HomeMy WebLinkAboutAgenda Packet – Part 2 of 3 – Item No. 3, Attachment No. 4 – IS/MND Only Attachment No. 4
Attachment No. 4
Draft Initial Study/MND, Response to
Comments, and MMRP
Initial Study/Mitigated Negative Declaration
Arcadia Hotel and Annex
(Hotel Indigo) Project
Prepared for:
City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Prepared by:
38 N. Marengo Avenue
Pasadena, California 91101
FEBRUARY 2020
Printed on 30% post-consumer recycled material.
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Table of Contents
SECTION PAGE NO.
ACRONYMS AND ABBREVIATIONS .............................................................................................................................. V
1 INTRODUCTION ............................................................................................................................................. 1
1.1 Project Overview ..................................................................................................................................... 1
1.1.1 Previously Approved Development Project.............................................................................. 1
1.1.2 Proposed Project ....................................................................................................................... 1
1.2 Document Contents and Format ........................................................................................................... 2
1.3 Public Review Process ........................................................................................................................... 3
1.4 Mitigation Measures .............................................................................................................................. 4
2 PROJECT SETTING AND DESCRIPTION ........................................................................................................ 13
2.1 Project Location ................................................................................................................................... 13
2.2 Existing Conditions and Setting .......................................................................................................... 13
2.2.1 On-Site Land Uses.................................................................................................................. 13
2.2.2 Transit Priority Area ............................................................................................................... 14
2.2.3 Surrounding Land Uses ......................................................................................................... 14
2.3 Project Description .............................................................................................................................. 15
2.3.1 Hotel Indigo ............................................................................................................................ 15
2.3.2 Parking and Pedestrian Improvements ................................................................................ 16
2.3.3 Landscape Improvements ..................................................................................................... 17
2.3.4 Off-Site Improvements ........................................................................................................... 17
2.3.5 Short-Term Construction Activities ....................................................................................... 17
2.4 Discretionary Actions ........................................................................................................................... 18
3 ENVIRONMENTAL IMPACT ANALYSIS .......................................................................................................... 19
3.1 Aesthetics ............................................................................................................................................ 19
3.2 Agriculture and Forestry Resources ................................................................................................... 25
3.3 Air Quality ............................................................................................................................................. 27
3.4 Biological Resources ........................................................................................................................... 40
3.5 Cultural Resources .............................................................................................................................. 44
3.6 Energy .................................................................................................................................................. 47
3.7 Geology and Soils ................................................................................................................................ 53
3.8 Greenhouse Gas Emissions ................................................................................................................ 57
3.9 Hazards and Hazardous Materials ..................................................................................................... 65
3.10 Hydrology and Water Quality ............................................................................................................... 70
3.11 Land Use and Planning ....................................................................................................................... 77
3.12 Mineral Resources .............................................................................................................................. 78
3.13 Noise .................................................................................................................................................... 80
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3.14 Population and Housing ...................................................................................................................... 89
3.15 Public Services .................................................................................................................................... 90
3.16 Recreation ............................................................................................................................................ 93
3.17 Transportation ..................................................................................................................................... 94
3.18 Tribal Cultural Resources .................................................................................................................. 114
3.19 Utilities and Service Systems ............................................................................................................ 116
3.20 Wildfire ............................................................................................................................................... 121
3.21 Mandatory Findings of Significance ................................................................................................. 123
4 REFERENCES AND PREPARERS................................................................................................................ 127
4.1 References Cited ............................................................................................................................... 127
4.2 List of Preparers and Contributors ................................................................................................... 133
APPENDICES
A Air Quality and Greenhouse Gas Calculations
B Tree Survey
C Sacred Lands File and Native American Contacts List Request
D Preliminary Low Impact Development Report
E Noise Measurement Data Sheets
F Transportation Impact Analysis
G Architectural Design Review and Variance Application
FIGURES
1 Project Location ............................................................................................................................................ 1345
2 Zoning ............................................................................................................................................................ 137
3 Surrounding Land Uses .................................................................................................................................. 139
4A Site Plan ........................................................................................................................................................... 141
4B Enlarged Site Plan ........................................................................................................................................... 143
4C Building Perspectives ...................................................................................................................................... 145
5A Building C Elevations ...................................................................................................................................... 147
5B Building D Elevations ...................................................................................................................................... 149
6 Preliminary Landscape Plan ........................................................................................................................... 151
7 Noise Measurement Locations ...................................................................................................................... 153
8 Vicinity Map ..................................................................................................................................................... 155
9 Existing Lane Configurations .......................................................................................................................... 157
10 Existing Traffic Volumes (Weekday AM Peak Hour) ...................................................................................... 159
11 Existing Traffic Volumes (Weekday PM Peak Hour) ...................................................................................... 161
12 Existing Traffic Volumes (Saturday PM Peak Hour) ...................................................................................... 163
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13 Location of Related Projects .......................................................................................................................... 165
14 Existing with Project Traffic Volumes (Weekday AM Peak Hour) .................................................................. 167
15 Existing with Project Traffic Volumes (Weekday PM Peak Hour) .................................................................. 169
16 Existing with Project Traffic Volumes (Saturday PM Peak Hour) .................................................................. 171
TABLES
1 Mitigation Measures ............................................................................................................................................ 4
2 Hotel Building Components .............................................................................................................................. 16
3 General Plan, Development Code, and Municipal Code Consistency Analysis ............................................. 21
4 SCAQMD Air Quality Significance Thresholds .................................................................................................. 30
5 Construction Assumptions for Air Quality Modeling ........................................................................................ 32
6 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Unmitigated .............................. 33
7 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Unmitigated .............................. 34
8 Construction Localized Significance Threshold Analysis ................................................................................ 36
9 Construction Equipment Diesel Demand for Off-Road Equipment ................................................................ 48
10 Construction Worker Gasoline Demand .......................................................................................................... 49
11 Construction Vendor Diesel Demand ............................................................................................................... 49
12 Construction Haul Truck Diesel Demand......................................................................................................... 50
13 Annual Mobile Source Demand (Gasoline and Diesel) ................................................................................... 51
14 Estimated Annual Construction GHG Emissions ............................................................................................. 60
15 Estimated Annual Operational GHG Emissions ............................................................................................... 61
16 Ambient Measured Noise Levels...................................................................................................................... 81
17 Construction Equipment Maximum Noise Levels ........................................................................................... 82
18 Construction Noise Model Results Summary .................................................................................................. 83
19 Off-Site Traffic Noise (Existing and Existing-with-Project) ............................................................................... 87
20 Off-Site Traffic Noise (Future and Future-with-Project) ................................................................................... 87
21 Summary of Volume to Capacity Ratios/Delays and Levels of Service Weekday AM, PM,
and Saturday PM Peak Hours .......................................................................................................................... 99
22 Related Projects List and Trip Generation ..................................................................................................... 102
23 Project Trip Generation ................................................................................................................................... 105
24 Street Segment Analysis Summary Existing and Future Weekday and Weekend Conditions ................... 107
25 Existing Transit Routes ................................................................................................................................... 111
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Acronyms and Abbreviations
Acronym/Abbreviation Definition
ACM asbestos-containing material
AIN Assessor Identification Number
APD Arcadia Police Department
AQMP Air Quality Management Plan
BMP best management practice
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
Cal/OSHA California Division of Occupational Safety and Health
CalRecycle California Department of Resources, Recycling, and Recovery
Caltrans California Department of Transportation
CARB California Air Resources Board
CHRIS California Historical Resources Information System
CEQA California Environmental Quality Act
City City of Arcadia
CMP Congestion Management Plan
CNEL Community Noise Equivalent Level
County County of Los Angeles
CUP Conditional Use Permit
dB Decibel
dBA A-weighted decibel
DOC California Department of Conservation
DOGGR California Division of Oil, Gas, and Geothermal Resource
DTSC Department of Toxic Substances Control
DWR California Department of Water Resources
EB eastbound
EIR Environmental Impact Report
EPA U.S. Environmental Protection Agency
IS/MND Initial Study/Mitigated Negative Declaration
FAR Floor Area Ratio
FHWA Federal Highway Administration
GHG greenhouse gas
gpm gallons per minute
GWP global warming potential
HVAC heating, ventilation, and air conditioning
kW kilowatt
LACSD Sanitation District of Los Angeles County
LACM Natural History Museum of Los Angeles County
LARWQCB Los Angeles Regional Water Quality Control Board
Leq time-averaged equivalent noise level
LID Low Impact Development
LOS level of service
LST Localized Significance Threshold
LUST Leaking Underground Storage Tank
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Acronym/Abbreviation Definition
MBTA Migratory Bird Treaty Act
mgd million gallons per day
MM mitigation measure
MRZ Mineral Resource Zone
MS4 Municipal Separate Storm Sewer System
MT metric ton
MWD Metropolitan Water District of Southern California
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NPDES National Pollutant Discharge Elimination System
PRIMP Paleontological Resources Impact Mitigation Program
RCNM Roadway Construction Noise Model
ROW right-of-way
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy
SB Senate Bill
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCCIC South Central Coastal Information Center
SCE Southern California Edison
sf square feet
SVP Society of Vertebrate Paleontology
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TCR tribal cultural resource
UWMP Urban Water Management Plan
V/C Volume-to-capacity
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic gas
WB westbound
WRP Water Reclamation Plant
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1 Introduction
1.1 Project Overview
The City of Arcadia (City) has prepared an Initial Study/Mitigated Negative Declaration (IS/MND) for the Arcadia
Hotel and Annex Project (Hotel Indigo or proposed Project), located in downtown Arcadia in northeast Los Angeles
County (County). The proposed Project site is located at two addresses: 125 West Huntington Drive and 175
Colorado Place. The Project site is located on one legal parcel with the following four Assessor Parcel Numbers
(APN) for tax purposes: 5775-015-024, 5775-015-025, 5775-015-026, and 5775-015-027. As part of the Project,
the hotel will receive a new address (123 W. Huntington Drive), which will replace the 175 Colorado Place address.
1.1.1 Previously Approved Development Project
The approximately 4.59-acre Project site is the location of a previously approved development project. On January
22, 2013, the Arcadia Planning Commission approved the construction of four new buildings on the Project site,
and on February 5, 2013, the City Council affirmed the Planning Com
buildings, as follows:
Building 1: A 163,468 square-foot (sf), four-level parking structure
Building 2: A 19,995 sf, three-story medical office building
Building 3: A 19,441 sf, three-story medical office building with 3,000 sf of ground floor restaurant
Building 4: A 24,819 sf, three-story general office building with 1,600 sf of ground floor restaurant
The existing 60,811 sf, three-story office building (formerly occupied by Parsons Engineering) would remain. Four
modifications, which included concessions to allow new windows facing residential properties, designated loading
spaces in lieu of required parking, special front yard setbacks, and to allow trash enclosures to be located within
the 20-foot rear yard setback were approved with the previously approved project.
Additionally, the 2013 project included a City right-of-way dedication of 3,192 sf, thereby reducing the lot area to
200,085 sf. The Lot Line Adjustment No. LLA 12-03, Conditional Use Permit (CUP) No. CUP 11-18, Modification NO.
MP 12-10, and Architectural Design Review No. ADR 11-29 including additional conditions, were approved by the
City. Subsequently, portions of the previously approved 2013 project were constructed, including the parking
structure (Building 1) and the two medical office buildings (Buildings 2 and 3).
1.1.2 Proposed Project
The current development proposal is to build a new hotel. This Project would include the conversion of the existing
general office use (formerly occupied by Parsons Engineering) and the construction of a new five-story tower that is
located near the corner of Huntington Drive and San Rafael Avenue. The proposed Project site includes the same
property boundary as the 2013 submittal but would only involve changes to the eastern portion of the site. The two
recently constructed medical office buildings (hereafter referred to as Building A and B) and the new parking
structure are proposed to remain as-is. Under the proposed Project, the existing 60,811 sf, three-story office
building (former Worley Parsons Building, hereafter referred to as Building C) would continue to remain on the
Project site but would be redeveloped from the existing office use into a hotel.
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In summary, the proposed Project includes a hotel (renovated Building C) and a hotel annex (new Building D) on
the Project site. Building C would be remodeled to allow for 76,754 sf of hotel and appurtenant uses. The first floor
includes a lobby/lounge, restaurant, kitchen, fitness room, management offices, meeting rooms, and banquet hall
space. The second and third floors would accommodate 90 hotel rooms. Building D would be constructed as a
61,538 sf, five-story hotel building on the southeastern portion of the Project site that includes the hotel spa, café,
outdoor patios and an additional 75 hotel rooms. In total, 165 new hotel rooms would be constructed on the Project
site. Building A, Building B, and the existing parking structure would be left as is and protected in place during
construction of the proposed Project.
