per day. • n/a PM2.5 • Project will exceed the applicable screeninglevel LST of 15 rounds per day. • n/a Localized Construction Emissions Daily Overlapping Construction Activities CONSTRUCT EMISSIONS IMPACT DESCRIPTION IGNIFICANT IMPACTS OPERATIONAL EMISSION IMPACT DESCRIPTION Regional Daily Operational Emissions NOx • n/a • Project will exceed the SCAQMD daily significance threshold of 55 pounds per day. VOC • n/a • Project will exceed the SCAQMD daily significance threshold of 55 pounds per day. CO • n/a • Project will exceed the SCAQMD daily significance threshold of 550 pounds per day. PM10 • n/a • Project will exceed the SCAQMD daily significance threshold of 150 pounds per day. PM2s • n/a • Project will exceed the SCAQMD daily significance threshold of 55 pounds per day. NO2 — State Hourly Threshold • n/a • Project's maximum hourly state NO2 incremental concentration of 245.6 jig /m3 exceeds state hourly threshold. NO2 — Federal Hourly Threshold • n/a • Project's maximum hourly federal NO2 incremental concentration of 205.8 gg /m3 exceeds federal hourly threshold. Localized Emissions from Operational Activities: Ambient Operation NO2 Impacts Event Day: An event with an attendance level of 72,000 at the Event Center combined with an attendance level of 19,500 at the Los Angeles Convention Center, which may occur up to 37 times per year. 2 NOISE CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS OPERATIONAL IMPACT DESCRIPTION Construction Noise and Vibration Impacts: On-Site Construction Noise Sources New Hall Construction • • L.A. Live Way Garage • Receptor R6 o 625 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 1.5 dBA (during the interior/exterior phase). o Late Evening Hours - Project will exceed the significance threshold by 1.7 dBA (during the interior/exterior phase). Receptor R26 o 690 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 6.7 dBA (during the interior/exterior phase). o Late Evening Hours - Project will exceed the significance threshold by 3.2 dBA (during the interior/exterior phase). . n/a Receptor R6 o 275 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 1.5 dBA. o Late Evening Hours - Project will exceed the significance threshold by 5.4 dBA (during the concrete/steel/precast frame phase). • n/a S. ilFICANT IMPACTS Event Center • • Overlapping Construction Activities • • CONSTRUCT! IMPACT DESCRIPTION Receptor R1 o 465 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 7.9 dBA (during the foundation phase). o Late Evening Hours - Project will exceed the significance threshold by 6.4 dBA (during the interior/exterior phase). Receptor R6 o 610 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 1.7 dBA (during the foundation phase). o Late Evening Hours - Project will exceed the significance threshold by 1.7 dBA (during the interior/exterior phase). Receptors R.1, R3, R4, R5, R6, R7, and R26 o Daytime Hours - Project will exceed the significance threshold from 0.2 dBA (at R4) to 10.3 dBA (at R1). Receptors R1, R4, R5, R6, R7, R23, and R26 o Late Evening Hours - Project will exceed the significance threshold from 1.9 dBA (at R23) to 9.6 dBA (at R1). Construction Noise and Vibration Impacts: Off-Site Construction Noise Sources 4 OPERATIONAL IMPACT DESCRIPTION • n/a • n/a SIGNIFICANT IMPACTS Pico Station Second Platform • • CONSTRUCTION IMPACT DESCRIPTION Receptor R2 o Daytime Hours - Project will exceed the significance threshold by 3.7 dBA (Leg). o Late Evening Hours - Project will exceed the significance threshold by 105 dBA (Lett). Receptor R3 o Daytime Hours - Project will exceed the significance threshold by 1.4 dBA o Late Evening Hours - Project will exceed the significance threshold by 3.4 dBA. OPERATIONAL IMPACT DESCRIPTION • Construction Noise and Vibration Impacts: Composite Noise Levels from Project Construction Bond Street Garage • ▪ Receptor R26 o 640 ft. to the nearest construction site boundary. o Daytime Hours - Project will exceed the significance threshold by 5.6 dBA (Leg). Receptors R4, R5, R6, and R26 o The receptors are, respectively, 525 ft., 900 ft., 590 ft., and 640 ft. to the nearest construction site boundary. o Late Evening Hours - Project will exceed the significance threshold from 14 dBA (at R4) to 5.6 dBA (at R6). • IFICANT IMPACTS New Hall • • 1..A. Live Wa], Garage • • CONSTRUCTI IMPACT DESCRIPTION Receptors RI, R3, R5, R6, and R26 o The receptors are, respectively, 1247 ft., 880 ft., 1090 ft., 625 ft., and 690 ft. to the nearest construction site boundary. o Daytime Hours - Project will increase ambient noise levels by 5.2 dBA and 12.0 dBA, which will exceed the 5 dBA significance threshold. Receptors R1, R3, R4, R5, R6, R7, R21, R23, R25, and R26 o The receptors are, respectively, 1247 ft., 880 ft., 755 ft., 1090 ft., 625 ft., 1065 ft., 2595 ft., 1720 ft., 1590 ft., and 690 ft. to the nearest construction site boundary. o Late Evening Hours - Project will increase ambient noise levels by 3.4 dBA (at R25) to 10.4 dBA (at R26), which will exceed the 3 dBA significance threshold. Receptor R6 o 275 ft. to the nearest construction site boundary. o Daytime Hours - Project will increase ambient noise levels by a maximum of 7.7 dBA (Leg), which will exceed the 5 dBA significance threshold. Receptors R5, R6, R7 o The receptors are, respectively, 810 ft., 275 ft., and 250 ft. to the nearest construction site boundary. o Late Evening Hours - Project will increase ambient noise levels by 4.3 to 9.4 dBA (Leg), which will exceed the 3 dBA significance threshold. OPERATION A L IMPACT DESCRIPTION • n/a • n/a SIGNIFICANT IMPACTS Event Center • • Overlapping Construction Activities • • CONSTRUCTION IMPACT DESCRIPTION Receptors R1, R5, R6, and R7 o The receptors are, respectively, 465 ft., 1215 ft., 610 ft., and 420 ft. to the nearest construction site boundary. o Daytime Hours - Project will increase ambient noise levels by 5.0 to 13.1 dBA (Leg), which will exceed the 5 dBA (LI) significance threshold. Receptors RI, R3 through R8, R21, R23, and R25 o The receptors are, respectively, 465 ft., 1215 ft., 1220 ft., 1251 ft., 610 ft., 420 ft., 1385 ft., 3155 ft., 1905 ft., and 1530 ft. to the nearest construction site boundary. o Late Evening Hours - Project will increase ambient noise levels by 3.1 to 13.5 dBA (Leg), which will exceed the 3 dBA (Leg) significance threshold. OPERATIONAL IMPACT DESCRIPTION • n/a Receptors R1, R3, R4, R5, R6, R7, R9, and R26 o Daytime Hours - Project will increase ambient noise levels by 0.3 dBA (at R9) to 10.4 dBA (R1), which will exceed the 5 dBA (La) significance threshold. Receptors R1 through R8, R16, R20, R21, R22, R23, R25, and R26 o Late Evening Hours - Project will increase ambient noise levels by 0.5 dBA (at R20) to 11.3 dBA (at R6), which will exceed the 3 dBA (Li) significance threshold. • n/a Impact Pile Driver Vibration- Project will generate vibration levels from 74 VdB (at L.A. Live Garage 250 ft. away) to 86 VdB (at Event Center 100 ft. away), which will exceed the 72 VdB significance threshold. • n/a Construction Noise and Vibration Impacts: Construction Vibration Impact Pile Driver Nokia Theater • CONSTRUCTI IMPACT DESCRIP ii. ION IFICANT IMPACTS OPERATIONAL IMPACT DESCRIPTION Operation Impacts: On-Site Noise Sources Parking Garages • nla • (Bond Street Garage & L.A. Live Way Garage) • • Outdoor Plazas • n/a • • 8 Receptor R5 o Daytime Hours - Project will exceed the significance threshold by 1.8 dBA. Receptor R6 o Daytime Hours - Project will exceed the significance threshold by 6.7 dBA. Receptors R4, R5, R6, R7, R23, and R25 o Late Evening Hours - Project will exceed the significance threshold by 1.3 dBA to 8.6 dBA. Receptors R1, R2, R3, and R13 o Daytime Hours - Project will exceed the significance threshold by 7.4 dBA (at R13) to 13.7 dBA (at R1). Receptors R1, R2, R3, R13, and R14 o Nighttime Hours - Project will exceed the significance threshold by 6.5 dBA (at R14) to 16.1 dBA (at R2). CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS Even t Center Sport Even t • nia OPERATIONAL IMPACT DESCRIPTION In House Sound System • Receptors R1, R3, R5, and R6 o The receptors are, respectively, 465 ft., 1125 ft., 1215 ft., and 610 ft. to the nearest construction site boundary. o Daytime Hours — Project will exceed significance thresholds by up to 3.2 dBA (1-max). • Receptors R1, R3, R5 through R9, R14, R21, R23, and R25 o The receptors are, respectively, 465 ft., 1125 ft., 1215 ft., 610 ft., 420 ft., 1385 ft., 1270 ft., 1730 ft., 3155 ft., 1905 ft., and 1530 ft. to the nearest construction site boundary. • Late Evening Hours — Project will exceed significance thresholds by up to 6.9 dBA (L.). Crowd Cheering: • Receptors R1, R5, R6, R7, and R8 o The receptors are, respectively, 465 ft., 1215 ft., 610 ft., 420 ft., and 1385 ft. to the nearest construction site boundary. o Daytime Hours — Project will exceed significance thresholds by up to 7.7 dBA (Lmax). • Receptors R1, R5 through R9, R13, R23, R24, and R25 o The receptors are, respectively, 465 ft., 1215 ft., 610 ft., 420 ft., 1385 ft., 1270 ft., 1245 ft., 1905 ft., 1590 ft., and 1530 ft. to the nearest construction site boundary. o Late Evening Hours — Project will exceed significance thresholds by up to 8.1 dBA (Ln.,E). CONSTRUCT IMPACT DESCRIP1 ION 4IFICANT IMPACTS Event Center -, Concert Event • n/a OPERATIONAL IMPACT DESCRIPTION Concert Touring Sound System • Receptors R1, R3 through R9, R17, R21, R23, R25, and R26 o The receptors are, respectively, 465 ft., 1125 ft., 1220 ft., 1215 ft., 610 ft., 420 ft., 1385 ft., 1270 ft., 2965 ft., 3155 ft., 1905 ft., 1630 ft., and 1250 ft. to the nearest construction site boundary. o Daytime Hours — Project will exceed significance thresholds by 0.4 dBA (at R22) to 10.5 dBA (at R9). • Receptors R1 through R10, R14, R15, R17, and R21 through R26 o The receptors are, respectively, 465 ft., 680 ft., 1125 ft., 1220 ft., 1215 ft., 610 ft., 420 ft., 1385 ft., 1270 ft., 1300 ft., 1730 ft., 1575 ft., 2965 ft,, 3155 ft., 2555 ft., 1905 ft., 1590 ft., 1530 ft., and 1250 ft. to the nearest construction site boundary. o Late Evening Hours — Project will exceed significance thresholds by 0.5 dBA (at R25 and R25) to 13.0 dBA (at R9). Crowd Cheering: • Receptors R1, R5, R6, R7, and R8 o The receptors are, respectively, 465 ft., 1215 ft., 610 ft., 420 ft., and 1385 ft. to the nearest construction site boundary. o Daytime Hours — Project will exceed significance thresholds by up to 7.7 dBA • Receptors R1, R5 through R9, RI3, R23, R24, and R25 o The receptors are, respectively, 465 ft., 1215 ft., 610 ft., 420 ft., 1385 ft., 1270 ft., 1245 ft., 1905 ft., 1590 ft., and 1530 ft. to the nearest construction site boundary. o Late Evening Hours — Project will exceed significance thresholds by up to 8.1 dBA (L). 0 10 CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS Event Center - Fireworks 0 n/a • • OPERATIONAL IMPACT DESCRIPTION All Receptors o Project will exceed the significance threshold by 8.9 dBA (at R12) to 45.4 dBA (at R5). Note: Fireworks will be 15 ft. to 200 ft. high. Operation Impacts: Off-Site Mobile Noise Sources Motor Vehicle Travel • n/a Grand Avenue — between 17th St. and Washington Ave. Motor Vehicle Travel • • • n/a • Weekday Event Day (Post-Event Day) —Project and Project with Convention Center Dark will cause up to 6.1 dBA increase. • n/a • Sunday Event Day (Post-Event Hour) —Project will cause up to 6.8 dBA increase and Project with Convention Center Dark will cause up to 7.6 dBA increase. • n/a • Sunday Event Day (Post-Event Hour) —Project and Project with Convention Center Dark will cause up to 7.0 dBA increase. • n/a • Weekday Event Day (Post-Event Day) —Project and Project with Convention Center Dark will cause up to 5.5 dBA increase. • n/a • Project will result in of 6.0 dBA (hourly Lel) and exceed the significance threshold. • Project's ambient noise will exceed significance threshold by 5.0 dBA (44). West 114 St. — between Blaine St. and L.A. Live Way Motor Vehicle Travel West le St. - West of Flower St. Motor Vehicle Travel West 184 St. — West of Grand Ave. Motor Vehicle Travel West 39th St. — East of1-110 Freeway. Public Transit Sunday Event Day (Post-Event Hour) —Project and Project with Convention Center Dark will cause up to 5.0 dBA increase. Weekday Event Day (Post-Event Day) —Project and Project with Convention Center Dark will cause up to 5.8 dBA increase. Blue Line Helicopters • CONSTRUCTI IMPACT DESCRIPi ION ,IFICANT IMPACTS OPERATIONAL IMPACT DESCRIPTION Operation Impacts: Composite Noise Level Impacts Typical Event Days without Fireworks • n/a • • • • Typical Event Days with Fireworks Receptor R1 o Project will result in an increase of 8.1 dBA CNEL, which exceeds the 3 dBA CNEL significance threshold. Receptor R2 o Project will result in an increase of 8.2 dBA CNEL, which exceeds the 3 dBA CNEL significance threshold. Receptor R3 o Project will result in an increase of 7.8 dBA CNEL, which exceeds the 3 dBA CNEL significance threshold. Receptor R13 o Project will result in an increase of 4.0 dBA CNEL, which exceeds the 3 dBA CNEL significance threshold. • n/a • Receptor R1 through R9, R11, R13, R14, R16, R17, and R19 through R26 o Project's ambient noise will range from 4.5 dBA CNEL (at R11) to 17.9 dBA CNEL (at R3). • Project together with the related projects could increase ambient noise levels at receptors that are located within 500 feet from the construction sites by 5 dBA or more. • lila Cumulative Impacts Construction Noise 12 CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS Operation Noise • • • • OPERATIONAL IMPACT DESCRIPTION Sunday scenario - At 11 analyzed roadway segments, the Project may produce a maximum increase of up to 9.9 dBA along 18th Street (west of Grand Avenue). Sunday scenario - At 8 analyzed roadway segments, the Project may produce a maximum increase of up to 8.5 dBA along 11th Street (west of Grand Avenue). Sunday scenario - At 12 analyzed roadway segments, the Project may produce a maximum increase of up to 8.8 dBA along Grand Avenue (between 17th Street and Washington Avenue). TRANSPORTATION CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS OPERATIONAL IMPACT DESCRIPTION Roadway Intersections • n/a • Significant Traffic Impact at Intersections: o Blaine St. & 11th St.; Figueroa St. & 8th St.; Vermont Ave. & Pico Blvd.; Vermont Ave. & I-10 EB; Hill St. & 17th St.; Broadway & 17th St.; Main St. & 17th St.; Los Angeles St. & 17th St.; Alvarado St. & Pico Blvd.; Olive St. & 17 St.; Vermont Ave. & Olympic Blvd. • Of the 11 impacted intersection, 9 will continue to operate at level of service ("LOS") D or better, and 2 will operate at LOS E. • n/a • Significant Traffic Impact at Intersections: o Broadway & 18th St; Figueroa St. & Martin Luther King Jr. Blvd.; I-110 SB & Martin Luther King Jr. Blvd.; Grand Ave. & 1st St.; Vermont Ave. & Pico Blvd.; Hoover St. & Venice Blvd.; I-10 WB & 20'h St.; Main St. & 18th St.; Grand Ave. & US-101 NB; Western Ave. & Olympic Blvd.; Union Ave. & Pico Blvd.; Hill St. & 17th St.; Hill St & 16'h St.; Blaine St & 11th St.; Hill St. & 18* St.; Los Angeles St. & 18th St. • Of the 18 impacted intersection, 13 will continue to operate at LOS D or better, 2 will operate at LOS E, and 3 will operate at LOS F. Sunday Day Event Pre-Event Hour (12:00-1:00 PM) Sunday Day Event Post-Event Hour (4:30-5:30 PM) 14 • CONSTRUCTION IMPACT DFSCRIPTION mra • • 'L .1 • SIGNIFICANT IMPACTS Saturday Day Event Pre-Event Hour (12:00-1:00 PM) Saturday Day Event Post-Event Hour (4:30-5:30 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at Intersections: o Olive Ave. & Olympic Blvd.; Blaine St. & 11th St.; Hill St. & Adams Blvd,; Flower St. & 8th St.; Lucas Ave. & 6th St.; Spring St. & Cesar Chavez Ave.; Glendale Blvd. & Temple St.; Western Ave. & Wilshire Blvd.; Union Ave. & Olympic Blvd.; Vermont Ave. & Pico Blvd.; Vermont Ave. & Venice