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HomeMy WebLinkAboutCanyon Road_2006 MND and Updated Analysis TERRA NOVA PLANNING & RESEARCH, INC. 42635 MELANIE PLACE, SUITE 101, PALM DESERT, CA 92211 (760) 341-4800 May 30, 2017 Mr. Jim Kasama Community Development Director City of Arcadia 240 West Huntington Drive Arcadia, CA 91066-6021 RE: CEQA Evaluation – revised Nevis Capital Project on Canyon Rd., City of Arcadia Tentative Parcel Map No. TPM 16-08 (1182) Residential Mountainous Permit No. RM 16-01 Tree Permit Nos. TRE 16-56 and TRH 16-03 Development Code Modification No. MP 16-10 Dear Mr. Kasama, Terra Nova Planning & Research is pleased to submit the following analysis of the California Environmental Quality Act (CEQA) review previously conducted by the City for this project site, and comparing it to the currently proposed project, for your consideration. Introduction Beginning in December 2016, Nevis Capital, LLC submitted revised development plans and documents to the City of Arcadia for a two-lot subdivision and development of a single-family residence on each of the new lots on Canyon Road in the City of Arcadia. A similar project on the same property was proposed and approved in 2010 by City Council. The following analysis compares the previously approved (2010) and currently proposed (2016) projects, and evaluates a range of environmental considerations to determine whether the 2016 project will result in substantial changes that will result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects, pursuant to the California Environmental Quality Act (CEQA). 2010 Project: Environmental Review Background In 2010, a development project was evaluated under CEQA through the preparation and approval by the City of Arcadia of a Mitigated Negative Declaration (MND) (TPM 09-08 and RM 07-01). The project proposed the subdivision of a 90±-acre undeveloped property into three parcels in the foothills of Arcadia. According to the MND, the project required the following applications: City of Arcadia CEQA Analysis Page 2 of 14 2 1. Tentative Parcel Map to subdivide the property into three lots: Parcel 1 (approximately 2 acres), Parcel 2 (approximately 0.82 acres), and Parcel 3 (approximately 80.33 acres not proposed for development). The proposal was later revised to include only two lots, with approximately 80 acres to remain open space (Staff Report, City of Arcadia Development Services Department, February 23, 2010). 2. Residential Mountainous (R-M Zone) Development Permit for the grading of Parcels 1 and 2. According to the MND, Parcel 1 was proposed to be improved with a two-story, 5,490 square-foot residence on a 2,940.5 square-foot pad. Parcel 2 was proposed to be developed with a two-story 5,110 square-foot residence on a 2,991.5 square-foot pad. The grading to accommodate the proposed developments would involve approximately 5,000 cubic yards of cut and 40 cubic yards of fill. A Mitigation Monitoring and Reporting Program was prepared pursuant to CEQA and included mitigation measures for aesthetics, biological resources, air quality, geology and soils, noise, and transportation/traffic. 2016 Project Proposal On December 27, 2016, the applicant submitted the following applications and corresponding plans to the City. Additional supporting material was provided to the City on subsequent dates. The project proposes the subdivision of the same undeveloped property into two parcels and development of a single-family residence on each. 1. Tentative Parcel Map [TPM 16-08 (71182)] to subdivide the property into two lots: Parcel 1 (1.99 acres), and Parcel 2 (88.64 acres). 2. Residential Mountainous Development Permit (RM 16-01) for grading of the parcels. According to the Revised Tentative Parcel Map (March 21, 2017) and Site Plan (November 21, 2016), Parcel 1 is to be improved with a two-story, 5,523 square-foot (including garage and double-height ceiling space) residence (“House A”). Parcel 2 is to be improved with a two-story, 5,768 square-foot (including garage and double-height ceiling space) residence (“House Z”). The Earthwork Exhibits (May 22, 2017) indicates the project will require 5,330 cubic yards of cut and 60 cubic yards of fill. 3. Tree Permits (TRE 16-56 and TRH 16-03) based on a “Protected Tree Plan” prepared by EGL Associates, Inc. on November 22, 2016; and arborist report entitled “Revised Preliminary Arborist Report for 2111 and 2125 Canyon Road, Arcadia,” prepared by Jan C. Scow Consulting Arborists, LLC, March 22, 2017 (revised). 