1.2 Document Contents and Format
Because of the substantive differences between the proposed Project and the originally proposed and approved
project and 2013 IS/MND, the City has determined that it is appropriate to prepare a new IS/MND to evaluate the
environmental impacts of the proposed Project. As such, if approved, this IS/MND would become the primary
environmental compliance documentation pursuant to the California Environmental Quality Act (CEQA) for the
proposed Project. Relevant information from the 2013 IS/MND may be incorporated into this IS/MND, where
appropriate, and is referenced accordingly.
The CEQA applies to proposed projects initiated by, funded by, or requiring discretionary approvals from state or
local government agencies. The proposed Project constitutes a project as defined by CEQA (California Public
Resources Code, Section 21065). The City of Arcadia is the CEQA lead agency for the proposed Project. Pursuant
to CEQA Guidelines Section 15063(d), an Initial Study must contain the following:
1) A description of the project including the location of the project;
2) An identification of the environmental setting;
3) An identification of environmental effects by use of a checklist, matrix, or other method, provided that
entries on a checklist or other form are briefly explained to indicate that there is some evidence to
support the entries. The brief explanation may be either through a narrative or a reference to another
information source such as an attached map, photographs, or an earlier EIR or negative declaration. A
reference to another document should include, where appropriate, a citation to the page or pages where
the information is found.
4) A discussion of the ways to mitigate the significant effects identified, if any;
5) An examination of whether the project would be consistent with existing zoning, plans, and other applicable
land use controls; and,
6) The name of the person or persons who prepared or participated in the Initial Study.
An Initial Study (IS) has been prepared by the City, as the lead agency, in accordance with CEQA Guidelines to
evaluate potential environmental effects and to determine whether an Environmental Impact Report, a Negative
Declaration, or a Mitigated Negative Declaration (MND) should be prepared for the proposed Project. The Initial
Study has also been prepared to satisfy CEQA requirements of other agencies that may provide approvals, permits,
and/or funding for the proposed Project.
In accordance with CEQA G
identified potentially significant effects on the environment, but (1) revisions in the project plans or proposals made
by, or agreed to by, the Applicant before the proposed negative declaration and initial study are released for public
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review would avoid the effects or mitigate the effects to a point where clearly no significant effect on the
environment would occur, and (2) there is no substantial evidence in light of the whole record before the lead
Project determined that the Project could cause some potentially significant impacts on the environment, but as
shown in the environmental analysis contained herein, those potentially significant impacts would be reduced to
less than significant levels through the implementation of mitigation measures. Consequently, an MND has been
be prepared for the proposed Project.
makers must review and consider the MND in its discretion to approve, revise, or deny the
Project, as appropriate. The MND will serve as the primary environmental document pursuant to CEQA for
implementation of the Project, including all required discretionary approvals.
This IS/MND is composed of four sections. Section 1 provides a general overview of the proposed Project, CEQA
requirements related to the Project, the public review process, and a summary of the mitigation measures required.
Section 2 provides a description of the environmental setting and the proposed Project components, anticipated
construction schedule, and operational characteristics. Section 3 includes the CEQA Initial Study checklist, which
provides an assessment of potential environmental impacts and identifies mitigation measures to reduce potentially
significant impacts to less than significant. Section 4 provides a list of staff and consultants involved in preparing the
IS/MND. The IS/MND also includes appendices that contain technical memoranda and/or data files related to air quality
and greenhouse gas (GHG) emissions (see Appendix A), biological resources (see Appendix B), cultural resources (see
Appendix C), low impact development (Appendix D), noise (see Appendix E), traffic (see Appendix F), and an architectural
design review and variance application (See Appendix G).
1.3 Public Review Process
In accordance with CEQA and the CEQA Guidelines, a public review period for this IS/MND commenced on Thursday,
February 13th, 2020 and will conclude on Thursday, March 5th, 2020. The IS/MND has been distributed for review
to interested and involved public agencies, responsible/trustee agencies, organizations, and private individuals
that have requested in writing to be informed of the proposed Project. A hardcopy of the IS/MND is also available
for public review during regular business hours at:
City of Arcadia Planning Services Division
240 West Huntington Drive
Arcadia, California 91007
and
City of Arcadia Library (Circulation Desk)
20 W. Duarte Road
Arcadia, California 91007
An electronic copy of the IS/MND can be viewed at: https://www.arcadiaca.gov/government/city-departments/
development-services/planning/current-significant-projects
In accordance with CEQA Guidelines Section 15073, the IS/MND will be available for public review for not less than
20 days. Because this proposed Project does not require review by any state agencies, a minimum 20-day public
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review period is appropriate. During the public review period, the public will have the opportunity to provide written
proposed Project will also be based on the information contained in this document.
In reviewing the IS/MND, interested members of the public should focus on the sufficiency of the document in
identifying and analyzing potential Project impacts on the environment, as well as the sufficiency of any mitigation
measures proposed to reduce potential impacts to a less-than-significant level. Comments on the IS/MND should be
submitted by the end of the public review period and must be postmarked by Thursday, March 5th, 2020. Please
Luis Torrico, Senior Planner
City of Arcadia Development Services Department
240 West Huntington Drive
Arcadia, California 91007
ltorrico@arcadiaca.gov
1.4 Mitigation Measures
Prior to mitigation, Project implementation would result in potentially significant impacts to Biological Resources,
Cultural Resources, Noise, and Tribal Cultural Resources. However, mitigation measures (MMs) have been
developed to avoid or reduce these impacts to levels considered less than significant. These MMs would be included
in the Contractor Specifications and bid documents, as appropriate, and verified as part of the Mitigation Monitoring
and Reporting Program. These MMs must be implemented to the satisfaction of the City and are listed below in
Table 1, Mitigation Measures.
Table 1. Mitigation Measures
Potential Impact Mitigation Measure
Biological Resources
Project construction has the
potential to disrupt nesting
birds protected under the
Migratory Bird Treaty Act
(MBTA).
MM BIO-1. Commencement of construction activities shall avoid the February 1
through August 31 bird nesting season to the greatest extent feasible. If construction
activities begin within this nesting season, a survey for nesting birds shall be
conducted by a qualified biologist within 7 days of the commencement of
construction activities, but not prior to this 7-day window. The area surveyed shall
include all clearing/construction areas, as well as areas within 100 feet of the
boundaries of these areas, or as otherwise determined by the biologist. If no active
bird nests are identified on, or within 100 feet of the limits of the proposed
disturbance area, no further action is necessary and construction activities could
commence. For any off-site areas that are inaccessible, the qualified biologists may
survey the off-site area with binoculars to capture the full 100-foot survey area.
If active nests are found during pre-construction surveys or at any time throughout
the course of construction activities during the nesting bird season, all
clearing/construction activities within a minimum of 100 feet of the nest shall be
postponed until a wildlife biologist has identified the nesting species. If the bird
species is not protected under the MBTA and/or the California Fish and Game Code,
no further action is required and construction activities may proceed. If the avian
species is protected under the MBTA and/or the California Fish and Game Code, a
minimum buffer zone shall be established by the qualified biologist based on the type
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Table 1. Mitigation Measures
Potential Impact Mitigation Measure
of bird/raptor species identified and the construction buffer shall be established on
site through the erection of cones/flagging/fencing to clearly delineate the protection
zone.
All construction activities shall avoid this protection zone until a qualified biologist has
confirmed that the nest(s) is no longer active and the nest is vacated, and there is no
evidence of second nesting attempts. Upon completion of any site survey for nesting
birds conducted by a qualified biologist, documentation of the survey activity,
findings, and any resulting actions taken shall be prepared and submitted to the City.
Cultural Resources
Archaeological resources
could potentially be
discovered/unearthed
during Project construction.
MM-CUL-1. In the event that archaeological resources are unearthed during ground-
disturbing activities, the construction contractor shall immediately cease all earth-
disturbing activities within 100 feet of the discovery and shall retain a qualified
Standards. Construction activities may continue in other areas outside of the
designated protection zone, which shall be delineated with cones, flagging, or fencing.
The archaeologist shall evaluate the significance of the find and determine whether
QA Guidelines.
If the archaeological find is determined to be a resource, the archaeologist shall
formulate a Mitigation Plan in consultation with the City of Arcadia that satisfies the
requirements of the above-listed Code Sections. Upon approval of the Mitigation Plan
by the City, the Project shall be implemented in compliance with the Plan. If the
Archaeologist determines that the resource is not significant, s/he shall record the
evaluation and submit the recordation form to the California Historical Resources
Information System (CHRIS) at the South Central Coastal Information Center (SCCIC).
The archaeologist shall prepare a report of the results of any study prepared as part
of a testing or Mitigation Plan, following accepted professional practice. The report
shall follow guidelines of the California Office of Historic Preservation although format
will be dependent on the nature of the archaeological investigation required. Copies
of the report shall be submitted to the City and to the CHRIS at the SCCIC.
Geology and Soils
Paleontological resources
could potentially be
discovered/unearthed
during Project construction.
MM-GEO-1. Prior to commencement of any grading activity on-site, the Applicant shall
retain a qualified paleontologist per the Society of Vertebrate Paleontology (SVP)
(2010) guidelines. The paleontologist shall prepare a Paleontological Resources
Impact Mitigation Program (PRIMP) for the project. The PRIMP shall be consistent
with the SVP (2010) guidelines and should outline requirements for preconstruction
meeting attendance and worker environmental awareness training, where monitoring
is required within the project area based on construction plans and/or geotechnical
reports, procedures for adequate paleontological monitoring and discoveries
treatment, and paleontological methods (including sediment sampling for
microvertebrate fossils), reporting, and collections management. The qualified
paleontologist shall attend the preconstruction meeting and a paleontological monitor
shall be on-site during all rough grading and other significant ground-disturbing
activities in previously undisturbed, fine-grained older Quaternary alluvial fan
deposits. These deposits may be encountered at depths as shallow as 5-10 feet
below ground surface. In the event that paleontological resources (e.g., fossils) are
unearthed during grading, the paleontological monitor will temporarily halt and/or
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Table 1. Mitigation Measures
Potential Impact Mitigation Measure
divert grading activity to allow recovery of paleontological resources. The area of
discovery will be roped off with a 50-foot radius buffer. Once documentation and
collection of the find is completed, the monitor will remove the rope and allow grading
to recommence in the area of the find.
Noise
The Project would not
exceed any construction-
related noise standards in
Municipal Code. However,
to be conservatively
protective of adjacent
residences during
construction activities, MM-
NOI-1 includes best
practices that would reduce
construction noise levels at
the adjacent residential
property line.
MM-NOI-1. Prior to the issuance of a grading permit, the Project Applicant shall
provide a Construction Noise Control Plan (CNCP) to the City for review and approval.
The CNCP shall include best management practices to reduce short-term
construction noise. Enforcement of the CNCP shall be accomplished by field
inspections during construction activities and/or documentation of compliance, to the
Development Services Department. Recommended best
management practices may include, but not be limited to, the following:
All construction equipment, fixed or mobile, shall be equipped with properly
operating and maintained mufflers consistent with the manufacturer
specifications and standards.
Construction noise reduction methods such as shutting off idling equipment,
maximizing the distance between construction equipment staging areas and
adjacent residences, and use of electric air compressors and similar power tools,
rather than diesel equipment, should be used where feasible.
Stationary equipment should be placed as far away from the adjacent residential
property boundary as feasible and positioned such that emitted noise is directed
away from or shielded from sensitive receptors. Acoustically attenuating shields,
shrouds, or enclosures may be placed over stationary equipment.
During all Project site construction, the construction contractor shall limit all
construction-related activities, including maintenance of construction equipment
and the staging of haul trucks, to between the hours of 7:00 a.m. to 6:00 p.m.
Monday through Friday and 8:00 a.m. to 5:00 p.m. on Saturday.
Construction hours, allowable workdays, and the phone number of the job
superintendent should be clearly posted at all construction entrances to allow
surrounding property owners to contact the job superintendent, if necessary. In
the event the City receives a complaint, appropriate corrective actions should be
implemented and a r
Development Services Department.
Operation of the HVAC
system and/or emergency
generator has the potential
to generate noise in excess
of City standards, which
could adversely affect
sensitive noise receptors.
MM-NOI-2 The Project Applicant shall retain an acoustical specialist to review the
level plans to ensure that the equipment specifications and
plans for HVAC and emergency backup generator incorporate features to ensure that
operational noise will not exceed relevant noise standards at nearby noise-sensitive
land uses (e.g., residential). Such features could include, but not be limited to, the
specification of quieter equipment, relocation of facilities to be of further distance
from residential homes, and/or the provision of acoustical enclosures. The acoustical
specialist shall certify in writing to the City that the equipment specifications and
Tribal Cultural Resources
Tribal Cultural Resources
could potentially be
discovered/unearthed
during Project construction.