Blvd.; Hoover St. & Venice Blvd.; Hoover St. & Washington Blvd.; Hill St & 16th St; Figueroa St. & Olympic Blvd.; I110 NB Off-Ramp & Adams Blvd.; Alvarado St. & Olympic Blvd.; Vermont Ave. & Washington Blvd.; Hoover St. & I10 EB ; San Pedro St. & 16th St.; Flower St. & Olympic Blvd.; Blaine St. & Olympic Blvd.; Figueroa St & 8th St; Alvarado St. & Pico Blvd.; Vermont Ave. & I-10 EB Ramps; Olive St. & 17th St.; Hill St. & 17th St.; Broadway & 17th St.; Main St. & 17th St.; Los Angeles St. & 17th St.; Vermont Ave. & Olympic Blvd. • Of the 31 impacted intersections, 20 will operate at LOS D, 5 will operate at LOS E, and 6 will operate at LOS F. Significant Traffic Impact at Intersections: o Hill St. & Pico Blvd.; Flower St. & Venice Blvd.; Grand Ave. & 17th St.; Figueroa St. & Washington Blvd.; Figueroa St. & Martin Luther King Jr. Blvd.; I-110 SB Ramp & Martin Luther King Jr. Blvd.; Georgia St. & 9th St.; Figueroa St. & 8th St.; Hill St. & College Ave.; Western Ave. & Olympic Blvd. Vermont Ave. & Pico Blvd.; Union Ave. & Pico Blvd.; San Pedro St. & 16 th St.; Arlington Ave. & Venice Blvd.; Georgia St & Olympic Blvd.; Figueroa St. & Olympic Blvd.; Flower St & Olympic Blvd.; Blaine St. & Olympic Blvd.; Figueroa St. & Wilshire Blvd.; Grand Ave. & 1st St.; Glendale Blvd. & Temple St.; Alvarado St. & Olympic Blvd.; Hoover St. & Venice Blvd.; Hoover St. & Washington Blvd.; I-10 WB Ramps & 20th St; Figueroa St & Venice Blvd.; Alvarado St. & Pico Blvd.; Blaine St. & 11th St.; Hill St. & 17th St.; Hill St. & 18th St.; Broadway & 18th St.; Main St. & 18th St.; Los Angeles St & 18th St.; Grand Ave. & US-101 NB Ramps; Hill St & 16th St. • Of the 36 impacted intersection, 25 will operate at LOS D or better, 3 will operate at LOS E, and 8 will operate at LOS F. CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS • Weekday Evening Event Pre-Event Hour N:30-1-30 PA.!) Ilia OPERATIONAL IMPACT DESCRIPTION • Significant Traffic Impact at IntersectionN. o Georgia St. & Olympic Blvd.; Olive St. & Olympic Blvd.; Grand Ave. & 11th St; Flower St. & Pico Blvd.; Hill St. & Pico Blvd.; Grand Ave. & Washington Blvd.; Olive St. & Washington Blvd.; Hill St. & Washington Blvd.; Georgia St. & 9th St.; Figueroa St. & 9th St.; Olive St. & 5th St.; Normandie Ave. & Olympic Blvd.; Western Ave. & Venice Blvd.; Normandie Ave. & Venice Blvd.; Hill St. & 16th St.; Arlington Ave. & Olympic Blvd.; Arlington Ave. & Washington Blvd.; Flower St. & Olympic Blvd.; Broadway & Olympic Blvd.; Blaine St. & Olympic Blvd.; Blaine St. & SR-110 SB; Grand Ave. & 17th St.; Figueroa St. & Washington Blvd.; Broadway & Washington Blvd.; Grand Ave. & Adams Blvd.; I-110 NB Ramps & Martin Luther King Jr. Blvd.; Bixel St. & 6th St.; Hope St. & 1st St.; Hope St. & Temple St.; Western Ave. & Wilshire Blvd.; Union Ave. & Olympic Blvd.; Vermont Ave. & Pico Blvd.; Union Ave. & Pico Blvd.; Vermont Ave. & Venice Blvd.; Vermont Ave. & I-10 EB; Hoover St. & I-10 EB; San Pedro St. & 16th St.; Central Ave.& Washington Blvd.; La Brea Ave. & Olympic Blvd.; Figueroa St & Pico Blvd.; Figueroa St & Venice Blvd.; Olive Street & 17th St.; Flower St. & Adams Blvd.; 1-110 NB Off-Ramp & Adams Blvd.; Hill St & Blvd.; Spring St & Cesar Chavez Ave.; Normandie Ave. & Wilshire Blvd.; Alvarado Str. & Wilshire Blvd.; Alvarado St. & Olympic Blvd.; Alvarado St. & Pico Blvd.; Hoover St. & Venice Blvd.; Hoover St & Blvd.; Main St. & 16th St.; Arlington Ave. & Venice Blvd.; Crenshaw Blvd.& Olympic Blvd.; Crenshaw Blvd.& Venice Blvd.; Crenshaw Blvd.& Washington Blvd.; Figueroa St. & Olympic Blvd.; Main St & Olympic Blvd.; Main St. & Pico Blvd.; Blaine St. & 11th St.; Hill St & 17th St.; Broadway & 17th St.; Main St. & 17th St.; Los Angeles St. & 17th St.; Figueroa St. & Adams Blvd.; Bixel St. & 8th St.; Figueroa St. & 8th St.; Figueroa St. & Wilshire Blvd.; Lucas Ave. & 6th St.; Figueroa St. & 6th St.; Figueroa St. & 5th St.; Grand Ave. & 1st St.; Vermont Ave. & Wilshire Blvd.; Western Ave. & Olympic Blvd.; Vermont Ave. & Olympic Blvd.; Vermont Ave. & Washington Blvd. • Of the 77 impacted intersections, 39 will operate at LOS D or better, 18 will operate at LOS E, and 20 will operate at LOS F. • CONSTRUCTION IMPACT DESCRIPTION n/a • • n/a • Policy Load Capacities Exceeded at: o Metro Blue Line o Metrolink o Metro Silver Line (South & North) o Express Buses • n/a • Policy Load Capacities Exceeded at: o Metro Red Line o Metro Blue Line o Expo Line o Metrolink o Metro Silver Line (South & North) o Rapid Bus o Express Buses • n/a • Policy Load Capacities Exceeded at: o Metro Red Line o Metro Blue Line o Metro Silver Line (South & North) o Rapid Bus o Express Buses • n/a • Policy Load Capacities Exceeded at: o Metro Red Line o Metro Blue Line o Expo Line o Metrolink o Metro Silver Line (South & North) o Express Buses SIGNIFICANT IMPACTS Weekday Evening Event Post-Event Hour (9:00-10:00 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at Intersections: o Hill St. & 17th St; Vermont Ave. & Olympic Blvd.; Broadway & 18th St.; Main & 18th St.; Grand Ave. & US-101 NB; Hill St. & 16th St.; Blaine St. & 1 l th St.; Hill St. & 18th St.; Los Angeles St. & 18th St. • Of the 9 impacted intersections, 4 will operate at LOS D or better, 2 will operate at LOS E, and 3 will operate at LOS F. Transit Facilities Sunday Day Event Pre-Event Hour (12:00-1:00 PM) Sunday Day Event Post-Event Hour (4:30-5:30 PM, Saturday Day Event Pre-Event Hour (12:00-1:00 Saturday Day Event Post-Event Hour (4:30-5:30 PM) SIGNIFICANT IMPACTS • CONSTRUCTION IMPACT DESCRIPTION n/a • Weekday Evening Event Post-Event Hour (9:00-10:00 PM) • OPERATIONAL IMPACT DESCRIPTION Overall ridership will exceed available capacity. o Passenger-carrying capacity: 9,225 riders o Total projected ridership at this time: 14,992 riders Policy Load Capacities Exceeded at: o Metro Red Line o Metro Red/Purple Line o Metro Blue Line o Green Line (East & west) o Gold Line (Pasadena & East LA.) o Metro Silver Line (South & North) o Rapid Bus o Express Buses Freeway Segments • n/a • Significant Traffic Impact at: a SR-110 N of Alpine St.; I-5 S of Stadium Way; US-101 at Glendale Blvd.; US-101 S of Vermont Ave. • The demand/capacity ("D/C") ratio would be less than 1.10 at 3 of the 4 impacted freeway locations, and would be between 1.10 and 1.20 at the other location. • n/a • Significant Traffic Impact at: o 1-110 at Vernon Ave.; 1-5 South of Stadium Way; SR-110 Between James M. Wood Blvd. & Olympic Blvd.; 1-10 West of Vermont Ave.; US-101 South of Vermont Ave.; US-101 North of Vignes St.; 1-5 West of Indiana St.; US-101 at Glendale Blvd.; SR-110 South of US-101. • The D/C ratio would be less than 1.10 at 6 impacted freeway locations, between 1.10 and 1.20 at 2 locations, and greater than 1.2 at 1 location. Sunday Day Event Pre-Event Hour (12:00-1:00 PM) Sunday Day Event Post-Event Hour (4:30-5:30 PM) 18 • CONSTRUCTION IMPACT DESCRIPTION n/a • • n/a • SIGNIFICANT IMPACTS Saturday Day Event Pre-Event Hour (12:00-1:00 PM) Saturday Day Event Post-Event Hour (4:30-5:30 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at: o 1-5 S of Stadium Way; 1-110 North of Martin Luther King Jr. Blvd.; US-101 at Glendale Blvd.; US-101 North of Vignes St.; US-101 S of Vermont Ave.; 1-110 at Slauson Ave. • 8 freeway segments would operate at LOS D or better, 6 locations would operate at LOS E, 5 locations would operate at LOS F(0), and 1 would operate at LOS F(1). • The majority of D/C ratios at LOS F locations would be less than 1.10. At 1 location, the D/C ratio would be between 1.10 and 1.20, and at 1 location it would be greater than 1.20. Significant Traffic Impact at: o 1-10 West of Vermont Ave.; 1-5 South of Stadium Way, US101 South of Vermont Ave.; 1-10 East of San Pedro St.; I110 at Vernon Ave.; 1-110 North of Martin Luther King Jr. Blvd.; 1-5 West of Indiana St.; I-110 at Slauson Ave.; SR110 North of Alpine St.; US-101 at Glendale Blvd.; SR-110 Between James Wood Blvd. & Olympic Blvd.; US-101 North of Vignes St.; SR-110 South of US-101. • 7 of the freeway segments would operate at LOS D or better and 13 would operate at LOS F(0). • The D/C ratio would be less than 1.10 at 6 of the impacted locations, between 1.10 and 1.20 at 6 locations, and greater than 1.20 at the 1 location. • CONSTRUCTION IMPACT DESCRIPTION n/a • • n/a • Significant Traffic Impact at: o US-101 at Glendale Blvd.; SR-110 South of US-101; 1-5 West of Indiana St. • 3 locations would operate at LOS F(0). • A113 locations will have a D/C ratio less than 1.02. • n/a • Significant Traffic Impact at: o 1-10: Los Angeles St. WB Off-Ramp o US 101: Grand Ave. NB Off-Ramp o SR 110: 9th St. NB Off-Ramp o 1-10: Hoover St. EB Off-Ramp • At 3 locations, the 85th percentile queue would exceed the storage capacity of an individual lane and at 1 location it would exceed the overall ramp capacity. SIGNIFICANT IMPACTS Weekday Evening Event Pre-Event Hour (4:30-5:30 PM) Weekday Evening Event Post-Event Hour (9:00-10:00 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at o 1-110 South of Martin Luther King Jr. Blvd.; 1-5 South of Stadium Way; SR-110 Between James Wood Blvd. and Olympic Blvd.; US-101 at Glendale Blvd.; 1-5 West of Indiana St.; I-110 at Vernon Ave.; US-101 North of Vignes St.; US-101 South of Vermont Ave.; SR-110 North of Alpine St.; 1-10 East of San Pedro St.; 1-10 West of Vermont Ave.; SR-110 South of US-101; 1-10 East of Crenshaw Blvd. • 6 locations will operate at LOS D or better 14 will operate at LOS F. • The D/C ratio will be less than 1.10 at 2 locations, between 1.10 and 1.20 at 5 locations, between 1.20 and 1.30 at 3 locations and greater than 1.30 at the 3 location. D/C ratio increase would be Less than 10% at 6 locations, and in the 15-25% range at 4 locations. Freeway Ramps Freeway Off-Ramps Sunday Day Event Pre-Event Hour (12:004:00 PM) 20 • CONSTRUCTION IMPACT DESCRIPTION n/a • • n/a • Significant Traffic Impact at: o I-10: Los Angeles St. WB Off-Ramp o I-10: Hoover St. EB Off-Ramp o US 101: Grand Ave. NB Off-Ramp o I-110: Adams Blvd. NB Off-Ramp o SR 110: 9th St. NB Off-Ramp • n/a • Significant Traffic Impact at: o US 101: Los Angeles St. EB On-Ramp o I-10: Los Angeles St. EB On-Ramp o I-10: Washington Blvd. SB On-Ramp o SR 110: Blaine St. SB On-Ramp o SR 110: 8th St. SB On-Ramp o I-10: Grand Ave. WB On-Ramp o US 101: Glendale Blvd. On-Ramp o SR 110: 5th St. NB On-Ramp o SR 110: 8th St. NB On-Ramp o SR 110: 9th Street NB On-Ramp o SR 110: 11th St. NB On-Ramp • At 3 of these locations volumes would exceed ramp capacities by less than 10%. SIGNIFICANT IMPACTS Freeway On-Ramps Sunday Day Event Post-Event Hour (4:30-5:30 PM) Freeway Off-Ramps Saturday Day Event Pre-Event Hour (12:00-1:00 PM) Freeway On-Ramps Saturday Day Event Post-Event Hour (4:30-5:30 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at: o I-10: Los Angeles St. EB On-Ramp o I-10: Washington Blvd. SB On-Ramp o SR 110: Blaine St. SB On-Ramp o SR 110: 8th St. SB On-Ramp o SR 110: 5th St. NB On-Ramp o SR 110: 8th St. NB On-Ramp o SR 110: 11th St. NB On-Ramp • At 3 locations, volumes would exceed ramp capacities by less than 10%. • CONSTRUCTION IMPACT DESCRIPTION n/a • • n/a • • n/a • SIGNIFICANT IMPACTS Freeway Off-Ramps Weekday Evening Event Pre-Event Hour (4:30-5:30 PM) Freeway On-Ramps Weekday Evening Event Post-Event Hour (9:00-10:00 PM) OPERATIONAL IMPACT DESCRIPTION Significant Traffic Impact at: o US 101: Grand Ave. NB Off-Ramp o 1-10: Los Angeles St. WB Off-Ramp o SR 110: 9th St. NB Off-Ramp o I-10: Hoover St. EB Off-Ramp o SR 110: 6th St. SB Off-Ramp o SR 110: Olympic Blvd. SB Off-Ramp o I-110: Martin Luther King Jr. Blvd. NB Off-Ramp o I-110: Adams Blvd. NB Off-Ramp • At 2 locations it will only be lane impacts, and at 6 locations it will be overall ramp impacts. Significant Traffic Impact at: o 1-10: Los Angeles St. EB On-Ramp o SR 110: Blaine St. SB On-Ramp o SR 110: 5th St. NB On-Ramp o SR 110: 8th St. NB On-Ramp o SR 110: 9th St. NB On-Ramp o SR 110: 11 St. NB On-Ramp Congestion Management Plan Freeway Analysis Weekday Evening Event Pre-Event Hour (4:30-5:30 PM)' 22 Significant impact at the following CMP freeway monitoring locations that would exceed eh 150 trip threshold: o 1-5 at Lemoran Ave. (NB); 1-5 at Ferris Ave. (NB); 1-5 at Stadium Way (SB); 1-5 south of Colorado Blvd. (SB); 1-5 at Burbank Blvd. (SB); I-10 east of Overland Ave. (EB); I-I0 east of La Brea Ave. (EB); I-I0 at Budlong Ave. (EB); I-10 east of Puente Ave. (WB); I-10 at Grand Ave. (WB); US-101 North of Vignes St (NB); US-101 south of Santa Monica Blvd. (SB); US-101 at Coldwater Canyon Ave. (SB); US101 at Winnetka Ave. (SB); I-110 at Manchester Blvd. (NB); I-110 at Slauson Ave. (NB); SR-110 south of US-101 (SB); SR-110 north of Alpine St (SB); 1-405 south of I-110 at Carson Scales. OPERATIONAL IMPACT DESCRIPTION CONSTRUCTION IMPACT DESCRIPTION SIGNIFICANT IMPACTS Roadway Lane Closures: • Reduces overall capacity of Pico, which may result in increased travel time and delays or decreased level of service that is significant o May lead to traffic shifting to East-West roadways (Olympic Blvd., Venice Blvd., Washington Blvd. 9* St., or 8* St.) • Reduced roadway capacity could lead to some traffic diverting to east-west arterial roadways and substantial diversions in Pico-Union to reach parallel arterials which may cause significant impacts. Pico Blvd. Closure Traffic Impact (Where 3 Northerly/Southerly Lanes Closed) Pico-Union Neighborhood Impact (Between L.A. Live & Concourse Hall Bridge) • n/a *LADOT guidelines indicate that local residential streets can potentially be impacted through increased vehicle trips if traffic is diverted to local residential streets as cut-through routes to bypass congested arterial roads. LOS E and F are considered congested arterial conditions. girttaiUmnr mite an iv au Moto 111 PO WE qi.J71 l I.FigITADE Q5)=ANI-5/20C, Search ABOUT SOHO OUR MUSEUMS ADVOCACY TOURS & EVENTS PRESERVATION RESOURCES PUBLICATIONS SUPPORT Qualcomm Stadium LISTS FROM PAST YEARS San Diego Stadium, (the original name) is one of the few remaining mid-century designed multi-purpose stadiums left in the United States. It was opened in 1967 as home to the San Diego Chargers, the San Diego Padres and the San Diego State University Aztecs football team. Frank L Hope Associates architect Gary Men, who spent his formative years in the office of Philip Johnson, designed the stadium for the city. With its innovative design features which included pre-cast concrete, pre-wired light towers, and spiral concrete pedestrian ramps, the stadium received an American Institute of Architects Honor award in 1969 for outstanding design, the first time an architecture firm in San Diego had received a national honor award. The City of San Diego must find a way to preserve this modem monument. 