4. Development Code Modifications (MP 16-10) for the height limit of the crib wall(s). City of Arcadia CEQA Analysis Page 3 of 14 3 In letters dated February 10, 2017 and April 13, 2017, the City determined the applications were incomplete due to various inconsistencies in the application materials, particularly regarding the amount of cut and fill, number of truck loads/trips, type of environmental documentation cited, and uncertainty as to whether or not the plans comply with the new Development Code regarding crib wall height(s), house setbacks from crib walls, and number of stories of House A. CEQA Considerations The proposed project constitutes a “project,” as defined by CEQA. As stated in CEQA Guidelines Section 15162: “When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determined, on the basis of substantial evidence in the light of the whole record, one or more of the following…” (1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) Substantial changes occur with respect to circumstances under which the project is undertake which will require major revisions to the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the EIR was certified as complete or the Negative Declaration was adopted, shows any of the following signs: (A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (C)Mitigation measures or alternatives previously found not feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternative which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measures or alternative. This analysis evaluates the currently proposed project in the context of CEQA Section 15162. City of Arcadia CEQA Analysis Page 4 of 14 4 Project Comparison The 2010 and 2016 projects both propose subdividing the subject property into two lots for development of two single-family residences. Both propose maintaining approximately 80 acres as undisturbed hillside. The location and general footprint of the two residences near the southwesterly boundary of the subject property along Canyon Road is the same for both projects. The square footage of the residences is nearly the same (± 5,100 to 5,700 square feet). Both projects propose two-story buildings. (The 2016 project initially proposed three stories for House A; however, it has been revised to include only two stories, and new architectural plans will be submitted to the City.) As relates to construction impacts, the MND indicated the 2010 project would require 5,000 cubic yards of cut and 40 cubic yards of fill, resulting in a total export of 4,960 cubic yards. The Earthwork Estimates plan for the 2016 project indicates the currently proposed project would require 5,330 cubic yards of cut and 60 cubic yards of fill, resulting in a total export of 5,270 cubic yards. Compared to the 2010 project, this represents a 7% increase in cut, and a 50% increase in fill. Several conflicting estimates of the number of truckloads required to transport graded earth material from the subject property to the landfill are provided in various project plans and documents. Section XV.a, Transportation/Traffic, of the 2010 MND states that the 2010 project would require 108 truck trips; however, no formula, factor, or data source is cited to indicate how the estimate was calculated. The Earthwork Estimates plan (May 22, 2017) for the revised project uses a standard of 14 cubic yards per truckload. At a rate of 14 cubic yards per truckload, the 2010 project would have generated approximately 355 truckloads to export 4,960 cubic yards. At the same rate, the 2016 project would generate 377 truckloads to transport 5,270 cubic yards of cut. Compared to the 2010 project, the 2016 project represents a 6% increase in the number of truckloads required. The California Emissions Estimator Model (CalEEMod) version 2016.3.2, modeling software used to estimate air pollutant emissions generated during various stages of construction, uses a default rate of 16 cubic yards per truckload for haul trucks. At this rate, the 2010 project would require approximately 310 truckloads to transport 4,960 cubic yards, and the 2016 project would require approximately 330 truckloads to transport 5,270 cubic yards. At this rate, the 2016 project represents an increase of 6% in the number of truckloads. The 2016 project is similar to the 2010 project in regard to proposed land use, lot configurations, scale and siting of buildings, and retaining hillside open space. Relatively minor architectural and design changes are proposed, including construction of a crib wall system instead of a standard retaining wall. However, these will not result in a substantial increase in environmental impacts. During construction, the 2016 project will result in a relatively low (6%) increase in City of Arcadia CEQA Analysis Page 5 of 14 5 haul truckloads, but as was determined in the 2010 MND, impacts to local roadways would be mitigated to less than significant levels by limiting the hours and days during which hauling could occur. In the overall, the proposed project will not create substantial changes that will result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects. Impacts associated with aesthetics, agricultural resources, air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use planning, mineral resources, noise, population and housing, public services, recreation, traffic, and utilities and service systems will be comparable to those presented in the MND. Following is a brief discussion of impact comparisons, by category. Aesthetics The 2010 project would have converted a portion of the subject property from an undisturbed hillside to low-density residential development; however, approximately 80 acres, including the higher elevations and ridgelines, would have remained undisturbed open space. The 2010 project proposed two 2-story dwelling units with contemporary styles and low-profile, flat rooflines. The MND determined that visual impacts would be less than significant because the residences would be located below the ridgeline and views from surrounding properties would be preserved, proposed land uses would be