MM-TCR-1. Should a possible TCR be encountered, construction activities within 50
feet of the discovery shall be temporarily halted and the City notified. The City will
notify Native American tribes that have been identified by the NAHC to be traditionally
and culturally affiliated with the geographic area of the Project. If the potential
resource is archaeological in nature, appropriate management requirements shall be
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Table 1. Mitigation Measures
Potential Impact Mitigation Measure
implemented as outlined in MM-CUL-1. If the City determines that the potential
resource is a TCR (as defined by PRC, Section 21074), tribes consulting under AB 52
would be provided a reasonable period of time, typically 5 days from the date of a
new discovery is made, to conduct a site visit and make recommendations regarding
future ground disturbance activities as well as the treatment of any discovered TCRs.
A qualified archaeologist shall implement a plan for the treatment and disposition of
any discovered TCRs based on the nature of the resource and considering the
recommendations of the tribe(s). Implementation of proposed recommendations will
be made based on the determination of the City that the approach is reasonable and
feasible.
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Environmental Checklist Form
1. Project Title: Arcadia Hotel and Annex (Hotel Indigo) Project
2. Lead agency name and address: City of Arcadia
Development Services Department
240 West Huntington Drive
Arcadia, California 91007
3. Contact person and phone
number:
Luis Torrico, Senior Planner
(626) 574-5442
4. Project location: 125 West Huntington Drive and 175 Colorado Place, Arcadia
5.
address:
Pacific Design Group
C/O Donnie Jurgensen
150 El Camino Real, Suite 112
Tustin, CA 92780
6. General plan designation: (C) Commercial
7. Zoning: (C-G) General Commercial Zone with a Downtown Overlay
8. Description of project: The proposed Project includes the construction of the Hotel Indigo to be
located in the existing Worley Parsons Building (Building C), which would
be remodeled to allow for 76,754 sf of hotel and appurtenant uses.
Building C would be remodeled, as follows: the first floor would be
renovated to include a lobby/ lounge, restaurant, kitchen, fitness room,
management offices, meeting rooms, and banquet hall space; the second
and third floors would be remodeled to accommodate 90 hotel rooms.
Also, a new, 61,538-square-foot, five-story building (Building D) would be
constructed on the site and would include a hotel spa, café, outdoor patios
and an additional 75 hotel rooms, for a Project-wide total of 165 hotel
rooms. See Section 2, Project Setting and Description, for details.
9. Surrounding land uses and
setting:
The proposed Project site is surrounded by single-family residential land
uses to the north, commercial land uses to the east, recreational, and
hotel to the south, and commercial land uses and the Santa Anita Race
Track to the west.
10. Other pu blic agencies whose
approval is required:
There are no public agencies, other than the City of Arcadia, whose
approval is required for the proposed Project
11. Have California Native
American t ribes tradit ionally
and c u ltu rally affilia ted with
the pro ject a rea re quested
consu ltation pursuant to
Public Resou rces Co de s ec tion
210 8 0.3.1 ?
See Section 3.18, Tribal Cultural Resources.
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Evaluation of Environmental Impacts
1. answers that are adequately supported
answer is adequately supported if the referenced information sources show that the impact simply does
not apply t
answer should be explained where it is based on project-specific factors as well as general standards (e.g.,
the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative
as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3. Once the lead agency has determined that a particular physical impact may occur, then the checklist
answers must indicate whether the impact is potentially significant, less than significant with mitigation, or
less than significan
determination is made, an Environmental Impact Report (EIR) is required.
4.
st describe the mitigation measures, and briefly explain how they
in (5) below, may be cross-referenced).
5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect
has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this
case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review.
b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope
of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state
whether such effects were addressed by mitigation measures based on the earlier analysis.
c.
from the earlier
document and the extent to which they address site-specific conditions for the project.
6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential
impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document
should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7. Supporting Information Sources: A source list should be attached, and other sources used or individuals
contacted should be cited in the discussion.
8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies
should normally address the questions from this checklist that are relevant to a pro
effects in whatever format is selected.
9. The explanation of each issue should identify:
a. The significance criteria or threshold, if any, used to evaluate each question; and
b. The mitigation measure identified, if any, to reduce the impact to less than significance.
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2 Project Setting and Description
2.1 Project Location
As shown in Figure 1, Project Location, the proposed Project site is located in downtown Arcadia in northeast Los Angeles
County. The proposed Project site is located at two addresses: 125 West Huntington Drive and 175 Colorado Place. The
Project site is located on one legal parcel with APN: 5775-015-024. The Project site is bound by Colorado Place to the
south, San Juan Drive to the west, San Rafael Road to the east, and residential homes on Santa Cruz Road to the north.
Regional access to the Project site is via Interstate (I) 210, exiting Santa Anita Avenue to Colorado Place.
2.2 Existing Conditions and Setting
2.2.1 On-Site Land Uses
the zoning for the Project site is General Commercial (C-G) with a Downtown Overlay. Figure 2, Zoning, provides an
overview of the land designation and zoning of the Project site and surrounding areas. The C-G Zone is intended to
provide areas for the development of retail and service uses, offices, restaurants, public uses, and similar and
compatible uses and it implements the General Plan Commercial designation (City of Arcadia 2016a). The
maximum Floor Area Ratio (FAR) permitted under the C-G Zone and under the Downtown Overlay Zone is 1.0 for
new development and the maximum height permitted for new buildings is 48 feet. The proposed Project would have
a FAR of 0.85 and thus would be compatible with the C-
proposed Project would include a five-story building (Building D), which would be 63 feet 10 inches in
height above average grade. Given the 48-foot height restriction, the Project would be subject to a height variance,
which will be processed concurrently with Project approvals. Additionally, Project approval would be subject to a
CUP, which is required in order to develop hotel land uses in the C-G Zone, and Site Plan and Design Review.
As shown on Figure 1, the Project site includes Building A, Building B, Building C, a three-story parking structure
and two surface parking lots; one small surface parking lot on the northwestern corner of the Project site and one
o Place.
Buildings A and B, the northwestern surface parking lot and the three-level parking structure would remain as-is
under the proposed Project. Building C (the former Worley Parsons Building) is vacant under existing conditions and
would be redevelop
northeastern corner would be partially demolished to accommodate the construction of Building D, the hotel annex
building. Existing landscaping on the Project site includes 38 intermittent ornamental trees, four of which are
protected City trees within the public sidewalk between the Project site and San Rafael Road. Additionally, planter
beds containing shrubbery, trees, and groundcover surround the Project site and are dispersed throughout the
existing surface parking lots. Access to the Project site is provided via three driveways, as follows:
Ingress/egress off San Rafael Road to the east, which provides access to the northeastern surface parking lot.
A primary two-lane driveway located in the center of the Project site off Colorado Place, which provides
access to both the three-level parking structure and the northeastern surface parking lot.
Ingress/egress west of the Project site off San Juan Drive, which provides access to the small northwestern
surface parking lot and to the three-level parking structure.
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2.2.2 Transit Priority Area
Senate Bill (SB) 743 [Public Resources Code (PRC) §21099(d)] sets forth new guidelines for evaluating project
-use
residential, or employment center project on an infill site within a transit priority area (TPA) shall not be considered
significant impacts on the en -
planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or
site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the
intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the
project located on property zoned for commercial uses with a floor area ratio of no less than 0.75 and that is located
has been previously developed, or on a vacant site where at least 75% of the perimeter of the site adjoins, or is
separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses. This
state law supersedes the aesthetic impact thresholds in the 2019 CEQA Guidelines, including those established for
aesthetics, obstruction of views, shading, and nighttime illumination.
All development on the Project site is within a TPA due to its proximity to the Metro Gold Line Stop (0.5-mile
northeast), as well as the intersection of the Metro and Foothill Transit bus routes, which have a frequency service
interval of 15 minutes or less during the morning and afternoon peak commute periods (0.25-mile east). The
proposed Project refers specifically to the hotel development (i.e., the remodel of the existing Building C and the
construction of Building D) and associated surface parking/pedestrian improvements, which are within 0.5-mile of
a major transit stop and thus, within the boundaries of the TPA (SCAG 2019). As explained in Section 2.2.1, On-Site
Land Uses, the Project site is zoned General Commercial (C-G) with a Downtown Overlay and, as such, meets the
rking impacts would not be considered
significant impacts pursuant to PRC Section 21099(d).
2.2.3 Surrounding Land Uses
As shown on Figure 3, Surrounding Land Uses, the proposed Project site is surrounded by low density residential to
the north; commercial land uses to the east, recreational, commercial, and hotel uses to the south, and horse racing
land uses to the south and west. Nearby land uses to the south of the Project site include surface parking associated
with the Santa Anita Race Track, a new Le Méridien Hotel at the former Santa Anita Inn site (currently under
construction) with a new mixed-use project, and the Arcadia Community Regional Park. Further south is the Civic
Center Athletic Field Recreation Area, City of Arcadia City Hall, the Police Department and the Santa Anita Golf
Course. The Methodist Hospital, which is a not-for-profit regional institution, is located 0.3-mile south of the Project
site. Nearby land uses to the west include the Peppers Mexican Grill and Cantina located on the corner of San Juan
Drive and Colorado Place, and Santa Anita Race Track surface parking. Nearby land uses to the north consist
entirely of single-family residential uses. Nearby land uses to the east, along Huntington Drive, include Citizens
Business Bank and strip mall commercial with surface parking, Rusnak/Arcadia Mercedes-Benz Dealership, and
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There are three schools within the general vicinity of the Project site: Barnhart School, located approximately 0.15-
mile north of the Project site; Excelsior School, located approximately 0.16-mile east of the Project site; and First
Avenue Middle School, located approximately 0.37-mile southeast of the Project site. The closest parks to the
Project site are the Arcadia Community Regional Park, located directly southeast of the Project site, and Newcastle
Park, located 0.34-mile north of the Project site. The Los Angeles Arboretum and Botanical Gardens are located
approximately 0.8-mile west of the Project site, on the other side of the Santa Anita Racetrack.
Regional access to the Project site is provided via the I-210, which travels in an east-west direction and lies approximately
0.5-mile north of the Project site. The California Department of Transportation (Caltrans) classifies the I-210 as an Eligible
State Scenic Highway (not officially designated) where it traverses the City (Caltrans 2011). Local access to the Project
site is provided via Huntington Drive and Colorado Place, which intersect at the Project site. Colorado Place in the vicinity
of the Project site is Historic Route 66. There are no existing bicycle lanes on Huntington Drive or Colorado Place near
the Project site; however, public sidewalks abutting the Project site on Colorado Place, San Rafael Road and San Juan
Drive provide pedestrian access to the Project site and surrounding land uses. Metro bus line no. 79 and Foothill Transit
Line no. 187 have bus stops located along Huntington Boulevard in the vicinity of the Project site.
2.3 Project Description
2.3.1 Hotel Indigo
As previously described, the approximately 4.59-acre Project site is currently located at 125 West Huntington Drive
and 175 Colorado Place. As part of the Project, the hotel will receive a new address (123 W. Huntington Drive),
which will replace the 175 Colorado Place address. The Project site includes two recently constructed medical office
buildings and parking garage, one general office building, and surface parking. As shown on Figure 4a, Site Plan,
Building A, Building B, the northwestern surface parking lot, and the existing parking structure would be left as is
and protected in place during construction of the proposed Project. The proposed Project would only redevelop the
eastern portion of the site with the proposed Hotel Indigo (Buildings C and D), as well as surface parking and
sidewalk/pedestrian improvements. Figure 4b, Enlarged Site Plan, identifies the portion of the Project site that
would remain and the portion of the Project site that would be redeveloped. Figure 4c, Building Perspectives,
provides various depictions of the proposed structures and architectural details.
Building C is the existing Worley Parsons office building, which would be remodeled to allow for 76,754 sf of hotel
and appurtenant uses. Building C would be remodeled, as follows: the first floor would be renovated to include a
lobby/ lounge, restaurant, kitchen, fitness room, management offices, meeting rooms, and banquet hall space; the
second and third floors would be remodeled to accommodate 90 hotel rooms. Details of the proposed interior
changes to Building C are described in Table 2, Hotel Building Components, below. The façade of Building C would
be comprised primarily of aluminum and glass with stucco in neutral colors (e.g., grey, tan, olive green). As shown
on Figure 5a, Building C Elevations, Building C would include a centrally located exterior, architectural projection,
and would be approximately above average grade at its tallest point.