2014 1 2013 1 2012 1 2011 2010 I 2009 I 2008 2007 Newly Added • Rancho Guejito • Salk Institute • Serra Cross • Casa de Carrillo • Whalen Ranch • Tijuana Bullring Remaining from past years • Villa Montezuma • San Pasqua! Valley Old Adobe School House & the Clevenger House/Homestead • Warner-Carrillo Ranch House • Border Field State Park • Qualcomm Stadium • Red Roost and Red Rest cottages 2006 2005 1 2004 1 2003 1 2002 1 2001 Sign up for our Email Ust 2476 San Diego Avenue • San Diego CA 92110 • Phone (619) 297-9327r‘i Home I Contact Historic Real Estate • For Sale T Select Lanauaa V b1 IPaC U.S. Fish & Wildlife Service My project San Diego County, California OVERVIEW RESOURCES IMPACT ANALYSIS REGULATORY DOCUMENTS This project potentially impacts 50 resources managed or regulated by the U.S. Fish & Wildlife Service Tasks 00 Local office Review potentially impacted resources Carlsbad Fish And To see endangered species, migratory birds, wetlands Wildlife Office or refuges which may be impacted by this project 0 (760) 431-9440 This project could impact: • 20 endangered species • 29 migratory birds • 90 acres of wetland View the complete resource list to see more Gr http://www.fws.gov/i information. Ei Request an official species list To receive an official document from the Carlsbad Fish And Wildlife Office An official species list obtained from IPaC is considered a U.S. Fish & Wildlife Service official response. An official species list has not been requested for this project. IA Analyze the impacts of your project Provide additional details and get recommended conservation measures for your project There are no species in your project area with conservation measure recommendations available. Please contact the local U.S. Fish & Wildlife office to review impacts for this project. IPaC U.S. Fish & Wildlife Service My project San Diego County, California OVERVIEW RESOURCES IMPACT ANALYSIS REGULATORY DOCUMENTS This project potentially impacts 50 resources managed or regulated by the U.S. Fish & Wildlife Service Endangered species Proposed, candidate, threatened, and endangered species that are managed by the Endangered Species Program and should be considered as part of an effect analysis for this project. Birds IMM 0 California Least Tern Sterna antillarum browni Endangered (A species in danger of extinction throughout all or a significant portion of its range) Coastal California Gnatcatcher Polioptila californica californica 0 Threatened (A species likely to become endangered within the foreseeable future throughout all or a significant pardon of its range) M• 0 Z...a ' 0 Least Bell's Vireo Vireo beilii pusillus Endangered (A species in danger of extinction throughout all or a significant portion of its range) Light-footed Clapper Rail Rallus longirostris levipes Endangered (A species in danger of extinction throughout all or a significant portion of its range) Om 0 Southwestern Willow Flycatcher Empidonax traillii extimus Endangered (A species in danger of extinction throughout all or a significant portion of its range) Western Snowy Plover Charadrius alexandrinus nivosus Threatened (A species likely to become endangered within the foreseeable future throughout all or a significant portion of its range) Crustaceans IM1 0 Riverside Fairy Shrimp Streptocephalus woottoni Endangered (A species in danger of extinction throughout all or a significant portion of its range) San Diego Fairy Shrimp Branchinecta sandiegonensis 0 Endangered (A species in danger of extinction throughout all or a significant portion of its range) Flowering Plants IOW 0 California Orcutt Grass Orcuttia californica Endangered (A species in danger of extinction throughout all or a significant portion of its range) Del Mar Manzanita Arctostaphylos glandulosa ssp. crassifolia 0 =Lamm 0 MMI 0 Endangered (A species in danger of extinction throughout all or a significant portion of its range) Salt Marsh Bird's-beak Cordylanthus maritimus ssp. maritimus Endangered (A species in danger of extinction throughout all or a significant portion of its range) San Diego Ambrosia Ambrosia pumila Endangered (A species in danger of extinction throughout all or a significant portion of its range) San Diego Button-celery Eryngium aristulatum var. parishii 0 .Z.' 0 Endangered (A species in danger of extinction throughout all or a significant portion of its range) San Diego Mesa-mint Pogogyne abramsii Endangered (A species in danger of extinction throughout all or a significant portion of its range) San Diego Thornmint Acanthomintha ilicifolia 0 Threatened (A species likely to become endangered within the foreseeable future throughout all or a significant portion of its range) Spreading Navarretia Navarretia fossalis 0 .L7..am 0 Threatened (A species likely to become endangered within the foreseeable future throughout all or a significant portion of its range) Thread-leaved Brodiaea Brodiaea filifolia Threatened (A species likely to become endangered within the foreseeable future throughout all or a significant portion of its range) Willowy Monardella Mona rdel la vim inea 0 Endangered (A species in danger of extinction throughout all or a significant portion of its range) insects Quino Checkerspot Butterfly Euphydryas editha quino (=E. e. wrighti) 0 Endangered (A species in danger of extinction throughout all or a significant portion of its range) Mammals IME 0 Pacific Pocket Mouse Perognathus longimembris pacificus Endangered (A species in danger of extinction throughout all or a significant portion of its range) Critical habitats Potential effects to critical habitat(s) within the project area must be analyzed along with the endangered species themselves. THERE IS NO CRITICAL HABITAT WITHIN THIS PROJECT AREA Migratory birds Birds are protected by the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act. Any activity which results in the take (to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct) of migratory birds or eagles is prohibited unless authorized by the U.S. Fish and Wildlife Service (1). There are no provisions for allowing the take of migratory birds that are unintentionally killed or injured. You are responsible for complying with the appropriate regulations for the protection of birds as part of this project. This involves analyzing potential impacts and implementing appropriate conservation measures for all project activities. Bald Eagle Haliaeetus leucocephalus Season: Wintering Bell's Sparrow Amphispiza belli Year-round 0 0 Black Oystercatcher Haematopus bachmani Year-round Black-chinned Sparrow Spizella atrogularis Season: Breeding Brewer's Sparrow Spizella breweri Year-round NM 0 Burrowing Owl Athene cunicularia Year-round Cactus Wren Campylorhynchus brunneicapillus Year-round •=1 0 • =1 0 0 ..= 0 =MI 0 NM 0 Costa's Hummingbird Calypte costae Season: Breeding Fox Sparrow Passerella iliaca Season: Wintering Green-tailed Towhee Pipilo chiorurus Season: Breeding Gull-billed Tern Gelochelidon nilotica Season: Breeding Lawrence's Goldfinch Carduelis lawrencei Year-round Least Bittern Ixobrychus exilis Year-round Lesser Yellowlegs Tringa flavipes 0 Season: Wintering Lewis's Woodpecker Melanerpes lewis Season: Wintering 0 Loggerhead Shrike Lanius ludovicianus Season: Wintering Long-billed Curlew Numenius americanus Season: Wintering Marbled Godwit Limosa fedoa 0 Season: Wintering Mountain Plover Charadrius montanus Season: Wintering 0 Nuttall's Woodpecker Picoides nuttallii Year-round Oak Titmouse Baeolophus inornatus 0 Year-round Peregrine Falcon Falco peregrinus Season: Wintering Red-crowned Parrot Amazona viridigenalis Year-round Short-billed Dowitcher Limnodromus griseus Season: Wintering Short-eared Owl Asio flammeus Season: Wintering Tricolored Blackbird Agelaius tricolor Year-round Whimbrel Numenius phaeopus Season: Wintering Yellow Warbler dendroica petechia ssp. brewsteri Season: Breeding Red Knot Calidris canutus ssp. roselaari Season: Wintering Wildlife refuges Any activity proposed on National Wildlife Refuge lands must undergo a 'Compatibility Determination' conducted by the Refuge. If your project overlaps or otherwise impacts a Refuge, please contact that Refuge to discuss the authorization process. THERE ARE NO REFUGES WITHIN THIS PROJECT AREA Wetlands in the National Wetlands Inventory Impacts to NWI wetlands and other aquatic habitats from your project may be subject to regulation under Section 404 of the Clean Water Act, or other State/Federal Statutes. Project proponents should discuss the relationship of these requirements to their project with the Regulatory Program of the appropriate U.S. Army Corps of Engineers District. Freshwater Forested/shrub Wetland PFO/SSC 90.1 acres PSSAx 0.131 acre it VOICE 11 SAN DIEGO -rn STILL INSPIRES I UU MAI )1 isumn taw Mission Valley Keeps Getting More Roads and More Traffic Matthew Hose December 15, 2014 fhe mtersection of Friars Road and Frazee Road. Any San Diegan knows Mission Valley at rush hour is a gridlocked mess. At the intersection of Friars Road and Frazee Road, eight lanes of cars wait at red lights, backed up hundreds of feet waiting to get on the freeway. Bicyclists make the choice to either merge into the gridlock or hop onto a sidewalk as the bike lane disappears and cars zip from SR-163 onto local streets. The few pedestrians who cross the street must scamper to make it to the other side before the light turns red. For decades, Mission Valley infrastructure has mainly been developed to keep traffic moving. This has meant one thing: roads, roads and more roads. Mission Valley becomes synonymous with massive residential development and people begin to call it home, it faces a crossroads: Will it become a livable neighborhood and another piece to San Diego's City of Villages puzzle, or will it continue to be a throughway between the sprawled-out areas in San Diego? Right now, it is firmly planted in the latter. +++ With a huge influx of residential development coming in the near future, Mission Valley is going road-crazy. Like many other neighborhoods in San Diego, Mission Valley has a wish-list for community projects that need funding. The plan details over 30 of the community planning group's top-priority transportation projects for the area. All but one of the projects improves roadway conditions for cars. Projects range from restriping areas of Hotel Circle, creating new lanes on Friars Road and creating entirely new stretches of road on Camino de la Reina. The one project that didn't involve cars: a proposed pedestrian crossing that would go over they traffic-frenzied, eight-lane Friars Road at the intersection of Frazee Road. But that had to be deleted from the plans. It conflicted with a project to improve the vehicle intersection of the 163 and Friars Road. Photo by Dustin Michelson Pedestrians cross near the intersection of Friars Road and Frazee Road This presents a problem. Research now shows that building new roads isn't the answer to traffic in fact, it's the cause of increased traffic. .4)anding the capacity of roadways leads to something called "induced demand." That means it isn't demand that ends up driving the supply, but the supply that ends up bringing more demand for the roadways. So more lanes on a road actually incentivizes more people to drive down that road, and it ends up having the same or worse traffic after improvements. Compounding the problem: building and widening roads also discourages bikers and pedestrians from using the roads and makes it difficult to implement good transit systems. For Mission Valley, the logic of extending roads comes from the huge influx in residential development that's happened for the past several decades. There's the Civita development of over 5,000 new homes on the northern side of Friars Road. There's Doug Manchester's planned development of 200 more apartments at the U-T headquarters. And there's a long-idling plan to redevelop the Riverwalk Golf Course into 4,000 homes. The idea is that the throng of new residents in Mission Valley will bring more demand for road use, which means that the city needs to increase the supply of roads in order to match the demand. But if the research holds true, that means more roads in Mission Valley will just mean more traffic in Mission Valley. Level of Service In San Diego and in cities across the country, traffic engineers in the 1960s began using a concept known as "level of service" to measure roadway success and to decide when to improve streets. It's a standard operating procedure among traffic engineers and planners that gives a report cardstyle letter grade to a section of road based on how long cars are delayed due to congestion. Typically, if cars are waiting anywhere above a minute to get through a red light or a section of highway, then that road needs improvements. Photo courusy of ?co l licks The arrival of highways and interstates in the 1960s helped turn Mission Valley car-centric. It was a concept that led to bigger and bigger streets and helped to shape the interstate system. But as cities grow, and more people move in, level of service on streets tends to keep getting worse unless planners add lanes of traffic to the streets. There's a domino effect at work here: The more lanes of road, the harder it is to put in bike lanes. The more lanes of road, the faster cars can drive down city roads, which makes the roads re dangerous for pedestrians. And the faster cars can go, the farther people can drive to get to work, which creates more sprawl. Further complicating things, the concept of level of service is couched within California's Environmental Quality Act, or CEQA, the state's landmark environmental law. Among other things, the law can hold developers liable if a project increases traffic on a certain road. If a developer or community planner doesn't want to be sued for increasing traffic, the easiest thing to do is build more lanes. But Joe LaCava, chair of San Diego's Community Planners Committee, said that won't help. "You can't physically do anything about the traffic anymore," LaCava said. "The road system is the road system." A Mindset Shift Mission Valley is at the middle of a major culture shift, said Brian Schoenfisch, a senior planner for the city. It's a change in mindset happening in neighborhoods, cities, the county and the state all at once. In the next three years, Mission Valley planners and engineers will be drafting the first major update to its 1985 community plan. Schoenfisch said he expects public transportation, parks and alternative forms of transportation will be vital pieces of the plan. He also expects full implementation of the San Diego River Park Master Plan, a project to create a continuous, 17-mile-long park along the banks of the San Diego River. The park would dude pedestrian and bike paths from Ocean Beach through Mission Valley and up to Santee. Schoenfisch's vision falls under the city's established plan for how it should grow and absorb more residents, called its general plan. The general plan envisions San Diego as a "city of villages" that emphasizes dense housing near transit centers, with walkable streets and stores nearby. It's a concept that goes against the roads-first mindset. Changes to state law could also facilitate that shift. This year, lawmakers passed a bill that will change the way CEQA measures environmental impacts on traffic, shying away from the level of service metric. Under the new bill, the Office of Planning and Research is drafting revisions to CEQA which will not allow developers to use "traffic congestion" as a basis for an environmental impact. State officials will likely swap in a new measure called "vehicle miles traveled." This looks at how many extra miles cars will drive as a result of the road changes, instead of congestion. It gives points to public transit, biking and walking, and it eschews more cars on the road. Kip Lipper, a state staffer who helped draft the new legislation, said the switch is going to have a profound impact on development and traffic in California. "This change gets away from the giant thoroughfares that you see all over Southern California," Lipper said. LaCava also said that the change will give planners in neighborhoods like Mission Valley more leeway to implement crosswalks, bike lanes and bus lanes. Too Far Gone? The concept of building out roads through Mission Valley worked when it was just a waypoint to get from outlying neighborhoods to the center of San Diego, or to get to the beach from the east. But now, Mission Valley is quickly becoming a bustling neighborhood in itself. Mission Valley is in a tough spot geographically though, Schoenfisch said, because it serves a dual role: It's both a neighborhood with a rapidly booming residential sector, and the geographic center of the city that serves as a vital connection to other areas. "it's a big challenge because many of the major freeways that are in the San Diego region cross 11irough Mission Valley ... but at the same time, it has that neighborhood component. This is where people live, this is where people shop and this is where people work," Schoenfisch said. But if history is any example, residents have reason to be skeptical. The valley has been noted for its haphazard planning, with the community not adopting a development blueprint until 1985 despite big hotel developments there since the 1950s. It doesn't have any schools, was slow to bring in a library, and doesn't have any big parks. And, despite all of the big ideas, the roads keep getting built. This article relates to: Community Plans, Growth and Housing, Infrastructure, Land Use, Neighborhood Growth, News, Public Transportation, Share Stay up-to-date on stories like this. Sign up for a VOSD newsletter. Written by Matthew Hose Matthew is a freelance contributor to Voice of San Diego. You can reach him at mafthew.hose@voiceofsandiego.org. PARTNER VOICES NOTES TO USERS LEGEND nvoco.A. l=7.7.17===7•47.1747: rrt -I 1,[i•olui.n.lra 14..1 worevot 1 . :1; rrid7= iZs 4. 