consistent with surrounding residential development, and the conceptual design had been approved by the Homeowner’s Association Architectural Review Board. The 2010 project would, however, require removal and/or encroachment upon up to 12 mature Coast Live Oak trees and 1 California Sycamore. One large Oak tree was to be preserved. To mitigate for impacts to trees, the Mitigation Measure No. 1.1, included in the Mitigation Monitoring and Reporting Program (MMRP) required the project applicant to comply with the tree protection measures recommended in the arborist report (November 15, 2007), or as amended by an updated report to be submitted prior to issuance of a grading permit. Additionally, Mitigation Measure No. 1.2 required the applicant to plant indigenous low growing plant cover and acorns from nearby Oak trees into the slope under the supervision of a certified arborist who would be responsible for submitting a report to the City following its completion. Impacts were determined to be less than significant with implementation of the referenced mitigation measures. The currently proposed project will alter the same limited portion of the subject property from an undisturbed hillside to two 2-story residences of approximately the same size, scale, and footprint as the 2010 project. Like the previous project, approximately 80 acres of the property will remain in a natural, undeveloped state, and the residences will be built below the ridgeline to maintain the hilltop’s integrity and preserve scenic viewsheds. The residences will be developed in a Modern Ranch style with contemporary features, including a combination of flat and pitched rooflines that are consistent with surrounding development. The previously approved retaining City of Arcadia CEQA Analysis Page 6 of 14 6 wall system will be replaced with a crib wall constructed on the hillside; the crib wall will be landscaped and structurally blended into the hillside, which can be considered a visual improvement compared to the 2010 project. Both houses will no longer be built into the hillside, as was proposed in 2010, but will be set back 20 feet from the crib wall. Impacts to scenic vistas, existing visual character, quality of the site and surroundings, and light and glare will be less than significant and comparable to those analyzed in the 2010 MND. Like the 2010 project, the currently proposed project would result in impacts to existing onsite trees. As provided for in the 2010 MMRP, an updated arborist survey was conducted in November 2016 in accordance with the requirements of the Arcadia Oak Tree Preservation Ordinance (Jan C. Scow Consulting Arborists, LLC to Maggie Teng, Nevis Capital, LLC, revised March 22, 2017). The report contained recommended mitigation measures and was submitted to the City. It identified a total of 16 protected trees (15 oaks and 1 sycamore) onsite. Of these, 3 (2 oaks and 1 sycamore) would be removed as a result of the project, 4 oaks would be encroached upon (pruning and/or root loss), and 9 would not be impacted. The report also indicated there are an estimated 100 additional oak trees on the site that would not be disturbed in any way by the proposed project. The report recommended mitigation measures, including specific measures to protect a large oak tree (tree no. 219), installation of protective fencing, a clearance pruning program, and general impact mitigation measures to be applied where relevant. Implementation of these mitigation measures, as well as Conditions of Approval imposed by the City based on its tree protection Ordinances No. 2323 and 2338, will reduce impacts to trees to less than significant levels. Impacts will be comparable to those analyzed in the 2010 MND. Agricultural Resources The 2010 MND determined the previously approved project would have no impact on agricultural resources. As was the case in 2010, the subject property is not designated or zoned for agricultural uses, subject to a Williamson Act contract, or located in the vicinity of farmland such that it could result in the conversion of agricultural land to non-agricultural uses. The currently proposed project will result in equivalent impacts to those analyzed in the MND because there are no agricultural resources in the project vicinity. No project-related impacts would occur. Air Quality According to the MND, the 2010 project would have no impact on implementation of an applicable air quality plan because it would comply with the City’s General Plan. It would not create objectionable odors affecting a substantial number of people. The project would, however, have the potential to violate air quality standards; result in cumulatively considerable net increases in criteria pollutants for which the region is a nonattainment area; and expose sensitive City of Arcadia CEQA Analysis Page 7 of 14 7 receptors to substantial pollutant concentrations. The MND determined that long-term air quality impacts would be less than significant because the project complied with the land use density allowed in the City’s General Plan. However, short-term impacts would require implementation of standard site preparation and construction measures listed in MMRP Mitigation Measures No. 2-1 through 2-10 to reduce impacts to less than significant levels. No modeling or projections