Building D is a new, 61,538 sf, five-story building on the southeastern portion of the Project site. Building D would
serve as the hotel annex building and includes the hotel spa, café, outdoor patios and an additional 75 hotel rooms.
Details of the proposed interior of Building D are described in Table 2, under Project Details below. The façade of
Building D would be comprised of white stucco with neutral-colored (e.g., grey, tan, olive green) accents. Building D
would include aluminum and glass design features with large windows fronting each side of the building. As shown
on Figure 5b, Building D Elevations, Building D would include architectural projections of various heights, and would
be in height above average grade at its tallest point.
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Given that Building A and Building B would not be altered, for the purpose of this documen
specifically to the hotel development (i.e., the remodel of the existing Building C and the construction of Building D)
and associated surface parking/pedestrian improvements. The proposed Project includes outdoor garden
amenities, including a swimming pool, bike lockers, and approximately 12,212 sf of landscaping, encompassing
13.5% 2 shows the proposed floor-by-floor uses for Building C and Building D.
Table 2. Hotel Building Components
Building/Floor Project Details Total Size (Square feet)
Building C 76,754
Basement Maintenance area, electrical room, laundry room and employee
break room
2,726
1st Floor Lobby, lounge, banquet and meeting rooms, gym, restaurant, dining
room and 11 guest rooms
24,664
2nd Floor 39 guest rooms and waiting area 24,870
3rd Floor 40 guest rooms, waiting area, executive lounge and balcony 24,494
Building D 61,538
1st Floor Hotel spa, banquet rooms. Kitchen, and lobby 14,414
2nd Floor Patio, café, waiting area and 20 guest rooms 13,124
3rd Floor 20 guest rooms and waiting area 12,836
4th Floor 20 guest rooms and waiting area 12,849
5th Floor 15 guest rooms and waiting area 8,315
Source: Project Site Plans
2.3.2 Parking and Pedestrian Improvements
Development Code section 9103.07.060, the proposed Project would be required to provide 471
parking spaces. On-site parking provided by the Project would include 482 stalls; four loading parking zones, 95
surface parking spaces and 387 spaces within the three-level parking garage. The Project would also include 30
bike racks and 24 bike lockers, 38 fuel-efficient vehicle parking spaces and 15 electric vehicle parking spaces.
Details of the proposed parking are shown, in part, in Figure 4b and are as follows:
The existing parking structure, which comprises 387 parking spaces, including 52 fuel efficient spaces and
23 Americans with Disabilities Act (ADA) spaces would be left as is.
The 95 surface parking spaces would be dispersed throughout the Project site as follows:
o 24 parking spaces would remain on the northwestern corner of the Project site
o 71 parking spaces, including 15 electric vehicle parking spaces, four loading spaces and eight (six
regular and two van accessible) ADA compliant parking spaces would be dispersed throughout the
remaining portion of the northeastern surface lot.
The proposed bike racks would be located adjacent to the circular arrival/drop off zone and in the
northeastern parking lot, adjacent to San Rafael Road.
The proposed bike lockers would be placed immediately north of Building C, adjacent to the new circular
arrival/drop-off zone.
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2.3.3 Landscape Improvements
As shown in Figure 6, Preliminary Landscape Plan, the proposed Project would include approximately 12,212 sf of
landscaping improvements, including 690 sf of planting on the second floor deck and 175 sf of planting on the
sixth floor deck. Seven existing trees (four within the public sidewalk fronting San Rafael Road and three abutting
(see Appendix B). The remaining
Development Code, Section 9702.01, no protected tree shall be
removed or have its protected zone encroached upon without the approval of a Tree Permit.
Landscaping proposed under the Project would include groundcover, shrubbery, trees and turf/lawn areas, as well
as colored concrete paving with sandblast finish in neutral colors (e.g., mesa bluff, beige and grey). The proposed
swimming pool would be located between Building C and Building D and would be landscaped with five 24-inch
diameter Marina Strawberry Trees and paved with colored concrete with sandblasted finish in mesa bluff. The
northeastern surface parking lot would be landscaped with 36-inch diameter London Plane trees. Additionally,
seven vegetated bioswales would be constructed around the Project site in order to reduce pollution in any potential
surface water runoff. The southern perimeter of the Project site, fronting Huntington Drive, would be landscaped
with 36-inch diameter London Plane Trees, 36-inch diameter Naked Coral Trees, and 24-inch diameter Marina
Strawberry Trees.
2.3.4 Off-Site Improvements
The proposed Project would not include any off-site improvements.
2.3.5 Short-Term Construction Activities
As shown on Figure 4b, demolition would include the removal of the existing vegetation, including removal of 34
trees on site (the four City street trees in the sidewalk between the Project site and San Rafael Road would be
protected in place). Additionally, demolition would include the removal of the surface parking, two light poles, and
two enclosed trash enclosures dispersed throughout the northeastern parking lot to accommodate the new Building
D and associated parking and landscaping. Project demolition activities would begin in approximately the first
quarter of 2020, and construction activities would last approximately 20 months. Construction activities would
occur in one phase, with the occupancy of Building C expected in the first quarter of 2021 and the occupancy of
Building D occurring in the fourth quarter of 2021. Construction activities could take place Monday to Friday from
7:00 a.m. to 6:00 p.m. and Saturday from 8:00 a.m. to 5:00 p.m.
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2.4 Discretionary Actions
This IS/MND is intended to serve as the primary environmental document pursuant to CEQA for actions associated
with the Hotel Indigo, including discretionary approvals required to implement the Project. In addition, this IS/MND
is the primary reference document for the formulation and implementation of the Mitigation Monitoring and
Reporting Program for the Project, in accordance with Section 15097 of the State CEQA Guidelines. The City of
Arcadia may approve the IS/MND if it finds, on the basis of the whole Project record, that there is no substantial
evidence that the Project would have a significant effect on the environment.
review and approval include, but are not limited to:
1. Adoption of the IS/MND
2. Approval of a Height Variance within the Downtown Overlay Zone.
3. Approval of a CUP for the construction of a hotel in a Commercial Zone.
4. Approval of a Protected Tree Permit (If any protected trees are proposed for removal or have their protection
zone encroached into).
5. Site Plan and Design Review
6. Architectural Design Review
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3 Environmental Impact Analysis
3.1 Aesthetics
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista?
b) Substantially damage scenic resources including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of
the site and its surroundings? (Public views are
those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area,
would the project conflict with applicable zoning and
other regulations governing scenic quality?
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views
in the area?
a) Would the project have a substantial adverse effect on a scenic vista?
Less Than Significant Impact. Scenic vistas generally refer to views of expansive open space areas or other
natural features, such as mountains, undeveloped hillsides, large natural water bodies, or coastlines. Less
commonly, certain urban settings or features, such as a striking or renowned skyline, may also represent a
scenic vista. Scenic vistas generally refer to views that are accessible from public vantage points, such as
d scenic
vistas in the City. However, views of the San Gabriel Mountains to the north are readily available and provide
an aesthetic backdrop for the City (City of Arcadia 2010a). Views of the San Gabriel Mountains are generally
south roadway corridors, which are often obscured by distance, street trees,
freeway/light rail overpasses, and other urban features, such as utility lines, buildings, and signage. Potential
effects of the proposed Project on public views of the San Gabriel Mountains are characterized below.
Colorado Place: Colorado Place is a generally east-west running arterial that borders the southern
perimeter of the Project site. Views of the San Gabriel Mountains to the north from Colorado Place
adjacent to the Project site are limited and generally obstructed by existing building massing and
streetscaping, including trees and utility poles. Building C would require interior renovations only and
would not alter the existing public views of the mountains. The proposed Project includes the
construction of a new, 61,538 sf hotel annex building (Building D). With approval of a height variance,
Building D would be in height above average grade, which would be approximately one story
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taller than surrounding multistory buildings, including Building C, which is approximately 44 in
height above average grade at its tallest point. Given this, existing views of the San Gabriel Mountains
to the north would be further obstructed by the proposed Building D.
San Juan Drive: San Juan Drive is a small, local connector street that runs in a southwest-northeast
direction and connects Colorado Place to Santa Cruz Road. Existing views of the San Gabriel Mountains
from the San Juan Drive right-of-way (ROW) are partially obscured by single-story residential
development and streetscaping, including trees and utility poles. The proposed Project would not
include any construction in the San Juan Drive ROW and upon operation, would not result in any
changes to the existing views of the San Gabriel Mountains from San Juan Drive.
San Rafael Road: San Rafael Road is a small, local connector street that runs in a north-south direction
and connects Huntington Drive to San Antonio Road and San Luis Rey Road. Existing views of the San
Gabriel Mountains from the San Rafael Road ROW are predominantly clear with only partial obstructions
from existing single-story residential development and streetscaping, including trees and utility poles to
the north. The proposed Project would not include any construction in the San Rafael Road ROW and
upon operation, would not result in any changes to the existing views of the San Gabriel Mountains.
Arcadia Community Regional Park: The Arcadia Community Regional Park is a large public park that is
maintained by the Los Angeles County Department of Parks and Recreation. The park is located
southeast of the proposed Project site, across Huntington Drive. Existing views of the San Gabriel
Mountains from the Arcadia Community Regional Park are predominantly clear with only partial
obstructions from the existing two- and three-story buildings on the Project site. In general, the visual
quality of views of the San Gabriel Mountains from the Arcadia Community Regional Park is moderate
due to the presence of interceding streetscaping, including trees and utility poles to the north. The
proposed Project includes the construction of a new, 61,538 sf hotel annex building (Building D). With
approval of a height variance, Building D would be in height above average grade, which would
be approximately one story taller than surrounding multistory buildings, including Building C, which is
approximately in height above average grade at its tallest point. Given this, existing views of the
San Gabriel Mountains to the north would be further obstructed by the proposed Project.
In summary, views of the San Gabriel Mountains are available from one or more public viewpoints, including
roadways and the Arcadia Community Regional Park, surrounding the Project site. However, these existing
views are limited due to obstructions typical of urban development, such as utility poles, street trees, and
commercial and residential development. The proposed Project would introduce new development to the
Project site, which would reach a height of above average grade. The new Building D would have
the potential to further obstruct existing views of the San Gabriel Mountains beyond the existing conditions
from motorists and pedestrians along Colorado Place.
However, motorists and pedestrians are transient, and their views of the mountains are fleeting and would
only briefly be affected by Building D as they pass the site. Colorado Place is not a north-south corridor in
the vicinity of the Project site; therefore, longer-term views of the mountains for pedestrians and motorists
would not be affected. Additionally, views of the mountains from recreational visitors to the Arcadia
Community Regional Park would not be affected by the proposed Project because existing views are already
limited by existing development. Partial obstructions of these views of the San Gabriel Mountains are
prevalent throughout the City and the region and are part of the existing condition of the visual environment.
As such, the introduction of a new structure on the Project site would not have a substantial adverse effect
on a scenic vista of the San Gabriel Mountains. Additionally, as stated in Section 2.2.2, the proposed Project
is within a TPA and, as such, ing impacts would not
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be considered significant impacts pursuant to PRC Section 21099(d). The proposed Project would have a
less than significant impact on scenic vistas. No mitigation is required.
b) Would the project substantially damage scenic resources including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
No Impact. The proposed Project is not within the immediate vicinity of a state designated scenic highway).
The California Department of Transportation (Caltrans) classifies the I-210 as an Eligible State Scenic
Highway (not officially designated) where it traverses the City (Caltrans 2011). However, the Project site is
located 0.5-mile south of the I-210 and would not be visible from the highway. Additionally, as stated in
Section 2.2.2, the proposed Project is within a TPA and, as such,
aesthetic and parking impacts would not be considered significant impacts pursuant to PRC Section
21099(d). As such, the proposed Project would have no impact on any scenic resources within a state
scenic highway. No mitigation is required.
c) In non-urbanized areas, would the project substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are experienced from publicly
accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable
zoning and other regulations governing scenic quality?
Less Than Significant Impact. The City has undertaken an update to the Design Guidelines for various
development types, which was made available for public review and comment in June 2019. The Draft
Commercial/Mixed Use Design Guidelines provide direction to project applicants about site planning and
building placement; public and private open spaces; pedestrian and vehicular access; and massing and
scale. Other topics addressed include guidelines related to architectural style, awnings, rooflines,
articulation, windows/doors, colors/materials, landscaping, equipment and service areas, site furnishing,
lighting, and public art. The guidelines are intended as a reference point for a common understanding of
the minimum qualitative design expectations within the City.
The General Plan policies specific to the aesthetic character and quality of development within the City, as
well as the applicable City Municipal Code requirements that affect aesthetic character are listed and
analyzed in Table 3, General Plan, Development Code, and Municipal Code Consistency Analysis.