67.7 .774 .7=0ZL7:4 ypg, ia • a Ammon., ,r•AA A.M.* 1.•••• mook NIA ..A...PIAANYala Aaa •••••=m• =.: ."' Fr.:=1:1•••==•=70 I.R ."7"" .1 memam.m.A.Anno-ome•AA••••....•••••••....... n21 99. 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City of San Diego SEISMIC SAFETY STUDY Geologic Hazards and Faults Updated 2008 gag Disclaimer IMmiellee primal en MN mem Is Musa" legalese F. *raft mimeo aud NMI sel he mestniml es AMNON Mks Dm smells MN The lelmmess presesled le • celedlen MIAs meet NNW mulable dale .8 the Um se emplailso A. Ilmelt el IN MI emelien NY tim Ansel hem rime sl d'art's mein, Se mama Is WAN Development Services Department Eery nhatakikle Merl lus Me made tome. the seasam ei e,l. em. Hemmer, imam the NAM peillchimis Der UM Diew DM PaseemIN C.110180. SUM. my IMMO erlAng ism Ns ma NINE MPS ARE NOVIDED WITHOUT WARRANTY OP ANT MAD EITHER EXPRESS ON MIMED WELKIN], SIR NOT UNITED TO, THE IMPLIED WARRANTIES OP MENHANAMLITT AND Mime FORA PARTICULAR WIRPOIE PROPRIETWIT INDRMATEN TM NA. el UM Merinutlen I. payment le seNcesse emsmimit enly. Am maims Mem sine eflorimmees meAMIN, eicepl Is &awed sem NM melt milMemsehm se munents. SAN DIEGO SEISMIC SAFETY STUDY Introduction The first edition of the San Diego Seismic Safety Study (SDSSS) was completed and adopted by City Council (Resolution 211594) on September 18, 1874 to comply with California regulations requiring cities to adopt a Seismic Safety Element within their General Plan. The original maps, issued in 1974 and updated In 1983, have been revised and upgraded to reflect the latest interpretation of the geologic features and to streamline the site review process. The new maps are poduced at a larger scale (1 inch = 800 ft.) and in full color, incorporating the most advanced GIS computer mapping capabilities. The GIS computer-based system provides easy public access to the latest version of the maps. quick evaluation for permit processing, and timely maintenance and upgrading of date. The SDSSS can be used to determine what geologic conditions are likely to underlie your site. The study consists of a series of maps showing locations of faults and other geologic hazards which are suspected or known to exist within the city of San Diego. This information is necessary for determining which level of geotechnical review will be required by the city when applying for planning, development or building permits. Index MO MAD 27) Legend 1701 am p 54 FA 11 Active. Alumni-Mob Earthquake Fault Zone 1713 12 Potentially Active, Inactive, hem:led Inactive, ca Activity Unknown 1737 49 12 13 Downtown special fault zone 52 322 47 &AM 48 IN/ Faro -42 43 38 39 34 35 36 29 30 31 32 2 25 26 27 ./s v Inferred Fault • 15 • • Concealed Fault Shear Zone Zr, —V— Rambo° verde.' fault movernul Fault Zooce represent portable limns atter, alich &mks could be located. Ana cooper required due to possible plotting error fun !different male of mauve maps end IL.Uf fey of pleb and The new edition contains several Important changes that will shorten the review process. Geologic Hazard Categories and Fault Zones are now shown on a single sheet instead of two separate sheets, and the GeolechnIcal Lend-Use Capability sheet has been eliminated. A revision and expansion of the Geologic Hazard Categories, a larger map format end scale, and the precision of GIS computer software has allowed the elimination of two-thirds of the old maps. This edition simplifies and consoldetes the review process for all city departments by utilizing the same criteria (Geologic Hazard Categories) for site evaluation. 760 FAULT ZONES ovaday. All fault locatkow ere blued on the best interpretation of mailable Arta r4 the lane of amtpileliao. Ohm, due to the extreme di Ilerenees in mule between the dam aute and ,tie up. intetprentacto of the fault iefeired furl, and cmceeled feult was required. wars Thor is shah &wee., medal:ay that the fault loution maill lie within the limas 1151513 linen are included to indicate .weed um for explorelion in ord. to woorescly locate the 911 33 20 210 18 .4 104 How To Use the SDSSS The procedure for determining which level of geotechnical study is required by the various city departments for planning, development or building permits differs slightly, based upon the type of permit sought. For permits dealing with land-planning and land-development (i.e., grading, public improvements), refer to the procedure described in "PLANNING AND DEVELOPMENT PERMITS" on sheet 2. For building permits. refer to the procedure described In "BUILDING PERMITS" on sheet 3. 71 1% 146 Disclaimer The information presented on these maps is primarily intended for planning purposes and should not be construed as definitive data for a specific site. The information presented Is a collection of the most readily available date at the time of compilation. As much of the information was transferred from maps of differing scales, the accuracy is limited. 1757 k4i7:4 i:453217:..-27761‘,, 1741 1711 130 pare Sheet 1 SAN DIEGO SEISMIC SAFETY STUDY: PLANNING & DEVELOPMENT PERMITS Type of Hazard Ground Follow this procedure to determine which level of geotechnical study is required by the City for Land-Planning and Land-Development permits: Table 2-B Table 2-A i u. in fWin, f". Rupture Geologic Hazard Categories -Ncereril RelotIns REP Low asia* 11 Mahe, Sokol24-Pololls 61.1114mb NMI Zorn • la pdmiooyaoolm • beelles.114suresd IMIes, sr Retell Mum, 13 001.1111...n *MI fed owe • , 5 Slope • 7.4 Frbt kslimorsOls to kyle mans Instability — 0 • • • • 26Aralte mrseembe polook sInmlft • 1.Referring to the Index (Sheet 1), find the map sheet number containing your site. Turn to the proper map sheet and locate your site. Roam Foollias, Lam Dare lffld Regfcml Elmical bower Gmatine Mots 2. From the map, determine the Hazard Category for your site. The Hazard Category is identified by a specific number (11 thru 55) and color code. Refer to Table 2-A fora description of the Hazard Category and the relative risk assigned to the suspected type of Hazard. 143.6m114 Rio, Poke. Etrasooroy Carrervalcabon Foades, CrikalTranaporeasom Elmmola, nal, es erklws. Owewusek Semler Dom Mame Ugly Coma UMW. Clam:hos. tunie or HOW. Illalleibus. or other Mom Warmly Airmilng Lam Commotions ol Poo* DWI.. CW Rulings. L. Commercial Somme, Mel Reek, OM Miles, Graeae, a Rooldentiol (214nols-Fanify Rookiences, Rporimets, oir,3 Mom Comerclaf arcrIAMPublle Smarm 3. Determine the Building Type/Land Use Group for your project per Table 2-B. V Nina oesustollat OMer Miner Cosnromdal (Wamomee, Masses, Docks, 1.4aanas) 4. Referring to Table 2-C. determine the required geotechnical study for the Building Type/Land Use Group and Hazard Category at your site. VI Aorlalm, P. • 211.Matla Motor Menelo roloolo olnaluir I I Ill 0 211 Fart aimi or rembls pelage. MM. i • • Z/ Pomble er callombel Potential Building Type/Land Use Group ], I • 21 ColVirmoi Imre at highly eapeoad 5 High Op.. SP4.4 0 My, bmabbior. el Won Potential Ground Failize ']1 M Igh 1.0101•11- aglow swarm* f•Mbe *Was" Male Mb i i • 12Lam PoloOdel - fluuboOng plemisolur Table 2-C Required Geotechnica! Study • Mor Mom 47 Gem*/ analog; Num. ImbIN., MO 444P bluffs, mmentomalissrable yob& sinam f Coastal 1 Muff 1 Stability -- I • 43 Guard, wobble llama* }Mks MI hifmrosioa • • 32, 42-45. • NOMINAL TO LOW 51, 52, 55 63 Lail or AM/ itortio Mamma 'Mole Annum Lembo sessebnis el* 31,41 12. 22.21. I-V MA IN VI I-V I-V IV 1-111 53. 54 • • I --- •sweiyofft.in,ora.rii..f....0.011 > ' Is•luele IWO" Meer rib . — 55 PAW Did Weis lybOsel 10441 _ _ _ Mogi rlsk • fib Cm** poiceIc MM. town* , LOW TO MODERATE 41 eledisoMtable Soso reambis polo* Ohre" 11/114 sr no maim • GEOLOGIC GEOLOGIC HAZARD SOIL RECONNA25INVESTIGATION CATEGORY SVVESTIGATION SANCE • • 51 Lovil mas -usarbln by arm emit srW MOM RELATIVE RISK 11,13,21, • 41.GelerMy Amble bob WW1 nu, avekcet turbo. • MODERATE To HIGH 44 Meow* MN Mostly stslolo forMlont, PM legh mien 45 1.4.11.r.bly bib Sano Moo limiiiiiiso Mimaslon ...raerux •stOthr busied... osntly dopier lam. liaoln. All Conditions 42 Cmataly artoshIs ti tormIng plelra. bk5,4. 5.5 Famish retook Mem mks* or mambo or. OnItiliss 1/ Other • 47 Orly VIOL t • • • 4160 • 446 -7::77.44 a —W. .76: Sheet 2 SAN DIEGO SEISMIC SAFETY STUDY: BUILDING PERMITS FOOTNOTES TO TABLE 145.1802 1.1{seard Ctsgety. Ter Hued Clown cinder Its geolopheens or maw impeder it de eh. Thu Herd Cavern le &WNW by Werra to le mare City of Sin doge Mese SeleY Rosh eirelle) liefe leading, othotem we haft &sew A. B.C. WO. A- CP. A relies Oh lalerIng 13 &sorrel Feelers se &lined le Breen 11043 alma Caere, Belding Cads. 2)Any hulking, Pod" or Way sem b the °Plan err &deep rellaW, sleeked prenthes or deep albedo. hued" or &mese* needs rsi acre. Oilifeele d Owl mire& wr W noassad sessolres net em rises they present B. till B heed. ten folading dersiohnoes, oncressey weeps, mad ortioiers peek' goy s& nal PPM in Class k 1) Pi daseepresee carsitille cif her areas strodorn. a AI now inchers were Pep herdlike. Pm or pings). 3) AI be Dery .car Pee dories In Pier /4 AI trick go aosteleirig !he %brim mcopeodes glee tO e17 Grande Bailed Cad/, Chapin 23: 0- &Tee e. Melons 1, Usage. b. Gaup E. crane LI, Dlesiaos1, 2 aid 3, Diem. 1, 2 and 3. RAI baldest PS An creepie lead of ern than lino horsed Bee paean, ▪ dabrierod belies 1144 dile Unreel Belding Code. Toile bee Meter eke. ind else sleep sirederes dm en ha PPP harhered (BAH) gem epodly beaded to ewe took, Undoes, or lemma* eerie* he in not morhtiel ter, sirschnr. or hate in Cho A. 73 Toter Nor hopper, dos, me draw stains aver %keep Be lest Vows reelthidelh• el) ht me. e Retaining rte (height la paind iron the top al it. faadeg 10 Ma tip of the wee e. Rateeleg vas we 12 he le Might. b. Regina rib awl path Wyeesppaegr sweep or retoitileg beds leardeses. treemesbe erebeh. e Retiree eels Neardes4 reit Owlets, leered le lealieob C. Chu C heeds@ So ralseing pommy pep and rinsehros peeled Ire re not heeded In Closes A or Eh 1) Al hidings oerdaleng les Mowing compralos lure la Califon& Mai Cod., Chapel: Mellen 2.3 and 6. ▪ b. arms B. c Group E. aerate F, thisiono 1 and 2. ▪Greer 11, desire end S. Croup I, Belem t g. gawp le 14 an,* Belgians 1 led 2, L Gi0IP B. Crieekr 1. a Rdenei wls prdyeb siren ham be top of the Otero to the bp al fa, edy. ▪Reeler...pis ow I fest le Wilt A. Reeking vies rimy Might stegerthe secharge or toldeing heardoth, ter ihnesids canter& 31 Tees, bits, happen, eke, and cher dams ernehrres istrodod h star hie, immix., ebonies Santee. Tanks, hip happen, .des, cad shier stretrans age tar* PI leder& 3) Tamen weer he high. O. Clots 11) bee., ihe Oaken ocoupory greens re sitaremors parldsd thy ent net Includel In Moses A, Boor C.: 13 AI bedew meddle IP logoeleg wagerer (Rte h5 Cdfami Buichg Cada, eloper 24 ✓evue R. Weskits 28,44. Follow this procedure to determine which level of geotechnical study is required by the City for building permits: T. Fade led WI Zeros -Huard Cslegoiell, 12, ad 13. AMP and Beene* KIM bulls ad Pend lo do mod mast sedan of ireilieplme Aired bees Y taillersie" Spoil Prlikagan 47, cereals Deprirend of Cogwheel. illesian diem re thew, s copy of PIM Is an Ile Mee sem ales City Clod ss Docesent lia.111411772-4. 1.Referring to the Index (Sheet 1), find the map sheet number containing your site. Turn to the proper map sheet and locate your site. Fisk men Peas tes Pie vier whici halts re suspects& Fre ton Is Yak& Is Alqiisterioto Eerie. sirs /sue Zoo., The Derirtrie Spachl Felt eaters we es Me sie4101 feet on both sides dew baifee indicated an the curse en Pap Wank Betty Bledy 0012133) Pp. ROW le BUM map far lender, dines and took aortas. 2.From the map, determine the Hazard Category for your site. The Hazard Category is identified by a specific number (11 thru 55) and is color coded. The Daentren Spode Fait Zees camel al an rie *Mehra al h. Wormier stem chrterlins of Leavi etreolegol the marks of Herm Mt Sasso In gime wedeln and ovethushistly civetlee along Or eintererre aflame Sheet hes Istarsoden oleo mess el Haar Odes, thanes rettorly es intoresollos St em U B Bibbed M dlw Orgo Boy, grime In spiral seta* ad seelisaseds emcee gong sea Bailesed In to on Perham of IN a ragemetely prolpgathe alts heielno al Me SPA, Oren Pepe longer optedlne of 21111 Shanties. lelsneolon des ordwerto of Coop else Bagenni, theme rareristerly ere the weeks el Own Vise Severed her iniroreen of thscorstehe al2211 Brest le the Iniepelen stir cerierles al Feiss Beeireard, thanes welly den en iseangagen a/ rid eseorite d Fine Beekval la Is loierpolleo a/ gm ointelin• at iliermy 45, them he wee afire onduologiyillaweal shag es orderer 01 ▪ kite the ishoserthe des ember of Noised 165,11hres puree Bode* along tie embalm al Fiteele1111,60 PohtalPim dspbedee, I. liqufadien Pemba/-Hazed Crispy di cad 32. Bhp se Wheedler le reheat diets to Becton 1102 ales 2147 Corositie BeigIng Cads for Prawn niquirosaints, 3. IlsoleiredbporL Arepeldlspairenkelcedren b mend fasts rem sphicede here AIM eisperisr pier b Preen eliselleg Pend. The wasted d ire antedo. hawing share pelage reconnaissance, of in Irdepth dish Inbar eel Prir led arifole, sparse inentlgeffie„ Ito pease mare memo rogertind gm peep Iseestipdas resat real Iodide 01 perm roptorents K otleieshed by Baia, Or Al mock sip s pra prod Is hoodoo Pit Ms restruceal seer. el Ss Cky al ha Dego neared eireelered Cheer" en Ms mote mom'. melee He 4047222.5. These minims rehirsinall she le seentesd pane middies parried le the type al proposed pope and 002123peod =teed of ocrenellas, Pee sere ha eleselsol le he MM. For baking@ read h bee a MP lop end • heed category gene es nine ntotredve rehirement she govern. 3.Referring to Table 145.1802, determine the required geologic study for the Hazard Category and the proposed Building, Structure, or Facility Class (A, B, C, or D). The footnotes to the table are provided to further clarify the procedure. Table 145.1802 Required Geotechnical Investigation 5 Hazard Category' Building, Structure, and Facility Class' 111, 137. 21, 31', 41 A, B, C, D le, 22, 42-48, 54 A, B, C. D 23.27.321 A, B, C 51, 52. 53. 55 A. B NOTE: Refer to Municipal Code section 145.1802 for complete foundation investigation requirements. Rsprdles al tiro reedrennts ar This 141802, the BuBigMloil nay mem s gooier ierernelesates nport a ■ peep boostigehan report la any ate If the Be kite Deed has woos to below Ohl I penile herd my Wit k dire see lbw No peak* knestigglons re Nand for manrocy Comp rya .7 yaw, grucers of +siredir minor Men. 