of potential criteria air pollutant emissions was provided or cited in the MND. Like the 2010 project, the currently proposed project will comply with the land use designations set forth in the City’s General Plan and, therefore, have no impact on an applicable air quality plan. The project will not create objectionable odors that affect a substantial number of people; any short-term odors associated with construction equipment would be quickly dispersed. The current project proposes the same of number of dwelling units proposed in 2010, which is consistent with the land use densities allowed in the General Plan, and therefore, its long-term air quality impacts will be less than significant and comparable to those analyzed in the 2010 MND. Short-term site preparation and grading impacts would be comparable to those anticipated in 2010 because the area to be graded is similar in size, scope, and location to the 2010 project. The currently proposed project will require export of approximately 5,270 cubic yards of earth material during grading, compared to approximately 4,960 cubic yards of export generated by the 2010 project. The following table uses the California Emissions Estimator Model (CalEEMod) to estimate pollutant emissions generated by hauling trucks for the 2010 and 2016 projects, and indicates whether they would exceed pollutant emission thresholds established by the South Coast Air Quality Management District (SCAQMD), which monitors air quality in the South Coast Air Basin in which the subject property is located. 2010 Project vs. 2016 Project Haul Trips Emissions Comparison (pounds per day) Hauling Emissions CO NOx ROG SO2 PM10 PM2.5 2010 Project – 4,960 cubic yards 1.32 6.98 0.21 0.01 0.40 0.13 2016 Project – 5,270 cubic yards 1.39 7.38 0.22 0.01 0.42 0.14 SCAQMD Thresholds 550.00 100.00 75.00 150.00 150.00 55.00 Exceeds thresholds? No No No No No No 1 Average of winter and summer emissions, unmitigated, 2017. Source: CalEEMod model, version 2016.3.2 2010 Haul Trips = 620 round trips (310 truckloads) 2016 Haul Trips = 660 round trips (330 truckloads) The data show that, compared to the 2010 project, the 2016 project would result in slightly greater pollutant emissions associated with more hauling trips. However, pollutant emissions for City of Arcadia CEQA Analysis Page 8 of 14 8 both projects would be well below established SCAQMD emission thresholds. Project impacts will be comparable to those analyzed in the 2010 MND. Implementation of the air quality mitigation measures provided in the 2010 MMRP will reduce impacts of the 2016 project to less than significant levels. As shown in the Table above, even with the increase above the 108 truckloads (cited in the 2010 MND), there would not be additional significant impacts. Biological Resources The 2010 MND determined that the project would have no impact on federally protected wetlands because none exist onsite. The project would not conflict with an adopted habitat conservation plan or natural community conservation plan because the subject property is not within the boundaries of such a plan. The project would have a less than significant impact on special-status species because biological field surveys in the project area determined no such species were identified onsite; and would have a less than significant impact on the movement of migratory species because wildlife movement corridors do not existing in the portion of the site proposed for development. The MND determined that mitigation measures would be required to reduce impacts to existing oak trees that would be removed or encroached upon during construction. Specific mitigation measures (No. 1.1 and 1.2) were identified in the MMRP (refer to Aesthetics, above). Like the 2010 project, the currently proposed project will have no impact on federally protected wetlands because none are known to occur on the portion of the site proposed for development. The subject property is not within the boundaries of a habitat conservation plan and, therefore, will not conflict with such a plan. Since the 2010 MND, there have been no significant changes regarding special-status species or wildlife movement in the project area. Approximately 80 acres of hillside will remain undisturbed and be preserved as oak woodland; and the portion of the site that will be disturbed for development is adjacent to an existing roadway. Impacts to existing protected trees are described, and mitigation measures provided, in an arborist report dated March 22, 2017 (refer to Aesthetics, above). Implementation of the mitigation measures will reduce project-related impacts to less than significant levels, and impacts will be comparable to those described in the 2010 MND. Cultural Resources The 2010 MND determined that the previously approved project would have no impact on cultural resources because no historic, archaeological, or paleontological resources were known to be located on the subject property. No changes pertaining to cultural resources have occurred onsite since the MND was approved, and no known cultural resources are known to be located onsite. The currently proposed project will have no impact on cultural resources; impacts will be comparable to those of the 2010 project. City of Arcadia CEQA Analysis Page 9 of 14 9 Geology