Table 3. General Plan, Development Code, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
General Plan
Policy LU-1.1: Promote new infill and
redevelopment projects that are
compatible with surrounding existing
uses.
Consistent. The proposed Project would be an infill development project.
The proposed Project would be consistent with the designated C-G zone
with City approval of a CUP (to allow for hotel uses is a commercial zone)
and approval of a height variance (to allow for the construction of the
hotel annex building, which would exceed the 40-foot height requirement
for the C-G zone). The proposed Project would be under the allowable
FAR (of 1.0) for the Downtown Overlay C-G zone and would adhere to the
minimum setbacks required under Section 9102.03.030. As such, the
compatible with surrounding existing uses.
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Table 3. General Plan, Development Code, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy LU-1.2: Promote new uses of land
that provide diverse economic, social,
and cultural opportunities, and that
reinforce the characteristics that make
Arcadia a desirable place to live.
Consistent. The proposed Project is a hotel development project, which,
upon completion would provide hospitality amenities to the general
public, including hotel, restaurant, and venue amenities. The proposed
Project would contribute to the economic diversity of the City by providing
a commercial amenity that can support visitors to the downtown areas of
Arcadia, as well as surrounding communities. The Project would be
Commercial/Mixed Use Design
Guidelines to ensure the structures c
aesthetics and community character.
Policy LU-1.4. Encourage the gradual
redevelopment of incompatible,
ineffective, and/or undesirable land
uses.
Consistent. The proposed Project would redevelop an existing structure
that has been underutilized and/or vacant for years, thereby eliminating
an ineffective land use in the downtown area.
Policy LU-2.1: Ensure that trees planned
in the public right-of-way continue to be
well maintained where they exist, are
planted in areas where they are
currently lacking, and encourage
replacement of undesirable tree species
in public right-of-ways.
Consistent. The proposed Project would include approximately 12,212 sf
of new landscaping, which would include trees throughout the Project
site. The Project would adhere to the requirements of Chapter 7, Tree
sycamores, and mature trees as significant aesthetic and ecological
resources that benefit current and future residents of the City. The
proposed Project would require the removal of 34 ornamental trees, but
would protect the four City trees located in the sidewalk between the
Project site and San Rafael Road in place during construction. The
proposed Landscape Plan, illustrated in Figure 6, would be subject to
City review and approval.
Policy LU-2.2. Emphasize the use of
public spaces and design that are
oriented toward the pedestrian and use
of transit throughout the community.
Consistent. Huntington Drive is identified in the General Plan as a major
corridor with large mature trees, and a secondary gateway opportunity is
identified near the Project site. The proposed Project has frontage on
Huntington Drive, which encourage pedestrian connectivity to the Gold
Line Station, which is within 0.5-mile of the Project site.
Policy LU-2.6: Ensure the aesthetic
quality and pedestrian orientation of the
implementing the recommendations of
this Community Design section, as well
as the Architectural Design Guidelines
for commercial and industrial properties.
Consistent. The proposed Project would be required to comply with the
Commercial/Mixed Use Design Guidelines. Project plans would be
Policy LU-6.1: Encourage all new
commercial development, through the
use of entitlement incentives and/or
requirements, to provide public
gathering spaces and pedestrian
facilities and connections.
Consistent. The proposed Project is a hotel development project, which,
upon completion would provide hospitality amenities to the general
public, including hotel, restaurant, and venue amenities. The proposed
Project has frontage on Huntington Drive, which encourage pedestrian
connectivity to the Gold Line Station, which is within 0.5-mile of the
Project site. Additionally, the proposed Project includes a Landscaping
Plan (see Figure 6) that includes paved, well lit, and landscaped on-site
pedestrian amenities that front onto Huntington Drive.
Policy LU-6.4: Encourage design
approaches that create a cohesive,
vibrant look and that minimize the
appearance of expansive parking lots on
major commercial corridors for new or
redeveloped uses.
Consistent. The proposed Project would redevelop the existing expansive
surface parking lot with a new hotel annex building, landscaping, and
upgraded parking (including parking for fuel-efficient vehicles). The
proposed parking would remain to the rear of the property and would not
front the primary pedestrian corridor of Huntington Drive. As such, views
of the proposed parking would be minimized.
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Table 3. General Plan, Development Code, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy LU-6.6: Develop landscaping that
efficient landscape ordinance and
façade standards for commercial
properties, and require all new
development to adhere to them.
Encourage the improvement of rundown
buildings by offering entitlement
incentives.
Consistent. The proposed Project would include approximately 12,212 sf
of new landscaping, which would include trees throughout the Project
site. The Project would adhere to the requirements of Chapter 7, Tree
, which recognizes oaks,
sycamores, and mature trees as significant aesthetic and ecological
resources that benefit current and future residents of the City. The
proposed Project would require the removal of 34 ornamental trees, but
would protect the four City trees located in the sidewalk between the
Project site and San Rafael Road in place during construction.
Additionally, the proposed Landscape Plan, illustrated in Figure 6, would
be subject to City review and approval. The proposed Project would re-
design the interior of an existing underutilized building, thereby resulting
in improvements to the current condition.
Policy LU-6.11: Provide mature street
trees, continuous landscaping (that
includes drought-tolerant plants), and
pedestrian amenities along corridors
and within districts to create a more
visually pleasing and cohesive
streetscape.
Consistent. The proposed Project does not require the removal of any
street trees. New trees and landscaping would be planted in accordance
Water Efficient Landscaping Ordinance.
Policy LU-6.12: Create pedestrian
connections along corridors and districts
that link surrounding neighborhoods and
provide a more pedestrian-friendly
atmosphere.
Consistent. The proposed Project would redevelop the existing
expansive surface parking lot with a new hotel annex building,
landscaping, and upgraded parking. The proposed parking would
remain to the rear of the property and would not front the primary
pedestrian corridor of Huntington Drive. The proposed Project has
frontage on Huntington Drive, which encourage pedestrian
connectivity to the Gold Line Station, which is within 0.5-mile of the
Project site.
Municipal Code
Section 9701, Tree Preservation Consistent. The Project would adhere to the requirements of Chapter 7,
sycamores, and mature trees as significant aesthetic and ecological
resources that benefit current and future residents of the City. The
proposed Project would require the removal of 34 ornamental trees, but
would protect the four City trees located in the sidewalk between the
Project site and San Rafael Road in place during construction.
Additionally, the proposed Landscape Plan, illustrated in Figure 6, would
be subject to City review and approval.
Development Code
Section 9102.03.020, Land Use
Regulations and Allowable Uses
Consistent. The proposed Project would be consistent with the
designated C-G zone with City approval of a CUP (to allow for hotel uses
is a commercial zone) and approval of a height variance (to allow for the
construction of the hotel annex building, which would exceed the 40-foot
height requirement for the C-G zone). The proposed Project would be
under the allowable FAR (of 1.0) for the Downtown Overlay C-G zone and
would adhere to the minimum setbacks required under Section
9102.03.030.
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Table 3. General Plan, Development Code, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Section 9103.01.120, Exterior Lighting Consistent. The proposed Project would be required to comply with the
exterior lighting standards to balance safety and security needs for
lighting that also avoids light trespass (spill light), light pollution, and
glare onto surrounding properties.
Section 9103.11.070, Permanent Signs
by Zone Locations and Allowed Sign
Area.
Consistent. The proposed Project would be required to comply with
-G zone. The Project would
Commercial/Mixed Use
Design Guidelines to ensure the structures complim
design aesthetics and community character.
Section 9103.09.040 (C), Landscape
Requirements for Commercial, Mixed
Use, and Industrial Zones
Consistent. The proposed Project would include approximately 12,212 sf
of new landscaping, which would include shrubs, groundcover, trees, and
turf throughout setbacks, parkways, open areas, plazas, paseos, and
non-work areas that are visible from a public street/alley or from a
parking lot available to the general public. The proposed Landscape
Plan, illustrated in Figure 6, would be subject to City review and approval.
Section 9107.19, Site Plan and Design
Review
Consistent.
Commercial/Mixed Use Design Guidelines to ensure the structures
.
As described above in Table 3, the proposed Project would be consistent with th
policies, Development Code, and Municipal Code Sections that pertain to the preservation of the aesthetic
character of the City. With approval of a CUP and a Height Variance, the proposed Project would be in visual
agreement with the
designations. Furthermore, proposed Project design would add architectural and landscape features that
would improve the visual quality of the Project site and the Project area as a whole compared to existing
conditions. Additionally, as stated in Section 2.2.2, the proposed Project is within a TPA and, as such, the
pursuant to PRC Section 21099(d). For these reasons, the proposed Project would not conflict with
applicable zoning and/or other regulations governing scenic quality, and impacts would be less than
significant. No mitigation is required.
d) Would the project create a new source of substantial light or glare which would adversely affect day or
nighttime views in the area?
Less Than Significant Impact. Lighting is of most concern when it may spill over or trespass from a Project
site onto sensitive surrounding land uses, such as residential properties, resulting in a potential nuisance.
The proposed Project is located within the Downtown Overlay Zone and is surrounded by low density
residential to the north; commercial land uses to the east, recreational, commercial, and hotel land uses
to the south, and horse racing land uses to the south and west. Existing sources of daytime and nighttime
light include streetlights, business identification signs and lit windows. Any lighting that would be
implemented as part of th Development Code, Section
9103.01.120, which establishes the standards for exterior lighting in the City.1 In summary, the standards
1 City of Arcadia Development Code. Article IX: Division and Use of Land, Chapter 1, Section 9103.01.120 - Exterior Lighting.
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require: lighting be shielded or recessed so that glare is contained within the property boundaries; lighting
be directed downward away from adjoining properties; lighting cannot illuminate more than 1.0 foot-candle
on any property within a residential zone; lighting must be appropriate in scale, intensity, and height; lighting
cannot be blinking/flashing or have high-intensity brightness; and fixtures must be full-cutoff fixtures to
avoid glare and up-light.
Similarly, extraneous glare associated with the use of highly reflective building materials (glass, steel etc.)
could result in nuisance to surrounding land uses. The proposed Project would include some reflective
building materials such as glass and steel; however, these materials would be utilized in a manner
consistent with Development Code, Section 9103.10.070, which requires that any proposed land use or
activity producing glare be shielded so that glare is not perceptible beyond the property line.2 Additionally,
as stated in Section 2.2.2, the proposed Project is within a TPA and, as such,
on aesthetic and parking impacts would not be considered significant impacts pursuant to PRC Section
21099(d). As such, and with compliance with City regulations, the proposed Project would have a less than
significant impact regarding the creation of a new source of substantial light or glare, which would adversely
affect day or nighttime views in the area. No mitigation is required.
3.2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
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
Department 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
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?
b) Conflict with existing zoning for agricultural use, or a
Williamson Act contract?
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))?
2 City of Arcadia Development Code. Article IX: Division and Use of Land, Chapter 1, Section 9103.13.070 - Light and Glare.
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Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
d) Result in the loss of forest land or conversion of forest
land to non-forest use?
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?
a) Would the project 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?
No Impact.
spaces (DOC 2018). The Agricultural Land Mitigation Program, California Farmland Conservancy Program,
Williamson Act Contracts, and Farmland Mapping and Monitoring Program are all farmland conservations
programs currently in effect and administered by the DLRP (DOC DLRP 2018). The City of Arcadia does not
contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown
on the maps prepared pursuant to the Farmland Mapping and Monitoring Program. As such, there are no
designated farmlands in or near the Project site (DOC DLRP 2016). Also, there are no existing or ongoing
agricultural activities on or near the Project site. The City is fully developed with urban land uses and there
are no existing forestlands, or timberland production zones within the City (City of Arcadia 2010a). As such,
the Project would not result in the conversion of any farmland to non-agricultural use.
b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
No Impact. The Project site is located in an urban area on a site that is fully developed with buildings and
asphalt paving. The Project site is designated Commercial (C) and zoned General Commercial (C-G) with a
Downtown Overlay. The C-G Zone is intended to provide areas for the development of retail and service
uses, offices, restaurants, public uses, and similar and compatible uses (City of Arcadia 2016a). There are
no agricultural land use zones or lands under Williamson Act contracts on or near the Project site under
existing conditions (DOC DLRP 2017). Given this, the proposed Project would not conflict with existing
zoning for agricultural use or with a Williamson Act contract.
c) Would the project 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))?
No Impact. As discussed in Section 3.2(b) above, the C-G Zone applicable to the Project site provides for
the development of retail and service uses, offices, restaurants, public uses, and similar and compatible
uses (City of Arcadia 2016a). The Project site is located approximately 2.6 miles south of the Angeles
National Forest and, as such, would not conflict with existing zoning for, or cause rezoning of, forest land,
timberland, or timberland zoned Timberland Production.
