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:
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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).
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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.
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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
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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
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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
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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
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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.
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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
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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,
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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.
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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
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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
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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