and Soils The MND determined that any slope instability resulting from the 2010 project would be mitigated to less than significant levels through implementation of recommendations provided in the site-specific geotechnical engineering investigation (MMRP Mitigation Measure No. 3.1). Impacts associated with seismic ground shaking, landslides, and the loss of topsoil would be less than significant. No project-related impacts associated with rupture of an earthquake fault, liquefaction, expansive soils, or soils supporting alternative waste water disposal systems would occur. Overall onsite geologic conditions have not changed since the MND was approved. An update to the geotechnical engineering investigation determined the currently proposed project is feasible from a geotechnical engineering and geological viewpoint (Environmental Geotechnology Laboratory, Inc. letter to Nevis Capital, LLC, March 1, 2017). Implementation of the measures recommended in the report will reduce potential impacts to less than significant levels, consistent with the 2010 recommendations. Impacts will be comparable to those provided in the 2010 MND. Hazardous and Hazardous Materials According to the 2010 MND, the previously approved project would have no impact on hazards or hazardous materials because none would be used or released onsite, and the site was not listed as a hazardous materials site or within an airport land use plan. Given that the property was designated as a Very High Fire Hazard Zone 1 and in proximity to the urban-wildland interface, it could be susceptible to fire hazards. The MND determined that the project would comply with all applicable Fire Department, code, and ordinance requirements for construction, access, water mains, fire flows, and fire hydrants; as a result, project-related impacts would be less than significant. The currently project proposes the same land uses that were proposed in 2010 (two single-family residential units), and as such, impacts associated with hazards and hazardous materials will be comparable to those analyzed in the MND. The project can be expected to store and use typical household cleaners, but no significant public hazard associated with the storage, release, or disposal of hazardous materials is anticipated. The project will comply with all applicable fire safety codes and requirements, and no increase in hazards will occur. Hydrology and Water Quality The MND determined that the 2010 project would result in less than significant impacts to water quality standards, polluted runoff, quality of receiving waters, depletion of groundwater supplies, drainage patterns and systems, and erosion. Potential impacts would be minimized through preparation and implementation of a standard Urban Stormwater Mitigation Plan pursuant to the City of Arcadia CEQA Analysis Page 10 of 14 10 National Pollutant Discharge Elimination System (NPDES), and inclusion of onsite gutters, slope stabilization practices, retaining walls, and similar improvements. The project would have no impact on the biological integrity of water bodies, violate water quality standards, or place housing or other structures within a 100-year flood hazard area. The 2016 project proposes the same land uses, number of residences, general size and scale of buildings, and general site plan as the 2010 project. The proposed drainage and erosion control plan is comparable to the 2010 plan, with onsite flows draining to Canyon Road. Like the 2010 project, onsite drainage will be accommodated by standard stormwater improvements (such as gutters) and implementation of a standard Urban Stormwater Mitigation Plan. The subject property is not located within a 100-year floodplain, and the project will not place housing within a 100-year floodplain. Impacts will be comparable to those described in the 2010 MND. Land Use and Planning The 2010 MND determined that the previously approved project would have no impact on land use and planning. The project would not physically divide an established community, or conflict with an applicable land use plan or habitat conservation plan. The currently proposed project will result in equivalent impacts to those analyzed in the MND. The project proposes the same land uses: two single-family residences and approximately 80 acres of natural, undisturbed hillsides. Its two-story design is consistent with previously approved plans. It would comply with zoning standards but could require a modification for crib wall height, as described above. This modification is permitted through the City’s Municipal Code. The currently proposed project is consistent with General Plan and zoning land use classifications. It is not within the boundaries or vicinity of a habitat conservation plan or natural community conservation plan. No increase in the severity of impacts would occur. Mineral Resources The MND found that the previously approved project would result in no impacts to mineral resources because the subject property does not contain locally important mineral resources, is not located near an area known to contain mineral resources, and is not identified as a mineral resources site in the General Plan. The same onsite conditions currently exist; the site is not designated for mineral uses and is not known to contain mineral