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d) Would the project result in the loss of forest land or conversion of forest land to non-forest use?
No Impact. As stated above in Section 3.2(b), the Project site is an urban developed land and there is no
forest land in the immediate vicinity of the Project site. The Project site is located approximately 2.6 miles
south of the Angeles National Forest and, as such, would not result in the loss of forest land or the
conversion of forest land to non-forest use.
e) Would the project 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?
No Impact. As stated above in Section 3.2(c) and (d), the Project site is located in an urban area, and is
surrounded by developed land uses and there is no farmland or forest land on or near the Project site. The
proposed Project would include the conversion of an existing building into a hotel and the construction of
a hotel annex building, neither of which entail land uses that 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.
3.3 Air Quality
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Where available, the significance criteria established by the applicable air quality management district 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?
b) 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?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
a) Would the project conflict with or obstruct implementation of the applicable air quality plan?
Less Than Significant Impact. The proposed Project site is located in the City of Arcadia within the South
Coast Air Basin (SCAB), which includes the non-desert portions of Los Angeles, Riverside, and San
Bernardino Counties, and all of Orange County, and is within the jurisdictional boundaries of the South
Management Plan (AQMP), which is a comprehensive document outlining an air pollution control program
for attaining the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality
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Standards (NAAQS). The most recently adopted AQMP for the SCAB is the 2016 AQMP (SCAQMD 2017).
The 2016 AQMP focuses on available, proven, and cost-effective alternatives to traditional air quality
strategies while seeking to achieve multiple goals in partnership with other entities seeking to promote
reductions in greenhouse gases (GHGs) and toxic risk, as well as efficiencies in energy use, transportation,
and goods movement (SCAQMD 2017).
The purpose of a consistency finding with regard to the AQMP is to determine if a project is consistent with
ability to comply with federal and state air quality standards. The SCAQMD has established criteria for
determining consistency with the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3 of the
SCAQMD CEQA Air Quality Handbook. These criteria are as follows (SCAQMD 1993):
Consistency Criterion No. 1: Whether the project would result in an increase in the frequency or severity of
existing air quality violations, cause or contribute to new violations, or delay timely attainment of the
ambient air quality standards or interim emission reductions in the AQMP.
Consistency Criterion No. 2: Whether the project would exceed the assumptions in the AQMP or increments
based on the year of project buildout and phase.
To address the first criterion, Project-generated criteria air pollutant emissions have been estimated and
analyzed for significance and are addressed under Section 3.3(b) below. Detailed results of this analysis
are included in Appendix A, Air Quality and Greenhouse Gas Calculations, of this IS/MND. As presented in
Section 3.3(b), construction and operation of the proposed Project would not generate criteria air pollutant
the Project would therefore be consistent with
Criterion No. 1.
The second criterion regarding the potential of the proposed Project to exceed the assumptions in the AQMP
or increments based on the year of Project buildout and phase is primarily assessed by determining
e population
growth. In general, projects are considered consistent with, and not in conflict with or obstructing
implementation of, the AQMP if the growth they produce in socioeconomic factors is consistent with the
underlying regional plans used to develop the AQMP (SCAQMD 1993). The SCAQMD primarily uses
demographic growth forecasts for various socioeconomic categories (e.g., population, housing, and
employment by industry) developed by the Southern California Association of Governments (SCAG) for its
2016 2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (SCAG 2016).
SCAQMD uses this document, which is based in large part on general plans for cities and counties in the
SCAB, to develop the AQMP emissions inventory (SCAQMD 2017).3 The SCAG RTP/SCS, and associated
Regional Growth Forecast, are generally consistent with the local plans; therefore, the 2016 AQMP is
generally consistent with the Arcadia General Plan.
3 Information necessary to produce the emissions inventory for the SCAB is obtained from the SCAQMD and other governmental
agencies, including the California Air Resources Board, Caltrans, and SCAG. Each of these agencies is responsible for collecting
data (e.g., industry growth factors, socioeconomic projections, travel activity levels, emission factors, emission speciation profile,
and emissions) and developing methodologies (e.g., model and demographic forecast improvements) required to generate a
comprehensive emissions inventory. SCAG incorporates these data into its Travel Demand Model for estimating/projecting vehicle
activities projections in their 2016 2040 Regional
Transportation Plan/Sustainable Communities Strategy are integrated in the 2016 AQMP (SCAQMD 2017).
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As discussed in Section 2.2, Existing Conditions and Setting, of this IS/MND, the proposed Project site is
Commercial (C-G) with a Downtown Overlay. The proposed Project would be compatible with the C-G Zone
and Downtown
to the City prior to Project approval. Additionally, Project approval would be subject to a CUP, which is
required in order to develop hotel land uses in the C-G Zone, and Site Plan and Design Review. The proposed
uses for the Project site are consistent with the existing land use designation for the Project site, and no
amendments to the General Plan would be required.
The Project site is well-located to encourage the use of public transit and active transportation modes, as
it is located within 0.5-which provides light rail service into Downtown
Los Angeles and throughout Los Angeles County. The site is in close proximity to restaurants, recreational
centers, public/civic, and other businesses along Huntington Drive, which facilitates pedestrian and bicycle
trips along these corridors. Local public transit is provided along Huntington Drive. Additionally, the Foothill
Transit bus line No. 187 is directly in front of the Project site, and the Metro bus lines Nos. 78/79/378 are
located at the intersection of Huntington Drive and Santa Anita Avenue approximately 0.25-mile east of the
Project site. Therefore, the proposed P imity to the Gold Line Station could result in a reduction
of miles traveled and associated air emissions from the visitor trips to local and regional destinations.
Accordingly, the proposed Project is consistent with the SCAG RTP/SCS forecasts used in the SCAQMD
AQMP development.
In summary, based on the considerations presented for the two criteria, impacts relating to the proposed
less than
significant. No mitigation is required.
b) Would the project 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?
Less Than Significant Impact. Air pollution is largely a cumulative impact. The nonattainment status of
regional pollutants is a result of past and present development, and the SCAQMD develops and implements
plans for future attainment of ambient air quality standards. Based on these considerations, project-level
emissions would exceed the SCAQMD significance thresholds, it would be considered to have a
cumulatively considerable contribution. Conversely, projects that do not exceed the project-specific
thresholds are generally not considered to be cumulatively significant (SCAQMD 2003).
A quantitative analysis was conducted to determine whether proposed construction activities would result
in a cumulatively considerable net increase in emissions of criteria air pollutants for which the SCAB is
designated as nonattainment under the NAAQS or CAAQS. Criteria air pollutants include ozone (O3), nitrogen
dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), particulate matter with an aerodynamic diameter
less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter less than or
equal to 2.5 microns (PM2.5), and lead. Pollutants that are evaluated herein include volatile organic
compounds (VOCs) and oxides of nitrogen (NOx), which are important because they are precursors to O 3,
as well as CO, sulfur oxides (SOx), PM10, and PM2.5.
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Regarding NAAQS and CAAQS attainment status,4 the SCAB is designated as a nonattainment area for
national and California O3 and PM2.5 standards (CARB 2018; EPA 2018). The SCAB is designated as a
nonattainment area for California PM10 standards; however, it is designated as an attainment area for
national PM10 standards. The SCAB nonattainment status of O3, PM10, and PM2.5 standards is the result of
cumulative emissions from various sources of air pollutants and their precursors within the SCAB, including
motor vehicles, off-road equipment, and commercial and industrial facilities. The SCAB is designated as an
attainment area for national and California NO 2, CO, and SO2 standards. Although the SCAB has been
designated as partial nonattainment (Los Angeles County) for the federal rolling 3-month average lead
standard, it is designated attainment for the state lead standard.5
The proposed Project would result in emissions of criteria air pollutants for which the California Air
Resources Board (CARB) and U.S. Environmental Protection Agency (EPA) have adopted ambient air quality
standards (i.e., the NAAQS and CAAQS). Projects that emit these pollutants have the potential to cause, or
contribute to, violations of these standards. The SCAQMD CEQA Air Quality Significance Thresholds, as
revised in March 2015, set forth quantitative emission significance thresholds for criteria air pollutants,
which, if exceeded, would indicate the potential for a project to contribute to violations of the NAAQS or
CAAQS. Table 4 lists the SCAQMD Air Quality Significance Thresholds (SCAQMD 2015).
Table 4. SCAQMD Air Quality Significance Thresholds
Criteria Pollutants Mass Daily Thresholds
Pollutant Construction (Pounds per Day) Operations (Pounds per Day)
VOC 75 55
NOx 100 55
CO 550 550
SOx 150 150
PM10 150 150
PM2.5 55 55
Leada 3 3
Toxic Air Contaminants (TACs) and Odor Thresholds
TACsb
(including carcinogens and
noncarcinogens)
Maximum incremental cancer risk 10 in 1 million
Cancer Burden > 0.5 excess cancer cases (in areas > 1 in 1 million)
Chronic and Acute Hazard index 1.0 (project increment)
Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402
Source: SCAQMD 2015.
Notes: SCAQMD = South Coast Air Quality Management District; VOC = volatile organic compound; NO x = oxides of nitrogen; CO =
carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; TAC = toxic air
contaminant; NO2 = nitrogen dioxide; ppm = parts per million; g/m3 = micrograms per cubic meter
a The phase-out of leaded gasoline started in 1976. Since gasoline no longer contains lead, the proposed Project is not anticipated
to result in impacts related to lead; therefore, it is not discussed in this analysis.
b TACs include carcinogens and non-carcinogens.
4 An area is designated as in attainment when it is in compliance with the NAAQS and/or the CAAQS. The NAAQS and CAAQS are
set by the Environmental Protection Agency (EPA) and California Air Resources Board (CARB), respectively, for the maximum level
of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare.
Attainment = meets the standards; attainment/maintenance = achieve the standards after a nonattainment designation;
nonattainment = does not meet the standards.
5 Re-designation of the lead NAAQS designation to attainment for the Los Angeles County portion of the SCAB is expected based on
current monitoring data. The phase out of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is
not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis.
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A project would result in a substantial contribution to an existing air quality violation of the NAAQS or CAAQS
for O3, which is a nonattainment
exceed the SCAQMD VOC or NOx thresholds shown in Table 4. These emission-based thresholds for O3
i.e., the potential for
adverse O3 impacts to occur) because O3 itself is not emitted directly, and the effects of an individual
3 precursors (VOCs and NO x) on O3 levels in ambient air cannot be determined
through air quality models or other quantitative methods.
The following discussion quantitatively evaluates project-generated emissions and impacts that would result
from implementation of the proposed Project.
Construction Emissions. Construction of the proposed Project would result in the temporary addition of
pollutants to the local airshed caused by on-site sources (e.g., off-road construction equipment, soil
disturbance, VOC off-gassing from architectural coatings and asphalt pavement application) and off-site
sources (e.g., vendor trucks, haul trucks, and worker vehicle trips). Specifically, entrained dust results from
the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM 10
and PM2.5 emissions. Internal combustion engines used by construction equipment, haul trucks, vendor
trucks (i.e., delivery trucks), and worker vehicles would result in emissions of VOC, NO x, CO, PM10, and PM2.5.
Construction emissions can vary substantially from day to day depending on the level of activity; the specific
type of operation; and, for dust, the prevailing weather conditions.
Application of architectural coatings, such as exterior paint and other finishes, and application of asphalt
pavement would also produce VOC emissions. VOC off-gassing emissions result from evaporation of
solvents contained in surface coatings such as in paints and primers used during construction of the facility.
CalEEMod calculates the VOC evaporative emissions from application of surface coatings based on the VOC
emissions factor, the building square footage, and the assumed fraction of surface area.
The proposed Project would be required to comply with SCAQMD Rule 403 (SCAQMD 2015) to control dust
emissions generated during any dust-generating activities. Standard construction practices that would be
employed to reduce fugitive dust emissions include watering of the active dust areas up to two times per
day, depending on weather conditions.
Emissions from the construction phase of the proposed Project were estimated using the California
Emissions Estimator Model (CalEEMod) version 2016.3.2. For a conservative emission estimation,
construction is assumed to begin in May 1, 2020 and conclude in October of 2021. In the event actual
construction proceeds longer into year 2021, this analysis provides a conservative approach resulting in
slightly higher daily emissions and annual emissions. A detailed depiction of expected construction
schedules including information regarding phasing, equipment used during each phase, trucks, and
worker vehicles is provided in Appendix A of this IS/MND.
General construction equipment modeling assumptions are provided in Table 5, Construction Assumptions
for Air Quality Modeling. Default values for equipment mix, horsepower, and load factor provided in
CalEEMod were used for all construction equipment. It is anticipated that approximately 1,360 cubic yards
of fill material would be imported and no soils would be exported during construction. For the analysis, it
was generally assumed that heavy-duty construction equipment would be operating at the site 6 days per
week, including Saturday.