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July 20, 2015 ATTN: Martha Blake, Senior Planner, City of San Diego Development Services RE: Comments in response to Notice of Preparation for Draft Environmental impact Report for Stadium Reconstruction Project; Project No. Not yet available; SCH No. Not yet available; Community Plan Area: Mission Valley, Council District: 7 Include a San Diego River Park as one of the Options in the required Alternatives Analysis I am submitting the following comments for the above referenced Stadium Reconstruction Project. Please include in the Draft Environmental Impact Report (DEIR) an alternatives analysis for a San Diego River Park utilizing at least the same amount of acreage as proposed for the Stadium Reconstruction Project. This alternative will meet the project goals of providing updated recreation facilities to enable San Diego to continue to host recreation events such as family entertainment events, concerts and meeting activities. A San Diego River Park would be beneficial for the public and visitors alike because it could provide new and updated recreation facilities. This would enhance public access and enable San Diego to increase the number and type of recreational events and activities at the site. Examples include such things as providing an amphitheater for concerts, festivals and entertainment events, a recreational facility, soccer fields, ball fields, running tracks, hiking trails, public meeting and gathering spaces and open space.The site is situated close to transit, including the trolley. A San Diego River Park will help address the park deficiencies in Mission Valley, while providing recreational and economic value as a regional asset to our existing park, recreation, and open space system. There is an identified funding source for at least 20-acres of the park and opportunities are available for funding additional acreage. The inclusion of a San Diego River Park in the alternatives analysis serves a dual purpose, because the information can be used for the Mission Valley Community Plan Update. A San Diego River Park has been contemplated for years, and is already discussed in existing City planning and financing documents including the Mission Valley Community Plan, the 2013 Mission Valley Public Facilities Financing Plan and the San Diego River Park Master Plan. A San Diego River Park at this site is also consistent with the City of San Diego?s General Plan, including the basic principles, core values and the recreation element. Mission Valley Community Plan (MVCP) The 1985 MVCP recognized the lack of public parks in Mission Valley: ?The need for active and passive recreational opportunities will increase as residential development increases in the Valley? and identifies City?owned land in Mission Valley as a location for park facilities. The MVCP also discussed financing with possible ?incorporation into a facility benefit financing program (FBA), financing as a condition of approval of any San Diego Jack Murphy Stadium reuse program; and/or other means found feasible during the implementation studies.? Unfortunately, very little has changed since 1985 to address the park needs. Mission Valley is still park deficient and has only one dedicated public park, Sefton Field, located within the community, with approximately 8 usable acres. Another 17-acre neighborhood park is being planned within the Civita project as a required condition of the development. A San Diego River Park will help address the existing park deficiencies, while providing added value as a regional asset to our existing park, recreation and open space system. In addition, an alternatives analysis will serve a dual purpose because it can be used for the Mission Valley Community Plan Update.The City of 2 San Diego recently held a public workshop to begin that update which includes issues such as recreation and the San Diego River Park and Open Space. It is possible the same consultant (AECOM) who is working on the Stadium Reconstruction Project will also be working on the Mission Valley Community Plan Update. On May 12, 2015, the mayor requested and the city council approved ?Four As-Needed Planning ConsultantAgreements with AECOM, Dyett Bhatia, Place Works, and RRM Design Group? for a total value of $8.5 million. The anticipated work includes assisting staff with ?3 comprehensive community plan updates, according to the Request for Human Resources Approval for Purchase Requisition. Mission Valley Public Facilities Financing Plan (PFFP) The 2013 interim update to the PFF ?considers the cost for a community park and calculates a public parkland requirement for the community, which equates to 2.4 acres per thousand p0pu/ation. "According to the PF P, the required park acreage needed to address current and future needs just in Mission Valley is approximately ?96.80 acres.? ?The entire park acreage and projected population is used in determining the park component of the Development Impact Fee (DIF). The DIF provides a funding source for the park improvements and is paid by new development at building permit issuance.? ?Possible sites for neighborhood parks could be in the vicinity of the Levi Cushman development and in the vicinity of Qua/comm Stadium for the community park as recommended in the community plan. In order to meet the standard of 2.8 acres of parkland per 1,000 population set forth in the General Plan, the City may impose additional fees on discretionary projects on a case?by?case basis.? Although a financial analysis is not required by CEQA, it is helpful to know that funding sources have already been identified in the PFFP for a 20-acre community park. It is estimated to cost $17,876,260. The PFFP assumes the community park would be located on city-owned land in the vicinity of the stadium and therefore no land acquisition costs are included. 3 The PFFP also states, ?As an assessment Option, physical improvements, ?nancial or land contributions for improvements, or development of public facilities such as parks in lieu of direct payment of assessments may be considered. The magnitude of the future public facilities required in Mission Valley strongly suggests that the landowners and responsible government agencies work closely together to minimize cost and ensure their timely installation.? This option could allow developers to build the public park and associated recreational facilities at the stadium site. In addition, because the City of San Diego owns the land, it could be utilized for mitigation to potentially offset impacts from new development projects in Mission Valley and areas in close proximity. San Diego River Park Master Plan The describes the importance of the entire reach of the San Diego River Park and explains how the City of San Diego would benefit. ?The San Diego River Park will unify the City. Every neighborhood in and adjacent to the river valley should connect to the San Diego River Park, linking each of these neighborhoods to the City?s other great parks and to each other. In addition, developed parks are proposed along the river, offering an even larger spectrum of experiences to park users. The river park will also connect isolated pockets of devel0pment along the river with established neighborhoods, knitting the valley as a whole and cultivating a river valley identity. ?The San Diego River Park?s most significant benefit may be its ability to create a new way to see the City. By linking two of the area?s richest natural and recreational resources, Mission Bay Park and Mission Trails Regional Park, the San Diego River Park will offer a new way to recreate and move within the City. The San Diego River Park stands to become as vital a resource as the City?s other great parks. Together with these two existing parks, the San Diego River Park will create a distinctive and identifiable park infrastructure which will become a source of pride and contribute to a new identity for the City. 4 The following is specific to the Stadium Reconstruction Project site. Part of the project site is envisioned as an active recreation area including such things as ?ball fields, soccer ?elds, an amphitheater, active sports complex and a natural children?s play area. ?This site is the last remaining City?owned property that is large enough to be in scale with the river valley. A river-oriented community park could provide public recreation facilities adjacent to the naturalized open space San Diego River Park, which would complement Mission Bay Park and Mission Trails Regional Park.? It is a ?critical location for meeting community-based park and recreation needs in Mission Valley, as identi?ed in the Mission Valley Community Plan? and there are ?no acquisition costs required; land is currently owned by City of San Diego.? General Plan The General Plan integrates guiding principles which describe its essential structure and ?reflects the core values that guide its development. ?The first core value listed is: ?An open space network formed by parks, canyons, river valleys, habitats, beaches, and ocean.? The General Plan?s Strategic Framework Element includes our physical environment as something we value and includes the following: future that meets today?s needs without compromising the ability of future generations to meet their needs; parks and public spaces, accessible by foot, transit, bicycle, and car, as areas for neighborhood, community and regional interaction and convenient The Recreation Element of the General Plan also addresses the importance of parks. Its stated purpose is, ?To preserve, protect, acquire, develop, operate, maintain and enhance public recreation opportunities throughout the City for all users.? 5 Alternatives May Have Been Determined in Advance I am also raising my concern that the alternatives to be analyzed may have already been determined based on staff comments at the July 14, 2015, City Council meeting ITEM-S500: Establishment of Stadium Reconstruction Project CIP and Amendment to AECOM Agreement for Environmental Review Services). At that meeting, staff identified project alternatives in their presentation, even though the deadline for submitting public comments had not passed. However, I am assuming that, in compliance with CEQA, all public input will be reviewed and given full consideration. Possible Piecemeal Approach to Development CEQA, Section 2.1.1 states that, ?The correct and complete definition of all reasonably foreseeable elements of a proposed project is the single most important element of the CEQA compliance process.? It is next to impossible to know how much acreage is being proposed since that information is not included in the project description. Also, based upon the best public information available, it is not clear if the project includes the entire site or just part of it. For this reason, there is a concern that the City is attempting to piecemeal or segment the project by failing to mention that the plans may include more than is noticed in the NOP. If this is the case, a full and complete analysis of the entire project, not just the stadium, must be included in the EIR. The confusion regarding the project description and whether it accurately describes what the City is actually planning to build is due to conflicting public information. First, on April 1, 2015, Councilmember Scott Sherman proposed developing the 166-acre site with 6,000 new residential units, 3 million square feet of office space, some retail and hotel space and a 20 acres of park. This development plan was proposed with or without a stadium. Then on May 18, 2015, the mayor?s task force issued a report stating that 75 acres of the site should be sold to a developer to build ancillary development to help offset the cost for the stadium. All indications were that the Mayor supported the recommendations of the task force he created. However, on July 13, 2015, an article in the Voice of San Diego, stated that the mayor ?has simply dropped the idea that real estate development around the new stadium will help pay for the new stadium.? And the mayor?s spokesman said ?that although the mayor?s task force did recommend ancillary development, it was just that: a recommendation.? It appeared that the mayor had a plan to pay for the stadium that did not rely on ancillary development, but no details were shared with the public. This was a huge change; the public was now being told that the EIR had nothing to do with ancillary development and the property around the stadium, whereas before, we were told it had everything to do with it. Just two days ago, on July 18, 2015, an article by Jonathan Horn in The San Diego Union -Tribune quoted Matt Awbrey, ?a spokesman for San Diego Mayor Kevin Faulconer, San Diego is in better shape than St. Louis when it comes to a new stadium for the Chargers. He said the city already has the land for a new venue - the Qua/comm Stadium site - and a financial framework laid about by a Faulconer appointed task force. It now appears the ancillary development is part of the project. Please ensure that a full and complete project is described and analyzed in the Finally, please add my name to the interested parties list for this project. Thank you, Donna Frye State of California - Natural Resources Agencv EDMUND G. BROWN JR, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region 3883 Ruffin Road San Diego. CA 92123 (858) 467-4201 FIE-H July 20. 2015 Ms. Martha Blake, Senior Planner City of San Diego Development Services Department 1222 First Avenue, MS-501 San Diego. California 92101 DSDEAS@sandiego.gcv Subject: Comments on the Notice of Preparation of a Draft Environmental Impact Report for the Stadium Reconstruction Project (SCH No. 2015061061) Dear Ms. Blake: The California Department of Fish and Wildlife (Department) has reviewed the above- referenced Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) for the Stadium Reconstruction Project. dated June 22, 2015. The following statements and comments have been prepared pursuant to the Department's authority as Trustee Agency with jurisdiction over natural resources affected by the project (California Environmental Quality Act Guidelines ?15386) and pursuant to our authority as a Responsible Agency under CEQA Guidelines section 15331 over those aspects of the proposed project that come under the purview of the California Endangered Species Act Fish and Game Code 2050 et seq.) and Fish and Game Code section 1600 et seq. The Department also administers the Natural Community Conservation Planning (NCCP) program. a California regional habitat conservation planning program. The City of San Diego (City) participates in the NCCP program by implementing its approved Multiple Species Conservation Program (MSCP) Subarea Plan (SAP). The proposed project site is located within the existing footprint of the Qualcomm Stadium property located south of Friars Road. west of Interstate 15. and north of the San Diego River and Interstate 8. The proposed project would replace the existing stadium with an updated facility located north of the existing San Diego trolley line. The updated facility would be up to 1.75 million square feet, have a structure footprint of 750,000 square feet (approximately 1? acres), a maximum height of 260 feet, and hold 68,000 to 72,000 seats. The existing stadium would eventually be demolished and replaced with parking. The NOP does not include Biological Resources as an issue area for study in the DEIR. The Department disagrees with this assumption; we believe the preposed project could potentially have signi?cant effects to biological resources. Accordingly. we recommend the DEIR include an in-depth analysis of impacts to biological resources. The Department offers the following comments and recommendations to assist the City in avoiding, minimizing. and adequately mitigating project-related impacts to biological resources. Speci?c Comments 1. The Department is concerned about potential project-related direct and indirect effects on the San Diego River and Murphy Canyon Creek, the sensitive habitats they support, the Conserving California?s Willf?? Since 1870 Ms. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 2 of 8 adjacent upland habitat, and the sensitive species that occur in both the riparian and upland habitats in proximity to the redevelopment proposal (see Exhibit 1). Speci?cally, we are concerned about biological effects wildlife movement, behavior such as breeding activity) from both project-reiated construction and operational long- term) disturbances to these biological resources resulting from: encroachment by humans and domestic animals; possible conflicts resulting from wildlife-human interactions at the interface between the proposed development and the biological buffer; iine-of?sight disturbances: noise; light; glare; shading; and hydrological changes both within the reach of the San Diego River adjacent to the project site and 2. Based on the proximity of the San Diego River corridor, any redevelopment project (including alternatives) needs to recognize the importance of adequate and appropriately managed riparian buffers for protecting riparian habitat. Riparian buffers serve numerous functions for riparian habitat and the species they support, including: expansion of the habitat?s biological values buffers are an integral part of the complex riparian ecosystems that provide food and habitat for the fish?and wildlife they support); protection from direct disturbance by humans and domestic animals; and reduction of edge effects from, for example, arti?cial noise and light, Iine-of-sight disturbances, invasive species. and anthropogenic nutrients and sediments (streams should not be burdened by anthropogenic pollutants which often represent levels beyond their natural assimilative capacity). In determining the adequate buffer width, as measured from the outside edge of the riparian habitat, it is necessary to consider that edge effects can penetrate up to 650 feet into habitat. The Fish and Game Commission Policy on the Retention of Wetland Acreage and Habitat states, ?Buffers should be of suf?cient width and should be designed to eliminate potential disturbance of ?sh and wildlife resources from noise, human activity, feral animal intrusion, and any other potential sources of disturbance.? The City?s MSCP SAP identi?es the San Diego River corridor as a habitat linkage between core resource areas (riparian habitat and adjacent upland vegetation communities in proximity to the redevelopment proposal are within the Multi-Habitat Planning Area The City has previously acknowledged Grantville Redevelopment Project 20040711221) that for redeveloped proposed to occur along the San Diego River corridor that ?the San Diego River riparian habitat and adjacent Diegan coastal sage scrub are still areas of relatively high species diversity and abundance and provide a regional Ms. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 3 of 8 wildlife corridor? between Mission Trails Park and Mission Bay Park, and that ?these habitats and linkages are crucial for wildlife species survival and reproduction within the Redevelopment Area and surrounding region.? The above statements remain applicable for the stadium reconstruction project proposal, therefore the Department encourages the City to focus on protecting the biological resources associated with the San Diego River corridor by including design features that provide an enlarged biological buffer along the affected areas of the San Diego Riverz. The Department recommends that the stadium reconstruction proposal include a minimum 100 foot wetland buffer in order to comply with the Biology Guidelines and the MSCP conditions of coverage for least Bell?s vireo (Vireo bellii pusillus: vireo). The buffer should be designed such that post-construction storm water facilities and brush management areas are located within the development footprint and not in the buffer and adequate fencing with signs discouraging human intrusion, illegal dumping, and water pollution should be installed. Any proposal for the placement of public trails (if applicable) within the upland buffer should be kept to a minimum. Any buffer areas not already within the MHPA should be added to it and managed accordingly. Providing a wetland buffer is also important to ensure MSCP conditions of coverage for vireo are being met. The San Diego River population of vireo (CESA- and federal Endangered Species Act-listed endangered, MSCP covered) is recognized as a major population within the MSCP plan area (MSCP 1995 and 1996 Species Evaluations). Surveys on the San Diego River conducted during 2011 detected 67 territorial male least Bell?s vireo, 42 confirmed pairs, and 5 transient individuals (Kus and 20113). As a condition of coverage for least Bell?s vireo for the MSCP SAP, Area Speci?c Management Directives are to include? measures to provide for appropriate successional habitat, upland buffers for all known populations. cowbird control, and speci?c measures to protect against detrimental edge effects to the species. Although the Department may recommend a buffer greater than 100 feet for other, more sensitive areas along the River, we believe that 100 feet is a reasonable minimum for this portion of the San Diego River. 3. Aerials taken before the construction of the current stadium prior to 1966, see http:llhistoricaerials.com) show the San Diego River occupying a considerable portion of the stadium property, sweeping north and then west through the area of the current stadium in a wide, braided system. Murphy Canyon Creek can be seen running in a southwesterly direction, entering the San Diego River west of the current con?uence. In order to accommodate installation of the fill pad on which the current stadium and parking lot are located, Murphy Canyon Creek was relocated to the eastern property line, and the San Diego River was channelized and relocated to the southern edge of the property. Any 2 The Department has commented on various development proposals along the San Diego River where we emphasized the importance of providing an adequate wetland buffer in relation to the development footprint ShawneeiCGTEpDO Master Plan, Grantville Redevelopment Project, Grantville Master Plan, Draft San Diego River Natural Resource Management Plan and San Diego River Park Master Plan). 3 Kus, BE. and Lynn, S. 20] 1. Distribution, Abundance, and Breeding activities of the Least Bell?s Vireo along the San Diego River, California. 20] 1 Annual Data Summary. Prepared for the San Diego River Conservancy. Ms. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 4 of 8 plan to redevelop the site should consider returning Murphy Canyon Creek to a more natural con?guration, and allowing the San Diego River channel to occupy a greater area. Any development on the project site should be located such that it does not preclude restoration of Murphy Canyon Creek and the San Diego River to nearer their historic conditions. The development footprint should be outside the River Corridor Area, described in the San Diego Municipal Code as the 1DO-year ?oodway as mapped by the Federal Emergency Management Agency plus a 35-foot wide area on each side of the ?oodway?. The southern and eastern areas of the current stadium parking lot, despite being fully paved, are periodically subject to inundation from Murphy Canyon Creek and the San Diego River and, as such, are a component of the stream bed and channel. Any project activity that will divert or obstruct the natural ?ow of, or change or use material from the bed, channel, or bank (which may include associated riparian resources) of a river or stream, including an activity that seeks to exclude the stream from its floodplain, such as installation of ?ll to bring portions of the site out of the 100-year flood zone, could trigger the need for the project applicant (or ?entity?) to notify the Department pursuant to section 1600 et seq. of the Fish and Game Code. Based on this noti?cation and other information, the Department would determine whether a Lake and Streambed Alteration Agreement (LSA) with the applicant is required prior to conducting the proposed activities. The Department?s issuance of a LSA for a project that is subject to CEQA would require CEQA compliance actions by the Department as a Responsible Agency. The Department as a Responsible Agency under CEQA may consider the City?s Environmental Impact report for the project. To minimize additional requirements by the Department pursuant to section 1600 et seq. andi'or under CEQA the document should fully identify the potential impacts to the stream or riparian resources, including flood plain exclusion, and provide adequate avoidance, mitigation, monitoring, and reporting commitments for issuance of the LSA. 4. The DEIR should accurately and thoroughly disclose how the proposed project is consistent with the City?s MSCP SAP how it conforms to the general planning policies and design guidelines in Section 1.4.2 of the SAP, and the land use adjacency guidelines in section 1.4.3 of the SAP), and how the project would avoid and minimize biological impacts to the maximum extent practicable. Also, the DEIR should address biological issues that are not addressed in the SAP and Implementing Agreement (IA), such as speci?c impacts to and mitigation requirements for wetlands or sensitive species and habitats that are not covered the principles of the San Diego River Park Master Plan is to reorient development towards the San Diego River. The project description does not provide speci?c details of the stadium reconstruction proposal and whether additional development would be cc-located in association with replacing the stadium. Situating additional development in such a manner could result in otherwise avoidable indirect impacts to the San Diego 4 San Diego Municipal Code; Chapter 15, Article 14, Division 3, pages 6 and 7: Planned Districts, ?1514.0302 and Diagram 15 l4-03A San Diego River Park Subdistriet Components. Ms. Martha Biake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 5 of 8 River and the associated biological resources and adjacent upland areas, as well as potentially contribute to cumulative impacts. If components of the reconstruction project include windows or glass doors on the side of the building facing the River, or amenities outdoor tables) intended to attract human activities between the building and the biological buffer, we request that the project description in the DEIR include that the windows and glass doors facing the biological buffer would be of non-re?ective glass and would be treated to prevent indoor light from shining through them (see to avoid or minimize avian collisions because of re?ection during the day and disorientation from indoor lighting shining out through windows at dusk and after dark, and prohibit the placement of tables and other amenities that would encourage prolonged human presence between the building and the biological buffer. 6. The Department suggests the DEIR include a discussion about the proposed project's conformance to the City?s draft San Diego River The Department awarded the City a Local Assistance Grant (Contract P0150007) in 2001 to fund the preparation of the San Diego River NRMP. The Department received and commented on a draft of the NRMP in February 2004, but the plan has yet to be ?nalized. The purpose of are to ensure the implementation of the management goals and objectives of the MSCP Framework Management Plan. also include Area Speci?c Management Directives for those species requiring them as an MSCP condition of coverage, and occurring within the plan area. Within the San Diego River Park plan area, these Species could include (but are not limited to): southwestern pond turtle (Emys marmorata ssp. patiida), orange- throated whiptail (Cnemidophorus beidingii), Cooper?s hawk (Accipiter coopen'i), least Bell?s vireo, southwestern willow flycatcher (Empio?onax extimus), and tricolored blackbird (Agelaius tricolor?). 7. One of the purposes of CEQA is to ?prevent significant. avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible? Guideline, ?15002 Because of the proximity of the San Diego River. the MHPA, and sensitive species and habitats that could be negatively affected by the proposed project, the CEQA alternatives analysis is extremely important. The Department is interested in the DEIR describing a "range of reasonable alternatives to the project (particularly options to expandlmaximize open space in proximity to the MHPA), 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 signi?cant effects of the project, and evaluate the comparative merits of the alternatives," as required by Section 15126.6(a) of the CEQA Guidelines. The alternatives should include an ?alternative [that] would impede to some degree the attainment of the project objectives, or would be more costly? of the CEQA Guidelines]. "The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed 5 Draft San Diego River Natural Resource Management Plan, Nov. 6, 2003, produced by Merkel Associates on behalf of the City of San Diego, Park and Recreation Department; as a deliverable for Local Assistance Grant Ms. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 6 of 8 decision making" [?151 of the CEQA Guidelines]. For example, the Mission Valley Community Plan (October 2008) identifies proposals to provide a community park (as an active park, oriented to organized sports) in the vicinity of San Diego Jack Murphy Qualcomm Stadium and utilize the San Diego River corridor for passive recreation. Any consideration given to such a proposal should ensure that the least intensive activities are adequately buffered from environmentally sensitive lands along the San Diego River corridor. The Department will consider the alternatives analyzed in the context of their relative impacts on biological resources on both a local and regional level. 8. The project description in the DEIR should include the use of native plants in the landscaped areas adjacent to the MHPAibiological buffer. The applicant should not plant, seed, or otherwise introduce invasive exotic plant species to landscaped areas adjacent andlor near native habitat areas. Exotic plant species not to be used include those species listed on the California Invasive Plant Council?s Invasive Plant Inventory. This list includes such species as: pepper trees, pampas grass, fountain grass, ice plant, myoporum, black locust, capeweed, tree of heaven, periwinkle, sweet alyssum, English ivy, French broom, Scotch broom, and Spanish broom. In addition, landscaping adjacent to native habitat areas should not use plants that require intensive irrigation, fertilizers, or pesticides. Water runoff from landscaped areas should be directed away from the buffer and contained andlor treated within the development footprint. 9. All construction and post-construction best management practices (BMPs) should be located within the development footprint included in the impact analysis for loss of habitat). The DEIR should include a figure(s) depicting the location of BMPs in relation the development footprint. Additionally, all post-construction BMPs such as grass swales, filter strips, and energy dissipaters, should be outside of the riparian buffer and the riparian corridor they should be within the development footprint). All filtration and attenuation of surface flows provided by the proposed BMPs should occur prior to the discharge of the flows into the buffer areas. General Comments 10. The DEIR document should contain a complete discussion of the purpose and need for, and description of, the proposed project, including all staging areas and access routes to the construction and staging areas. 