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HomeMy WebLinkAboutItem 1 - Part 2 of 3_SPAmendment_GPA_ZC Attachment No. 3 Amended Draft Initial Study/MND and Comments from Agencies Attachment No. 3 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT CITY OF ARCADIA INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Specific Plan 13-02 Amendment No. SPA 16-05 General Plan Amendment No. GPA 16-04 September 28, 2016 Lead Agency: City of Arcadia 240 West Huntington Drive Arcadia, CA 91006 Prepared by: LSA Associates, Inc. 1500 Iowa Avenue, Suite 200 Riverside, CA 92507 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 ii ARCADIA SEABISCUIT PACIFICA AMENDMENT PROJECT CONTENTS INITIAL STUDY SECTION 1 BACKGROUND ................................................................................... 1 1.1 SUMMARY .................................................................................................. 1 1.2 INTRODUCTION ......................................................................................... 1 SECTION 2 PROJECT DESCRIPTION...................................................................... 2 2.1 PROJECT BACKGROUND .............................................................................. 2 2.2 PROJECT CHARACTERISTICS ....................................................................... 3 2.3 REGULATORY REQUIREMENTS, PERMITS, AND APPROVALS ........................ 14 SECTION 3 ENVIRONMENTAL DETERMINATION .................................................. 16 3.1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ................................. 16 3.2 DETERMINATION...................................................................................... 16 SECTION 4 ENVIRONMENTAL CHECKLIST AND DISCUSSION ................................ 17 I. AESTHETICS ............................................................................................ 17 II. AGRICULTURE RESOURCES ....................................................................... 20 III. AIR QUALITY ............................................................................................ 22 IV. BIOLOGICAL RESOURCES .......................................................................... 29 V. CULTURAL RESOURCES ............................................................................. 32 VI. GEOLOGY AND SOILS ............................................................................... 36 VII. GREENHOUSE GAS EMISSIONS .................................................................. 39 VIII. HAZARDS AND HAZARDOUS MATERIALS .................................................... 43 IX. HYDROLOGY AND WATER QUALITY ........................................................... 47 X. LAND USE AND PLANNING ........................................................................ 55 XI. MINERAL RESOURCES ............................................................................... 60 XII. NOISE ..................................................................................................... 61 XIII. POPULATION AND HOUSING ..................................................................... 66 XIV. PUBLIC SERVICES ..................................................................................... 68 XV. RECREATION ............................................................................................ 69 XVI. TRANSPORTATION/TRAFFIC ...................................................................... 71 XVII. UTILITIES AND SERVICE SYSTEMS ............................................................ 76 XVIII. MANDATORY FINDINGS OF SIGNIFICANCE ................................................. 80 SECTION 4 LIST OF PREPARERS ........................................................................ 82 4.1 LSA ASSOCIATES, INC. ............................................................................. 82 4.2 CITY OF ARCADIA .................................................................................... 82 SECTION 5 REFERENCES ................................................................................... 83 SECTION 6 SUMMARY OF MITIGATION MEASURES .............................................. 87 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 iii APPENDICES (on CD) A Seabiscuit Pacifica Specific Plan No. 13-02 B Air Quality/Greenhouse Gas Study C Historical Assessment D Geotechnical Constraints E Phase 1 Hazmat Study F Hydrology and Water Quality Studies G Traffic Impact Assessment H Noise Assessment LIST OF TABLES Table A: Seabiscuit Pacifica Specific Plan Land Uses ................................................. 13 Table B: Short-term Construction Impacts ............................................................... 25 Table C: Long-Term Operational Emissions .............................................................. 25 Table D: Construction LST Impacts (pounds per day) ............................................... 27 Table E: Long-Term Operational LST Numbers (pounds per day) ............................... 28 Table F: Short-Term Construction GHG Emissions ..................................................... 40 Table G: Long-Term Operational Project GHG Emissions ........................................... 41 Table H: General Plan Land Use and Zoning Designations ......................................... 56 Table I: Summary of Intersection Analysis (2013) .................................................... 72 Table J: Summary of Intersection analysis (2016) .................................................... 72 Table K: Summary of Roadway Analysis Existing (2016) ............................................ 73 LIST OF FIGURES Figure 1: Regional Location ...................................................................................... 4 Figure 2: Aerial Photograph ...................................................................................... 5 Figure 3: Site Photographs ....................................................................................... 6 Figure 4: Proposed Site Plan ..................................................................................... 8 Figure 5: Landscaping Plan ....................................................................................... 9 Figure 6: Project Elevations .................................................................................... 10 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 1 SECTION 1 BACKGROUND 1.1 SUMMARY Project Title: Arcadia Seabiscuit Pacifica Specific Plan Amendment Lead Agency Name and Address: City of Arcadia 240 West Huntington Drive Arcadia, CA 91006 Contact Person and Phone Number: Lisa Flores, Planning Services Manager (626) 574-5445 Project Location: 240 West Huntington Drive Project Sponsor’s Name and Address: Continental Asset Management1 488 East Santa Clara Street Arcadia, California 91006 General Plan Designation: Commercial - Downtown Overlay (FAR 1.0) Zoning Designation: General Commercial (C-2) with Height Overlay H-8 (95 feet or 8 stories) 1.2 INTRODUCTION The City of Arcadia incorporated in 1904 and has had contributed to the rich history of Southern California for over 100 years. The City is home to the famous Santa Anita Park horse racing track. In 1955, the Santa Anita Inn, a 2-story hotel with 110 rooms, was constructed on 5.73 acres just east of Santa Anita Park to provide lodging for park workers, jockeys, guests, and management. Continental Assets Management, acting as Seabiscuit Pacifica, LLC, proposed a new hotel and condominium project on the existing hotel site and in 2014 received approval of the Seabiscuit Specific Plan. The original Seabiscuit Pacifica Specific Plan proposed to construct two hotels, a Marriott Residence Inn and Fairfield Inn and Suites, with a total of 210 rooms or units, and a hotel condominium tower with 50 units. The project was intended to continue to provide lodging for guests and workers of Santa Anita Park as well as other visitors to the City. The project was to be completed in two phases - Phase 1 would consist of the two hotels with hotel surface parking, plus a portion of the existing Santa Anita Inn would remain in service until Phase 2 had begun. Phase 2 would consist of the hotel condominium tower, garage parking, and condo surface parking. The Residence Inn would have six floors with a maximum height of 80 feet. The Fairfield Inn and Suites 1 Doing business as Seabiscuit Pacifica LLC for this project. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 2 would have four floors with a maximum height of 60 feet. During Phase 1, surface parking with 211 spaces for both hotels will also be developed. In Phase 2, the hotel condominium tower was proposed to have eight floors and include 9 townhouses, 36 condos, 5 penthouses, and subterranean parking. The condominium tower would have a maximum height of 88 feet to the roof and 98 feet including the penthouse architecture. During Phase 1, a portion of the existing hotel would be demolished, but 63 units will remain in operation until the start of Phase 2 construction, at which time the remaining hotel buildings would be demolished. Since the time the project was approved, the applicant has been unable to acquire financing for the hotel condominium portion of the project, and so is requesting an amendment to the Specific Plan to allow residential condominiums rather than hotel condominiums. In addition, the applicant is asking for a General Plan Amendment for the site from downtown commercial to downtown mixed use. The condominium tower in Phase 2 would have 6,762 square feet of office/retail uses to fulfill the General Plan requirement of ground floor commercial in mixed use projects. The entitlements needed for this modification are outlined in Section 2. SECTION 2 PROJECT DESCRIPTION 2.1 PROJECT BACKGROUND Location and Existing Uses The Seabiscuit Pacifica Specific Plan Amendment (SPSPA or proposed project) proposes to construct two hotels, a Marriott Residence Inn and Fairfield Inn and Suites, and a residential condominium tower in the City of Arcadia. The project is intended to provide lodging for guests and workers of the nearby Santa Anita Park race track. The project site occupies approximately 5.9 acres and is located at 100-130 West Huntington Drive in Arcadia The main Assessor’s Parcel Number (APN) of the site is 577-501-4014 and is found on the Mt. Wilson 7.5 minute USGS Quadrangle. It is located in Township 1 North, Range 11 West (no section listed) and is at latitude 34◦ 08’ 21.7” North and longitude 118◦ 02’ 77” West,). The project site has an existing 110-room (34,775 square feet) hotel on it that the developer plans to demolish. The proposed project site is bounded by Colorado Place to the north, the Arcadia City Hall complex to the south, West Huntington Drive to the east, and Huntington Drive to the west. Figures 1 and 2 show the location of the project site and surrounding land uses, while Figure 3 provides photographs of the project site and surrounding land uses. The project consists of Specific Plan Amendment No. SP 16-05 and General Plan Amendment No. GPA 16-04. The project site currently contains the Santa Anita Inn with 110 hotel rooms which was built in 1955. The project site is a potential historical significance due to its age and connection to the nearby Santa Anita Park race track. The developer plans to eventually demolish all of the existing buildings on the project site. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 3 2.2 PROJECT CHARACTERISTICS Existing Specific Plan. The following description is for the original Seabiscuit Pacifica Specific Plan project processed through the City in 2014. This information is provided for context prior to describing the currently proposed Specific Plan Amendment and related entitlements: The Seabiscuit Pacifica Specific Plan project proposes a total of 257,589 square feet of commercial uses with 142,320 square feet of “dual” (connected) hotel space in two buildings and 115,269 square feet of condominiums with 50 total units including 6,762 square feet of office/retail uses to meet the General Plan requirements for mixed use projects. Figure 4 shows the proposed project site plan. For financial reasons, the applicant has proposed to develop the project in two phases - Phase 1 will consist of the Residence Inn, Fairfield Inn and Suites, a portion of the existing Santa Anita Inn, and surface parking, while Phase 2 will consist of the mixed use/condominium tower, garage parking, and surface parking. Phase 1 includes constructing a total of 145,000 square feet of hotel space in two connected buildings, the Marriot Residence Inn and the Fairfield Inn and Suites. The two hotels will contain a total of 210 rooms. The Residence Inn will have six floors with a maximum height of approximately 80 feet. The Fairfield Inn and Suites will have four floors with a maximum height of approximately 60 feet. During Phase 1, both new hotels will be constructed, a portion of the Santa Anita Inn will be demolished, but the 4 southern-most buildings (C-F) with 63 rooms of the existing hotel will remain in operation until the start of Phase 2 construction. Phase 1 will also include surface parking with 197 spaces for both new hotels plus adequate parking for the portion of the Santa Anita Inn that will remain in service. Phase 2 includes demolition of the remaining Santa Anita Inn buildings and construction of the condominium tower with 115,269 square feet and 50 total units. The condominium tower will have eight floors and include 9 townhouses, 36 condos, 5 penthouses, and subterranean parking. The condominium tower will have a maximum height of 88 feet to the roof and 98 feet including the penthouse architecture. The basement parking, which will be constructed during Phase 2, will contain 73 parking spaces. The Phase 2 surface parking will include 98 parking spaces. Table A provides a summary of the various uses proposed as part of this project. The project landscape plan is shown in Figure 5, and project elevations are shown in Figure 6. Appendix A contains the Seabiscuit Pacifica Specific Plan. Grading for the project will require approximately 7,000 cubic yards of fill but will be largely balanced onsite, although there may be some need for offsite soil transport. COLORADO PLACE HUNTINGTON DRIVE HUNTINGTON DRIVEHUNTINGTON DRIVE FIGURE 1 Seabiscuit Pacifica ProjectSpecific Plan Regional and Project Location 01,0002,000 Feet S!!N I:\CMG1301\Reports\SpecPlan\fig1_reg_loc.mxd (8/13/2013) SOURCE: USGS 7.5' Quads: El Monte (81), CA; Mt. Wilson (88), CA; Thomas Bros., 2009 ?Ý Aä ?l!"^$ %&o( !"`$ ?q A» %&l( A» !"a$ !"`$ %&l( !"^$ KË %&g( %&g( AË A¥ !"a$ !"a$ !"`$KË Pacific Ocean Los Angeles County Orange County San Bernardino County Riverside County Regional Location 01020 Miles S!!N Project Location ¦§¨¦210 Project Area SOURCE: Gene Fong Associates, 2013 N I:\CMG1301\Reports\SpecPlan\fig2_Aerial_Photo.cdr (8/13/13) FIGURE 2 Aerial Photograph Seabiscuit Pacifica Project Specific Plan FIGURE 3 Photograph 1:View facing south, from the north side of the site, of the Santa Anita Inn entryway. Photograph 3:View facing southwest, from Huntington Drive, of the Colorado Place and Huntington Drive intersection with the Santa Anita Park racetrack in the background. Photograph 2:View facing south, from the center of the site, of the interior landscaping and gazebo. Photograph 4:View facing southwest of the Santa Anita Park racetrack, from northwest of the site on West Huntington Drive. I:\CMG1301\Reports\SpecPlan\fig3_SitePhotos.cdr (08/14/13) Site Photographs Seabiscuit Pacifica Project Specific Plan LANDSCAPED ENTRY SOURCE: Gene Fong Associates, 2013 I:\CMG1301\Reports\SpecPlan\fig4_SitePlan.cdr (9/15/16) FIGURE 4 Proposed Site Plan Seabiscuit Pacifica Project Specific Plan SOURCE: Gene Fong Associates and Wilson Associates, 2013 I:\CMG1301\Reports\SpecPlan\fig5_Landscape.cdr (8/13/13) FIGURE 5 Landscape Plan Seabiscuit Pacifica Project Specific Plan SOURCE: Gene Fong Associates, April 1, 2015. I:\CMG1301\Reports\SpecPlan\fig6ab_Elevations.cdr (09/15/16) FIGURE 6A Elevations Seabiscuit Pacifica Project Specific Plan SOURCE: Gene Fong Associates, April 1, 2015 FIGURE 6B Seabiscuit Pacifica Project Specific Plan Elevations I:\CMG1301\Reports\SpecPlan\fig6ab_Elevations.cdr (09/15/16) SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 12 THIS PAGE INTENTIONALLY LEFT BLANK SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 13 Table A: Seabiscuit Pacifica Specific Plan Land Uses Specific Plan Land Uses Rooms/ Spaces Floor Area (square feet) Building Area1 (square feet) Percent of Site Phase I (hotels) Residence Inn 121 93,895 22,745 9 Fairfield Inn and Suites 89 48,425 12,395 5 Santa Anita Inn (existing - temporary) 63 22,050 11,025 4 Subtotal 273 164,370 46,165 18 Phase II Mixed Use/Condominiums2 50 115,269 13,524 5 Subtotal 50 115,269 13,524 5 Parking Needed -- -- -- Hotel (1/room x 210 rooms) 210 -- -- -- Condos (2.5/unit x 50 units) 125 -- -- -- Office/Retail ((5/1000 SF) 33 -- -- -- Subtotal 368 -- -- -- Parking Provided Surface Parking Phase I 197 — — — Underground Parking Phase II 73 -- — — Surface Parking Phase II 98 — — — Subtotal 368 — — — Development Total Dual Hotels 210 142,320 35,140 14 Mixed Use (Office/Retail) - 6,762 13,524 5 Condominiums 50 108,507 13,524 5 Total Rooms 260 -- -- -- Total Floor Area - 257,589 48,664 19 Total Non-Residential Floor Area - 149,082 Total Parking Spaces 368 -- — — FAR3 (without condos) -- 0.58:1 — — Source: Table 2.B, Seabiscuit Pacifica Specific Plan, Gene Fong Associates (September 2016) 1 Building footprint 2 includes 6,762 square feet of offices on first floor, condos on 2nd floor and up. 3 Floor Area Ratio = Building Area (in square feet). Site Area (approx. 257,619 square feet or 5.9 acres with the 100:1 Club property included). Data extrapolated from ALTA survey and County Assessor’s Parcel data NOTE: Per General Plan, FAR is for non-residential uses and does not include any square footage for residential (condo) units. Residential density max. is 30 units/acre. The primary access point for the hotels will be at the merger of Colorado Place and West Huntington Drive. Primary access to the condominiums tower will be off of West Huntington Drive. A driveway off of East Huntington Drive will serve as a secondary/emergency access point for both the condominium and dual hotel. During construction of Phase 1, only buildings A and B of the existing “Santa Anita Inn” hotel will be demolished (Buildings A and B with 47 rooms), while the remaining buildings will stay in operation (63 of the 110 rooms). The remaining buildings will be demolished with Phase 2 construction. The Seabiscuit Pacifica Specific Plan No. SP 13-02 was submitted to the City to define the range of permitted uses, development regulations and design guidelines for the development of the project site. The Specific Plan document indicates it will accomplish the following objectives: SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 14 • Provide high quality development consistent with the City’s General Plan and in conformance with municipal standards, codes, and policies; • Provide uses that will compliment and support the Santa Anita Park race track and other important regional facilities in the City, and the current downtown revitalization community district; • Design the development to minimize the potential for environmental impacts; • Augment the City’s economic base by increasing tax-generating commercial uses within the City; and • Create employment-generating opportunities for the citizens of the City and surrounding communities. Proposed Specific Plan Amendment. The applicant is requesting to amend the SPSP to remove the “hotel” condominium designation in the plan. The applicant has indicated that the condominium concept cannot be effectively financed at present. The SPSP would also be amended to show ground floor office uses on 50% of the floor area of the condominium tower building to be consistent with the General Plan requirements for the Downtown Mixed Use category (see below). General Plan Amendment. In support of the SPA, the applicant is requesting a General Plan Amendment from the existing Commercial (0.5 FAR) with Downtown Overlay to Downtown Mixed Use (50 du/ac and 1.0 FAR). This GPA is proposed to allow standard residential condominiums on the site (separate condo tower shown as Phase 2 in the SPSP). As with the current approved project, the exiting hotel use (Santa Anita Inn) would be fully removed by the start of Phase 2 (condominiums). The current approval allows for limited operation (i.e., temporary continuation of approximately half of the Santa Anita Inn) until the start of Phase 2 construction. In addition, the site already has a Downtown Height Overlay (H-8) that will allow heights consistent with the approved SPSP (max. 98 feet). The current proposal also incorporates the small lot at the corner of Huntington Drive and Colorado Place to improve visibility and allow for a more comprehensive site plan since the 100 to 1 Bar has already been removed. It is proposed to change the General Plan designation on this small parcel to DMU as well to better integrate it into the SPSP site plan, and that it will be used exclusively for landscaping as a project entry with no development square footage. Zone Change. In support of the SPA, the applicant is also requesting a zone change from the existing General Commercial (C-2) to Downtown Mixed Use (DMU) to also allow for full residential uses as outlined above. The new proposal would eliminate the current proposed Development Agreement. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 15 2.3 REGULATORY REQUIREMENTS, PERMITS, AND APPROVALS The project applicant has applied for or will need the following discretionary approvals from the City relative to this project:  Seabiscuit Pacifica Specific Plan Amendment No. SPA 16-05;  General Plan Amendment No. GPA 16-04;  Revised Mitigated Negative Declaration in compliance with CEQA;  Conceptual Review of the overall project site plan and visual renderings; and  Review of landscape and irrigation plans. Other non-discretionary actions anticipated to be taken by the City at the Staff level as part of the proposed project include:  Approval of a Storm Water Pollution Prevention Plan (SWPPP) to mitigate site runoff during construction (i.e., over the short-term) and a Standard Urban Stormwater Management Plan (SUSMP) to mitigate for post-construction runoff flows (i.e., over the long-term during project occupancy and operation).  Building permit. The comprehensive building permit includes building permit, plumbing, mechanical, and electrical permits.  Grading permit.  Sewer connection permit. Development of the proposed Seabiscuit Pacifica project may require the following permits and/or approvals from other responsible agencies:  A National Pollutant Discharge Elimination System permit from the Regional Water Quality Control Board - Los Angeles Region to ensure that construction site drainage velocities are equal to or less than the pre-construction conditions and downstream water quality is not harmed. IMPORTANT NOTE: In the following analysis, each environmental topic will be evaluated by first describing the impacts of the original project (“Original SPSP Analysis”) and then an analysis of the proposed changes to the project (“Proposed SPA Analysis”). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 17 SECTION 4 ENVIRONMENTAL CHECKLIST AND DISCUSSION I. AESTHETICS Would the project: a) Have a substantial adverse effect on a scenic vista? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact I.a) Original SPSP Analysis. The most prominent scenic resources that can be viewed from the project area are the San Gabriel Mountains to the north. There are no other unique vistas, natural or undisturbed areas, or officially recognized scenic areas in the surrounding area. The Santa Anita Park race track is just west of the project site, but it is not considered a visual resource per se although the grandstands of the park are visual from surrounding land uses. However, the race track is a designated historic district which is discussed in Section V., Cultural Resources. The project site contains the existing Santa Anita Inn, a collection of two-story buildings with extensive mature landscaping. At present, the hotel and landscaping do not generally block views of the San Gabriel Mountains for drivers heading northbound on East and West Huntington Drives. The existing hotel buildings also do not block views of the mountains from City Hall or surrounding public facilities, but views are partially blocked by the tall redwood trees in the center of the existing hotel property, and to some degree by tall trees along the northern boundary of the City Hall athletic fields north of City Hall. There are approximately 45 redwood trees on site with about half of which are part of a windrow on the eastern boundary of the site. The proposed SPSP project would construct one six-story and two eight-story buildings on the site that would temporarily block views of the mountains for northbound travelers on either East or West Huntington Drive. At 35 miles per hour, the time of view obstruction would be approximately five seconds. The proposed project may also block views of the mountains from public facilities and residential areas south of the project site. When viewed from a vantage point of a two-story house south of the golf course and west of Arcadia High School, approximately 3 degrees or 2.2 percent of the existing viewshed (approximately 135 degrees) to the north. Therefore, only a small portion of the permanent view of the mountains from these areas would be blocked by the proposed project. A similar percentage of the viewshed from City Hall would also be blocked by the project buildings. The remainder of the residential and public views south of the project would remain unimpeded. Views of the mountains from the Civic Center Athletic Fields (north of City Hall) would be almost entirely blocked by the proposed project. However, these views are already somewhat obscured by tall trees along the north side of the athletic field property, and individuals using the athletic fields would be present for limited periods of time, so the project would only result in temporary or short-term visual impacts for this area. There is also a 12-foot tall chain link fence with fabric screening and landscaped vines covering most of SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 18 the fence along the southern boundary of the site (i.e., north boundary of the athletic fields) that will remain after the completion of the project. The Arcadia County Park is located directly east of the proposed project site and its primary viewshed is the San Gabriel Mountains to the north. The proposed project is not expected to block or eliminate these views for persons using the park or the Santa Anita Golf Course which is located directly south of the Arcadia County Park. In addition, mature trees located in the park and redwood trees located along the eastern boundary of the project site will help soften views of the new dual hotel and condominiums. The height the three proposed buildings will make them visible throughout much of the City of Arcadia, however, the buildings are not expected to significantly block views of the San Gabriel Mountains for the general public. The proposed project will not substantially block any views from residential land uses. Based on this analysis, the project is not expected to result in substantial adverse effects on scenic vistas, so impacts to public views would be less than significant. Proposed SPA Analysis. The proposed SPA, GPA, and ZC will not affect the height or appearance of the proposed buildings under the SPSP, so impacts to views are the same as those identified in the previous Initial Study (i.e., less than significant). b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact I.b) Original SPSP Analysis. The project site or surrounding area do not contain any designated scenic highways. The nearest designated State scenic highway is the Angeles Crest Highway approximately 15 miles away. Based on these conditions, the project will not significantly damage scenic resources, including trees, rock outcroppings, or historic buildings within a state scenic highway. Proposed SPA Analysis. The proposed SPA, GPA, and ZC will have the same effect as the original SPSP project. Therefore, impacts are the same as identified in the previous Initial Study (i.e., no impact). c) Substantially degrade the existing visual character or quality of the site and its surroundings? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact I.c) Original SPSP Analysis. The project proposes to demolish the existing 2-story hotel buildings and construct three hotel-related buildings with heights of 60, 80, and 86 feet. During SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 19 construction, persons travelling on area roads, using nearby land uses, and staying in the existing hotel while it is still open would have views of the project site in various stages of site preparation and construction. The proposed project will adhere to the City’s standard screened construction fencing requirement, and due to construction and fencing being temporary the impact is considered temporary and less than significant. In addition, the current hotel will be demolished, so impacts to hotel guests’ views would be temporary and less than significant. The proposed project will be taller and not to scale with existing office and hospital buildings within the immediate area. However, the zoning of the site includes a height allowance (8 stories or 95 feet) under which the proposed project would be consistent. The City allowed this special height limit for this property to provide a “landmark” project just east of the race track that would provide a visual focal point or entry statement into the City along Colorado Boulevard. Therefore, the project is not expected to detract from the planned visual quality of the immediate neighborhood, or from any residential neighborhoods to the distance from the project site. Therefore, the proposed project will not significantly degrade the existing visual character or affect the visual quality of the site and its surroundings over the long term. Proposed SPA Analysis. The proposed SPA, GPA, and ZC will not affect the height or appearance of the proposed buildings under the SPSP, so impacts to visual character are the same as those identified in the previous Initial Study (i.e., less than significant). d) Create a new source of substantial light or glare, which would adversely affect daytime or nighttime views in the area? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact I.d) Original SPSP Analysis. The existing hotel buildings do not cause a substantial amount of glare at present due to the extensive landscaping present onsite. At certain times of day, glare can occur from the sun shining off of the windows of nearby office buildings and the hospital, especially in the morning and late afternoon hours. The SPSP project proposes dual hotel and condominium buildings that will substantially increase the amount of night lighting such as parking lights and streets lights over the lighting levels of the existing hotel buildings. However, the project site is directly east of Santa Anita Park (i.e., horseracing track), which produces a substantially greater amount of night light during its nighttime events compared to the existing hotel or the proposed project due to its large parking lot lighting and stadium lighting. The other substantial source of night lighting in the area is the field lighting of the Civic Center Athletic Fields immediately south of the project site. The proposed project will also be required to be consistent with State Building Code (i.e., Title 24) and City Municipal Code lighting requirements. For more information on exterior lighting and its controls related to energy efficiency, see Section VII. Greenhouse Gas Emissions. Due to their height, the project buildings will be able to be seen at night from much of the City, but the renderings of the project indicate they will be aesthetically pleasing, even at night, so they are not expected to cause significant adverse impacts on nighttime views. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 20 The new hotel and condominium buildings will introduce tall buildings into the area with hundreds of glass windows which would need to have glazing or coatings to help minimize glare in the surrounding area and on nearby roadways, therefore, mitigation is required. Mitigation Measures AES-1 Prior to issuance of a building permit, the applicant shall demonstrate that all project windows are glazed or otherwise treated to minimize glare on surrounding roads and properties, to the satisfaction of the Development Services Director or designee. In summary, the proposed hotel buildings will increase ambient lighting levels and glare from the project site, and will change night time views of the area. However, these changes are not expected to result in significant adverse impacts to nighttime views in the area mainly due to visual conditions that already exist in the project area and implementation of the recommended mitigation measure. Proposed SPA Analysis. The proposed SPA will not change the appearance, height, or overall design of the project buildings, including lighting. With implementation of MM AES-1, the proposed SPA will have the same impacts as those identified for the original project (i.e., less than significant with mitigation). II. AGRICULTURE RESOURCES In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state's inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest protocols adopted by the California Air Resources Board. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact II.a) Original SPSP Analysis. The site is almost completely covered over at present by impervious man-made surfaces. According to the Farmland Mapping and Monitoring Program (FMMP) maps, the project site is designated as “Urban Land” and is not underlain by any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, so there will be no impact in this regard. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 21 Proposed SPA Analysis. The proposed SPA will to have any effect on agricultural land so the impact is the same as under the original project (i.e., no impact). b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact II.b) Original SPSP Analysis. There is no agricultural use zoning or Williamson Act contracts in the City of Arcadia. Therefore, there will be no impacts in this regard. Proposed SPA Analysis. The proposed SPA will to have any effect on agricultural zoning or Williamson Act contracts so the impact is the same as under the original project (i.e., no impact). c) Conflict with existing zoning for, or cause rezoning of , forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526, or timberland zoned Timberland Production (as defined by Government Code section 51104 (g))? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact II.c) Original SPSP Analysis. The site is almost completely covered by man-made impervious surfaces (e.g., buildings and parking lots) at present. The City of Arcadia has no timberland or timberland production land, and has no property zoned for forest land. There is no farmland in the City of Arcadia, so the project will not convert farmland to non-agricultural use, and there are no impacts in this regard. Proposed SPA Analysis. The proposed SPA will to have any effect on forestland or forest zoning so the impact is the same as under the original project (i.e., no impact). d) Result in the loss of forest land or conversion of forest land to non-forest use? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact II.d) Original SPSP Analysis. As outlined in II.c above, the proposed development will not result in the loss of forest land or conversion of forest land to non-forest use. Therefore, there is no impact. Proposed SPA Analysis. The proposed SPA will have no impact on loss of forestland, so impacts are the same as those for the original project (i.e.. no impact). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 22 e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact II.e) Original SPSP Analysis. As outlined in II.c above, there is no farmland in the City of Arcadia. Therefore, the project would not convert farmland to non-agricultural use and there is no impact. Proposed SPA Analysis. The proposed SPA will have no impact on loss of farmland, so impacts are the same as those for the original project (i.e.. no impact). III. AIR QUALITY Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact III.a) Original SPSP Analysis. LSA Associates, Inc. (LSA) prepared a detailed assessment of air quality impacts for the proposed project based on the project development characteristics (LSA 2013)(Appendix B) and the project traffic impact analysis (Kimley-Horn and Associates 2013)(Appendix G). The Air Quality Management Plan (AQMP) for the South Coast Air Basin (Basin) sets forth a comprehensive program that will lead the Basin into compliance with all federal and state air quality standards. Air quality in the Basin is regulated by the South Coast Air Quality Management District (SCAQMD). The AQMP control measures and related emission reduction estimates are based upon emissions projections for a future development scenario derived from land use, population, and employment characteristics defined in consultation with local governments. Accordingly, conformance with the AQMP for development projects is determined by demonstrating compliance with local land use plans and/or population projections. The proposed project involves the construction and occupancy of 257,589 square feet of dual hotel and condominiums on 5.9 acres of land. The project would also involve the demolition of an existing hotel, the Santa Anita Inn, with 34,775 square feet of buildings. As outlined in Section X, Land Use and Planning, the proposed project uses are consistent with the General Plan and zoning land use designations for the site. Since it is consistent with the General Plan, the proposed project is consistent with the Southern California Association of Governments (SCAG) Regional Comprehensive Plan (RCP) Guidelines and the SCAQMD Air Quality Management Plan (AQMP). Therefore, the proposed project is consistent with the applicable air quality plan, and there are no significant impacts in this regard. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 23 Proposed SPA Analysis. The General Plan and zoning were modified for the original project to make them consistent with the SPSP. The proposed SPA is now requesting a GPA and zone change to allow residential uses in what was previously identified as a commercial zone. However, the SPA is requesting only those uses approved under the SPSP so it is generally consistent with the AQMP, and the project will implement similar mitigation to that approved for the original SPSP. Therefore, impacts relative to the AQMP are similar to the original SPSP (i.e., less than significant). b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact III.b) Original SPSP Analysis. The following analysis analyzes both short-term impacts caused by construction activities and long-term impacts caused by occupancy and operation of the project as proposed. Short-Term Impacts Grading and other construction activities would result in combustion emissions from heavy-duty construction vehicles, haul trucks, and vehicles transporting construction crews. Exhaust emissions during these construction activities will vary daily as construction activity levels change. The grading and demolition phases of construction represent the most intense construction period during which daily emissions would be at their greatest level, based on the potential amount of equipment and duration of use. The other construction phases would not result in any greater construction emissions due to less equipment being used and shorter construction duration. Construction-related impacts also include demolition of some of the Santa Anita Inn buildings in Phase 1 and the remaining buildings in Phase 2, as well as excavation for the subterranean parking in Phase 2. Currently, the Basin is designated as a nonattainment area for ozone, PM10, and PM2.5. Project construction will be required to comply with regional fugitive dust reduction practices (SCAQMD Rule 403) that assist in reducing short-term air pollutant emissions. The purpose of SCAQMD Rule 403 is to reduce the amount of particulate matter in the atmosphere resulting from man- made fugitive dust sources. Among the requirements under this rule, fugitive dust must be controlled so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emission source. This is achieved by requiring actions to prevent, reduce, or mitigate dust emissions. Adherence to Rule 403 is a standard requirement for any construction activity occurring within the Basin. Adherence to Rule 403 can reduce fugitive dust emissions by 50 percent or more. As depicted in Table B, construction emissions would not exceed regional thresholds, so impacts are less than significant. However, the following measure is recommended to help assure that air quality impacts during construction, especially on the nearby Salvation Army facility, remain at less than significant levels: AIR-1 Prior to issuance of a grading permit, the general contractor for the project shall prepare and file a Dust Control Plan with the City that complies with SCQAMD SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 24 Rule 403 and requires the following during excavation and construction as appropriate:  Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more).  Water active sites at least twice daily (locations where grading is to occur will be thoroughly watered prior to earthmoving.)  Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 2 feet of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the requirements of California Vehicle Code (CVC) Section 23114.  Pave construction access roads at least 100 feet onto the site from the main road.  Control traffic speeds within the property to 15 mph or less. AIR-2 Prior to the issuance of a grading permit, the project developer shall require by contract specifications that contractors shall utilize California Air Resources Board (CARB) Tier II Certified equipment or better during the rough/mass grading phase for rubber-tired dozers and scrapers. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City. AIR-3 Prior to the issuance of a grading or building permit for each phase, the project developer shall require by contract specifications that contractors shall place construction equipment staging areas at least 200 feet away from sensitive receptors. Contract specifications shall be included in the project construction documents, which shall be reviewed by the City. AIR-4 Prior to the issuance of a building permit for each phase, the project developer shall require by contract specifications that contractors shall utilize power poles or clean-fuel generators for electrical construction equipment. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City. Long-Term Impacts Long-term air pollutant emission impacts result from stationary sources and mobile sources involving any project-related changes. The project would result in a net increase in the amount of hotel lodging or seasonal residences of 222,814 square feet (257,589 new square feet minus the 34,775 existing square feet). Thus the project would result in net increases in both stationary and mobile source emissions. The stationary source emissions would come from the use of consumer products, landscape equipment, general energy, and solid waste, while trip generation factors were taken from the ITE Trip Generation Manual, Eight Edition and the traffic impact analysis prepared by for the proposed project by Kimley-Horn and Associates (Appendix G). The long-term operational emissions associated with the proposed project, calculated using the CalEEMod 2011.1.1 model are shown in Table C. The air quality study shows that the increase of all criteria pollutants as a result of the proposed project would be less than the SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 25 applicable SCAQMD daily emission thresholds. Therefore, project-related long-term air quality impacts would be less than significant, and no mitigation is required. Table B: Short-Term Construction Impacts Construction Activity/Phase Total Regional Pollutant Emissions (pounds per day) ROG NOX CO SO2 Fugitive PM10 Exhaust PM10 Fugitive PM2.5 Exhaust PM2.5 Demolition 5.9 56 42 0.054 5.8 2.6 1.3 2.5 Site Preparation 5.8 58 44 0.042 7.2 3.1 3.9 2.9 Grading 4.3 41 28 0.032 2.7 2.4 1.4 2.2 Building Construction 11 41 45 0.07 2.6 2.4 0.7 2.3 Architectural Coating 39 3.1 5.2 0.0086 0.44 0.25 0.12 0.25 Paving 2.9 2.8 4.9 0.0086 0.44 0.23 0.12 0.22 Peak Daily Emissions 50 58 50 0.079 10 6.8 SCAQMD Thresholds 75 100 550 150 150 55 Significant Emissions? No No No No No No Source: Table I, LSA August 2013 CO = carbon monoxide CO2 = carbon dioxide CO2e = carbon dioxide equivalent lbs/day = pounds per day NOx = nitrogen oxides Table C: Long-Term Operational Emissions Source Pollutant Emissions (pounds per day) ROC NOX CO SOX PM10 PM2.5 Existing Hotel 12 8.0 29 0.076 4.7 1.4 Proposed Project Area Sources 25 0.38 29 0.04 3.8 3.8 Energy Sources 0.13 1.2 0.9 0.007 0.089 0.089 Mobile Sources 21 18 71 0.18 12 3.4 Total Proposed Project 46 20 100 0.23 16 7.3 Increase from Project 34 12 71 0.154 11 5.9 SCAQMD Thresholds 55 55 550 150 150 55 Significant? No No No No No No Source: Table K, LSA August 2013 CO = carbon monoxide lbs/day = pounds per day NOx = nitrogen oxides PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size ROC = reactive organic compound SCAQMD = South Coast Air Quality Management District SOx = sulfur oxides SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 26 Proposed SPA Analysis. The land uses of the proposed SPA are very similar to those of the approved SPSP with the exception of having actual condominiums (rather than hotel condos) and having half of the ground floor square footage of Phase 2 being office (i.e., ground floor commercial required by the General Plan for mixed use zones). The original air quality study used residential condominium as a worst case estimate for long-term air pollutants, but the addition of the office uses would incrementally increase the project emissions as shown in the revised Table C below: Table C: Long-Term Operational Emissions (REVISED) Source Pollutant Emissions (pounds per day) ROC NOX CO SOX PM10 PM2.5 Existing Hotel 12 8.0 29 0.076 4.7 1.4 Original SPSP Project 46 20 100 0.23 16 7.3 Revised SPA 48 21 102 0.24 17 7.6 SCAQMD Thresholds 55 55 550 150 150 55 Significant? No No No No No No Sources: Table K, LSA August 2013 and Table C, Initial Study, 2014. CO = carbon monoxide lbs/day = pounds per day NOx = nitrogen oxides PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size ROC = reactive organic compound SCAQMD = South Coast Air Quality Management District SOx = sulfur oxides The Revised Table C indicates the SPA project will not have significant long-term air pollutant emissions similar to the original SPSP. c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact III.c) Original SPSP Analysis. The majority of the project-related operational emissions would be due to vehicle trips to and from the new project buildings. The previous Tables B and C indicate that all emissions of criteria pollutants from the proposed project would be under the applicable SCAQMD thresholds, therefore, no significant impacts would occur and no mitigation is required. Proposed SPA Analysis. Construction-related emissions will be the same for the revised project as indicated for the proposed project in Table B above. The Revised Table C above shows that long-term air pollutant emissions form the revised project will be incrementally higher, but still less than significant, compared to the original SPSP project analysis. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 27 d) Expose sensitive receptors to substantial pollutant concentrations? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact III.d) Original SPSP Analysis. Localized Significance Thresholds (LSTs) represent the maximum emissions from a project that would not result in an exceedance of the national or state ambient air quality standards. LSTs are based on the ambient concentrations of that pollutant within the project source receptor area (SRA) and the distance to the nearest sensitive receptor. For this project, the appropriate SRA is the East San Gabriel Valley according to the project air quality analysis (LSA August 2013) included in Appendix B of this report. Short-Term LST Impacts As previously described, it is expected that construction would occur in two phases, so no more than 5 acres of the site would be actively worked on during any given day. Other than the one Salvation Army facility at the southwest corner of the site, the closest sensitive receptors to the site are residences located 1,000 feet north of the project site across Colorado Place. Table D shows that emissions would not exceed LST thresholds and thus would not require mitigation. Short-term emissions from the proposed project will cease once construction of the project is completed, and implementation of Mitigation Measures AIR-1 through AIR-4 will help assure that short-term emissions on nearby sensitive receptors will remain at less than significant levels. Long-Term LST Analysis Table L of the Air Quality Analysis shows the calculated emissions for the proposed operational activities compared with the appropriate LSTs, which only includes on-site sources; however, the CalEEMod 2011.1.1 model outputs do not separate on-site and off-site emissions for mobile sources. For a worst-case scenario assessment, the emissions shown in Table L include all on- site project-related stationary sources and 5 percent of the project-related new mobile sources, which is an estimate of the amount of project-related new vehicle traffic that will occur on site. Considering the total trip length included in the CalEEMod 2011.1.1 model, the 5 percent assumption is conservative. Table E shows that the operational emission rates would not exceed the LST thresholds for the closest sensitive receptors. Therefore, the proposed operational activity would not result in a localized significant air quality impact and no mitigation is required. Table D: Construction LST Impacts (pounds per day) Emissions Sources NOX CO PM10 PM2.5 On-site Emissions 58 43 10.2 6.8 LST Thresholds1 203 1,733 148 63 Significant Emissions? No No No No Source: Table J, LSA August 2013. 1 LST Assumptions: SRA = East San Gabriel Valley, site disturbance = 5 acres, 80-foot distance for workers and 1,000-foot distance for residents SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 28 CO = carbon monoxide lbs/day = pounds per day LST = local significance threshold NOX = nitrogen oxides PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size Table E: Long-Term Operational LST numbers (pounds per day) Emissions sources NOX CO PM10 PM2.5 Onsite emissions 1.3 33 4.4 4.0 LST Thresholds1 203 1,733 36 16 Significant Emissions? No No No No Source: Table L, LSA August 2013. 1 LST Assumptions: SRA = East San Gabriel Valley, 80-foot distance for workers and 1,000-foot distance for residents, onsite traffic = 5 percent of total CO = carbon monoxide lbs/day = pounds per day NOX = nitrogen oxides PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size Proposed SPA Analysis. There are no LST parameters that will change under the proposed SPA compared to the approved SPSP, so impacts would be the same as those identified for the original project (i.e., less than significant). e) Create objectionable odors affecting a substantial number of people? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact III.e) Original SPSP Analysis. Project construction will generate limited odors over the short-term, mainly fumes from gasoline- and diesel-powered construction equipment. These odors would be temporary and not likely to be noticeable beyond the project limits. The painting of buildings or the installation of asphalt surfaces may also create odors. SCAQMD Rule 1113 outlines standards for paint applications, while Rule 1108 identifies standards regarding the application of asphalt. Adherence to the standards identified in these SCAQMD Rules would reduce temporary odor impacts to a less than significant level, and no mitigation is required. Land uses generally associated with long-term objectionable odors include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. The proposed project does not include uses that would generate long-term objectionable odors. Because the project would not involve any substantial short-term or long-term sources of odors, impacts are considered less than significant and no mitigation is required. Proposed SPA Analysis. The proposed changes are the same as the original project regarding odors, so impacts would be the same as those identified for the original project (i.e., less than significant). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 29 IV. BIOLOGICAL RESOURCES Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IV.a) Original SPSP Analysis. The proposed project site is located on an urban infill site that contains no native vegetation and supports limited wildlife species, mainly those that are tolerant of regular human activity including ground squirrels, rodents, and song birds such as meadowlarks, finches, chickadees, and mockingbirds. The existing hotel landscaping on the project site includes rose gardens, man-made waterfalls, ornamental bushes and trees, and a windrow of mainly redwood trees adjacent to Huntington East Drive and the Arcadia County Park on the east side of the project site. The project developer is planning on preserving the windrow of redwood trees on the project site. There are approximately 100 other trees on the rest of project site, mainly ornamental varieties, including sycamore, palm, and weeping willow. These trees are mature and may provide roosting but likely not nesting opportunities for raptors and other birds due to the constant level of human disturbance. Migratory and raptorial birds are covered by the Migratory Bird Treaty Act, and may be impacted by project construction if birds or nests are present during grading or tree removal. In addition, redwood trees are not listed or otherwise protected species, but they do constitute a relatively unique biological resource in this area and as such should be preserved if possible. It should be noted that, during Phase 1 construction, the southern portion of the existing Santa Anita Inn and its associated mature landscaping, will remain in place until the start of Phase 2 construction. In addition, the City’s development guidelines for commercial uses encourage the preservation of mature trees. Potential impacts to the existing trees and nesting birds are considered potentially significant and require mitigation. Mitigation Measures BIO-1 Prior to issuance of a grading permit for each phase, the developer shall provide an assessment of existing trees on the areas to be developed. This tree assessment shall be prepared by a qualified landscape architect and identify any existing large bushes or trees that can be relocated or preserved as part of the new development project. The project landscaping plans shall attempt to preserve existing mature trees onsite to the extent feasible, based on the tree assessment. This measure shall be implemented to the satisfaction of the City Planning Division. BIO-2 During project construction in either phase, the existing redwood trees along the east side of the property shall be protected by being taped or roped off with appropriate signage so construction equipment will not accidentally come in contact with and damage or destroy any trees. The trees shall be sprayed with water at the end of each day when substantial amounts of dust are generated SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 30 (e.g., during grading or demolition) to minimize damage from dust deposition. This measure shall be implemented to the satisfaction of the City Planning Division. BIO-3 Construction in either phase should not occur during the local nesting season (estimated February 1 to July 15). If any construction occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to the issuance of a grading permit or removal of any large trees on the existing hotel property. If the biologist determines that nesting birds are present, an area of 100 feet shall be marked off around the nest and no construction activity can occur in that area during nesting activities. Grading and/or construction may resume in this area when a qualified biologist has determined the nest is no longer occupied and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City Planning Division. With implementation of Mitigation Measures BIO-1 through BIO-3, no significant impacts on biological resources are expected to occur from project implementation. Proposed SPA Analysis. The proposed changes are the same as the original project regarding biological resources as the entire site will be developed, so impacts would be the same as those identified for the original project (i.e., less than significant with mitigation). b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IV.b) Original SPSP Analysis. The project site does not contain any designated riparian habitat or other sensitive natural communities. The site is completely developed with man-made improvements and landscaping, and does not contain any natural drainages or riparian vegetation. Therefore, there are no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The proposed changes are the same as the original project regarding riparian habitat as the entire site will be developed, so impacts would be the same as those identified for the original project (i.e., no impact). c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 31 IV.c) Original SPSP Analysis. The project site and immediate surrounding area are completely developed with man-made improvements and do not contain any natural drainages, federally protected wetlands, or any biological resources that would be under the jurisdiction of federal or state resource agencies. Therefore, there are no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The proposed changes are the same as the original project regarding wetlands and the entire site will be developed, so impacts would be the same as those identified for the original project (i.e., no impact). d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IV.d) There are no known native resident or migratory fish or wildlife species within the City of Arcadia. The site also does not contain any vegetation other than a few landscaped ornamental trees, which provide minimal biological resource value. The site does not contain any drainage features that would support fish or other wildlife, nor does it contain any resources that would assist any species that are migrating or native wildlife raising their young. Mitigation Measures BIO-1 through BIO-3 address impacts to the onsite trees and nesting birds (under the Migratory Bird Treaty Act) if present. With implementation of these measures, there will be no significant impacts in this regard, and no additional mitigation is required. Proposed SPA Analysis. The proposed changes are the same as the original project regarding these resources as the entire site will be developed, so impacts would be the same as those identified for the original project (i.e., no impact) with mitigation from other sections included. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IV.e) Original SPSP Analysis. The City of Arcadia does have an Oak Tree Preservation ordinance. However, there are no oak trees on the proposed project site, so the SPSP project will not conflict with this or any other local policies or ordinances protecting biological resources. Since there are no impacts, no mitigation is required. See Mitigation Measure BIO-2 regarding preservation of onsite redwood trees. Proposed SPA Analysis. Since the original project approval, the City has adopted a native tree protection ordinance, so the proposed project will have to comply with those new SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 32 regulatory requirements, and nesting bird surveys are required during nesting periods. No additional mitigation is required. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IV.f) Original SPSP Analysis. The project site is not covered by any adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other local, regional, or state habitat conservation plan. Therefore, there will be no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The revised project has the same conditions regarding HCPs or NCCPs as the original project, so there are no impacts in this regard. V. CULTURAL RESOURCES Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact V.a) Original SPSP Analysis. The Santa Anita Inn, an existing 2-story hotel with 110 guest rooms, is located on the project site. The hotel was built in 1955, and the State Office of Historic Preservation recommends all structures over 50 years of age be surveyed for historical significance prior to demolition. In August 2013, LSA Associates, Inc. conducted a cultural assessment for historical resources of the hotel and the results are incorporated into this section (Appendix C). The Santa Anita Inn helped support Santa Anita Park by providing lodging for race track visitors as well as other City guests over the years. The City of Arcadia incorporated in 1903, and Santa Anita Park was built in its present location in 1934. The racetrack played and continues to play an important role in the City of Arcadia’s economy, which is based on entertainment, sporting, hospitality, and gambling opportunities. Other local historical resources in the immediate area include the Methodist Hospital of Southern California built in 1957 a quarter mile south of the SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 33 project site, and the Los Angeles County Arboretum and Botanic Garden a mile west of the site that opened to the public in 19482. The Santa Anita Inn was built in 1955 almost 50 years after the creation of the Santa Anita Park. The Inn was originally built to house Santa Anita Park workers, jockeys, and visiting guests to the race track. In 1985, the hotel went through a major renovation and all interior spaces were reconstructed or upgraded so that little if any of the original interior treatments or furnishings remain. The building exteriors were also renovated at that time, but the overall appearance and color scheme of the hotel were maintained. In addition, the hotel grounds contain extensive mature landscaping which provides a very pleasant ambiance to the facility. The historical assessment determined that the existing Santa Anita Inn property does not meet the requirements of listing for either the State or National Register of Historic Places. In addition, the City of Arcadia does not maintain a list of locally designated historical resources. Nevertheless, the Santa Anita Inn does represent a connection to the City’s past, and its character and contributions to the City’s history have been adequately documented in the California Department of Parks and Recreation (DPR) 523A and 523B forms filled out as part of the LSA historical assessment (see Appendix C). This documentation needs to be filed with the City to assure there will be no significant impacts to local historical resources (see Mitigation Measure CUL-1). The proposed dual hotels and condominiums will continue to supply seasonal housing for Santa Anita Park management, workers, jockeys, and guests, as well as other visitors to the City. This is an increasingly important role in the local economy since Hollywood Park has publicly announced its plan to close. Due to the closure of Hollywood Park, the Santa Anita Park race season will likely increase from five to seven months long. In addition, the proposed project would also be consistent with the City’s General Plan and appears to be consistent with its recently adopted downtown revitalization plan. Mitigation Measures CUL-1 Prior to demolition of any existing hotel buildings on the site, the completed DPR 523A forms and a cover memorandum shall be submitted to the City for filing to officially document the historical assessment for the Santa Anita Inn. This measure shall be implemented to the satisfaction of the City Planning Division. CUL-2 Prior to issuance of an occupancy permit for Phase 1, the applicant shall install a monument plaque indicating the location of the former Santa Anita Inn and its importance in the history of the City of Arcadia. The size, construction, and 2 http://www.santaanita.com/the-park/history http://www.ci.arcadia.ca.us/home/index.asp?page=1102 http://www.methodisthospital.org/ABOUTUS/Pages/History.aspx http://www.arboretum.org/index.php/explore/our_history/ SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 34 location of this plaque shall be up to the discretion of the City Manager, in consultation with the Planning Division. CUL-3 If cultural artifacts are discovered during project grading, work shall be halted in that area until a qualified historian or archaeologist can be retained by the developer to assess the significance of the find. The project cultural monitor shall observe the remaining earthmoving activities at the project site consistent with Public Resources Code Section 21083.2(b), (c), and (d). The monitor shall be equipped to record and salvage cultural resources that may be unearthed during grading activities. The monitor shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. If any resources of a prehistoric or Native American origin are discovered, the appropriate Native American tribal representative will be contacted and invited to observe the monitoring program for the duration of the grading phase at tribal expense. Any Native American resources shall be evaluated in accordance with the CEQA Guidelines and either reburied at the project site or curated at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the cultural monitor determines that monitoring is no longer necessary, such activities shall be discontinued. This measure shall be implemented to the satisfaction of the City Planning Division. Implementation of these measures will assure there will be no significant impacts to any existing or undiscovered historical or archaeological resources. Proposed SPA Analysis. The revised project has the same conditions regarding cultural resources, and with the recommended mitigation, impacts would be the same as with the original project (i.e., less than significant but mitigation recommended for impacts to local historical structures). b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IV.b) Original SPSP Analysis. The project site has been completely disturbed by previous development and human activity. Development of the proposed project is not expected to cause any significant impacts to archaeological resources on the site. However, it is still possible, though unlikely, that archaeological resources may be found during excavation of the project site. Implementation of Mitigation Measure CUL-3 will help assure that impacts to unanticipated archaeological resources will be reduced to less than significant levels. Proposed SPA Analysis. The revised project has the same conditions regarding archaeological resources, and with the recommended mitigation, impacts would be the same as with the original project (i.e., less than significant but mitigation recommended for impacts to local historical structures). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 35 c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IV.c) Original SPSP Analysis. The project site has been extensively disturbed in the past, and is currently covered with man-made structures and improvements. The project geotechnical report (Geo Inc. 2013) indicates that the entire area is underlain by hundreds of feet of alluvial (stream-deposited) materials, so it is unlikely that fossil-bearing geologic strata will be disturbed during project grading. However, it is possible, though not likely, that megafaunal (ancient large mammal) or related paleontological resources may be found during excavation of the project site, since such resources have been occasionally found during excavations elsewhere in the LA Basin. To prevent impacts to unanticipated paleontological resources, mitigation is required. Mitigation Measures CUL-4 If paleontological resources (fossils) are discovered during project grading, work will be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The project paleontologist shall monitor remaining earthmoving activities at the project site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. This measure may be combined with CUL-3 at the discretion of the City Planning Division. Implementation of this measure will help assure there will be no significant impacts to unexpected paleontological resources or unique geological features from project construction. Proposed SPA Analysis. The revised project has the same conditions regarding paleontological resources, and with the recommended mitigation, impacts would be the same as with the original project (i.e., less than significant with mitigation). d) Disturb any human remains, including those interred outside of formal cemeteries? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 36 IV.d) Original SPSP Analysis. The proposed project site does not contain any known human remains. However, there is always a small possibility that ground-disturbing activities during construction may uncover previously unknown buried human remains. Therefore, the following mitigation is recommended: Mitigation Measures CUL-5 In the event of an accidental discovery or recognition of any human remains, California State Health and Safety Code § 7050.5 dictates that no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to CEQA regulations and PRC § 5097.98. If human remains are found, the LA County Coroner’s office shall be contacted to determine if the remains are recent or of Native American significance. Prior to issuance of a grading permit, the developer shall include a note to this effect on the grading plans for the project. Implementation of this measure will help assure there will be no significant impacts if human remains are found during project grading. Proposed SPA Analysis. The revised project has the same conditions regarding human remains, and with the recommended mitigation, impacts would be the same as with the original project (i.e., less than significant with mitigation). VI. GEOLOGY AND SOILS Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 37 ii) Strong seismic groundshaking? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact iii) Seismic-related ground failure, including liquefaction? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact iv) Landslides? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VI.a.i-iv) Original SPSP Analysis. The Raymond Hill Fault Zone and the Sierra Madre Fault Zone are the only faults located in the City of Arcadia. The project study area is underlined by extremely thick alluvial deposits that are subject to differential settlement during any intense shaking associated with seismic events, which can be expected for any location in Southern California. This can result in damage to property when an area settles to different degrees over a relatively short distance. Almost the entire region is subject to this hazard, but building design standards do significantly reduce the potential for harm. The proposed project site is not located within the boundaries of an Earthquake Fault Zone for fault rupture hazard as defined by the Alquist-Priolo Earthquake Fault Zoning Act of 1972 (CGS 2005)(Appendix D), there are no known active or potentially active faults that traverse the project site, and the site is not located in an area with steep or unstable slopes (City General Plan 1995). In addition, local groundwater is found at depths well in excess of 50 feet, so the potential for liquefaction is considered low. As part of its development review process, the City will require the project to be built to withstand expected seismic groundshaking, as well as local soil conditions as outlined in the project geotechnical study (CGS 2005). Therefore, the project site is not expected to be subject to any significant impacts regarding fault zones, strong seismic groundshaking, ground failure, liquefaction, or landslides, and no mitigation is required. Proposed SPA Analysis. The revised project has the same conditions regarding faults and seismic impacts, and impacts would be the same as with the original project (i.e., less than significant or no impact). b) Result in substantial soil erosion or the loss of topsoil? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 38 VI.b) Original SPSP Analysis. The proposed project site gently slopes to the south at a gradient of 2.4 percent with elevations ranging from 473 feet above mean sea level (amsl) at the north corner sloping down to 466 feet amsl at the south corner. The site is currently covered over by buildings and mainly impervious surfaces and does not exhibit signs of erosion. Excavation and grading for the proposed project would temporarily expose some onsite soils to erosion from wind or water. However, the City will apply its standard erosion control measures as conditions of approval, so these potential impacts would be less than significant. Development of the site would involve more than one acre, therefore, the proposed project is required to obtain a National Pollutant Discharge Elimination System (NPDES) permit. A Storm Water Pollution Prevention Plan (SWPPP) would also be required to address erosion and discharge impacts associated with grading of the site for development of the proposed project. The majority of the soils present on the site have at least a slight erosion hazard potential, so the proposed project is required to adhere to the City’s grading requirements, obtain an NPDES permit, prepare a Standard Urban Stormwater Management Plan (SUSMP), and prepare an SWPPP. These actions are outlined in Mitigation Measures HYD-1 through HYD-3 in Section IX, Hydrology and Water Quality. Compliance with these measures will reduce potential impacts associated with soil erosion hazards to less than significant levels. Proposed SPA Analysis. The revised project has the same conditions regarding soil erosion so impacts would be the same as with the original project (i.e., less than significant with mitigation). c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-site or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VI.c) Original SPSP Analysis. Subsidence is the sudden sinking or gradual downward settling of the earth’s surface with little or no horizontal movement. Subsidence is caused by a variety of activities, which includes, but is not limited to, withdrawal of groundwater, pumping of oil and gas from underground, the collapse of underground mines, liquefaction, and hydrocompaction. However, the City of Arcadia is located on an alluvial plain that is relatively flat and expected to be stable. The project site is also a flat site and will not be subject to either onsite or offsite landslide hazards (CGS 2005). There will be no significant impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The revised project has the same conditions regarding geologic stability so impacts would be the same as with the original project (i.e., no impact). d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 39 VI.d) Original SPSP Analysis. Expansive soils generally have a substantial amount of clay particles, which can give up water (shrink) or absorb water (swell). The change in the volume exerts stress on buildings and other loads placed on these soils. The extent or range of the shrink/swell is influenced by the amount and kind of clay present in the soil. The occurrence of these soils is often associated with geologic units having marginal stability. Expansive soils can be widely dispersed and they can occur in hillside areas as well as low-lying alluvial basins. The proposed project site and surrounding area are underlain by deep well-drained alluvial soils that have low to moderate expansion potential. With implementation of the building recommendations in the project geotechnical study (Appendix D), the project will have no substantial risks to life or property related to expansive soils, Impacts in this regard will be less than significant, and no mitigation is required. Proposed SPA Analysis. The revised project has the same conditions regarding expansive soils so impacts would be the same as with the original project (i.e., no impact). e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of waste water? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VI.e) The proposed project would be connected to the existing sewer system, so no septic or alternative wastewater disposal systems are needed. Therefore, there will be no significant impacts in this regard. VII. GREENHOUSE GAS EMISSIONS Would the project: a) Generate gas emissions, either directly or indirectly, that may have a significant impact on the environment? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VII.a) Original SPSP Analysis. LSA Associates, Inc. (LSA) prepared a detailed assessment of air quality impacts including greenhouse gas emission impacts for the proposed project based on the project development characteristics (LSA 2013)(Appendix B) and the project traffic impact analysis (Kimley-Horn and Associates 2013)(Appendix G). During the construction of the project, expected equipment and vehicles will generate greenhouse gases in small amounts. There currently are no identified thresholds for greenhouse gas emissions. This section provides an analysis of greenhouse gas (GHG) emissions associated with the proposed project. This analysis examines the short-term construction and long-term operational impacts of the proposed project as it relates to greenhouse gases. A detailed SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 40 assessment of project-related GHG emissions is included in the project’s air quality study (Appendix B). Project-related emissions of GHGs have been modeled by including direct emissions from project vehicular traffic. Indirect emissions from electric power plants generating electricity, energy used to provide water, and the processing of solid waste were accounted for taking into account the nature of the project. The project would utilize quantifiable amounts of electricity, natural gas, water and generate solid waste that will contribute CO2, CH4, and N2O emissions. The emissions of GHG resulting have been estimated using parameters from both the State of California and the federal government. Calculation of Greenhouse Gas Emissions The project’s GHG emissions during construction and mobile sources during project operation were estimated by using the CalEEMod 2011.1.1 computer model developed and maintained by the South Coast Air Quality Management District (SCAQMD). The project’s GHG emissions from on-site equipment were estimated using the emission factors found on the SCAQMD website. The CalEEMod 2011.1.1 program estimates that the project would generate 644 pounds per day or a total of 885 metric tons of CO2e GHGs during construction, as shown in Table F below. By comparison, the proposed project’s long-term total unmitigated carbon dioxide equivalents for carbon dioxide, methane, and nitrous oxide would be 3,700 metric tons of CO2e per year or 0.0037 MMTCO2e/year, as shown in Table G below. The carbon dioxide, methane, and nitrous oxide emissions that would be associated with the proposed project is less than 0.0000075 percent of California’s total emissions for carbon dioxide, methane, and nitrous oxide (469.95 Tg CO2e). According to the Air Quality Analysis, GHG emissions of 3,700 tpy of CO2e from the proposed project expansion would be lower than the SCAQMD interim tiered GHG emissions threshold for commercial projects of 1,400 tpy of CO2e, and would be below the 25,000 MT of CO2e/yr of residual emissions. Table F: Short-Term Construction GHG Emissions Construction Phase Total Regional Pollutant Emissions (metric tons per year) CO2 CH4 N2O CO2e Demolition 51 0.010 0 51 Site Preparation 20 0.0056 0 20 Grading 30 0.0086 0 31 Building Construction 642 0.082 0 644 Architectural Coating 46 0.0042 0 46 Paving 23 0.0064 0 23 Source: Table M, LSA August 2013 CH4 = methane CO2 = carbon dioxide CO2e = carbon dioxide equivalent N2O = nitrous oxide SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 41 Table G: Long-Term Operational Project GHG Emissions Source Pollutant Emissions (metric tons per year) Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Construction emissions amortized over 30 years 0 29 29 0.0042 0 29 Operational emissions Area 5.3 11 16 0.017 0.00036 17 Energy 0 1,200 1,200 0.028 0.0091 1,200 Mobile 0 2,300 2,300 0.092 0 2,300 Waste 28 0 28 1.7 0 63 Water 2.7 79 82 0.28 0.007 90 Total Project Emissions 36 3,600 3,700 2.1 0.016 3,700 Source: Table N, LSA August 2013 Note: Numbers in table may not add up correctly due to rounding of all numbers to two significant digits. Bio-CO2 = biologically generated CO2 CO2e = carbon dioxide equivalent CH4 = methane N2O = nitrous oxide CO2 = carbon dioxide NBio-CO2 = Non-biologically generated CO2 The project air quality study concluded that the proposed SPSP project would be consistent with currently accepted state GHG strategies if it implemented the following mitigation: Mitigation Measures GHG-1 To ensure reductions below the expected “Business As Usual” (BAU) scenario, the project will implement a variety of measures that will reduce its greenhouse gas (GHG) emissions. To the extent feasible, and to the satisfaction of the City of Arcadia (City), the following measures will be incorporated into the design and construction of the SPSP project prior to the issuance of building permits: Construction and Building Materials Recycle/reuse at least 50 percent of the demolished and/or grubbed construction materials (including, but not limited to, soil, vegetation, concrete, lumber, metal, and cardboard). Use “Green Building Materials,” such as those materials that are resource- efficient and are recycled and manufactured in an environmentally friendly way, for at least 10 percent of the project. Energy Efficiency Measures Design all project buildings to exceed the 2013 California Building Code’s (CBC) Title 24 energy standard by 10 percent, including, but not limited to, any combination of the following: Design buildings to accommodate future solar installations. Limit air leakage through the structure or within the heating and cooling distribution system to minimize energy consumption. Incorporate ENERGY STAR or better rated windows, space heating and cooling equipment, light fixtures, appliances, or other applicable electrical equipment. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 42 Install efficient lighting and lighting control systems. Use daylight as an integral part of the lighting systems in buildings. Install light-colored roofs and pavement materials where possible. Install energy-efficient heating and cooling systems, appliances and equipment, and control systems. Install solar lights or light-emitting diodes (LEDs) for outdoor lighting or outdoor lighting that meets the 2013 California Building and Energy Code. Water Conservation and Efficiency Measures Devise a comprehensive water conservation strategy appropriate for the project and its location consistent with the City’s Water Efficiency Landscape Ordinance (WELO). The strategy may include the following, plus other innovative measures that may be appropriate: Create water-efficient landscapes within the development. Install water-efficient irrigation systems and devices, such as soil moisture-based irrigation controls. Design buildings to be water-efficient. Install water-efficient fixtures and appliances, including low-flow faucets, dual-flush toilets, and waterless urinals. Restrict watering methods (e.g., prohibit systems that apply water to nonvegetated surfaces) and control runoff. Solid Waste Measures To facilitate and encourage recycling to reduce landfill-associated emissions, among others, the project will provide trash enclosures that include additional enclosed area(s) for collection of recyclable materials. The recycling collection area(s) will be located within, near, or adjacent to each trash and rubbish disposal area. The recycling collection area will be a minimum of 50 percent of the area provided for the trash/rubbish enclosure(s) or as approved by the waste management department of the City of Arcadia. Provide employee education on waste reduction and available recycling services. Transportation Measures To facilitate and encourage non-motorized transportation, bicycle racks shall be provided in convenient locations to facilitate bicycle access to the project area. The bicycle racks shall be shown on project landscaping and improvement plans submitted for Planning Department approval and shall be installed in accordance with those plans. Provide pedestrian walkways and connectivity throughout the project. Fund or participate in some type of shuttle service for hotel guests to access the City’s downtown Gold Line Station. With implementation of Mitigation Measure GHG-1 and application of regulatory requirements, the project would have GHG emissions below those expected for a BAU project SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 43 and would not conflict with or impede implementation of reduction goals identified in AB 32, the Governor’s Executive Order S-3-05, and other strategies to help reduce GHGs to the level proposed by the Governor. Therefore, the project’s contribution to cumulative GHG emissions would be less than significant. Proposed SPA Analysis. The procedures for estimating GHG emission impacts has been changing in recent years, however, the proposed changes under the SPA would be only incrementally different than those of the approved SPSP, and emission rates for residential condominiums were already taken into account in the GHG emission estimates for the original project. Therefore, with implementation of the mitigation measures recommended for the original project, the revised SPA would have equivalent impacts relative to GHGs (i.e., less than significant with mitigation). b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VII.b) Original SPSP Analysis. The City of Arcadia has adopted policies under the City’s General Plan to reduce greenhouse gas emissions in compliance with SB 375 and AB 32, to reduce greenhouse gas emissions to 1990 levels by 2020, and 80 percent below 1990 levels by 2050. The City’s website also discusses an Energy Efficiency Plan that was not available at the time of this report. The SPSP project will be required to comply with these local GHG emission control measures as well. With implementation of Mitigation Measure GHG-1, the proposed SPSP will less than significant project and cumulative impacts related to GHGs and global climate change. Proposed SPA Analysis. The procedures for estimating GHG emission impacts have been changing in recent years, however, the proposed changes under the SPA would be only incrementally different than those of the approved SPSP, and emission rates for residential condominiums were already taken into account in the GHG emission estimates for the original project. Therefore, with implementation of the mitigation measures recommended for the original project, the revised SPA would have equivalent impacts relative to GHGs (i.e., less than significant with mitigation) compared to the original approval. VIII. HAZARDS AND HAZARDOUS MATERIALS Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 44 VIII.a) Original SPSP Analysis. The site currently contains an existing hotel, and Phase 1 Environmental Site Assessment prepared for the project site (RJL Associates March 20103) indicates that the site does not contain any hazardous materials or facilities. In addition, there are only a few sites in the surrounding area that store or handle hazardous materials, and none of them would have any effect or impact on the project site or the proposed SPSP project (RJL 2003)(Appendix E). The project proposes to develop two new hotels and condominiums that are not expected to use or generate substantial or significant amounts of hazardous materials. There would be an incremental impact in this regard from these expanded lodging-related uses, but compliance with existing federal, state, and local laws/regulations regarding hazardous materials should help ensure that these impacts are less than significant, and no mitigation is required. Proposed SPA Analysis. The onsite and regulatory conditions for hazardous materials would be the same for the proposed SPA as for the approved SPSP, so there would be no impacts in this regard. VIII.b) Original SPSP Analysis. The proposed project site is located in Los Angeles County, which is not among the counties that are found to have serpentine and ultramafic rock in their soils. Therefore, the potential risk for naturally occurring asbestos is small. However, due to the age of the existing Santa Anita Inn, it is very likely that asbestos-containing materials (ACMs) and/or lead-based paint (LBP) are present on the project site at this time. Prior to demolition, these materials will need to be removed by licensed personnel, as outlined in the following mitigation: Mitigation Measures HAZ-1 Prior to demolition of any existing hotel buildings or associated structures, a qualified contractor shall be retained to survey structures proposed for demolition to determine if asbestos-containing materials (ACMs) and/or lead- based paint (LBP) are present. If ACMs and/or LBP are present, prior to commencement of general demolition, these materials shall be removed and transported to an appropriate landfill by a licensed contractor. This measure shall be implemented to the satisfaction of the City Building Division including written documentation of the disposal of any ACMs or LBP in conformance with all applicable regulations. With implementation of Mitigation Measure HAZ-1, the proposed project will not create a significant hazard to the public or the environment. Proposed SPA Analysis. Removal of onsite improvements is required under the proposed SPA just like under the approved SPSP. Therefore, impacts will be similar (i.e., less than significant with mitigation). b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 45 c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.c) Original SPSP Analysis. There is one school located within a quarter mile of the project site - Barnhart School (Kindergarten through 8th grade). However, Section VIII.a above indicates the proposed project would not emit or produce any hazardous materials that would represent a health hazard to the public or to students or staff at Barnhart School. Therefore, there would be no significant impact in this regard, and no mitigation is required. Proposed SPA Analysis. The proposed SPA has no onsite or area conditions regarding schools that are different than those of the approved SPSP, so impacts will be the same (i.e., less than significant). d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.d) Original SPSP Analysis. There are no properties in the vicinity of the project site, nor is the project site itself on any Federal Superfund Sites (NPL), State Response Sites, Voluntary Cleanup Sites, School Cleanup Sites, Permitted Sites, or Corrective Action sites lists. Neither the project site nor the surrounding properties within one-quarter mile of the site are identified on the California State Water Resources Control Board’s Geotracker list of leaking underground fuel tank (LUFT) sites (2012). Therefore, there will be no impact in this regard and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site and it is not on any governmental hazmat lists. Therefore, impacts will be the same (i.e., no impact). e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.e) Original SPSP Analysis. The proposed project site is not located within an airport land use plan or within two miles of a public airport or public use airport. There would not be any airport-related safety hazards for people working at the proposed project site or guests of the hotels or condominiums. Therefore, the project will have no impacts related to airport activity, and no mitigation is required. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 46 Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which is not in the vicinity of an airport, so there are no impacts in that regard. f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.f) Original SPSP Analysis. There are no private airstrips within 2 miles of the project site, so there will be no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which is not in the vicinity of a private airstrip, so there are no impacts in that regard. g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.g) Original SPSP Analysis. The Santa Anita Inn currently occupies the project site. Police, fire, and paramedic services are currently provided by the City to the entire downtown area, including the project site. The site is accessible via the merger of Colorado Place and West Huntington Drive to the north and East Huntington Drive to the east. Development of the project site as proposed will not reduce the existing level of emergency access or the ability to evacuate onsite uses if an emergency or disaster occurs, so there will be no significant impacts in this regard and no mitigation is required. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP with the administrative change from hotel to residential condos, and the addition of a small amount of office space on the bottom floor of the condo tower in Phase 2. Anticipated public service impacts of the proposed project are expected to be equivalent to those of the approved SPSP project, so impacts are less than significant. h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact VIII.h) Original SPSP Analysis. According to the California Department of Forestry and Fire Protection (CAL Fire) mapping system the City of Arcadia contains areas considered to be Very High Fire Hazards Zones. The map created by CAL Fire has been adopted by the City to target these areas and implement stringent wild land fire mitigation strategies. The proposed project SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 47 site does not fall within any fire hazard zones, and is not within close proximity to any wildlands and will not have a fire hazard impact. Review of proposed building plans is a standard part of the City’s development review process, and the proposed project will be required to comply with any building design requirements of the City Fire Department (see Section XIV, Public Services) to mitigate urban (non-wildland) fire hazards. Therefore, wildfire hazard impacts would be less than significant and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which is not in a high fire hazard zone, so impacts in that regard will be the same as the original projet (i.e. less than significant). IX. HYDROLOGY AND WATER QUALITY Would the project: a) Violate any water quality standards or waste discharge requirements? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IX.a) Original SPSP Analysis. In 1972, the Clean Water Act (CWA) was amended to require National Pollutant Discharge Elimination System (NPDES) permits for the discharge of pollutants into “Waters of the U.S.” from any point source. In 1987, the CWA was amended to require that the U.S. Environmental Protection Agency establish regulations for permitting under the NPDES permit program, that at the local level cities must ensure provision of vegetates swales, buffers, and infiltration areas in new development projects. For Arcadia, the NPDES program is issued by the Regional Water Quality Control Board, Los Angeles Region. The NPDES program coordinates the actions of all incorporated cities within this region (except Long Beach) and Los Angeles County to regulate and control storm water and urban runoff into Los Angeles County waterways and ocean. The proposed project will be subject to NPDES requirements as well as the City of Arcadia’s Water Efficient Landscape Ordinance (WELO). Although this is a standard regulatory requirement, it is incorporated into the project mitigation to allow for better tracking through the Mitigation Monitoring and Reporting Program (MMRP) that will prepared for this project. Short-Term Impacts. It is possible that runoff during grading and construction activities could result in sediment and other urban pollutants into local drainage facilities. To protect water quality over the short-term (i.e., during construction), the project will be required to prepare a Storm Water Pollution Prevention Plan (SWPPP) which is a written document that describes the construction operator’s activities to comply with the requirements in the NPDES permit. Required elements of an SWPPP include (1) site description addressing the elements and characteristics specific to the project site; (2) descriptions of Best Management Practices (BMPs) for erosion and sediment controls; (3) BMPs for construction waste handling and disposal; (4) implementation of approved local plans; and (5) proposed post-construction controls, including a description of local post-construction erosion and sediment control requirements. The SWPPP is intended to facilitate a process whereby the operator evaluates potential pollutant sources at the site and selects and implements BMPs designed to prevent or SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 48 control the discharge of pollutants in stormwater runoff. During the construction period, the proposed project would use a series of BMPs to reduce erosion and sedimentation. These measures may include the use of gravel bags, silt fences, hay bales, check dams, hydroseed, and soil binders. The construction contractor would be required to operate and maintain these controls throughout the duration of on-site construction activities. Long-Term Impacts. Once the proposed project is completed, it is possible that operation or ongoing activities of project uses may contribute to long-term water quality impacts. To prevent such impacts, the project must implement a Standard Urban Stormwater Mitigation Plan (SUSMP) is required of the proposed project. Onsite runoff will be either infiltrated into the ground in landscaped areas or be directed to several catch basins and down drains which will then direct runoff into the City’s storm drain system. New development is required to meet or exceed pre-project conditions for stormwater discharge, and the proposed project would be required to retain any additional runoff onsite and discharge it to the storm drain system at rates that do not exceed pre-project conditions. Adherence to NPDES requirements is required of all development within the City, the incorporation of these requirements in the following measures is designed to track both standard requirements and specific mitigation measures as identified below: Mitigation Measures HYD-1 Prior to issuance of a grading permit, the developer shall file a Notice of Intent (NOI) with the Los Angeles Regional Water Quality Control Board to be covered under the National Pollutant Discharge Elimination System (NPDES) General Construction Permit for discharge of storm water associated with construction activities. The project developer shall submit to the City the Waste Discharge Identification Number issued by the State Water Quality Control Board (SWQCB) as proof that the project’s NOI is to be covered by the General Construction Permit has been filed with the SWQCB. This measure shall be implemented to the satisfaction of the City Engineer. HYD-2 Prior to issuance of a grading permit, the developer shall submit to the Los Angeles Regional Water Quality Control Board (RWQCB) and receive approval for a project-specific Storm Water Pollution Prevention Plan (SWPPP). The SWPPP shall include a surface water control plan and erosion control plan citing specific measures to control on-site and off-site erosion during the entire grading and construction period. In addition, the SWPPP shall emphasize structural and nonstructural best management practices (BMPs) to control sediment and non- visible discharges from the site. BMPs to be implemented may include (but shall not be limited to) the following:  Potential sediment discharges from the site may be controlled by the following: sandbags, silt fences, straw wattles, fiber rolls, a temporary debris basin (if deemed necessary), and other discharge control devices. The construction and condition of the BMPs are to be periodically inspected by the RWQCB during construction, and repairs would be made as required. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 49  Area drains within the construction area must be provided with inlet protection. Minimum standards are sand bag barriers, or two layers of sandbags with filter fabric over the grate, properly designed standpipes, or other measures as appropriate.  Materials that have the potential to contribute non-visible pollutants to storm water must not be placed in drainage ways and must be placed in temporary storage containment areas.  All loose soil, silt, clay, sand, debris, and other earthen material shall be controlled to eliminate discharge from the site. Temporary soil stabilization measures to be considered include: covering disturbed areas with mulch, temporary seeding, soil stabilizing binders, fiber rolls or blankets, temporary vegetation, and permanent seeding. Stockpiles shall be surrounded by silt fences and covered with plastic tarps.  Implement good housekeeping practices such as creating a waste collection area, putting lids on waste and material containers, and cleaning up spills immediately.  The SWPPP shall include inspection forms for routine monitoring of the site during the construction phase.  Additional required BMPs and erosion control measures shall be documented in the SWPPP.  The SWPPP would be kept on site for the duration of project construction and shall be available to the local Regional Water Quality Control Board for inspection at any time. The developer and/or construction contractor shall be responsible for performing and documenting the application of BMPs identified in the project-specific SWPPP. Regular inspections shall be performed on sediment control measures called for in the SWPPP. Monthly reports shall be maintained and available for City inspection. An inspection log shall be maintained for the project and shall be available at the site for review by the City and the Regional Water Quality Control Board as appropriate. HYD-3 Prior to issuance of a grading permit, a site-specific Standard Urban Stormwater Management Plan (SUSMP) shall be submitted to the City Planning Division for review and approval. The SUSMP shall specifically identify the long-term site design, source control, and treatment control BMPs that shall be used on site to control pollutant runoff and to reduce impacts to water quality to the maximum extent practicable. At a minimum, the SUSMP shall identify and the site developer shall implement the following site design, source control, and treatment control BMPs as appropriate: Site Design BMPs  Minimize urban runoff by maximizing maximizing permeable areas and minimizing impermeable areas (recommended minimum 25 percent of site to be permeable).  Incorporate landscaped buffer areas between sidewalks and streets. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 50  Maximize canopy interception and water conservation by planting native or drought-tolerant trees and large shrubs wherever possible  Where soil conditions are suitable, use perforated pipe or gravel filtration pits for low flow infiltration.  Construct onsite ponding areas or retention facilities to increase opportunities for infiltration consistent with vector control objectives.  Construct streets, sidewalks and parking lot aisles to the minimum widths necessary, provided that public safety and a walkable environment for pedestrians are not compromised.  Direct runoff from impervious areas to treatment control BMPs such as landscaping/bioretention areas. Source Control BMPs Source control BMPs are implemented to eliminate the presence of pollutants through prevention. Such measures can be both non-structural and structural: Non-Structural Source Control BMPs  Education for property owners, tenants, occupants, and employees.  Activity restrictions.  Irrigation system and landscape maintenance to minimize water runoff.  Common area litter control.  Regular mechanical sweeping of private streets and parking lots.  Regular drainage facility inspection and maintenance. Structural Source Control BMPs  MS4 stenciling and signage at storm down drains.  Properly design trash storage areas and any outdoor material storage areas. Treatment Control BMPs Treatment control BMPs supplement the pollution prevention and source control measures by treating the water to remove pollutants before it is released from the project site. The treatment control BMP strategy for the project is to select Low Impact Development (LID) BMPs that promote infiltration and evapotranspiration, including the construction of infiltration basins, bioretention facilities, and extended detention basins. Where infiltration BMPs are not appropriate, bioretention and/or biotreatment BMPs (including extended detention basins, bioswales, and constructed wetlands) that provide opportunity for evapotranspiration and incidental infiltration may be utilized. Harvest and use BMPs (i.e., storage pods) may be used as a treatment control BMP to store runoff for later non-potable uses. With implementation of these measures, potential short- and long-term impacts of the proposed project on local and regional water quality will be reduced to less than significant levels. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP with the administrative change from hotel to residential condos, and the addition of a small amount of office space on the bottom floor of the condo tower in Phase 2. None of these changes affect local runoff or water quality requirements, so impacts of the SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 51 proposed project in this regard are expected to be equivalent to those of the approved SPSP project (i.e., less than significant with mitigation). b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IX.b) Original SPSP Analysis. The proposed project is subject to NPDES requirements and will be designed and constructed to ensure compliance with the water quality standards and waste discharge requirements. It should be noted that there is a 16-inch water main on the west side of the site and a 12-inch water main on the east side of the site, both with 65 pounds per square inch of static pressure (65 psi). It may be necessary that the booster pumps be designed to provide sufficient pressure for the heights of the proposed buildings. Compliance with these regulations, and implementation of Mitigation Measures HYD-1 through HYD-3, along with all City water supply requirements, will assure there will be no significant impacts related to groundwater resulting from the proposed project. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. None of these changes would substantially affect local water or wastewater services or groundwater. affect local runoff or water quality requirements, so impacts of the proposed project in this regard are expected to be equivalent to those of the approved SPSP project (i.e., less than significant with mitigation). c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on site or off site? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IX.c) Original SPSP Analysis. The proposed project site slopes gently to the south at a gradient of 2.4 percent with elevations ranging from 473 feet above mean sea level (amsl) at the north corner sloping down to 466 feet amsl at the south corner. The proposed project site is fully developed and landscaped and does not contain any natural drainage courses. There is also no historical evidence of localized ponding or flooding on the project site. The proposed project includes landscaping that will reduce the potential for erosion. Although the amount of erosion or siltation onsite might incrementally increase as a result of development, there will be no long-term significant impacts with implementation of Mitigation Measures HYD-1 through HYD-3. Proposed SPA Analysis. The proposed SPA and approved SPSP are the same site which has no identified drainage channels or structures, and erosion can be controlled by implementation SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 52 of recommended mitigation. Therefore, impacts will be similar to those identified for the original project (i.e., less than significant with mitigation). d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner that would result in flooding on site or off site? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.d) Original SPSP Analysis. The site is already fully developed with structures and impervious surfaces, so construction of the proposed project would not substantially increase the amount of runoff from this site. There are no onsite drainage channels or features, and on- site drainage flows and direction will remain essentially as they are at present. Surface runoff flows from the northeast corner of the property through the southwest corner of the property before draining into the City’s storm drain system in East Huntington Drive. The proposed project would not have a significant impact on drainage patterns and will not substantially increase the rate of amount of surface water runoff; therefore, no mitigation is required. Proposed SPA Analysis. The site is the same for both projects and the site under both development scenarios will be fully developed, so impacts will be similar to those identified for the proposed project (i.e., no impact). e) Create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.e) Original SPSP Analysis. The existing site is relatively flat and already developed with a hotel, landscaping, and parking areas, and generally drains toward the south. There are no surface drainage courses on the project site, but the East Branch Arcadia Wash is located approximately 227 feet west of the site and the Arcadia Wash is located approximately 2,000 feet west of the site. The proposed project would replace the existing hotel with new hotel and related lodging facilities, landscaping, and parking areas. As outlined in the project hydrology study (Appendix F), the proposed project will not create or contribute runoff in addition to that already generated by the site, in compliance with the City’s flood control requirements, and adherence to the above Mitigation Measures HYD-1 through HYD-3. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. None of the changes affect local runoff or water quality requirements, so impacts of the proposed project in this regard are expected to be equivalent to those of the approved SPSP project (i.e., less than significant). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 53 f) Otherwise substantially degrade water quality? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.f) Original SPSP Analysis. The proposed project is in a developed urban setting and through adherence to City water quality regulations and Mitigation Measures HYD-1 through HYD-3 would not substantially degrade water quality. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. None of the changes affect local runoff or water quality requirements, so impacts of the proposed project in this regard are expected to be equivalent to those of the approved SPSP project (i.e., less than significant with mitigation in other sections). g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.g) Original SPSP Analysis. Most of the annual rainfall in the region occurs in the winter with potential flooding occurring in the City from intense storms resulting in rapid runoff. The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRMs) identify areas subject to flooding during the 100-year storm event. Note that the term “100-year” is a measure of the size of the flood, not how often it occurs. The “100-year flood” is a flooding event that has a one percent chance of occurring in any given year. Based on these FIRM maps (map 06037c1400F), the project site is not located within the 100-year floodplain. Because the project site is not located within a floodplain, the proposed project would not impede or redirect flood flows (FEMA 2011). In addition, the project hydrology study (Tritech Associates, Inc. July 2013)(Appendix F) indicates that the proposed project would not result in increased runoff from the project site over existing volumes. Therefore, no impacts associated with this issue would occur, and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which is not within a 100-year flood plain, so there are no impacts in that regard. h) Place within a 100-year flood hazard area structures that would impede or redirect flood flows? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact IX.h) Original SPSP Analysis. The proposed project site is not within a 100-year flood hazard zone. Since the proposed project would not place structures that would impede or SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 54 redirect flood flows, there would be no impact in regards to this issue, and no mitigation is required. i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.i) Original SPSP Analysis. Construction and operation of the proposed project would not cause or increase the likelihood of failure of a levee or dam that could result in flooding. Although the project site is located within the flood hazard zone for Santa Anita Dam, which is located along the Santa Anita Wash approximately 2 miles north of the project site, the proposed project would not involve housing as part of the project. Additionally, the entire community is in Zone D, which the City is not required to implement any flood plain management regulation as a condition per the National Flood Insurance Program from the Federal Emergency Management Agency. Therefore, impacts in this regard would be less than significant and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which does not face risks regarding flooding, so there are no impacts in that regard. j) Inundation by seiche, tsunami, or mudflow? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact IX.j) Original SPSP Analysis. The project site does not have any enclosed bodies of water (e.g., reservoir tank or pond) that could cause or result in a seiche (standing wave) during a seismic event. The site is also not located near the Pacific Ocean or within a tsunami or mudflow hazard area. Therefore, the project would not result in any significant impacts related to these hazards, and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are on the same site which is not subject to any of these risks, so there are no impacts in that regard. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 55 X. LAND USE AND PLANNING Would the project: a) Physically divide an established community? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact X.a) Original SPSP Analysis. The project site is in an urbanized area and is surrounded by developed uses. Directly west of the project site are the Santa Anita Park race track, the Arboretum of Los Angeles County is further to the west, and a regional mall called the Westfield Mall Santa Anita is to the southwest just south of the racetrack. North of the project site are offices and retail commercial areas along Colorado Place. North of these commercial and office uses are existing residential neighborhoods. A small bar called the “100 to 1” is located at the northeast corner of the project site. To the east of the project site is the Arcadia County Park. South of the proposed site are the Civic Center Athletic Field Recreational Area and the City Hall complex. An individual house used by the Salvation Army as a rehabilitation facility is immediately south of the southwest corner of the site, and farther southwest are the Methodist Hospital, Quest Diagnostics Medical Lab, and Medical Library. Demolition of the existing hotel and construction of new lodging and other commercial uses on the project site would not physically divide an established community, as the proposed site plan indicates that access in and around the site will be maintained similar or better than that which exists now. The only existing residential land use is north of the site (north of the office and commercial uses along Colorado Place) and the rest of the surrounding land uses are commercial in nature or public facilities. Therefore, the proposed project will not divide an existing community, and no mitigation is required. Proposed SPA Analysis. The proposed project and approved SPSP are the same site which has the same neighborhood conditions, so potential impacts in terms of dividing a neighborhood would be the same (i.e., less than significant). b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact X.b) Original SPSP Analysis. The City of Arcadia is a charter city as opposed to a general law city. Arcadia’s General Plan designates the proposed project area as commercial with a downtown overlay (for higher FAR), while the zoning is general commercial (C-2) with the downtown overlay and a height overlay (H-8) which allows buildings up to 95 feet or 8 stories, as shown in Table G. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 56 Table H: General Plan Land Use and Zoning Designations Area/Direction Land Use Designations Zoning Designations PROJECT SITE Commercial – Downtown Overlay1 General Commercial (C-2) with Downtown Overlay1 and Special Height Overlay (H-8)2 North of Project Site (downtown neighborhoods) Commercial - Downtown Overlay1 General Commercial (C-2) with Downtown Overlay1 South of Project Site (City Hall and Hospital) Public/Institutional Public Purpose (S-2) East of Project Site (Arcadia County Park) Open Space - Outdoor Recreation Public Purpose (S-2) West of Project Site (Santa Anita Park) Horse Racing Special Uses (S-1) Source: Arcadia General Plan Land Use Map, Hogle-Ireland 2010 and approved City Zoning Map, November 2010. 1 allows Floor Area Ratio (FAR) up to 1.0 otherwise commercial FAR is 0.5 2 H-8 allows building heights up to 95 feet or 8 stories The City’s General Plan says the following about the Commercial land use designation… The Commercial designation is intended to permit a wide range of commercial uses which serve both neighborhood and citywide markets. The designation allows a broad array of commercial enterprises, including restaurants, durable goods sales, food stores, lodging, professional offices, specialty shops, indoor and outdoor recreational facilities, and entertainment uses. Adjacent to Downtown, the Commercial designation is intended to encourage small-scale office and neighborhood-serving commercial uses that complement development in the Downtown Mixed Use areas. While the land use designation provides the general parameters within which development must take place, the Zoning Code or other land use regulatory document specifies the type and intensity of uses that will be permitted in a given area. In the Downtown area, for example, where properties are designated Commercial, land use regulations might specify that restaurants and cafes are permitted, but secondhand stores are not. The Zoning Code and other regulatory documents also indicate permitted building height limits for specific properties. Maximum FAR – 0.50 Higher intensity overlays are applied to portions of Downtown along Santa Anita Avenue, Colorado Place, and Huntington Drive (1.0 FAR). The description of “permitted” uses above lists “lodging” which typically includes hotels and other kinds of short-term, temporary, vacation, or seasonal residences. The Specific Plan indicates that the proposed hotel condominiums are considered to be more like a type of lodging because many of them would be used as “time share” or other types of temporary (short-term) or seasonal (limited) occupants, typically less than one year at a time. These units will be marketed directly to race track-related guests and staff. They are not intended to support a large number of full-time occupants compared to standard residential-type units that would have permanent long-term City residents. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 57 Section 9220.29 of the City’s Municipal Code (zoning) defines “Hotel is a building in which there are six or more guest rooms where lodging with or without meals is provided for compensation as the more or less temporary abiding place of individuals and where no provision is made for cooking in any individual room or suite.” All of the hotel rooms meet this definition. Although the condominium units will have kitchens, they are much closer to the definition of hotel units rather than standard residential units for the reasons listed above. Therefore, the two hotels and the hotel condominiums in the Seabiscuit Pacifica project are consistent with the allowable uses under the General Plan under the “commercial” land use designation, therefore, the Seabiscuit Pacifica Specific Plan does not require a General Plan Amendment. In response to questions about the specific nature of the hotel condominiums, the developer provided the following information: The hotel condominium concept was first introduced in Miami, Florida during the early 1980’s and was further developed through the1990’s. Developers started building newer and larger hotel condominiums next to hotels. Then the concept really took off in the last ten years. Franchise hotels have been developing high end, luxury extended stay hotels all over the world. The trend has been extremely successful and will only get more popular as time on. We have studied a handful of luxury hotels in Hawaii and Los Angeles, particularly the iconic buildings, L.A. Live in Los Angeles and W Hotel in Hollywood. Both projects have been very successful. Our hotel condominiums look to mimic the success of L.A. Live and will be anchored similarly by a Marriott hotel, brandishing the Ritz Carlton Residence name. The basic concept of the hotel condominium is to service business and leisure travelers who are looking to stay more than a few days in a luxury hotel in Arcadia. It will boast the full amenities of a real home and a grand view of the Santa Anita Race Track and the San Gabriel Valley. Internet, phone, concierge, mail service, and 24 hour security are just some of the accommodations that will be offered. Ideal patrons can range from international business people to families making long term visits. The condo tower will offer a high end lodging option in the heart of the city, which will accentuate the Arcadia lifestyle and provide something our community lacks. Our studies show a strong demand for a hotel condominium that can provide adequate service for business travelers, leisure travelers and overseas investors who are looking to stay more than a few days in a hotel. The hotel condominium will be a lodging option unlike any other in the city by providing more bedrooms, privacy and luxury comfort for all guests. As the developer, we hope to sell all 50 units to recover some of the construction costs. All units will be subdivided and sold once the certificate of occupancy is issued. The building will stand 8 stories tall with a French Normandy style and feature quality construction that will meet city code and regulations like the Ritz Carlton at L.A. Live. The estimated cost per square foot to market will be around $550/square foot and with an average of 2,000 square feet per unit, each unit will be worth at least $1 million. We estimate the weekly rental to be around $1,200 and monthly to be $4,500. We do not expect any difficulty with either soliciting buyers or renters since we have a limited supply of only 50 units. And at the end of the day, this will only make our project more exclusive and prestigious, falling in line with the 21st century lifestyle of Arcadia. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 58 The management company for the hotel condominiums can either be a licensed hospitality management group or a Marriott-approved management company. We will use Marriott’s list of recommended management companies since we hope to apply the Marriott franchise name to this development such as the Ritz Carlton. Through our studies, we feel very strongly that the hotel and hotel condominiums can be linked into one controlling entity. Developer’s Preference All new units will be built to the highest standard of quality. Like the Ritz Carlton, they will be sold on the open market to 50 different buyers from all over the world. We expect to have at least 150-200 qualified buyers on our waitlist and will reserve the right to have preference in approving buyers based on the intended use. Our pre-selected buyer will utilize the unit as an investment and only make short stays. Our selection process will be geared towards owners like jockey, horse owners, and especially overseas seasonal travelers. Compliance with City TOT Policy Since the hotel condominiums have some residential elements, guests will be subject to TOT tax just like the existing Santa Anita Inn. The TOT tax requirements will be written into the HOA policy for each individual owner to agree to and pay through the management company. The document will spell out a TOT tax requirement of 10% that will be paid within the first 90 days of stay once the owner turns the unit over for the management company to rent. The individual owner will not have the right to stay indefinitely without paying taxes and will be exposed to TOT tax in the first 90 days as well. The owner can only rent by using the on- site management and leasing company. And once they rent out a unit, there will be tax consequences. Our studies show 85% of buyers at L.A. Live are investors that use their purchases as rental units in the same way. Control of All Units No condominium unit can be sold without an HOA Policy approved by the California Department of Real Estate (DRE) and the City of Arcadia. Our company attorney will draft the HOA forming documents that will spell out all City TOT requirements and that all owners must agree to rent through the hotel management company. The management company will also collect the TOT tax and pay the City monthly. The key to the concept is that the hotel condominiums will be taxed no differently than how a regular hotel is. The additional income to that of the new 210 hotel rooms will benefit the City even more with another source for tax generation. The way the tax is collected and paid to the city makes this project unique and different from any other condominium project in the City. The City’s zoning map indicates the site is zoned General Commercial (C-2) which allows hotels with a Conditional Use Permit (CUP). Approval of the Specific Plan by the City Council would allow the hotels and condominiums by right and eliminate the need for a CUP consistent with state law for charter cities. In addition, no zone change would be required as the Specific Plan becomes the zoning for the property upon approval by the City. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 59 The City’s General Plan and zoning map indicate the site has a “Downtown Overlay” that allows a “Floor Area Ratio” (FAR) of up to 1.0 compared to a non-overlay commercial FAR of 0.5. The total building area of the Seabiscuit Pacifica Specific Plan indicates the project FAR is slightly over 1.0 (see Table 2.B). However, approval of the Specific Plan by the City Council will constitute acceptance by the City that the proposed Seabiscuit Pacifica Specific Plan is generally consistent with the General Plan, and that any modification to the building development characteristics shown in this Specific Plan will require City Council approval of a Specific Plan Amendment. The City’s zoning map indicates the site has a Height Overlay (H-8) which allows buildings up to 95 feet in height or 8 stories, as shown below from the City’s Municipal Code Section 9276.2.2: 9276.2.2. - HEIGHT LIMIT Any building or structure in Zone H may, by complying with the provisions of this Title, exceed the height limitation applicable to the basic zone in which it is located; provided, however, that no building or structure shall in any event exceed the height limit set forth in the following table: Zone H8 - Eight (8) stories or ninety-five (95) feet. The tallest building in the proposed Seabiscuit Pacifica project is 98 feet with 8 stories, so the Seabiscuit Pacifica Specific Plan is slightly inconsistent with the H-8 Height Overlay (+3% higher). However, approval of the Specific Plan would eliminate this minor inconsistency and no mitigation is proposed. Appendix B of the Specific Plan contains a detailed tabular comparison of the General Plan policies and goals that are applicable to this project. It indicates the proposed project is consistent with all of the applicable General Plan policies and goals. Based on this analysis, the proposed Specific Plan appears to be generally consistent with the City’s General Plan and zoning designations and applicable development guidelines and the City’s zoning designations. Therefore, the proposed project would have no significant land use impacts related to existing applicable land use plans, policies, and regulations, and no mitigation is required. Proposed SPA Analysis. The proposed project requests removal of the term “hotel” condominium from the SPSP and instead wishes to have standard residential condominiums. The General Plan designation for the site is commercial, and that designation does not allow residential uses, so the applicant has requested changing the land use designation to Downtown Mixed Use to allow both commercial (hotel and office) and residential (condominium) uses. A similar request for a zone change to mixed use has also been requested. The building heights in the proposed SPSPA are consistent with the height limits in the Downtown Height Overlay (H-8 to 95 feet) that is already in place on the property. Therefore, the proposed modified project will be consistent with the City General Plan and zoning and would be essentially the same as that already approved under the SPSP in terms of aesthetics and height. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 60 The main difference between the approved project and the proposed modified project is the inclusion of residential condominiums rather than hotel condominiums which will have some number of full-time residents. A worst case assumption would be that all the units are occupied at some point with 2 persons per unit or a total of 100 residents. This number of additional residents would not result in significant land use impacts on the project site or for the surrounding area, and in fact additional full-time residents would help improve the local economy through purchases of goods and services, in addition to the increased property taxes from additional residential units. The analysis of the original project in this Initial Study determined that the hotel and hotel condo uses on this site would not conflict with the goals or policies of the General Plan, and these are very similar uses to those under the proposed SPA. Therefore, the revised project would not conflict with the applicable General Plan goals and policies and its land use impacts would be similar to those of the approved SPSP (i.e. less than significant). c) Conflict with any applicable habitat conservation plan or natural community conservation plan? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact X.c) Original SPSP Analysis. The project site is not designated for any type of habitat protection under the City’s General Plan, and is not covered by any adopted Habitat Conservation Plan or Natural Community Conservation Plan. Therefore, there will be no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The revised project has the same site conditions regarding HCPs or NCCPs as the original project, so there are no impacts in this regard. XI. MINERAL RESOURCES Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XI.a) Original SPSP Analysis. The project site is within the fully developed downtown area of Arcadia, and does not contain, nor is it designated as, a source of mineral resources (e.g., construction aggregate). Therefore, there will be no impacts in this regard, and no mitigation is required. Proposed SPA Analysis. The revised project has the same site conditions regarding mineral resources as the original project, so there are no impacts in this regard. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 61 b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact XI.b) See response XI.a. XII. NOISE Would the project result in: a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact XII.a) Original SPSP Analysis. The proposed project is in an urbanized area and surrounded by developed uses. Directly west of the project site is the Santa Anita Park horse racing track, while the Arboretum of Los Angeles County is further to the west. A regional mall called the Westfield Mall Santa Anita is located southwest of the site just south of Santa Anita Park. Immediately north of the proposed project site are offices and retail commercial areas along Colorado Place, and further north of these offices are existing residential areas west of the main downtown area. Just east of the project site is the Arcadia County Park, while to the south is the Civic Center Athletic Field Recreational Area and (further south) is the Arcadia City Hall. A rehab facility in a single family house used by the Salvation Army is located at the southwest corner of the project site, while an old bar is located at the northeast corner of the project site. Farther to the southwest are the Methodist Hospital, Quest Diagnostics Medical Lab, and Medical Library. Short-Term Impacts A noise impact assessment for the proposed project was prepared by LSA Associates, Inc. (LSA August 2013)(Appendix H). The assessment indicates that short-term noise impacts would be associated with excavation, grading, and erecting of buildings on site during construction of the proposed project. Construction-related short-term noise levels would be higher than existing ambient noise levels in the project area today but would no longer occur once construction of the project is completed. Construction of the proposed project is expected to require the use of earthmovers, bulldozers, and water and pickup trucks. This equipment would be used on the project site. Based on the information in Table F of the Noise Impact Analysis, and assuming that each piece of construction equipment operates at some distance from the other equipment, the worst-case combined noise level during this phase of construction would be 91 dBA Lmax at a distance of 50 feet from the active construction area. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 62 According to the Noise Impact Analysis, the residences nearest to the project site are more than 1,000 feet to the north of the project boundary. These residences may be subject to short-term, intermittent, maximum noise reaching 65 dBA Lmax, generated by construction activities on the project site. Compliance with the construction hours specified in the City’s Noise Control Ordinance would reduce the construction noise impacts to less than significant. However, the existing Salvation Army rehab facility is so close to the southwest corner of the project site that demolition of the existing hotel buildings and construction of the new condominiums in Phase 2 may have significant noise impacts on the rehab facility. Out of an abundance of caution, it would be prudent to install a temporary noise barrier for this facility along the common boundary until Phase 2 construction is complete. Long-Term Impacts According to the Noise Impact Analysis, vehicular traffic trips associated with the proposed project would not result in significant traffic noise impacts on off-site sensitive uses. However, the proposed hotel units adjacent to Huntington Drive (Eastbound) and Huntington Drive (Westbound) would be potentially exposed to significant traffic noise from these streets. The Noise Impact Analysis Tables G-H (see Appendix H pages 12-16 in the study) show the existing traffic noise levels, existing plus cumulative with project traffic noise levels, opening year (2016) without project traffic noise levels , and opening year (2016) plus cumulative with project scenarios traffic noise levels. “These noise levels represent the worst-case scenario, which assumes that no shielding is provided between the traffic and the location where the noise contours are drawn” (page 12, LSA August 2013). The largest increase in noise in the area will be 1.0 dBA and will occur due to increased traffic along Huntington Drive (westbound) from Holly Drive to Santa Clara Street because of the proposed project. This noise increase is not perceptible to the human ear and will have a less than significant impact on long term noise impacts to off-site land uses. According to the Noise Impact Analysis, hotel balconies and patios along Huntington Drive westbound and eastbound will be exposed to traffic noise reaching 63 dBA CNEL, which is lower than the City’s 65 dBA CNEL noise standard for noise-sensitive outdoor active uses. Therefore, no noise barrier is required. Interior noise levels with windows closed would also be below the City’s 45 dBA CNEL noise standard. However, with windows open, interior noise levels would be higher than 45 dBA CNEL. This is a significant impact and requires mitigation in the form of an air-conditioning system for frontline hotel rooms along both Huntington Drives. Residential uses north of the project site would be physically blocked from noise emanating from onsite loading/unloading activities for proposed project uses. Therefore, no significant noise impacts would occur for these off-site residences from on-site noise generating activities. Noise levels from parking lot noises are anticipated to be lower than that of the truck delivery and loading/unloading activities. Parking lot noise is not anticipated to be a significant noise issue with respect to hotel customers within the project site. HVAC equipment is typically located on the building rooftop and is assumed that, as a worst-case scenario, HVAC equipment would operate 24 hours a day. The closest neighboring residence to the HVAC equipment is estimated to experience noise levels below the City’s nighttime maximum noise level of 60 dBA Lmax. Therefore, noise generated from HVAC equipment would not have a significant noise SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 63 impact. Mitigation is not required for less than significant impacts from truck delivery loading, parking lot noises, and HVAC equipment. As with short-term noise impacts from construction, there may be long-term noise impacts at the existing Salvation Army rehab facility due to its proximity to the southwest corner of the project site. Occupancy of the new condominiums in Phase 2 is not expected to cause significant long-term noise impacts on the rehab facility. However, out of an abundance of caution, it would be prudent to install a filled cell block wall as a permanent noise barrier for this facility along its common boundary with the proposed project once construction of the condominium building is complete. This wall would help minimize any potential long-term noise impacts on the Salvation Army facility. Mitigation Measures N-1 Prior to issuance of grading and building permits for each phase of the project, the developer shall prepare a Construction Noise Control Plan and will submit the plan the City for review and approval. The plan shall include but will not be limited to the following:  During all project site excavation and grading, contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers consistent with manufacturers’ standards.  The project contractor shall place all stationary construction equipment so that emitted noise is directed away from the closest sensitive receptor to the project site (i.e., the Salvation Army facility at the southwest corner of the site).  The construction contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise sources and the closest noise-sensitive receptor to the project site (i.e., the Salvation Army facility at the southwest corner of the site) during all project construction.  During all project site construction, the construction contractor shall limit all construction-related activities that would result in high noise levels to between the hours of 7:00 a.m. to 7:00 p.m. on weekdays and Saturday. No construction shall be permitted on Sundays or any of the holidays listed in AMC Section 4261.  Prior to the start of Phase 2 grading, the developer shall install a wooden noise barrier along the common boundary of the project and the Salvation Army rehab facility at the southwest corner of the project site. This barrier shall be removed upon completion of Phase 2 construction. N-2 Prior to the issuance of building permit for each phase, the developer shall demonstrate that all buildings shall have air-conditioning to minimize noise impacts on hotel rooms along West and East Huntington Drives. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 64 N-3 Prior to the issuance of occupancy permits for the Phase 2 condominium building, the developer shall install a filled-cell concrete block wall along the common boundary with the Salvation Army rehab facility at the southwest corner of the project site. In lieu of the temporary construction wall outlined in Measure N-1, the developer may install this permanent wall “early” (i.e., prior to issuance of occupancy permits for Phase 1) which would eliminate the need for that portion of Measure N-1. With implementation of these measures, the proposed project will not have any significant short- or long-term noise impacts on surrounding land uses. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP with a change from hotel to residential condos, which could add permanent full-time residents to the area, and the addition of 6,762 square feet of office/retail space on the bottom floor of the condo tower in Phase 2. Despite these incremental changes, anticipated noise impacts of the proposed project are expected to be equivalent to those of the approved SPSP project, so impacts are less than significant with mitigation. b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XII.b) Original SPSP Analysis. Vibration refers to groundborne noise and perceptible motion. Groundborne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors, where the motion may be discernible, but without the effects associated with the shaking of a building, there is less adverse reaction. Bulldozers and other heavy-tracked construction equipment generate approximately 92 VdB of groundborne vibration when measured at 50 feet. This level of groundborne vibration exceeds the threshold of human perception, which is around 65 VdB. Every doubling of distance from 50 feet results in the reduction of the vibration level by 6 VdB; therefore, receptors at 100 and 200 feet from the construction activity may be exposed to groundborne vibration up to 86 and 80 VdB, respectively. Existing and proposed streets surrounding the project area are paved, smooth, and unlikely to cause significant ground-borne vibration. In addition, the rubber tires and suspension systems of buses and other on-road vehicles make it unusual for on-road vehicles to cause ground- borne noise or vibration problems. It is therefore assumed that no such vehicular vibration impacts would occur and that no vibration impact analysis of on-road vehicles is necessary. During Phase 1, demolition and excavation will take place mainly in the northern portion of the site, so the Salvation Army facility would not be significantly impacted by vibration from grading. During Phase 2, and especially during excavation of the subterranean parking, vibration from grading may be felt by residents of the Salvation Army facility. However, no blasting or pile-driving activities are expected as part of grading for this project, so vibration effects will be temporary and relatively limited relative to the Salvation Army facility. No other SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 65 sensitive receptors would be affected by project grading and construction due to the distance from the project site to these uses (i.e., residences to the north). Ground-borne vibration from construction activities will be mostly low to moderate, except during on-site grading and earthmoving activities. Vibrations associated with on-site construction would be reduced to a level less than what is perceptible to the average human. Additionally, groundborne vibration during construction activity would be temporary and cease upon completion of construction, and is therefore considered to be a less than significant impact of the proposed project. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. Anticipated vibration impacts of the proposed project are expected to be equivalent to those of the approved SPSP project, so impacts are less than significant. c) Substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XII.c) Original SPSP Analysis. Current noise levels on the project site are relatively low and are related to activities of the existing Santa Anita Inn. The proposed project would introduce more intense development to the site, which will increase ambient noise levels compared to those of the Santa Anita Inn. The project noise study indicated that these increases would be noticeable but would not represent a significant adverse noise impact (page 18, LSA August 2013). With the proposed Mitigation Meaures N-1 through N-4, the proposed project is not expected to result in significant adverse noise impacts or noise levels in excess of identified standards. For a more detailed analysis, see Section XII.a above. Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. Anticipated noise impacts of the proposed project are expected to be equivalent to those of the approved SPSP project, so impacts are less than significant. d) Substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XII.d) Original SPSP Analysis. Although activity on the site will increase as a result of the new land uses and construction, the analysis provided in Section XII.a demonstrates that the proposed project will not generate significant noise impacts over the long-term for either onsite or offsite uses (LSA August 2013). Proposed SPA Analysis. The proposed SPA is the same type and size of project approved under the original SPSP. Anticipated noise impacts of the proposed project are expected to be equivalent to those of the approved SPSP project, so impacts are less than significant. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 66 e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? Potentially Significant Impact Less than Significant With Mitigation Incorporated Less than Significant Impact No Impact XII.e) Original SPSP Analysis. The project site is not located within an airport land use plan study area, or within two miles of a public airport or public use airport. The proposed project would therefore have no impacts related to exposure of residents or workers to excessive airport noise levels, and no mitigation is required. Proposed SPA Analysis. The proposed project site is the same as the approved SPSP site, and it is not within two miles of a public airport. Therefore, impacts are the same as with the approved SPSP (i.e., no impact). f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XII.f) Original SPSP Analysis. The project site is not located within the influence area of a private airstrip. The proposed project would therefore have no impact related to exposure of residents or workers to excessive airstrip noise levels, and no mitigation is required. Proposed SPA Analysis. The proposed project site is the same as the approved SPSP site, and it is not within two miles of a private airstrip. Therefore, impacts are the same as with the approved SPSP (i.e., no impact). XIII. POPULATION AND HOUSING Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XIII.a) Original SPSP Analysis. The proposed project would result in only minor population growth for the City. The site contains an existing hotel with 26 employees at present (14 full time employees and 12 part time employees), while the proposed project would add 85 full- time or part-time commercial service employees to the local workforce. Also, the “population” of the new hotel and hotel condominiums would be approximately 442 people at buildout based SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 67 on at 85 percent average occupancy and assuming 2 people per unit.3 The population of the existing Santa Anita Inn at 85 percent occupancy would be 187 persons.4 Assuming similar occupancy for the existing 110 units of the Santa Anita Inn (i.e., 187 occupants on average), the proposed project would increase the hotel-related “population” of the City by approximately 255 people. It should be remembered that the proposed project uses are lodging and so would not add this number of actual full-time residents to the City’s population. For additional information on the nature of the hotel condominiums, see Section X, Land Use and Planning. This “population” increase would be primarily transient or seasonal based on the Santa Anita Park race schedule. The proposed project would also not result in the need for any new utilities, except for the planned sewer improvements. Therefore, due to the nature and size of the project, it is not expected to result in any significant indirect growth inducement to the City’s population or housing. No significant impacts are expected in this regard, and no mitigation is required. Proposed SPA Analysis. The proposed project would construct residential condos on the site rather than the original hotel condos under the SPSP. The previous analysis determined that “the proposed project would increase the hotel-related “population” of the City by approximately 255 people. It should be remembered that the proposed project uses would now be considered residences and could have permanent or full-time occupants as opposed to temporary lodgers under the original proposal. As a worst case estimate, if all 50 units had 2 full-time residents, the long-term population of the project would be 100 residents which would then incrementally increase the City’s population. However, some or all of these residents may now be counted as full-time residents under the amended this potential population-related increase is incremental compared to the City’s 2013 estimate population of 57,639 residents (0.17 percent), so the potential population impacts of the proposed project would be less than significant, similar to that of the approved SPSP. b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XIII.b) Original SPSP Analysis. The site does not currently contain any housing units, so construction of the proposed project would not result in displacement of existing housing or construction of replacement housing elsewhere in the City or nearby County areas. However, the project would eventually result in the loss of 110 hotel units, but provide a total of 260 hotel and condominium units, for a net increase in 150 lodging units. No significant housing impacts are expected, and no mitigation is required. Proposed SPA Analysis. The proposed project site is the same as the approved SPSP site, so impacts are the same as with the approved SPSP (i.e., no impact). 3 210 rooms x 0.85 x 2 people per room = 357 persons 4 50 rooms x 0.85 x 2 people per room = 85 persons SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 68 c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XIII.c) Original SPSP Analysis. The site does not currently contain any housing units but does have and an existing hotel. As outlined in Section XIII.a and XIII.b above, the existing hotel has an average occupancy of 187 guests, while the new hotel and condominium units would have an average occupancy of 442 guests. Demolition of the existing hotel is not expected to result in the displacement of existing housing (as opposed to lodging) or construction of replacement housing elsewhere in the City or nearby County areas. Therefore, no impacts are expected in this regard and no mitigation is required. Proposed SPA Analysis. The proposed project site is the same as the approved SPSP site, and the proposed uses would not change appreciably, the residential condos and offices would not result in any significant additional number of people on the site or in the City, so impacts are the same as with the approved SPSP (i.e., no impact). XIV. PUBLIC SERVICES a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:  Fire Protection?  Police Protection?  Schools?  Parks?  Other Public Facilities? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XIV.a) Original SPSP Analysis. The project site contains the existing Santa Anita Inn, a hotel with 110 rooms. The proposed project would place similar lodging-oriented commercial uses on this site that would generate more local traffic and introduce more employees and guests to the project area. The proposed project would introduce more employees to the site than at present (85 vs. 26), and this change of use would incrementally increase the need for fire, police, parks, and other public facilities. However, these increases would be incremental and not result in any significant service impacts. Since it will not include new homes or generate new residents, the proposed project will not have any significant impacts on local schools or parks. The proposed SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 69 project will pay all applicable Development Impact Fees to the City and local school district to alleviate potential impacts related to public services. Proposed SPA Analysis. The proposed project is very similar to the approved SPSP site, the only changes are the residential condos and offices would incrementally increase the need for some public services, but these minor increases would not change the overall assessment of impacts as there would not be a significant increase in the number of people on the site or in the City, so impacts are the same as with the approved SPSP (i.e., less than significant. XV. RECREATION a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XV.a) Original SPSP Analysis. The project proposes only commercial uses that will not generate a significant amount of new permanent residents in the City who would require additional recreational facilities or programs. Many project workers will likely live in or near to Arcadia, and can take advantage of existing City and County park facilities and services. Some new workers may live outside of Arcadia and may place incremental increased demand on City park facilities and services. However, these impacts would be incremental and would not represent significant impacts to City recreation facilities or services. Proposed SPA Analysis. The proposed project is very similar to the approved SPSP site, the only changes are the residential condos that would incrementally increase the need for recreation services (e.g., slightly more use of the County park to the east). If all 50 condos had full time residents, there might be as many as 100 additional residents in the area or in the City (assuming 2 residents per condo). This minor increase would not be expected to substantially change the overall assessment of impacts, although it would result in higher Developer Impact Fees for park services/facilities. Potential impacts to recreation would still be essentially the same as with the approved SPSP (i.e., less than significant. b) Does the project include recreational facilities or require the construction or expansion or recreational facilities, which might have an adverse physical effect on the environment? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XV.b) Original SPSP Analysis. The project proposes commercial lodging uses which would not generate a substantial amount of new City residents, so the proposed project would not generate a need to expand existing City recreational facilities. The proposed project will also have a number of indoor and outdoor event or public spaces which will help reduce potential impacts on local park facilities. Therefore, no significant impacts associated with this issue would occur, and no mitigation is required. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 70 Proposed SPA Analysis. See Response XV.a above. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 71 XVI. TRANSPORTATION/TRAFFIC Would the project: a) Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.a) Original SPSP Analysis. The traffic impact analysis prepared for the proposed project (Kimley Horn & Associates July 2013)(Appendix G) evaluated twelve (12) local roadways and four (4) local intersections based on the City’s traffic study requirements and the County’s Congestion Management Plan (CMP) criteria. It concluded that Phase 1 of the proposed project will generate a total of 842 daily trips on weekdays, 24 in the AM peak and 62 in the PM peak, and 844 trips on Saturday, 75 of which are during the PM peak. Phase 2 would generate a total of 412 daily trips on a weekday, 43 tips in the AM peak and 62 trips in the PM peak, and 395 trips on Saturday, 44 of which are during the PM peak. The project traffic impact analysis used the Highway Capacity Manual (HCM) methodology for both signalized and unsignalized intersections. The HCM method examines the ratio of volume to capacity (V/C) and emphasizes seconds of delay on each leg of an intersection. All traffic data are presented in Appendix G of this document. The following analysis summarizes the project traffic impacts using Level of Service (LOS) rankings, which are on a sliding scale of A though F, with A being excellent traffic flow through an intersection and F being extensive congestion. A more detailed explanation of LOS values is provided in the project traffic impact analysis and a supplemental memorandum addressing City staff comments in Appendix G. The City of Arcadia utilizes CMP traffic impact study guidelines that define a “significant traffic impact” as an increase in demand by at least 2 percent where the intersection would operate at LOS F with the project traffic. According to the traffic report the intersection at Huntington Drive and Colorado Place would be negatively impacted due to the proposed project. Phase 1 will have significant impacts on the intersection of Huntington Drive and Colorado Place due to increase of greater than 2 percent demand. However, Phase 2 of the proposed project will not have significant impacts on surrounding intersections. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 72 Table I: Summary of Intersection Analysis (2013)1 Intersection Weekday Saturday Am Peak Hour PM Peak Hour Impact PM Peak Hour Impact V/C LOS Change* V/C LOS Change* V/C LOS Change* 1. Huntington Drive/Santa Anita Avenue 0.747 C 0.010 0.811 D 0.001 No 0.691 B 0.001 No 2. Huntington Drive/Santa Clara Street 0.904 D 0.005 0.787 C 0.005 No 0.646 B 0.007 No 3. Huntington Drive/Colorado Place 868.850 F 868.306 887.6 F 886.42 Yes 1181.350 F 1180.71 Yes 4. Huntington Drive/Holly Ave 0.786 C 0.001 0.567 A 0.001 No 0.598 A 0.001 No Source: Table 13, Kimley Horn & Associates, July 2013 1 Level of Service (LOS) values that include Existing (2013) plus Cumulative plus Ambient plus Project traffic V/C = HCM methodology showing volume to capacity ratio — = HCM only applies to signalized intersections LOS = Level of Service (A through F) Table J: Summary of Intersection Analysis (2016)1 Intersection Weekday Saturday Am Peak Hour PM Peak Hour Impact PM Peak Hour Impact V/C LOS Change* V/C LOS Change* V/C LOS Change* 1. Huntington Drive/Santa Anita Avenue 0.785 C 0.012 0.840 D 0.000 No 0.716 C 0.000 No 2. Huntington Drive/Santa Clara Street 0.938 E 0.002 0.818 D 0.003 No 0.672 B 0.003 No 3. Huntington Drive/Colorado Place 0.530 A 0.003 0.792 C 0.004 No 0.655 B 0.000 No 4. Huntington Drive/Holly Ave 0.813 D 0.000 0.586 A 0.000 No 0.618 B 0.000 No Source: Table 21, Kimley Horn & Associates, July 2013 1 Level of Service values include 2016 plus Ambient Plus Project traffic V/C = HCM methodology showing volume to capacity ratio — = HCM only applies to signalized intersections LOS = Level of Service (A through F) SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 73 Table K: Summary of Roadway Analysis: Existing (2016)1 Roadway Segment V/C LOS Change 1. Huntington Drive Baldwin Avenue to Holly Drive 0.443 A 0.002 2. Huntington Drive (EB) Holly Drive to Santa Clara Street 0.505 A 0.001 3. Huntington Drive (WB) Holly Drive to Colorado Place 0.620 B 0.005 4. Huntington Drive Santa Clara Street to Santa Anita Avenue 0.657 B 0.005 5. Duarte Road Holly Drive to Santa Anita Avenue 0.592 A 0.000 6. Live Oak Avenue Anta Anita Avenue to Second Avenue 0.691 B 0.000 7. Baldwin Avenue Colorado Street to Santa Anita Mall Driveway A 0.823 D 0.003 8. Baldwin Avenue** Santa Anita Mall Driveway A to Huntington Drive 0.590 A 0.002 9. Santa Anita Avenue Foothill Blvd to I-210 WB Ramps 0.699 B 0.004 10. Santa Anita Avenue Colorado Boulevard to Santa Clara Street 0.795 C 0.004 11. Santa Anita Avenue Santa Clara Street to Huntington Drive 0.627 B 0.004 12. Santa Anita Avenue Huntington Drive to Campus Drive 0.686 B 0.001 Source: Table 20, Kimley Horn & Associates, July 2013 1 Level of Service values include 2016 plus Ambient Plus Project traffic V/C = HCM methodology showing volume to capacity ratio — = HCM only applies to signalized intersections LOS = Level of Service (A through F) Regarding parking, the site plan includes 340 parking spaces and the City requires 312 parking spaces. While parking was recently removed from the State CEQA Guidelines Appendix G Checklist as an environmental issue, it is nonetheless important to know how much parking is being provided by the project compared to how much is needed and/or required by the City to assure that project occupants will not have to park on adjacent properties due to a deficiency of onsite parking. Mitigation Measures The following measures are proposed to help ensure that project-related traffic, both short-term during construction and long-term after project occupancy, are reduced to less than significant levels, as outlined in the project traffic study (KHA 2013): TRA-1 Prior to issuance of an occupancy permit for either hotel in Phase 1, the developer shall be responsible for installing an additional signal phase to accommodate northbound movements exiting the shared hotel driveway and southbound movements entering the hotel driveway. The developer will also change the number one lane to a shared through and left turn lane to access the driveway for the hotels and modify the signal to account for the added phases and lanes. These changes shall be made to the satisfaction of and in coordination with the City traffic engineer. TRA-2 Prior to issuance of occupancy permits for either of the hotels or the condominiums, the developer shall install bike racks and provide showers and SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 74 locker rooms for employees who wish to ride bicycles to work. Bike racks shall also be installed for project guests in appropriate locations. An appropriate number of bike racks shall be located near each building to serve the anticipated number of employees and guests. This measure shall be implemented to the satisfaction of the City Engineer. TRA-3 Prior to issuance of building permits for either Phase 1 or Phase 2, the project plans shall be circulated to Foothill Transit (FT) and the Metropolitan Transit Authority (MTA) to determine if there is a need for a bus stop on the south side of Colorado Place in front of the project site (i.e., for either FT Route 187 or MTA routes 78, 79, or 378). If either agency determines a need for such a stop, the developer shall install a bus stop to agency specifications prior to issuance of occupancy permits for the affected phase of development. This measure shall be implemented for each phase to the satisfaction of the City Engineer. TRA-4 Prior to issuance of occupancy permits for either hotel in Phase 1, the developer shall demonstrate that the main hotel entrance for Phase 1 has a circular drive with signage to allow only one way circulation (counter-clockwise) to provide adequate vehicle queuing lanes for exiting at the traffic signal. This measure shall be implemented to the satisfaction of the City Engineer. With implementation of these measures, potential traffic and non-vehicular circulation impacts of the proposed project will be reduced to less than significant levels with mitigation. Proposed SPA Analysis. The original traffic study used residential condominiums as a worst case estimate for traffic impacts for the original project, and the additional amount of commercial space (i.e., offices on 50% of the ground floor) would not generate a significant amount of additional traffic beyond what was examined in the original traffic study. For example, the Phase 2 building is 115,269 SF so 50% coverage for offices would be 57,635 square feet which equals 640 daily trips max. and approx. 64 peak hour trips. By comparison, TIA Table 10 indicates the two hotels would generate 1,734 weekday trips and it is estimated the condos would generate an additional 400 trips (2,134 trips total). As long as the same mitigation measures are implemented, traffic impacts from the SPA would be equivalent to those estimated for the original project (i.e., less than significant with mitigation). b) Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.b) Original SPSP Analysis. The project Traffic Impact Analysis was performed in accordance with the Los Angeles County Congestion Management Program (CMP) guidelines. Therefore, the proposed project will not conflict an applicable congestion management program with implementation of Mitigation Measures TRA-1 through TRA-4. Proposed SPA Analysis. See Response XVI.a above. Similar level of impact. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 75 c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that result in substantial safety risks? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.c) Original SPSP Analysis. The proposed project does not include uses or components that would affect air traffic, so no substantial safety risks would result from project implementation. No significant impacts would occur, and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are the same site and any project on the site would have no impact on local air traffic patterns. d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.d Original SPSP Analysis. The proposed project will increase traffic onsite and on adjacent streets and intersections. The project leg of the skewed intersection adjacent to the project site entrance is presently uncontrolled and signed for “right turn only”. Although there have been no accidents at this location, a substantial increase in traffic from the project site would substantially increase the risk of traffic accidents at this location due to this leg of the intersection being uncontrolled. The project traffic study recommends the proposed project be responsible for improvements to the existing traffic signal to add controls to the project leg of the intersection (see Mitigation Measure TRA-1). This measure will provide traffic control as development intensity of the site increase and will prevent the increase of hazards due to design features of the proposed project. There will be no significant impacts with implementation of this mitigation measure. Proposed SPA Analysis. The proposed SPA has essentially the same external design and layout as the approved SPSP, so impacts will be less than significant as long as the mitigation measures recommended for the SPSP are implemented by the SPA. e) Result in inadequate emergency access? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.e) Original SPSP Analysis. The Arcadia Police Department is less than a minute away and the Arcadia Station 106 Fire Department is only three minutes away from the project site. Traffic associated with project construction may have a temporary effect on existing traffic SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 76 circulation patterns. However, the proposed project is in a urban setting and direct access to the site will be available primarily from West Huntington Drive and secondary emergency access will be provided by a driveway on East Huntington Drive. Due to the proximity of emergency services, the urban setting, and availability of access to the site impacts to emergency access will be less than significant. The proposed project will also comply with all of the City’s requirements for emergency access. Therefore, there will be no significant impacts and no mitigation is required. Proposed SPA Analysis. The proposed SPA and approved SPSP are the same site so any impacts related to emergency response and services would be the same (i.e., less than significant). f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVI.g) Original SPSP Analysis. With implementation of Mitigation Measures TRA-2 and TRA- 3, the proposed project would be consistent with City policies supporting public transit, bicycle, and pedestrian facilities. With this mitigation, impacts will be less than significant and no additional mitigation is required. Proposed SPA Analysis. The proposed SPA has essentially the same external design and layout as the approved SPSP, and mitigation measures regarding transit were included in the original approval. Impacts will be less than significant as long as the mitigation measures recommended for the SPSP are implemented by the SPA. XVII. UTILITIES AND SERVICE SYSTEMS Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.a) Original SPSP Analysis. The project site currently has an existing hotel that discharges its wastewater into the sanitary sewerage collection and treatment systems provided by the City of Arcadia and the County of Los Angeles, respectively. Under Section 402 of the Federal Clean Water Act (CWA), the Regional Water Quality Control Board (RWQCB) issues National Pollutant Discharge Elimination System (NPDES) permits to regulate waste discharges to “waters of the U.S.,” which includes rivers, lakes, and their tributary waters. Waste discharges include discharges of stormwater and construction project discharges. Construction of a project resulting in the disturbance of more than one acre requires an NPDES permit. Construction project proponents are also required to prepare a Storm Water Pollution SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 77 Prevention Plan (SWPPP). These measures are outlined in Mitigation Measures HYD-1 through HYD-3 in the previous Section IX.a, Hydrology and Water Quality. Prior to the issuance of grading permits, the project applicant would be required to satisfy City requirements related to the payment of fees and/or the provision of adequate wastewater facilities. The project would comply with the waste discharge prohibitions and water quality objectives established by the RWCQB and the City by implementing Mitigation Measures HYD-1 through HYD-3. By implementing these measures, project impacts related to this issue would be reduced to a less than significant level and no mitigation is required. Proposed SPA Analysis. The proposed SPA would incrementally increase wastewater generation from the site by adding full time residents and office workers in Phase 2. The original analysis determined wastewater impacts were less than significant, so an incremental increase in wastewater generation is not expected to substantially increase that level of impact, so impacts are still considered less than significant. b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.b) Original SPSP Analysis. Water and wastewater services are provided to the project site by the City of Arcadia Public Works Services Department. The department obtains water from both groundwater and imported water. The City also provides sewer service collection to the local area. Wastewater from the area is carried by sewers to the San Jose Creek Water Reclamation Plant which is operated by the Sanitation Districts of Los Angeles County. The proposed project would need to connect to the existing sewer line in West Huntington Drive which is currently considered to be deficient according to the City’s Public Work’s Department, and the proposed project would increase this deficiency. However, a Capital Improvement Project (CIP) design to upgrade the existing sewer pipe from 10” to 12” is scheduled for Fiscal Year (FY) 2014-2015 while actual construction is planned for FY 2015-2016. The proposed project would need to participate in (i.e., help fund) this CIP project. If the project participates in this CIP improvement, it will not cause a need to construct any new water or wastewater treatment facilities, or expansion of existing facilities because these facilities are adequately sized to service the site. Mitigation Measures UTL-1 Prior to issuance of a building permit for either hotel, the developer shall retain a qualified licensed civil engineer to conduct a sewer study to evaluate before and after conditions of the project on the City’s existing sewer system (both lateral and main lines). This measure shall be implemented to the satisfaction of the City Public Works Services Department. UTL-2 Prior to issuance of an occupancy permit for either hotel, the developer’s fair share payment to the City will be determined to help fund upgrading of the existing sewer in West Huntington Drive included in the City’s 2014-15 Capital Improvement Project Plan budget, based on the results of the sewer study SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 78 outlined in Mitigation Measure UTL-1. This measure shall be implemented to the satisfaction of the City Engineer and/or the City Public Works Services Department as appropriate. With implementation of these measures, the proposed project will not have a significant impact on water and wastewater facilities. Proposed SPA Analysis. See Response XVII.a above (with Mitigation Measures ULT-1 and UTL-2) impacts will be less than significant. c) Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.c) Original SPSP Analysis. The proposed project will pay the City’s established Development Impact Fees (DIF) to help offset costs for new stormwater drainage facilities. Therefore the proposed project will have a less than significant impact on these facilities, and no mitigation is required. Proposed SPA Analysis. The proposed SPA will pay the same City DIF fees based on impacts to City services, including affected utilities. With DIF, these impacts will be less than significant. d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.d) Original SPSP Analysis. Water service is provided to the project site by the City of Arcadia Public Works Services Department. The department obtains groundwater from the Main San Gabriel and Raymond Groundwater Basins. The City also obtains water imported from the Metropolitan Water District of Southern California (MWD) via the State Water Project and the Colorado River. According to MWD’s website, it will be able to meet the region’s water needs through 2030. In addition, the proposed project does not meet the threshold to prepare a project-specific Water Supply Assessment (WSA) under SB 610. Therefore, impacts related to water supply are considered to be less than significant, and no mitigation is required. Proposed SPA Analysis. The proposed SPA will result in a similar amount of water being consumed compared to the original project as residential condominiums were used as a worst case estimate for the original project. The revised project will also pay City DIF fees for water services as appropriate. With DIF, these impacts will be less than significant. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 79 e) Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.e) Original SPSP Analysis. The proposed project would not increase the area population or otherwise induce substantial new population growth, as outlined in the previous Section XIII, Population and Housing. Therefore, impacts related to wastewater are less than significant, and no mitigation is required. Proposed SPA Analysis. See previous Responses XIII.a and XVII.a above, no mitigation required and impact will be less than significant. f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.f) Original SPSP Analysis. The City of Arcadia does not contract with a particular landfill. However, the existing hotel contracts with Waste Management to dispose of trash generated on the site. The proposed project would likely contract with the same company or with a similar company in the area. The proposed project would generate wastes both during construction and occupancy of the hotels and condominiums. According to the California Recycle website, hotel uses generate approximately 10 pounds of trash per person per day, so the proposed project as a worst case scenario could generate up to 5,270 pounds of trash each day or 2.6 tons per day which adds to 962 tons per year (5275 persons times 10 pounds per person per day). Proposed SPA Analysis. The proposed SPA will generate similar levels of solid waste as residential condominiums were already used to provide a worst case estimate for Phase 2. Therefore, impacts would be similar to those of the approved project (less than significant). g) Comply with federal, state, and local statutes and regulations related to solid waste? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVII.g) Original SPSP Analysis. The proposed project would be required to comply with applicable elements of AB 1327, Chapter 18 (California Solid Waste Reuse and Recycling Access 5 260 total rooms x 85 percent occupancy x 2 persons per room average= 442 guests plus 85 employees = 527 persons. This is a worst case estimate. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 80 Act of 1991), and other applicable local, state, and federal solid waste disposal standards, thereby ensuring that impacts associated with this issue would be considered to be less than significant, and no mitigation is required. Proposed SPA Analysis. The proposed SPA will generate similar levels of solid waste as residential condominiums were already used to provide a worst case estimate for Phase 2. The revised project would be required to comply with local solid waste regulations. Therefore, impacts would be similar to those of the approved project (less than significant). XVIII. MANDATORY FINDINGS OF SIGNIFICANCE a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVIII.a) Original SPSP Analysis. The project site already supports an existing hotel and is fully developed. Development of the proposed project would not result in any significant impacts to important plants (redwood trees) or wildlife with implementation of the recommended mitigation measures BIO-1 through BIO-3. Proposed SPA Analysis. The proposed SPA will generate biological impacts equivalent to those identified for the original approved project, and so it must implement all of the mitigation recommended under the original plan. With those measures, potential impacts are less than significant. b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVIII.b) Original SPSP Analysis. As presented in the discussion of environmental checklist questions I through XVII, the project has no impact, a less than significant impact, or a less than significant impact with implementation of mitigation with respect to all environmental issues. Due to the limited scope of direct physical impacts to the environment associated with this development project, the project is not expected to have significant cumulative impacts within the City or surrounding areas. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 81 Proposed SPA Analysis. The Initial Study for the SPSP did not identify a substantial contribution to cumulative impacts from the approved project. Likewise, the proposed SPA is not expected to make significant contributions to cumulative impacts within the City, and would be equivalent to those already identified in the Initial Study for the SPSP (i.e., less than significant with mitigation). c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Potentially Significant Impact Less than Significant with Mitigation Incorporated Less than Significant Impact No Impact XVIII.c) Original SPSP Analysis. In general, impacts to human beings from the project may occur due to air pollutant emissions, hazards and hazardous materials, and noise. The South Coast Air Basin is currently designated as a non-attainment area for ozone, PM10, and PM2.5. Development of the project would contribute to air pollutant emissions on a short-term basis. The proposed project would be required to comply with regional rules that assist in reducing short-term air pollutant emissions. The purpose of SCAQMD Rule 403 is to reduce the amount of particulate matter in the atmosphere resulting from man-made fugitive dust sources (see AIR-1). Implementation of Mitigation Measures AIR-1 through AIR-4 will help reduce potential short- and long-term air pollutant impacts from the project. Adherence to these measures would help assure that short-term air quality impacts from construction would remain at less than significant levels. In addition, potential impacts related to potential hazardous materials and to water resources have also been addressed in the appropriate sections, including Mitigation Measures HAZ-1 and HYD-1 through HYD-3, respectively. With implementation of these measures, potential impacts of the project in these areas will remain or be reduced to less than significant levels. As detailed in the preceding responses, development of the proposed project would not result, either directly or indirectly, in adverse hazards and noise effects, resulting in a corresponding less than significant impact to human beings. Proposed SPA Analysis. The Initial Study for the SPSP did not identify any substantial direct or indirect impacts of the approved project. This Initial Study has demonstrated the revised SPA project would have equivalent or similar impacts to those already identified for the SPSP project (i.e., less than significant with mitigation). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 82 SECTION 4 LIST OF PREPARERS 4.1 LSA ASSOCIATES, INC.  Kent Norton, AICP, REA (Project Manager)  Lynn Calvert-Hayes, AICP (Principal in Charge)  Tony Chung, Ph.D. (Noise/Air Quality/GHG Studies)  Steve Dong (Editor)  Margaret Gooding (Graphics) 4.2 CITY OF ARCADIA  Jason Kruckeberg (Development Services Director)  Lisa Flores (Planning Services Manager) SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 83 SECTION 5 REFERENCES Arcadia 2010 “City of Arcadia General Plan.” City of Arcadia. November 2010. BB&N 1987 “Noise Control for Buildings and Manufacturing Plants,” Bolt, Beranek & Newman (BB&N), 1987. CalEPA 2013a “Managing Hazardous Waste,” California Environmental Protection Agency (CalEPA) and Department of Toxic Substances Control, website accessed August 1, 2013. http://www.dtsc.ca.gov/hazardouswaste CalEPA 2013b “Certified Unified Program Agency (CUPA) Program Directory,” California Department Environmental Protection Agency (CalEPA), website accessed August 10, 2013. http://www.calepa.ca.gov/CUPA/Directory/default.aspx CALREC Calrecycle website accessed August 12, 2013. www.calrecycle.ca.gov Caltrans 2001 “Transportation Related Earthborne Vibrations (Caltrans Experiences)”. California Department of Transportation (Caltrans), Division of Environmental Analysis, Office of Noise, Air Quality, and Hazardous Waste Management. Technical Advisory, Vibration. TAV-02-01-R9601. February 20, 2001. Caltrans 2013 California Department of Transportation Scenic Highway Program, California Department of Transportation (Caltrans), website accessed August 2, 2013. http://www.dot.ca.gov/hq/LandArch/scenic_highways/scenic_hwy.htm CAPCOA 2008 “CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act,” California Air Pollution Control Officers Association (CAPCOA), January 2008. CARB 2007 “Proposed Early Actions to Mitigate Climate Change in California,” California Air Resources Board (CARB), April 20, 2007. CCCPP 2013 “Hydrofluorocarbon, Perfluorocarbon, and Sulfur Hexafluoride Emissions,” California Climate Change Policy and Program (CCCPP), California Climate Change Portal, website accessed July 21, 2013. http://www.climatechange.ca.gov/policies/1990s_in_depth/page11.html CCR 2013 “California Health and Safety Code,” Section 7050.5, California Code of Regulations (CCR). July 2013. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 84 CDC 2013 “Farmland Mapping and Monitoring Program,” California Department of Conservation (CDC), Division of Land Resource Protection. Website accessed July 30, 2013. CGS 2013 “Fault Mapping in California”. California Geological Survey (CGS). 2005. Website accessed August 3, 2013. CIWMB 2013 “Estimated Waste Generation Rates,” California Integrated Waste Management Board (CIWMB) website accessed on August 2, 2013. www.ciwmb.ca.gov/wastechar/wastegenrates/default.htm CWC 2013 “Sections 10750–10756,” California Water Code (CWC), California Department of Water Resources website accessed August 2, 2013. DOF 2013 “E-5 Population and Housing Estimates for Cities, Counties and the State, 2001-2010, with 2000 Benchmark.” State of California, Department of Finance (DOF), Sacramento, California, July 2013. DOT 2013 “Code of Federal Regulations, Title 49—Transportation, Pipeline and Hazardous Materials Safety Administration,” U.S. Department of Transportation (DOT), website site accessed August 3, 2013. http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?sid=585c275ee19254ba07625d8c92fe925f&c=ecfr&tpl=/ecfrbrowse/ Title49/49cfrv2_02.tpl DTSC 2013 “Hazardous Waste and Substance Site (Cortese) List,” California Department of Toxic Substance Control (DTSC), website accessed August 3, 2013. http://www.envirostor.dtsc.ca.gov/public FEMA 2013 “Flood Limit Data and Mapping,” U.S. Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map Program, website accessed August 1, 2013. Geo Inc 2013 “Preliminary Geotechnical Assessment.” Geotechnologies, July 2013. Geotracker 2013 “Geotracker” database of hazardous material sites maintained by the Regional Water Quality Control Board, website accessed July 25, 2013. HII 2010 “City of Arcadia Zoning Map.” Hogle-Ireland Inc. 2010. KHA 2013 “Traffic Impact Assessment, Santa Anita Inn Redevelopment Project.” Kimley-Horn and Associates, Inc. 2013. LSA 2013a “Air Quality Analysis.” (includes greenhouse gas emissions). LSA Associates, Inc. August 2013. LSA 2013b “Noise Impact Analysis.” LSA Associates, Inc. August 2013. NRCS 2013 “Soil Data Mart,” Natural Resources Conservation Service, United States Department of Agriculture, website accessed August 2, 2013. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 85 http://soildatamart.nrcs.usda.gov/Report.aspx?Survey=CA675&UseState =CA and as documented in the “Soil Survey of Los Angeles County, California” issued by the U.S. Department of Agriculture, Soil Conservation Service, original research dated 1971. PDA 2012 “Initial Study and Mitigated Negative Declaration, For Two Medical Office Buildings, A General Office Building, and a Four-Level Parking Structure at 161 Colorado Place and 125 W, Huntington Drive.” Pacific Design Group. December 2012. RJLA 2003 “Phase I Environmental Site Assessment, Continental Assets Management.” RJL Associates, March 19, 2003. SCAG 2008 “Final 2008 Regional Comprehensive Plan,” Southern California Association of Governments (SCAG), adopted October 2, 2008. SCAG 2012a “2012-2035 Regional Transportation Plan/Sustainable Communities Strategy,” Southern California Association of Governments (SCAG), adopted April 2012. SCAG 2012b “Growth Forecast Appendix of the Regional Transportation Plan/Sustainable Communities Strategy” Southern California Association of Governments, adopted April 2012. http://rtpscs.scag.ca.gov/Documents/2012/pfinal/SR/2012pfRTP_Growth Forecast.pdf SCAQMD 2010 “Air Quality Management Plan,” South Coast Air Quality Management District (SCAQMD), 2010. SCAQMD 2013 SCAQMD website accessed August 2, 2013. www.aqmd.gov/ceqa/handbook/LST TTA 2013 “Hydraulic & Hydrology Calculation.” Tritech Associates, Inc. July 2013. USEPA 1998 “AP-42 Emission Factors, Natural Gas Combustion,” U.S. Environmental Protection Agency (USEPA), July 1998. www.epa.gov/ttn/chief/ap42/ch01/final USEPA 2004a “EPA420-P-04-016: Update of Methane and Nitrous Oxide Emission Factors for On-Highway Vehicles,” U.S. Environmental Protection Agency (USEPA), prepared by ICF Consulting. November 2004. http://www.epa.gov/otaq/models/ngm SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 86 USEPA 2004b “EPA430-K-03-004, Direct HFC and PFC Emissions from Use of Refrigeration and Air Conditioning Equipment.” U.S. Environmental Protection Agency (USEPA), Climate Leaders, October 2004. http://www.epa.gov/climateleaders/documents/resources/refrige_acequi puseguidance.pdf. USFWS 2011 “HCP/NCCP Planning Areas, Southern California,” U.S. Fish and Wildlife Service (USFWS), October 2011. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 87 SECTION 6 SUMMARY OF MITIGATION MEASURES I. AESTHETICS AES-1 Prior to issuance of a building permit, the applicant shall demonstrate that all project windows are glazed or otherwise treated to minimize glare on surrounding roads and properties, to the satisfaction of the Development Services Director or designee. II. AGRICULTURAL RESOURCES None III. AIR QUALITY AIR-1 Prior to issuance of a grading permit, the general contractor for the project shall prepare and file a Dust Control Plan with the City that complies with SCQAMD Rule 403 and requires the following during excavation and construction as appropriate:  Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more).  Water active sites at least twice daily (locations where grading is to occur will be thoroughly watered prior to earthmoving.)  Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 2 feet of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the requirements of California Vehicle Code (CVC) Section 23114.  Pave construction access roads at least 100 feet onto the site from the main road.  Control traffic speeds within the property to 15 mph or less. AIR-2 Prior to the issuance of a grading permit, the project developer shall require by contract specifications that contractors shall utilize California Air Resources Board (CARB) Tier II Certified equipment or better during the rough/mass grading phase for rubber-tired dozers and scrapers. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City. AIR-3 Prior to the issuance of a grading or building permit for each phase, the project developer shall require by contract specifications that contractors shall place construction equipment staging areas at least 200 feet away from sensitive receptors. Contract specifications shall be included in the project construction documents, which shall be reviewed by the City. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 88 AIR-4 Prior to the issuance of a building permit for each phase, the project developer shall require by contract specifications that contractors shall utilize power poles or clean-fuel generators for electrical construction equipment. Contract specifications shall be included in the proposed project construction documents, which shall be reviewed by the City. IV. BIOLOGICAL RESOURCES BIO-1 Prior to issuance of a grading permit for each phase, the developer shall provide an assessment of existing trees on the areas to be developed. This tree assessment shall be prepared by a qualified landscape architect and identify any existing large bushes or trees that can be relocated or preserved as part of the new development project. The project landscaping plans shall attempt to preserve existing mature trees onsite to the extent feasible, based on the tree assessment. This measure shall be implemented to the satisfaction of the City Planning Division. BIO-2 During project construction in either phase, the existing redwood trees along the east side of the property shall be protected by being taped or roped off with appropriate signage so construction equipment will not accidentally come in contact with and damage or destroy any trees. The trees shall be sprayed with water at the end of each day when substantial amounts of dust are generated (e.g., during grading or demolition) to minimize damage from dust deposition. This measure shall be implemented to the satisfaction of the City Planning Division. BIO-3 Construction in either phase should not occur during the local nesting season (estimated February 1 to July 15). If any construction occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to the issuance of a grading permit or removal of any large trees on the existing hotel property. If the biologist determines that nesting birds are present, an area of 100 feet shall be marked off around the nest and no construction activity can occur in that area during nesting activities. Grading and/or construction may resume in this area when a qualified biologist has determined the nest is no longer occupied and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City Planning Division. V. CULTURAL RESOURCES CUL-1 Prior to demolition of any existing hotel buildings on the site, the completed DPR 523A and 523B forms and a cover memorandum shall be submitted to the City for filing to officially document the historical assessment for the Santa Anita Inn. This measure shall be implemented to the satisfaction of the City Planning Division. CUL-2 Prior to issuance of an occupancy permit for Phase 1, the applicant shall install a monument plaque indicating the location of the former Santa Anita SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 89 Inn and its importance in the history of the City of Arcadia. The size, construction, and location of this plaque shall be up to the discretion of the City Manager, in consultation with the Planning Division. CUL-3 If cultural artifacts are discovered during project grading, work shall be halted in that area until a qualified historian or archaeologist can be retained by the developer to assess the significance of the find. The project cultural monitor shall observe the remaining earthmoving activities at the project site consistent with Public Resources Code Section 21083.2(b), (c), and (d). The monitor shall be equipped to record and salvage cultural resources that may be unearthed during grading activities. The monitor shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. If any resources of a prehistoric or Native American origin are discovered, the appropriate Native American tribal representative will be contacted and invited to observe the monitoring program for the duration of the grading phase at tribal expense. Any Native American resources shall be evaluated in accordance with the CEQA Guidelines and either reburied at the project site or curated at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the cultural monitor determines that monitoring is no longer necessary, such activities shall be discontinued. This measure shall be implemented to the satisfaction of the City Planning Division. CUL-4 If paleontological resources (fossils) are discovered during project grading, work will be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The project paleontologist shall monitor remaining earthmoving activities at the project site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. This measure may be combined with CUL-3 at the discretion of the City Planning Division. CUL-5 In the event of an accidental discovery or recognition of any human remains, California State Health and Safety Code § 7050.5 dictates that no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to CEQA regulations and PRC § 5097.98. If human remains are found, the LA County Coroner’s office shall be contacted to determine if the remains are recent or of Native American significance. Prior to issuance of a grading permit, the developer shall include a note to this effect on the grading plans for the project. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 90 VI. GEOLOGY AND SOILS None VII. GREENHOUSE GAS EMISSIONS GHG-1 To ensure reductions below the expected “Business As Usual” (BAU) scenario, the project will implement a variety of measures that will reduce its greenhouse gas (GHG) emissions. To the extent feasible, and to the satisfaction of the City of Arcadia (City), the following measures will be incorporated into the design and construction of the SPSP project prior to the issuance of building permits: Construction and Building Materials Recycle/reuse at least 50 percent of the demolished and/or grubbed construction materials (including, but not limited to, soil, vegetation, concrete, lumber, metal, and cardboard). Use “Green Building Materials,” such as those materials that are resource- efficient and are recycled and manufactured in an environmentally friendly way, for at least 10 percent of the project. Energy Efficiency Measures Design all project buildings to exceed the 2013 California Building Code’s (CBC) Title 24 energy standard by 10 percent, including, but not limited to, any combination of the following: Design buildings to accommodate future solar installations. Limit air leakage through the structure or within the heating and cooling distribution system to minimize energy consumption. Incorporate ENERGY STAR or better rated windows, space heating and cooling equipment, light fixtures, appliances, or other applicable electrical equipment. Install efficient lighting and lighting control systems. Use daylight as an integral part of the lighting systems in buildings. Install light-colored roofs and pavement materials where possible. Install energy-efficient heating and cooling systems, appliances and equipment, and control systems. Install solar lights or light-emitting diodes (LEDs) for outdoor lighting or outdoor lighting that meets the 2013 California Building and Energy Code. Water Conservation and Efficiency Measures Devise a comprehensive water conservation strategy appropriate for the project and its location consistent with the City’s Water Efficiency Landscape Ordinance (WELO). The strategy may include the following, plus other innovative measures that may be appropriate: SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 91 Create water-efficient landscapes within the development. Install water-efficient irrigation systems and devices, such as soil moisture- based irrigation controls. Design buildings to be water-efficient. Install water-efficient fixtures and appliances, including low-flow faucets, dual-flush toilets, and waterless urinals. Restrict watering methods (e.g., prohibit systems that apply water to nonvegetated surfaces) and control runoff. Solid Waste Measures To facilitate and encourage recycling to reduce landfill-associated emissions, among others, the project will provide trash enclosures that include additional enclosed area(s) for collection of recyclable materials. The recycling collection area(s) will be located within, near, or adjacent to each trash and rubbish disposal area. The recycling collection area will be a minimum of 50 percent of the area provided for the trash/rubbish enclosure(s) or as approved by the waste management department of the City of Arcadia. Provide employee education on waste reduction and available recycling services. Transportation Measures To facilitate and encourage non-motorized transportation, bicycle racks shall be provided in convenient locations to facilitate bicycle access to the project area. The bicycle racks shall be shown on project landscaping and improvement plans submitted for Planning Department approval and shall be installed in accordance with those plans. Provide pedestrian walkways and connectivity throughout the project. Fund or participate in some type of shuttle service for hotel guests to access the City’s downtown Gold Line Station. VIII. HAZARDS AND HAZARDOUS MATERIALS HAZ-1 Prior to demolition of any existing hotel buildings or associated structures, a qualified contractor shall be retained to survey structures proposed for demolition to determine if asbestos-containing materials (ACMs) and/or lead- based paint (LBP) are present. If ACMs and/or LBP are present, prior to commencement of general demolition, these materials shall be removed and transported to an appropriate landfill by a licensed contractor. This measure shall be implemented to the satisfaction of the City Building Division including written documentation of the disposal of any ACMs or LBP in conformance with all applicable regulations. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 92 IX. HYDROLOGY AND WATER QUALITY HYD-1 Prior to issuance of a grading permit, the developer shall file a Notice of Intent (NOI) with the Los Angeles Regional Water Quality Control Board to be covered under the National Pollutant Discharge Elimination System (NPDES) General Construction Permit for discharge of storm water associated with construction activities. The project developer shall submit to the City the Waste Discharge Identification Number issued by the State Water Quality Control Board (SWQCB) as proof that the project’s NOI is to be covered by the General Construction Permit has been filed with the SWQCB. This measure shall be implemented to the satisfaction of the City Engineer. HYD-2 Prior to issuance of a grading permit, the developer shall submit to the Los Angeles Regional Water Quality Control Board (RWQCB) and receive approval for a project-specific Storm Water Pollution Prevention Plan (SWPPP). The SWPPP shall include a surface water control plan and erosion control plan citing specific measures to control on-site and off-site erosion during the entire grading and construction period. In addition, the SWPPP shall emphasize structural and nonstructural best management practices (BMPs) to control sediment and non-visible discharges from the site. BMPs to be implemented may include (but shall not be limited to) the following:  Potential sediment discharges from the site may be controlled by the following: sandbags, silt fences, straw wattles, fiber rolls, a temporary debris basin (if deemed necessary), and other discharge control devices. The construction and condition of the BMPs are to be periodically inspected by the RWQCB during construction, and repairs would be made as required.  Area drains within the construction area must be provided with inlet protection. Minimum standards are sand bag barriers, or two layers of sandbags with filter fabric over the grate, properly designed standpipes, or other measures as appropriate.  Materials that have the potential to contribute non-visible pollutants to storm water must not be placed in drainage ways and must be placed in temporary storage containment areas.  All loose soil, silt, clay, sand, debris, and other earthen material shall be controlled to eliminate discharge from the site. Temporary soil stabilization measures to be considered include: covering disturbed areas with mulch, temporary seeding, soil stabilizing binders, fiber rolls or blankets, temporary vegetation, and permanent seeding. Stockpiles shall be surrounded by silt fences and covered with plastic tarps.  Implement good housekeeping practices such as creating a waste collection area, putting lids on waste and material containers, and cleaning up spills immediately.  The SWPPP shall include inspection forms for routine monitoring of the site during the construction phase. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 93  Additional required BMPs and erosion control measures shall be documented in the SWPPP.  The SWPPP would be kept on site for the duration of project construction and shall be available to the local Regional Water Quality Control Board for inspection at any time. The developer and/or construction contractor shall be responsible for performing and documenting the application of BMPs identified in the project-specific SWPPP. Regular inspections shall be performed on sediment control measures called for in the SWPPP. Monthly reports shall be maintained and available for City inspection. An inspection log shall be maintained for the project and shall be available at the site for review by the City and the Regional Water Quality Control Board as appropriate. HYD-3 Prior to issuance of a grading permit, a site-specific Standard Urban Stormwater Management Plan (SUSMP) shall be submitted to the City Planning Division for review and approval. The SUSMP shall specifically identify the long-term site design, source control, and treatment control BMPs that shall be used on site to control pollutant runoff and to reduce impacts to water quality to the maximum extent practicable. At a minimum, the SUSMP shall identify and the site developer shall implement the following site design, source control, and treatment control BMPs as appropriate: Site Design BMPs  Minimize urban runoff by maximizing maximizing permeable areas and minimizing impermeable areas (recommended minimum 25 percent of site to be permeable).  Incorporate landscaped buffer areas between sidewalks and streets.  Maximize canopy interception and water conservation by planting native or drought-tolerant trees and large shrubs wherever possible  Where soil conditions are suitable, use perforated pipe or gravel filtration pits for low flow infiltration.  Construct onsite ponding areas or retention facilities to increase opportunities for infiltration consistent with vector control objectives.  Construct streets, sidewalks and parking lot aisles to the minimum widths necessary, provided that public safety and a walkable environment for pedestrians are not compromised.  Direct runoff from impervious areas to treatment control BMPs such as landscaping/bioretention areas. Source Control BMPs Source control BMPs are implemented to eliminate the presence of pollutants through prevention. Such measures can be both non-structural and structural: Non-Structural Source Control BMPs  Education for property owners, tenants, occupants, and employees.  Activity restrictions. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 94  Irrigation system and landscape maintenance to minimize water runoff.  Common area litter control.  Regular mechanical sweeping of private streets and parking lots.  Regular drainage facility inspection and maintenance. Structural Source Control BMPs  MS4 stenciling and signage at storm down drains.  Properly design trash storage areas and any outdoor material storage areas. Treatment Control BMPs Treatment control BMPs supplement the pollution prevention and source control measures by treating the water to remove pollutants before it is released from the project site. The treatment control BMP strategy for the project is to select Low Impact Development (LID) BMPs that promote infiltration and evapotranspiration, including the construction of infiltration basins, bioretention facilities, and extended detention basins. Where infiltration BMPs are not appropriate, bioretention and/or biotreatment BMPs (including extended detention basins, bioswales, and constructed wetlands) that provide opportunity for evapotranspiration and incidental infiltration may be utilized. Harvest and use BMPs (i.e., storage pods) may be used as a treatment control BMP to store runoff for later non-potable uses. X. LAND USE AND PLANNING None XI. MINERAL RESOURCES None XII. NOISE N-1 Prior to issuance of grading and building permits for each phase of the project, the developer shall prepare a Construction Noise Control Plan and will submit the plan the City for review and approval. The plan shall include but will not be limited to the following:  During all project site excavation and grading, contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers consistent with manufacturers’ standards.  The project contractor shall place all stationary construction equipment so that emitted noise is directed away from the closest sensitive receptor to the project site (i.e., the Salvation Army facility at the southwest corner of the site). SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 95  The construction contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise sources and the closest noise-sensitive receptor to the project site (i.e., the Salvation Army facility at the southwest corner of the site) during all project construction.  During all project site construction, the construction contractor shall limit all construction-related activities that would result in high noise levels to between the hours of 7:00 a.m. to 7:00 p.m. on weekdays and Saturday. No construction shall be permitted on Sundays or any of the holidays listed in AMC Section 4261.  Prior to the start of Phase 2 grading, the developer shall install a wooden noise barrier along the common boundary of the project and the Salvation Army rehab facility at the southwest corner of the project site. This barrier shall be removed upon completion of Phase 2 construction. N-2 Prior to the issuance of building permit for each phase, the developer shall demonstrate that all buildings shall have air-conditioning to minimize noise impacts on hotel rooms along West and East Huntington Drives. N-3 Prior to the issuance of occupancy permits for the Phase 2 condominium building, the developer shall install a filled-cell concrete block wall along the common boundary with the Salvation Army rehab facility at the southwest corner of the project site. In lieu of the temporary construction wall outlined in Measure N-1, the developer may install this permanent wall “early” (i.e., prior to issuance of occupancy permits for Phase 1) which would eliminate the need for that portion of Measure N-1. XIII. POPULATION AND HOUSING None XIV. PUBLIC SERVICES None XV. RECREATION None XVI. TRANSPORTATION/TRAFFIC TRA-1 Prior to issuance of an occupancy permit for either hotel in Phase 1, the developer shall be responsible for installing an additional signal phase to accommodate northbound movements exiting the shared hotel driveway and southbound movements entering the hotel driveway. The developer will also change the number one lane to a shared through and left turn lane to access the driveway for the hotels and modify the signal to account for the added SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY LSA CMG1301 96 phases and lanes. These changes shall be made to the satisfaction of and in coordination with the City traffic engineer. TRA-2 Prior to issuance of occupancy permits for either of the hotels or the condominiums, the developer shall install bike racks and provide showers and locker rooms for employees who wish to ride bicycles to work. Bike racks shall also be installed for project guests in appropriate locations. An appropriate number of bike racks shall be located near each building to serve the anticipated number of employees and guests. This measure shall be implemented to the satisfaction of the City Engineer. TRA-3 Prior to issuance of building permits for either Phase 1 or Phase 2, the project plans shall be circulated to Foothill Transit (FT) and the Metropolitan Transit Authority (MTA) to determine if there is a need for a bus stop on the south side of Colorado Place in front of the project site (i.e., for either FT Route 187 or MTA routes 78, 79, or 378). If either agency determines a need for such a stop, the developer shall install a bus stop to agency specifications prior to issuance of occupancy permits for the affected phase of development. This measure shall be implemented for each phase to the satisfaction of the City Engineer. TRA-4 Prior to issuance of occupancy permits for either hotel in Phase 1, the developer shall demonstrate that the main hotel entrance for Phase 1 has a circular drive with signage to allow only one way circulation (counter- clockwise) to provide adequate vehicle queuing lanes for exiting at the traffic signal. This measure shall be implemented to the satisfaction of the City Engineer. XVII. UTILITIES AND SERVICE SYSTEMS UTL-1 Prior to issuance of a building permit for either hotel, the developer shall retain a qualified licensed civil engineer to conduct a sewer study to evaluate before and after conditions of the project on the City’s existing sewer system (both lateral and main lines). This measure shall be implemented to the satisfaction of the City Public Works Services Department. UTL-2 Prior to issuance of an occupancy permit for either hotel, the developer’s fair share payment to the City will be determined to help fund upgrading of the existing sewer in West Huntington Drive included in the City’s 2014-15 Capital Improvement Project Plan budget, based on the results of the sewer study outlined in Mitigation Measure UTL-1. This measure shall be implemented to the satisfaction of the City Engineer and/or the City Public Works Services Department as appropriate. SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix A: Seabiscuit Pacifica Specific Plan (See Staff Report Attachment No. 2) LSA CMG1301 97 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix B: Air Quality/Greenhouse Gas Study (See Staff Report Attachment No. 6) LSA CMG1301 98 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix C: Historical Assessment (See Staff Report Attachment No. 6) LSA CMG1301 99 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix D: Geotechnical Constraints (See Staff Report Attachment No. 6) LSA CMG1301 100 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix E: Phase 1 Hazmat Study (See Staff Report Attachment No. 6) LSA CMG1301 101 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix F: Hydrology and Water Quality Studies (See Staff Report Attachment No. 6) LSA CMG1301 102 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix G: Traffic Impact Assessment (See Staff Report Attachment No. 6) LSA CMG1301 103 SEABISCUIT PACIFICA SPECIFIC PLAN AMENDMENT INITIAL STUDY Appendix H: Noise Assessment (See Staff Report Attachment No. 6) LSA CMG1301 104 Attachment No. 4 Existing and Proposed Changes to General Plan Land Use Map Attachment No. 4 Proposed General Plan Land UseExisting General Plan Land Use Downtown Mixed Use (30-50 du/acre & 1.0 FAR) City of Arcadia Commercial Downtown Overlay (1.03 FAR) Ü 05001,000Feet Attachment No. 5 Letter from Marriott, dated November 1, 2016 Attachment No. 5               Mr. Andy Chang  Seabiscuit Development  488 East Santa Clara St. Suite 305  Arcadia, CA  91007    November 1, 2016    Dear Mr. Chang,    This letter is to confirm that Marriott has approved and signed a Franchise Agreement with  Seabiscuit Development to develop a 120 room Residence Inn by Marriott and a 85 room  Fairfield Inn & Suites by Marriott to be developed at the site of the current Santa Anita Inn.   This agreement was signed by Marriott and Seabiscuit Development on July 31, 2013.    We understand that you are working hard to get the site prepared to commence construction  as soon as possible.  If we can be of assistance to this process, please let me know.    Kind regards,        Scott McAllister Area Vice President Marriott Lodging Development cc: Jason Kruckeberg City of Arcadia – Assistant City Manager 2050 Main Street, Suite 1300 Irvine, CA 92614 Marriott International, Inc. Hotel Development Scott McAllister Area Vice President 480-862-9389 cell