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Table 5. Construction Assumptions for Air Quality Modeling
Construction
Phase
One-Way Vehicle Trips Equipment Schedule
Average Daily
Trips Total
Haul
Truck
Trips Types Quantity
Usage
Hours Start Date Finish Date Workers
Vendor
Trucks
Demolition 14 0 185 Concrete/Industrial
Saw
1 8 5/1/2020 6/1/2020
Rubber-Tired Dozers 1 8
Tractors/Loaders/
Backhoes
3 8
Site Prep 8 0 0 Graders 1 8 6/2/2020 6/12/2020
Rubber-Tired Dozers 1 7
Tractors/Loaders/
Backhoes
1 8
Grading 8 0 170 Graders 1 6 6/13/2020 6/25/2020
Rubber-Tired Dozers 1 6
Tractors/Loaders/
Backhoes
1 7
Building
Construction
78 30 0 Cranes 1 6 6/26/2020 8/16/2021
Forklifts 1 6
Generator Sets 1 8
Tractors/Loaders/
Backhoes
1 6
Welders 3 8
Paving 8 0 0 Cement and Mortar
Mixers
1 6 8/17/2021 9/8/2021
Tractors/Loaders/
Backhoes
1 8
Pavers 1 6
Paving Equipment 1 8
Rollers 1 7
Architectural
Coating
16 0 0 Air Compressors 1 6 9/9/2021 10/1/2021
Source: Appendix A
Table 6, Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Unmitigated, shows the
estimated maximum daily construction emissions associated with the construction phase of the proposed
Project. As shown in Table 6, daily construction emissions would not exceed the SCAQMD significance
thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5 during Project construction. Therefore, construction
impacts of the proposed Project would be less than significant, and no mitigation measure is required.
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Table 6. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Unmitigated
Year
VOC NOx CO SOx PM10a PM2.5a
(pounds per day)
2020 2.54 22.99 17.44 0.04 3.52 2.11
2021 70.42 16.80 16.80 0.04 1.76 0.96
Maximum Daily Emissions 70.42 22.99 17.44 0.04 3.52 2.11
SCAQMD Threshold 75 100 550 150 150 55
Threshold exceeded? No No No No No No
Source: Appendix A; SCAQMD 2015.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District.
a These estimates reflect control of fugitive dust required by SCAQMD Rule 403, specifically, watering of active site areas two times
per day (SCAQMD 2005).
Operational Emissions. As described in Section 2.2, under the proposed Project, the existing 60,811 sf,
three-story office building (former Worley Parsons Building, referred to as Building C) would continue to
remain on the Project site, but would be redeveloped from the existing office use into a hotel. The previously
approved new Building 4, which proposed to be constructed as a general office building, has been
redesigned and is proposed for development as a hotel annex (Building D). To develop a net change in air
operation emissions, Building C has been modeled as an existing condition in CalEEMod and the resulting
emissions are subtracted from the emissions estimated for the proposed Project, which includes
remodeled Building C and new Building D and associated features.
Operation of the proposed Project would produce VOC, NO x, CO, SOx, PM10, and PM2.5 emissions associated
with vehicular traffic, area sources (consumer products, architectural coatings, landscaping equipment),
energy sources (natural gas, appliances, and space and water heating), and stationary sources (emergency
generator). CalEEMod was used to estimate daily emissions from these operational sources including
modelling the emissions of an estimated 250 kilowatt (kW) (374 horsepower (hp)) natural gas-fired
emergency generator based on 1 hour per day and 50 hours per year of operation per SCAQMD Rule 1470,
which limits emergency generators to 50 hours of use per year for maintenance and testing. CalEEMod
default emission factors were used for the proposed generator, corresponding with the install dates.
On-road vehicular emissions associated with the proposed Project operation and existing Building C were
modeled using trip generation rates for the existing office and proposed hotel, coffee shop, spa, restaurant,
and bar estimated by Linscott, Law, & Greenspan, Engineers (LLG), included as Appendix F, Traffic Study,
of this IS/MND. Emissions from energy sources include natural gas combustion for appliances and space
and water heating. CalEEMod defaults were also used for area sources (landscape maintenance
equipment, consumer products, and architectural coatings for maintenance of buildings).
Table 7, Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Unmitigated, summarizes
the maximum daily area, energy, mobile, and stationary (emergency generator) emissions of criteria
pollutants that would be generated by the proposed Project and how the net change in emissions (proposed
Project minus existing emissions) compare to the SCAQMD thresholds of significance. As shown, the net
increase in all criteria pollutants are below SCAQMD thresholds. The values shown are the maximum
summer or winter daily emissions (i.e., foreseeable worst case) results from CalEEMod. Details of the
emission calculations are provided in Appendix A of this IS/MND. As shown in Table 7, the increase in
emissions associated with the operation of the proposed Project would not exceed the SCAQMD thresholds
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for VOC, NOx, CO, SOx, PM10, or PM2.5. Even without consideration of the existing conditions related to
operations in Building C, operational impacts from the proposed Project would still be less than significant,
and no mitigation is required.
Table 7. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Unmitigated
Emission Source
VOC NOx CO SOx PM10 PM2.5
(pounds per day)
Proposed Project
Area 3.41 0.00 0.03 0.00 0.00 0.00
Energy 0.15 1.33 1.12 0.01 0.10 0.10
Mobile 5.50 24.51 56.43 0.19 14.98 4.12
Stationary 3.29 0.32 8.57 0.001 0.02 0.02
Total 12.35 26.15 66.15 0.20 15.10 4.23
Existing Operation (Building C)
Area 1.36 0.00 0.01 0.00 0.00 0.00
Energy 0.02 0.17 0.14 0.00 0.01 0.01
Mobile 1.24 5.69 15.69 0.05 3.54 0.98
Total 2.62 5.86 15.84 0.05 3.55 0.99
Net Change in Emissions (Project Existing)
Area 2.06 0.00 0.02 0.00 0.00 0.00
Energy 0.13 1.16 0.97 0.01 0.09 0.09
Mobile 4.26 18.82 40.75 0.14 11.44 3.13
Stationary 3.29 0.32 8.57 0.00 0.02 0.02
Total Net Change
(Project Existing)
9.73 20.30 50.31 0.15 11.55 3.24
SCAQMD Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Source: SCAQMD 2015.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter. Area sources = consumer product use, architectural coatings, and landscape
maintenance equipment. Energy sources = natural gas. Mobile sources = motor vehicles. Stationary sources = emergency generator.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. Mobile
source modeling for the proposed Project and existing operation includes proximity to nearby Gold Line
station, and pedestrian access encouragement features and traffic calming features.
As previously discussed, the SCAB has been designated as a federal nonattainment area for O 3 and PM2.5,
and a state nonattainment area for O 3, PM10, and PM2.5. Construction and operational activities of the
proposed Project would generate VOC and NOx emissions (precursors to O 3) and emissions of PM10 and
PM2.5. However, as indicated in Tables 6 and 7, Project-generated emissions would not exceed the SCAQMD
emission-based significance thresholds for VOCs, NO x, PM10, or PM2.5, and therefore the proposed Project
would not cause a cumulatively significant impact.
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Cumulative localized impacts could potentially occur if a project were to occur concurrently with another
off-site project. With the exception of the projects that were approved under Seabiscuit Pacifica Specific
Plan (i.e., Le Méridien Hotel and a Mixed Use project) at 130 Huntington Drive, schedules for potential
future projects near the Project area are unknown; therefore, potential impacts associated with other
simultaneous projects would be considered speculative.6
At the time of the preparation of this IS/MND, the Seabiscuit Pacifica Specific Plan and Le Méridien Hotel
project sites have been graded and construction is underway. It is expected that construction will occur on
these sites for approximately 18 months. Therefore, there is a potential for some construction activities to
overlap with the construction of the proposed Project. However, all projects that are not exempt from CEQA
would be required to conduct an air quality analysis and, where necessary, implement mitigation measures
to reduce impacts. Criteria air pollutant emissions associated with construction activity of future projects
would also be reduced through implementation of control measures required by the SCAQMD. Cumulative
PM10 and PM2.5 emissions would be reduced because all future projects would be subject to SCAQMD Rule
403 (Fugitive Dust), which sets forth general and specific requirements for all sites in the SCAQMD. In
addition, cumulative VOC emissions would be subject to SCAQMD Rule 1113 (Architectural Coatings).
Therefore, the proposed Project would not result in a cumulatively considerable increase in emissions of
nonattainment pollutants, and impacts would be less than significant during construction and operation.
No mitigation is required.
c) Would the project expose sensitive receptors to substantial pollutant concentrations?
Less Than Significant Impact. Localized project impacts associated with construction criteria air pollutants
emissions are assessed below and were determined to be less than significant.
Sensitive Receptors. Sensitive receptors are those individuals more susceptible to the effects of air
pollution than the population at large. People most likely to be affected by air pollution include children, the
elderly, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD,
sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare
facilities, rehabilitation centers, convalescent centers, and retirement homes (SCAQMD 1993). Sensitive
receptors near the proposed Project site include single-family residential adjacent and to the north of the
proposed Project site. At its nearest, Project construction would take place within approximately 80 feet of
the adjacent single family residential dwellings north of the proposed Project site.
Localized Significance Thresholds. A localized significance threshold (LST) analysis was performed to
evaluate localized air quality impacts to sensitive receptors in the immediate vicinity of the proposed Project
site as a result of proposed Project activities. The impacts were analyzed using methods consistent with
is located within Source-Receptor Area 9 (East San Gabriel Valley).
The greatest on-site daily emissions of NO x, CO, PM10, and PM2.5 generated during construction occurred
during the demolition period of the proposed Project construction, it was assumed that one rubber-tired
dozer and three crawler tractors (CalEEMod category: tractor/loader/backhoes) would be used based on
CalEEMod defaults. CalEEMod default values assume that during an 8-hour day, rubber-tired dozers and
6 The CEQA Guidelines state that if a particular impact is too speculative for evaluation, the agency should note its conclusion and
terminate discussion of the impact (14 CCR 15145).
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crawler tractors can each disturb a maximum of 0.5 acres. This results in two acres disturbed per day from
one rubber-tired dozer and three crawler tractors. The SCAQMD LST values for two acres within Source
Receptor Area 9 with a receptor distance of 25 meters (82 feet), which are representative of the closest
sensitive receptor, were compared to emissions from the proposed Project.
Project construction activities would result in temporary sources of on-site criteria air pollutant emissions
associated with construction equipment exhaust and dust-generating activities. According to the Final
Localized Significance Thresho -site mobile emissions from the project should not be
with the proposed Project are not expected to cause substantial air quality impacts to sensitive receptors
along off-site roadways since emissions would be relatively brief in nature and would cease once the
vehicles pass through the main streets. Therefore, off-site emissions from trucks and worker vehicle trips
are not included in the LST analysis. The maximum daily on-site construction emissions generated during
construction of the proposed Project is presented in Table 8, Construction Localized Significance
Threshold Analysis, and compared to the SCAQMD localized significance criteria for Source Receptor
Area 9 to determine whether Project-generated on-site construction emissions would result in potential
LST impacts. As shown in Table 8, proposed construction activities would not generate emissions in
excess of site-specific LSTs; therefore, localized project construction impacts would be less than
significant. No mitigation is required.
Table 8. Construction Localized Significance Threshold Analysis
Year
NO2 CO PM10 PM2.5
pounds per day (On-site Emissions)
2020 20.95 14.66 6.62 3.71
2021 13.64 12.90 0.68 0.66
Maximum Daily On-site Emissions 20.95 14.66 6.62 3.71
SCAQMD LST Criteria 128 953 7 5
Threshold Exceeded? No No No No
Source: SCAQMD 2009.
Notes: NO2 = nitrogen dioxide; CO = carbon monoxide; PM10 = particulate matter; PM 2.5 = fine particulate matter; SCAQMD = South
Coast Air Quality Management District; LST = localized significance threshold.
Localized significance thresholds are shown for a 2-acre site and a distance of 25 meters (82 feet) to the nearest sensitive receptor.
CO Hotspots. Traffic-congested roadways and intersections have the potential to generate localized high
levels of CO. Localized areas where ambient concentrations exceed federal and/or state standards for CO
source. Under certain extreme meteorological conditions, however, CO concentrations near a congested
roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO
concentrations are associated with severely congested intersections operating at an unacceptable level of
service (LOS) (LOS E or worse is unacceptable). Projects contributing to adverse traffic impacts may result
in the formation of a CO hotspot. Additional analysis of CO hotspot impacts would be conducted if a project
would result in a significant impact or contribute to an adverse traffic impact at a signalized intersection
that would potentially subject sensitive receptors to CO hotspots.