11. The document should provide a complete assessment of the flora and fauna within and adjacent to the project area, with particular emphasis upon identifying endangered, threatened, sensitive. and locally unique species and sensitive habitats. This should include a complete floral and faunal species compendium of the entire project site, undertaken at the appropriate time of year. The DEIR should include the following information. a) CEQA Guidelines, section 15125tc), speci?es that knowledge on the regional setting is critical to an assessment of environmental impacts and that special emphasis should be placed on resources that are rare or unique to the region. b) A thorough assessment of rare plants and rare natural communities, following the Department's Protocols for Surveying and Evaluating Impacts to Special Status Ms. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 7 of 3 12. 13. 14. 15. Diversity Database in Sacramento should be contacted at (915) 322-2493 or to obtain current information on any previously reported sensitive species and habitat, including Signi?cant Natural Areas identified under Chapter 12 of the Fish and Game Code. d) An inventory of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect. Species to be addressed should include all those which meet the CEQA definition (see CEQA Guidelines, ?15380). This should include sensitive ?sh, wildlife, reptile, and amphibian species. Seasonal variations in use of the project area should also be addressed. Focused species- speci?c surveys, conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable, are required. Acceptable species-speci?c survey procedures should be developed in consultation with the Department and the US. Fish and Wildlife Service. The DEIR should provide a thorough discussion of direct, indirect, and cumulative impacts expected to adversely affect biological resources, with specific measures to offset such impacts. This discussion should focus on maximizing avoidance, and minimizing impacts. Additionally, a cumulative effects analysis should be developed as described under CEQA Guidelines, section 15130. General and specific plans, as well as past, present, and anticipated future projects, should be analyzed relative to their impacts on similar plant communities and wildlife habitats. The should include measures to fully avoid and otherwise protect Rare Natural Communities from project-related impacts. The Department considers these communities as threatened habitats having both regional and local signi?cance. The should include mitigation measures for adverse project-related impacts to sensitive plants, animals, and habitats. Mitigation measures should emphasize avoidance and reduction of project impacts. For unavoidable impacts, on-site habitat restoration or enhancement should be discussed in detail. If on-site mitigation is not feasible or would not be biologically viable and therefore not adequater mitigate the loss of biological functions and values, off-site mitigation through habitat creation andior acquisition and preservation in perpetuity should be addressed. The Department recommends that measures be taken to avoid project impacts to nesting birds. Migratory nongame native bird species are protected by international treaty under the Federal Migratory Bird Treaty Act (MBTA) of 1918 (Title 50, 10.13, Code of Federal Regulations). Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit take of all birds and their active nests including raptors and other migratory nongame birds (as listed under the Federal MBTA). Proposed project activities (including, but not limited to, staging and disturbances to native and normative vegetation, structures, and substrates) should occur outside of the avian breeding season which generally runs from February 1- September 1 (as early as January 1 for some raptors) to avoid take of birds or their eggs. If avoidance of the avian breeding season is not feasible, the Department recommends surveys by a quali?ed biologist with experience in conducting breeding bird surveys to detect protected native birds occurring in suitable nesting habitat that is to be disturbed and (as access to adjacent areas allows) any other such habitat within 300 feet of the disturbance area (within 500 feet for raptors). Project personnel, I'vls. Martha Blake, Senior Planner City of San Diego Development Services Department July 20, 2015 Page 8 of 8 including all contractors working on site, should be instructed on the sensitivity of the area. Reductions in the nest buffer distance may be appropriate depending on the avian species involved, ambient levels of human activity, screening vegetation, or possibly other factors. 16. Plans for restoration and revegetation should be prepared by persons with expertise in southern California ecosystems and native plant revegetation techniques. Each plan should include, at a minimum: the location of the mitigation site; the plant species to be used, container sizes, and seeding rates; a schematic depicting the mitigation area; planting schedule; is) a description of the irrigation methodology; measures to control exotic vegetation on site; (9) speci?c success criteria; a detailed monitoring program; contingency measures should the success criteria not be met; and identification of the party responsible for meeting the success criteria and providing for conservation of the mitigation site in perpetuity. We appreciate the opportunity to comment on the referenced NOP. Questions regarding this letter and further coordination on these issues should be directed to Marilyn Fluharty at Sincerely, I ?j Gail K. Sevens Environmental Program Manager South Coast Region Enclosure: Exhibit 1. Sensitive habitats and species in proximity to the redevelopment proposal. ec: Scott Morgan, State Clearinghouse David Zoutendyk, U.S. Fish and Wildlife Service, Carlsbad Of?ce .o @39 . ?xt??tf o. 033.Ob.) ?0 0 co .0 iayw 9 .99. ?3 9 #090099 .900 0 'flhtan LGefle From: Jesse Arroyo-- Senl: Monday. July 20. 2015 5:03 PM To: DSD EAS Subject: Stadium EIR suggestion Heller 1 served on Charger ten years (2001009) under the stadiutn ops manager, creative services directory and marketing department. My duties took the all throughout the stadium grounds and the building itself, inside and out. A big part of my job was fan interaction. I took feedback regarding facilities and relayed them to the stadium ops manager. 1 have several suggestions for the new stadium out the one that applies to the EIR would be to study the possibility of opening one or two roadways on the south side of the parking lot to provide access to Camino Del Rio North. Currently there is only access from the north. Camino Del Rio North has businesses that are usually not open on weekends. It will help alleviate the congestion on Friars Road which competes with the IKEA/Lowes/Cosrco shopping center and the residential rmffic. This would be a huge help! Sincerely, Jesse Arroyo 1 - Chargers 7 Union Tribune 7 DiscoverSD This Email and any attachments contain AECOM coniidential inioihiation that may be atopnetaiy oi oiiyilegeo it you teceiye this message in eitoi otare not the intended iecipient you should not retain distiioute disclose oi use any oi this inioihiation and you should destioy the ermal' and any attachments oi copies 'flhtan LGefle Attachments: Jim Peugh_post meeting MP3 From: HrenKo, Ray Senl: Tuesday, July 21' 2015 2:13 PM To: Leighton Lynette Subject: FW: Stadium Reconstruction Project/SCH 2015oo10o1 . NOP Cummem Letter Sooping meeting audio Pant at 2 Ray Hrenko Vtoe Prestdent/Prmcipa1 Enwonmem AECOM 401 West A street, Smle 1200' San Dlego' Calttomta 521m ,61 9510-7600 LS1 9510-7601 aeoomoom Please note that we have moved as of December Em. Please update your Contact ii'es w1lh the above information. From: Santom' Kerry Senl: Tuesday, July 21120151:57 PM To: HrenKo, Kay Subject: RE: Stadium Reconstruction Project/SCH 20150o10o1 . NOP Cummem Letter I tried to send these an hour ago, but 1 guess the we was too urge. 1'm resending, and the tapes aflhe general meeting, and Tust sending the Jim Peugn comments (2 of them) one at a time Kerry Samara 1 Deputy DirectorI Land Deue1ooment Revtew Division 1 Development Services Department 1 city afSan Diego 1 51974465121 1 KSantoszandlega.gov Correspondents should assume that an oornmunroatron to or tram this address is recarded and may be reviewed by third parties. From: Hrenko, Ray-- Senl: Tuesday, July 21' 201512 51 PM To: State, Martha Shearer--Nguyen, Etizabelh' Shackelmrd, Kris; Ptce, Jelf' Oasem, Labib', Farah Cc: Santoro Kerry Subject: Stadium Reconstruction Project/SCH 20150o10o1 . NOP Cummem Letter Thank you Martha and Kerry Ray Hrenko Vtoe Prestdent/Prmcipa1 Enwonmem AECOM 401 West A street, Smle 1200' San Dlego' Calttomta 521m ,61 9510-7600 LS1 9510-7601 aeoom Please note that we have moved as of December Em. Please update your Contact files with the above information. From: Blake, Martha Sent: Tuesday, July 21' 201512 50 PM To: HrenkO, Ray; Shearer-Nguyent Elizabeth Shackelford, Kris' Rice, Jeff Oasem, Labib' Mahzari, Farah Cc: Santoro, Kerry Subject: RE: Stadium Reconstruction Project/SCH . NOP Comment Letter Kerry is going to download the audio we and send it along. Martha From: HrenKo, Ray Sen . Tuesday, July 21' 201512 45 PM To: Shearer-Nguyen, Elizabeth; Blake' Martha; ShacKeiiord, Kris; Rice, Jelf', OzSem, Lamb; Farah Cc: Santoro' Kerry Subject: RE: Stadium Reconstruction Project/SCH . NOP Comment Letter Liz. can we get the input from Jim Pugh from the scoping meeting? Ray Hrenko Vlce President/Principal 401 West A street, Suite 1200' San Diego' Calttornia 52101 ,61 9510-7600 zeoomoom Please note that we have moved as of December Em. Please update your Contact files with the above information. Le gluon LGefle Amchmems: Jim Peugh_addllianal.MP3 From: Hrenko, Ray Sent: Tuesday, July 21, 2015 2:13 PM To: Lelghton, Lynetie Subject: FW: Stadium Reconstruction Project/SCH 201501510131 . NOP Comment Letter Scoping meeting audio Pan 2 ol 2 Ray Hrenkn Vice PvesidemlPTinclpal Envllonmerll AECOM 401 West A street. Skills 1200, San Diego, Calitdmla 92101 +1 ,6t9.6tD-7600 Please nole (hat we have moved as at December Em. Please update your Contact tiles with the above inlormation. From- Santoro, Kerry Sent. Tuesday, July 21, 20151:57 PM To: Hrenko, Ray; Blakel Martha: Shearer-Nguyen, Shackelfordl Rlce, Jefl', Oaseml Labib Mahzari, Farah Subject: RE: Stadium Reconstruction Project/SCH 2015061061 - NOP Comment Letter Here's the Second Peung audla file. Kerry Samara 1 Deputy Dlrectorl Land Development Review 1 Development Services Department 1 Clly alSan Diego 1 519744575121 1 Correspondents should assume that all communication in or lrarn this address is recorded and may be reviewed by third names. Fro renko, Ray Sent: Tuesday, July 21, 201512 51 PM To: Blake, Marina: Shearer-Nguyen, Elizabeth; Shackellord, Kris: Rice, Jelf', Oasem, Labib: Mahzari, Farah Cc: Santoro, Kerry Subject: RE: Stadium Reconstruction Project/SCH 201501510131 . NOP cdmment Leiier Thank you Maltha and Kerry Ray Hrenkn Vice PvesidemlPTinclpal Envllonmerll AECOM 401 West A street. Skills 1200, San Diego, Calitdmla 92101 +1 ,6t9.6tD-7600 Please note that we have moved as ol December Elh. Please update your Contact liles with the above inlormation. From: Blake, Martha Sent: Tuesday, July 21101512 50 PM To: Hrenko, Ray; Shearer-Nguyeni Elizabeth Shackelford, Kris: Rice, Jeff Oasem, Labib', Mahzari, Farah Cc: Santoro, Kerry Subject: RE: Stadium Reconstruction Project/SCH . NOP Comment Letter Kerry is going to download tne audio tie and send it along. Martha From: Hrenkoi Ray Sen . Tuesday, July 21: 201512 45 PM To: Shearer-Nguyen, Elizabeth; Blake: Martha; Shackellord, Kris: Rice, Jelf', Ozsem, Lamb; Farah Cc: Sanloro: Kerry Subject: RE: Stadium Reconstruction Project/SCH . NOP Comment Letter Liz. can we get the input from Jim Pugh from the seeping meeting? Ray Hrenkn Vice PvesidemlPIincipal Enviwnmenl AECOM 401 West A street. Suite 1200: San Diego: Calilomia 92101 +1 ,619.6tD-7600 Please note that we have moved as ol December Elh. Please update your Contact liles with the above inlormation. "ghlan LGefle Subject: fw. Stadium Reconstruction a NOP Comment Letter From: Jose Quinones Sent: Monday. July 20 To: DSD EAS Subject: EIR I think the Elk should look into the growth ofadditiorial features like the expans'lan of the trolley station and also focus on the impact of the suggested river park. etherthari that i don't see much change ifthe plan is to indeediust replace a stadium for a stadium. if the stadium does manage to bring back a Super bowl. The impact ofthat large ofcrowds should be also be figured in any kind of analysis too. Anotherthing that might need to be considered is the 100 year flood. what I would like to see is how a new stadium would be more greener. Howtechnology shows a better use of energy, better use ofwater, Use of vegetation iif any), use of solar panels. Maybe show how better access for bikes and environmental friendly vehincles reduces emission in the neighborhood. Those are the major concerns that I would like to see in an EIR. Again I have high hopes for this project and hope everything gets done and done correctly so in the end we can enjoy what we put together. Thanks for taking the time to listen as well. Jose Qu'nones This Ermall and any attachments contain AECOM contidential intoihiation that may he proprietary oi piiyileged lt you receive this message in eiroi orare not the intended iecipient you should not retain distiioute disclose oi ose any ot this intoihiation and you should destioy the Small and any attachments oi copies Le Ehlan LGefle From: Jose enmes-- Sen . Monday, July 20' ms 3, a PM To: DSD EAS Subject: EIR questions Oh I forgot to indude seismic improvements ofa new facility to Show how much more safer it wou'd be than the current. Thanks. Jose 0 ones Le flhtan LGefle From: Jose Quinones Sen .Tuesday, July 2i. 2015 o, 3 AM To: DSD EAS Subject: More EIR topics I know the deadline was the 20'" there are a couple of topics I remembered over the night that I hope would be included. A few things I hope an EIR will cover includes the Noise effect ofa new stadium and if itwill improve and be contained in a new stadium, and also possible issues which affected the building of Petco Park and should be settled early this time around which include the agreed size of the River park land included amenities) and whether ifthere is any historical site/ building complications. These two issues were a source of much controversy and should be addressed because they too impact the environment. Anyways those were the three things that I thought of during the night. I hope all ofour suggestions are taken into account and I thank you all taking the time to read these. Le shtan LGette Subject: FW. Stadium Reconstruction Projett Comments for Draft Sent: Tuesday, July 21, 2015 3:59 PM To: DSD EAS Subject: Stadium Reconstruction Project Camments for Draft EIR As part of the CEQA process the project needs to consider the potential for flooding over the entire property from Murphy Canyon Creek and the San Diego River. The analysis should demonstrate that the proposed stadium and parking areas where the stadium and parking areas will be placed is relation to the areas that have historically flooded, such as in December 2010. The placement ofthe structures should ensure that they will be protected from flooding and identify necessary setbacks for development from the creek and river, and space for riparian buffers along the eastern and southern portions ofthe property. Development setbacks and buffers are critical mitigation measures needed to protect structures in the future development. The latest in storm water best management practices and low impact development design features need to be included as part ofthe project. In consideration ofclimate change and the ongoing drought condition use of recycled water features needs to be incorporated, particularly for toilet flushing and landscape in the project design. With the growth of residential and commercial uses in Mission Valley, the traffic patterns Should be evaluated to ensure that vehicle traffic in and out of the Stadium during large events is practical and efficient. Thank you. 1. Ehsen Le flhtan LGette Subject: FW Stadium Reconstruction Project From-- Sent: Tuesday, July 21, 2015 6:05 PM To: DSD EAS Cc Subject: Stadium Reconstruction Project Dear Ms. Blake, Thank you for the opportunity to respond to the Notice of Preparation of a DEIR for the Stadium Reconstruction Project. We appreciate that many items will be required to be studied as a DEIR is prepared. We appreciate that the City staff has most likely already identified many potential significant impacts to be included. We request that we receive all notices of meetings being held or materials be distributed. As a stakeholder with an interest in the health and condition of the San Diego River as well as the provision of park and other public facilities along the San Diego River and its tributaries, we are Very interested in this project. We will limited our comments at this time to: 1. We believe that in the DEIR it is essential that the project be defined more completely. . will the contour ofthe land be altered? ifso, what are the impacts to the floodway, 100 year floodplain, wetlands, required buffers for wetlands, and multiple habitat planning area? . We believe that it is essential that ifthe land contours are proposed to be altered in any of the potential project designs or alternatives, that the impact of these on the before mentioned items must be studied and included in the analysis . what are the project boundaries? is all 166 acres included or is it a smaller or larger project? . Does this project include the proposed "Purple" mass transit line and if so, this should be included in the analysis ofthis project . will the proposed park and trail improvements be separated out as a different project which could proceed before, during or after the stadium reconstruction project . is Murphy Canyon Creek drainage which runs along the eastern edge of the site included in the analysis and as part ofthis project? 