resources. The currently proposed project will have no impact on mineral resources, which is comparable to the impacts of the 2010 project. Noise The 2010 MND determined that the project would produce short-term construction-related noise that could exceed the City’s Noise and Land Use Compatibility Guidelines for residential zones, City of Arcadia CEQA Analysis Page 11 of 14 11 but impacts would be mitigated to less than significant levels by enforcing limits on construction hours and days. The Mitigation Monitoring and Reporting Program (,) Mitigation Measures Nos. 4.1 through 4.4 restrict the times for grading and construction activities, including hauling of earth material. Other potential project-related noise impacts, including exposure to groundborne noise/vibration and permanent increases in ambient noise levels, were found to be less than significant (without mitigation). No airport-related impacts would occur because the subject property is not located in the vicinity of an airport or within an airport land use plan. The current project proposes a site plan that is very similar to the 2010 project, with construction of the same number of structures and similar footprints on the same portion of the property adjacent to Canyon Road. Some variations in grading will occur to accommodate different setbacks and design features. As explained previously, during construction, the project is expected to generate approximately 16% more haul truckloads than anticipated under the 2010 project, which will increase vehicular noise levels. However, noise level increases will be temporary and minimal, and will end once construction ends. Like the 2010 MND, impacts will be mitigated to less than significant levels through limits on construction days and times through implementation of Mitigation Measures Nos. 4.1 through 4.4 cited in the 2010 MMRP. The current project proposes the same number and type of buildings (two single-family residences) as proposed in 2010 and, therefore, permanent increases in ambient noise levels will be comparable to those analyzed in the MND. As was the case in 2010, the subject property is not located in the vicinity of an airport or within an airport use land plan, and no airport-related noise impacts will occur. Although construction-related noise impacts from hauling trucks will be slightly greater than the 2010 project, no substantial changes will occur that would result in new significant impacts or substantial increases in the severity of previously identified significant effects. Overall impacts will be comparable to those analyzed in the MND. Population and Housing The 2010 MND determined that the addition of two new single-family residences would not exceed the density of existing single-family residential development in the project vicinity, and impacts to population growth would be less than significant. It also determined that no existing housing or population would be displaced as a result of the project, and no impacts would occur. Onsite conditions remain the same as 2010 conditions; the subject property is vacant, and no existing housing or population will be displaced as a result of the currently proposed project. The current project proposes the same number of dwelling units as the 2010 project, and therefore, impacts to population growth will be comparable to those analyzed in the MND. City of Arcadia CEQA Analysis Page 12 of 14 12 Public Services The MND determined that the 2010 project would result in marginal increases in demand for fire and police protection services, schools, parks, and other public facilities. However, it was determined that existing services and facilities were adequate to serve the two proposed residences, and impacts would be less than significant. The currently project proposes the same number of residences as the previous project, and no new deficiencies in public services has been identified. Therefore, impacts will be comparable to those analyzed in the MND. Recreation The 2010 MND determined that the two new residences would incrementally increase the use of existing parks, but the payment of parks and recreation impact fees would help prevent the physical deterioration of the City’s facilities, and reduce impacts to less than significant levels. The MND also determined that existing recreational facilities were adequate to serve two additional residences, and no new or expanded facilities would be required. Like the previous project, the current project proposes two single-family residences and will be subject to payment of parks and recreation impact fees. Therefore, impacts will be comparable to those analyzed in the MND. Transportation/Traffic According to the 2010 MND, the previously proposed project would have no impact on air traffic patterns, hazardous design features, or conflicts with alternative transportation plans or policies. It would have a less than significant impact on emergency access and parking capacity because the export truck schedule, construction staging plan, and completed project would provide adequate emergency access and parking. The MND estimated that the grading process would require 108 truck trips to haul graded earth material off-site; however, no trip generation factor or equation is provided or cited to explain how the calculation was determined. The MND found that, with mitigation, impacts associated with increased short-term construction traffic would be less than significant. Mitigation Measures Nos. 4.1 through 4.4 address permitted times for grading and construction activities, and well as measures to assure compliance with the construction staging plan. Like the 2010 project, the currently proposed project will have no impact on air traffic patterns because the subject property is not in the vicinity of an airport or within an airport land use plan. It does not propose new roads, intersections, or other potentially hazardous features, and the new residential driveways would comply with the City’s visibility standards. The export truck schedule and construction staging plans will assure sufficient parking is provided during the City of Arcadia CEQA Analysis Page 13 of 14 13 construction phase, and both proposed dwelling units will include driveways and garages to provide adequate long-term parking. The Earthwork Estimates plan (May 22, 2017) prepared by the project engineer uses a haul trip generation factor of 14 cubic yards per truck to estimate the number of haul trips anticipated for the 2010 and 2016 projects. Based on the factor of 14 cubic yards per truck, the 2010 project would have required approximately 355 haul loads to remove 4,960 cubic yards of cut. The 2016 project would require approximately 377 haul loads to remove 5,270 cubic yards of cut. This represents 22 more haul loads than the 2010 project, or an increase of 6%. As discussed in the Air Quality section above, CalEEMod (version 2016.3.2) modeling software uses a default factor of 16 cubic yards per haul trip. Based on this factor, the 2010 project would have required approximately 310 haul trips to remove 4,960 cubic yards of cut. The 2016 project would require approximately 330 haul trips to remove 5,270 cubic yards of cut, which represents 20 more haul loads than the 2010 project, or an increase of 6%. Regardless of which haul trip generation factor is used, the currently proposed project is expected to require approximately 6% more truck haul trips compared to the 2010 project. This is a minimal increase in short-term impacts that would end once the project is completed. Even with the increase above 108 truckloads (cited in the 2010 MND), there would not be additional significant impacts. Impacts can be mitigated to less than significant levels with the same mitigation measures cited in the 2010 MMRP, namely limiting the hours and days during which hauling could occur and ensuring compliance with the construction staging plan and proposed truck haul route. With mitigation, the project would not individually or cumulatively exceed an established level-of-service. The MND (p. 18, 19) includes the following roadways in the project’s truck traffic route leading from the subject property to the 210 freeway: Canyon Road, Elkins Avenue, and Santa Anita Avenue; none are identified in the General Plan Circulation and Infrastructure Element as exceeding the City’s acceptable level-of-service, or requiring modifications or future studies to accommodate growth. Therefore, additional truck traffic generated during construction of the proposed project will not be substantial compared to the 2010 project or contribute to exceedances in acceptable levels-of-service. Impacts would be comparable to those analyzed in the MND. Utilities and Service Systems The 2010 MND determined that the previously proposed project would have no impact on utilities and service systems because increases in demand for utilities and public services from two single-family residential units would be minimal, existing services were sufficient to serve the units, and the project would not trigger the need for additional or expanded facilities or services. City of Arcadia CEQA Analysis Page 14 of 14 14 The current project proposes the same number of single-family residential units, and no new deficiencies in utilities or service systems have been identified. Impacts would be less than significant, which is the same as those analyzed in the MND. Conclusion The impacts of the 2010 project were fully analyzed in the approved 2010 MND. The currently proposed project will not result in substantial changes that involve new significant environmental effects or a substantial increase in the severity of previously identified significant effects. There has been no significant change in the circumstances under which the project will be undertaken, or change in the environment on or surrounding the subject property that would result in significant environmental impacts that weren’t analyzed in the 2010 MND. The mitigation measures included in the 2010 MMRP, and the recommendations provided in the updated geotechnical and arborist reports, will be applied to the currently proposed project where applicable. Accordingly, it is appropriate for the City to find, pursuant to CEQA Guidelines Section 15162, that no additional environmental review of the proposed project is required, and that all of the project’s potential impacts have already been analyzed in the 2010 MND, which fully covers the proposed project. Please feel free to contact me if you have any questions or require further information. Sincerely, Andrea M. Randall Senior Planner