2. The aquifer under the site is an important asset for the directly and indirectly associated ecosystems,  including the San Diego River. The impacts of contouring the site, including removal of any dirt to create the  new stadium, on groundwater and the surface waters of the San Diego River should be studied.     3. We request that a Wetlands Delineation should be conducted as part of the analysis.     4. The City of San Diego has explored restoration of the San Diego River adjacent to the Stadium site. An  analysis should be done to determine how this work would impact the project. Especially if recontouring of  the land is proposed wo alter the 100 year floodplain.     5. It is our understanding that a major sewer line traverses the south (river) side of the parking lot. Will this  pipe be removed or re‐aligned as part of this project. If so, what are the potential impacts and opportunities to  expand the floodway and riparian habitat.     6. Sediment has been a concern within Murphy Canyon Creek. This impacts of any proposed project design  should address how it will reduce sedimentation.     7. The San Diego River is a 303d listed impaired water body. How will this project impact the constituents of  concern?     8. Flooding has been a signficant issue within the Stadium parking lot. The DEIR should address this issue and  offer alternatives which improve this public safety and environmental issue.     9. The community of Mission Valley is significantly below national and city standards for providing public  parks.  The Mission Valley Community Plan identifies this site as one of two opportunities to address this issue.  Any project design should explore alternatives which maximize the potential to address this concern.  The  DEIR should also explore whether some of this park land could be located outside of the Floodway and  Wetland Buffer areas but within the 100 year Floodplain. The DEIR should also include an analysis of when  these public park areas would be closed or impacted by events at the new Stadium or associated areas  including the parking lot.     10. The San Diego River is an ecologically significant area. While fragile, it is also resileant.  The DEIR should  include an analysis of the impacts of the project on the ecoystem, including the aquatic ecosystem.  2 11. The placement ofthe stadium should be analyzed to provide alternatives which minimize the noise, visual, hydrologic, and biologic impact to the San Diego River ecosystem and the San Diego River Park system as identified in the City of San Diego River Park Master Plan and other documents. Thank you for the opportunity to comment on this important proiect for our San Diego River, our City and our Region. Rob Hutsel Executive Director The San Diego River Park Foundation Engaging people to create a better future for the San Diego River. Learn more at 401 Street, Suite 800 San Diego, CA 92701-4237 (679) 699-1900 Fax (619) 699?1905 sandagorg MEMBER AGENCIES Cities of Carlsbad Chula Vista Coronado Del Mar El Cajon Encinitas Escondido Imperial Beach La Mesa Lemon Grove National City Oceanside Poway San Diego San Marcos Santee Solana Beach Vista and County of San Diego ADVISORY MEMBERS imperial County California Department of Transportation Metropolitan Transit System North County Transit District United States Department of Defense San Diego Unified Port District San Diego County Water Authority Southern CaIifornia Tribal Chairmen '5 Association Mexico July 21, 2015 File Number 3330300 Ms. Martha Blake City of San Diego, DSC 1222 First Avenue, MS 501 San Diego, CA, 92101 Dear Ms. Blake: Comments on the Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) for the Stadium Reconstruction Project ("proposed project"). SUBJECT: Thank you for the opportunity to comment on the NOP for the Stadium Reconstruction Project. Our comments are based on policies included in the Regional Comprehensive Plan (RCP) and the 2050 Regional Transportation Plan and its Sustainable Communities Strategy (2050 and are submitted from a regional perspective, emphasizing the need for land use and transportation coordination, and implementation of smart growth and sustainable development principles. The goal of these regional plans is to focus housing and job growth in urbanized areas where there is existing and planned transportation infrastructure to create a more sustainable region. The 2050 sets forth a multimodal approach to meeting the region?s transportation needs. Therefore, it is recommended that the proposed project and related traffic analysis consider the needs of motorists, transit riders, pedestrians, and bicyclists, and the implementation of a robust Transportation Demand Management Program. The San Diego Association of Governments (SANDAG) recommends that the following comments be addressed. Multimodal Transportation Analysis The current San Diego River Park Master Plan (Plan) establishes an interim alignment for the San Diego River Trail pending the river park development at the stadium. As such, SANDAG requests that the proposed project take into account the San Diego River Park Master Plan (as it likely already intends to); consider establishing an ultimate alignment for the San Diego River Trail; and, as appropriate, consider ways the proposed project could support Plan implementation. SANDAG also requests that the traffic studies and transportation mitigation measures for the proposed project consider implementing a Qualcomm (Fenton Parkway) to Mission City Parkway bike and pedestrian bridge, which is included in the San Diego River Trail Gaps Analysis originally completed for the San Diego River Conservancy and updated by SANDAG in 2014. Transportation Demand Management (TDM) In considering mitigation for regional transportation impacts around the Qualcomm Stadium Reconstruction Project, consider integrating the following TDM measures: Provide dynamic message signs along Friars Road between I-805 and Mission Gorge Road to alert motorists of queues or slowdowns that result from stadium events. Provide discounted transit passes for event attendees or discounted ticket prices for attendees who take transportation alternatives. Offer secure bike parking and bike valet services to encourage biking to the stadium site. Designate a transportation coordinator to manage, monitor, and promote TDM programs for visitors and employees. Promote and provide space for shared mobility services (eg carshare, bikeshare, on-demand rideshare services) to help reduce automobile traffic and parking demand. Provide transportation kiosks that display real-time information about regional transit services and TDM programs. Regional TDM programs and services such as online ridematching and multimodal trip planning can be promoted to employees and visitors to assist with reducing traffic congestion in and around the proposed project. Information on these programs can be accessed through iCommuteSD.com, and the SANDAG TDM division can assist with integration of these measures as part of this project. Other Considerations We appreciate the opportunity to comment on the Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) for the Stadium Reconstruction Project. We encourage, where appropriate, consideration of the following tools in evaluating this project based on these SANDAG publications, which can be found on our website at (1) Designing for Smart Growth, Creating Great Places in the San Diego Region (2) Planning and Designing for Pedestrians, Model Guidelines for the San Diego Region (3) Trip Generation for Smart Growth (4) Parking Strategies for Smart Growth (5) Regional Multimodal Transportation Analysis: Alternative Approaches for Preparing Multimodal Transportation Analysis in Environmental Impact Reports (6) Integrating Transportation Demand Management into the Planning and Development Process - A Reference for Cities (7) Riding to 2050, the San Diego Regional Bike Plan (8) SANDAG Regional Parking Management Toolbox If you have any questions or concerns regarding this letter, please contact me at (619) 699-1943 or susan.baldwin@sandag.org. Sincerely, SUSAN BALDWIN Senior Regional Planner sstra/sba STATE OF TRANSPORTATION AND HOUSING AGENCY EDMUND G. BROWN, Jr.. Governor DEPARTMENT OF TRANSPORTATION DISTRICT 11, DIVISION OF PLANNING 4050 TAYLOR ST, ms. 240 SAN DIEGO, CA 92110 Serious drought. PHONE (619) 688?6960 Help save water! FAX (619) 688?4299 TTY 711 June 29, 2015 PM 6.81 Stadium Reconstruction Ms. Martha Blake City of San Diego 1222 First Avenue, San Diego, CA 92101 Dear Ms. Blake: The California Department of Transportation (Caltrans) has received the Notice of Preparation dated, June 22, 2015, for the Stadium Reconstruction Project located adjacent to the Interstate 15 (I- 15) at Friars Road. Caltrans has the following comments: Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the project referenced above. The mission of Caltrans is to provide a safe, sustainable, integrated and efficient transportation system to enhance California?s economy and livability. The Local Development-Intergovernmental Review (LD-IGR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities of infill, conservation, and efficient development. To ensure a safe, efficient, and reliable transportation system, we encourage early consultation and coordination with local jurisdictions and project proponents on all development projects that utilize the multi-modal transportation network. A traffic impact study (T18) is necessary to determine this proposed project?s near-term and long- term impacts to the State facilities existing and proposed and to propose appropriate mitigation measures. The study should use as a guideline the Caltrans Guide for the Preparation of Traffic Impact Studies. Minimum contents of the traf?c impact study are listed in Appendix of the T18 guide. All State?owned signalized intersections affected by this project should be analyzed using the intersecting lane vehicle (ILV) procedure from the Caltrans Highway Design Manual, Topic 406, page 400?21. The geographic area examined in the traffic study should include as a minimum all regionally significant arterial system segments and intersections, including State highway facilities where the project will add over 100 peak hour trips. State highway facilities that are experiencing noticeable delays should be analyzed in the scope of the traffic study for projects that add 50 to 100 peak hour trips. A focused analysis may be required for project trips assigned to a State highway facility that is experiencing significant delay, such as where traffic queues exceed ramp storage capacities. A focused analysis may also be necessary if there is an increased risk of a potential traffic accident. "Provide a safe. sustainable, integrated and efficieni transportation stolen: to enhance California '3 economy and livability Ms. Martha Blake June 29, 2015 Page 2 All freeway entrance and exit ramps where a proposed project will add a significant number of peak- hour trips that may cause any traffic queues to exceed storage capacities should be analyzed. If ramp metering is to occur, a ramp queue analysis for all nearby Caltrans metered on-ramps is required to identify the delay to motorists using the on-ramps and the storage necessary to accommodate the queuing. The effects of ramp metering should be analyzed in the traffic study. For metered freeway ramps, LOS does not apply. However, ramp meter delays above 15 minutes are considered excesswe. The data used in the TIS should not be more than 2 years old. Caltrans endeavors that any direct and cumulative impacts to the State Highway System be eliminated or reduced to a level of insignificance purSuant to the California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) standards. Mitigation measures to State facilities should be included in TIS. Mitigation identified in the traffic study, subsequent environmental documents, and mitigation monitoring reports, should be coordinated with Caltrans to identify and implement the apprOpriate mitigation. This includes the actual implementation and collection of any ?fair share? monies, as well as the appropriate timing of the mitigation. Mitigation improvements should be compatible with Caltrans concepts. Mitigation measures for proposed intersection modifications are subject to the Caltrans Intersection Control Evaluation (ICE) policy (Traffic Operation Policy Directive 13?02). Alternative intersection design(s) will need to be considered in accordance with the ICE policy; therefore, please refer to the policy for more information and requirements. The lead agency should monitor impacts to insure that roadway segments and intersections remain at an acceptable LOS. Should the LOS reach unacceptable levels, the lead agency should delay the issuance of building permits for any project until the appropriate impact mitigation is implemented. Mitigation conditioned as part of a local agency?s development approval for improvements to State facilities can be implemented either through a Cooperative Agreement between Caltrans and the lead agency, or by the project prOponent entering into an agreement directly with Caltrans for the mitigation. When that occurs, Caltrans will negotiate and execute a Traffic Mitigation Agreement. If you have any questions on the comments Caltrans has provided, please contact Roy Abboud of the Development Review Branch at (619) 688?6968. SinC://6 JACOB . Chief Development Review Branch ?Provide a safe, sustainable. integrated and e?icient transportation system to enhance Caly?ornia '3 economy and livability