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The Code of Federal Regulations (CFR) Procedures for Determining Localized CO, PM10, and PM2.5
Concentrations (hot-10, and PM2.5 hot-spot analyses are not required to
consider construction-related activities, which cause temporary increases in emissions. Each site which is
affected by construction-ods.
Temporary increases are defined as those which occur only during the construction phase and last five years or
-road vehicle trips
from trucks and workers during construction, construction activities are considered temporary. As a result, the
proposed construction activities would not require a Project-level construction hotspot analysis.
Projects contributing to adverse traffic impacts may result in the formation of CO hotspots. To verify that
the proposed Project would not cause or contribute to a violation of the CO standard, a screening evaluation
of the potential for CO hotspots was conducted. The Traffic Study for the proposed Project, which is included
in this IS/MND as Appendix F, evaluated whether there would be a decrease in the level of service (LOS)
(i.e., increased congestion) at the intersections affected by the proposed Project. The potential for CO
hotspots was evaluated based on the results of the traffic impact study. The California Department of
Transportation Institute of Transportation Studies Transportation Project-Level Carbon Monoxide Protocol
(CO Protocol; Caltrans 2010) was followed for this analysis. CO hotspots are typically evaluated when (1)
the LOS of an intersection decreases to LOS E or worse; (2) signalization and/or channelization is added to
an intersection; and (3) sensitive receptors such as residences, schools, and hospitals are located in the
vicinity of the affected intersection or roadway segment.
As determined by the traffic impact study, LOS at these roadway segments would not decrease to LOS E or
worse as a result of the Project; therefore, further analysis is not required. Accordingly, the proposed Project
would not generate traffic that would contribute to potential adverse traffic impacts that may result in the
formation of CO hotspots. In addition, due to continued improvement in vehicular emissions at a rate faster
than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily
decreasing. Based on these considerations, the proposed Project would result in a less than significant
impact to air quality with regard to potential CO hotspots. No mitigation is required.
Toxic Air Contaminants. Toxic air contaminants (TACs) are defined as substances that may cause or
contribute to an increase in deaths or in serious illness, or that may pose a present or potential hazard to
human health. As discussed under the LST analysis, the nearest sensitive receptors are single family
residential dwellings north of the proposed Project site.
Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SCAQMD
increased likelihood that a person continuously exposed to concentrations of TACs resulting from a project over
a 9-, 30-, and 70-year exposure period will contract cancer based on the use of standard Office of Environmental
Health Hazard Assessment risk-assessment methodology (OEHHA 2015). In addition, some TACs have non-
carcinogenic effects. The SCAQMD recommends a Hazard Index of 1 or more for acute (short-term) and chronic
(long-term) non-carcinogenic effects.7 TACs that would potentially be emitted during construction activities
associated with development of the proposed Project would be diesel particulate matter.
7 Non-cancer adverse health risks are measured against a hazard index, which is defined as the ratio of the predicted incremental
exposure concentrations of the various non-carcinogens from the project to published reference exposure levels that can cause
adverse health effects.
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Diesel particulate matter emissions would be emitted from heavy equipment operations and heavy-duty
trucks. Heavy-duty construction equipment is subject to a CARB Airborne Toxics Control Measure for in-use
diesel construction equipment to reduce diesel particulate emissions. As described for the LST analysis,
PM10 (representative of diesel particulate matter) exposure would be minimal. According to the Office of
Environmental Health Hazard Assessment, health risk assessments (which determine the exposure of
sensitive receptors to toxic emissions) should be based on a 30-year exposure period for the maximally
exposed individual resident. However, such assessments should also be limited to the period/duration of
activities associated with the project. The duration of the proposed construction activities would constitute
a small percentage of the total 30-year exposure period. The construction period for the proposed Project
would be approximately 20 months, after which construction-related TAC emissions would cease. Due to
this relatively short period of exposure and minimal particulate emissions on site, TACs generated during
construction would not be expected to result in concentrations causing significant health risks.
Following completion of on-site construction activities, the proposed Project would not involve routine
operational activities that would generate TAC emissions other than intermittent maintenance and testing
of the natural gas-fired emergency generator, which would be limited to 50 hours per year. (SCAQMD Rule
1470 limits operation of emergency generators to 50 hours per year for maintenance and testing). Due to
this relatively short period of exposure, small engine size of the emergency generator (250 kW), and
minimal on-site particulate emissions from other sources, TACs generated during operation would not result
in concentrations causing significant health risks as demonstrated through SCAQMD
for Rule 1401 and 212, (Version 8.1). The Risk Assessment Tool, a spreadsheet program, was used to
perform a screening level evaluation of the cancer and non-cancer health effects of the emergency
generator emissions pursuant to Rule 1401, see Appendix A for program results. As shown in Appendix A,
the emergency generator passes both the Tier I Cancer/Chronic Application Screening Index (ASI) and Acute
ASI and Tier II Maximum Individual Cancer Risk (MICR).
For the reasons described above, the Project would not result in substantial TAC exposure to sensitive receptors
in the vicinity of the Project site, and impacts would be less than significant. No mitigation is required.
Health Effects of Criteria Air Pollutants. Construction of the proposed Project would generate criteria air
pollutant emissions; however, the project would not exceed the SCAQMD mass-emission thresholds. Health
effects associated with O3 include respiratory symptoms, worsening of lung disease leading to premature
death, and damage to lung tissue (CARB 2019). VOCs and NO x are precursors to O3, for which the SCAB is
designated as nonattainment with respect to the NAAQS and CAAQS. Thus, existing O3 levels in the SCAB
are at unhealthy levels during certain periods. Because the proposed Project would not involve construction
or operational activities that would result in O3 precursor emissions (VOC or NOx) in excess of the SCAQMD
thresholds, the project is not anticipated to substantially contribute to regional O 3 concentrations and the
associated health impacts.
Exposure to NO2 and NOx can irritate the lungs, cause bronchitis and pneumonia, lower resistance to
respiratory infections, and enhance allergic responses (CARB 2019). Project construction and operation
would not exceed the SCAQMD NOx threshold, and existing ambient NO2 concentrations are below the
NAAQS and CAAQS. Thus, implementation of the proposed Project is not expected to exceed the NO2
standards or contribute to associated health effects.
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Health effects associated with CO include chest pain in patients with heart disease, headache, light-
headedness, and reduced mental alertness (CARB 2019). CO tends to be a localized impact associated with
congested intersections. CO hotspots were discussed previously as a less than significant impact. Thus, the
proposed Project
Particulate matter exposure has been linked to a variety of problems, including premature death in people
with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggravated asthma, decreased lung
function, and increased respiratory symptoms such as irritation of the airways, coughing, or difficulty
breathing (EPA 2016). The SCAB is designated as nonattainment for PM10 under the CAAQS and
nonattainment for PM2.5 under the NAAQS and CAAQS. Implementation of the proposed Project would not
generate emissions of PM10 or PM2.5
10 and PM2.5 emissions are not expected to cause any increase in related regional
health effects for these pollutants. Impacts would be less than significant. No mitigation is required.
In summary, the proposed Project would not result in a potentially significant contribution to regional
concentrations of non-attainment pollutants and would not result in a significant contribution to the adverse
health effects associated with those pollutants. Impacts would be less than significant. No mitigation is required.
d) Would the project result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people?
Less Than Significant Impact. The occurrence and severity of potential odor impacts depend on numerous
factors. The nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of
receiving location each contribute to the intensity of the impact. Although offensive odors seldom cause
physical harm, they can be annoying, cause distress among the public, and generate citizen complaints.
During Project construction, exhaust from equipment may produce discernible odors typical of most
construction sites. Potential odors produced during construction would be attributable to concentrations of
unburned hydrocarbons from tailpipes of construction equipment. However, such odors would disperse
rapidly from the Project site and generally occur at magnitudes that would not affect substantial numbers
of people. Accordingly, impacts associated with odors during construction would be less than significant.
SCAQMD provides a list of land uses associated with odor concerns, which include agricultural uses,
wastewater treatment plants, food-processing plants, chemical plants, composting, refineries, landfills,
dairies, and fiberglass molding (SCAQMD 1993). The proposed Project includes operation of hotel facilities,
and restaurant spaces, which are not anticipated to generate odors and does not result in operation of the
criteria. For the reasons described above, Project operation
would result in an odor impact that would be less than significant. No mitigation is required.
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3.4 Biological Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
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?
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?
c) Have a substantial adverse effect on state or federally
protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other
means?
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?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
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?
a) Would the project 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?
No Impact. The Project site is located approximately 2.6 miles south of the foothills of the San Gabriel
Mountains and the Angeles National Forest. As shown on Figure 3, the Project site is almost entirely paved
and the surrounding urban uses include recreational/park and commercial to the south, surface parking,
horse racing track, and commercial to the west, single-family residential to the north, and commercial to
the east. Vegetation on the Project site includes 38 trees; four of which are within the public right-of-way in
the sidewalk between the Project site and San Raphael Road and would be protected in place (see Figure
6). The remaining 34 trees and several landscaped planter beds are dispersed throughout the existing on-
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site surface parking lots and would be removed under the proposed Project. The Project site does not
support any naturally vegetated areas or connectivity to any habitats for candidate, sensitive, or special
status species under existing conditions. The nearest protected open space is the Santa Anita Habitat
Mitigation Project site, which lies approximately 1.23 miles northeast of the Project site (LADPW 2018a).
For these reasons, no special-status species are expected to occur in the Project area, and development of
the proposed Project would not either directly or through habitat modifications, result in a substantial
adverse effect 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, and no mitigation is required.
b) Would the project 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?
Less Than Significant Impact. There are no riparian habitat communities or other sensitive natural
communities located on the Project site, which is fully developed with urban uses and ornamental
landscaping. According to the U.S. ational Wetlands Inventory, the Arcadia
Wash runs in a north-south running subterranean channel approximately 100 feet west of the Project site
(USFWS and NWI 2019). The Arcadia Wash is not classified as a riparian habitat or other sensitive natural
community; however, it is considered an intermittent Riverine System, which only contains flowing water
for a part of the year. According to the National Wetlands Inventory, surface water is present for brief periods
(a few days to a few weeks) of the year, but the water table usually lies well below ground surface level for
the rest of the year (USFWS and NWI 2019). Demolition and construction activities at the Project site have
the potential to release small amounts of construction debris or sediment into the storm drain system.
However, given that the Arcadia Wash is subterranean for 0.8-mile where it traverses near the Project site,
any fugitive sediments would not flow into the Arcadia Wash with implementation of the construction Best
Management Practices (BMPs) described in Section 3.10, Hydrology and Water Quality. Given this, the
proposed Project would have a less than significant impact 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, and no mitigation is required.
c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or
other means?
No Impact. The State Water Resources Control Board and the Regional Water Quality Control Boards (Water
Boards) define an area as a wetland if it has the following characteristics: (1) the area has continuous or
recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2)
the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3)
no wetlands on the Project site, which is fully developed. Given this, the proposed Project would have a no
impact on state and federally protected wetlands. No mitigation is required.
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d) Would the project 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?
Less Than Significant with Mitigation Incorporated. As stated in Section 3.4(a), the Project site is located in
a fully developed, urban area surrounded by urban land uses. The existing ornamental landscaping on the
Project site does not provide substantial habitat for wildlife, nor could it serve as a native wildlife nursery
site. As stated in the General Plan EIR, wildlife movement is already greatly restricted within the City due to
existing urban development and is confined to the undeveloped areas of the San Gabriel Mountains and to
the Santa Anita Wash (City of Arcadia 2010a). The Project site lies approximately 2.6 miles south of the
San Gabriel Mountain foothills and approximately 0.8-mile east of the Santa Anita Wash. The Project site
is separated from both of these undeveloped areas by dense urban development, the presence of which
precludes native wildlife movement in the direction of the Project site. As such, the proposed Project would
not interfere substantially with the movement of any native resident or migratory wildlife species or with
established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.
However, the existing ornamental trees on the Project site could be utilized by migratory bird species for
nesting during the breeding season. Migratory birds are protected under the MBTA (USFWS 2017).
Construction-related activities could disturb nesting birds protected under the MBTA. This would be
considered a potentially significant impact. However, with implementation of Mitigation Measure (MM) BIO-
1, potential impacts to nesting birds would be reduced to a less-than-significant level.
MM BIO-1: Commencement of construction activities shall avoid the February 1 through August 31 bird
nesting season to the greatest extent feasible. If construction activities begin within this
nesting season, a survey for nesting birds shall be conducted by a qualified biologist within
7 days of the commencement of construction activities, but not prior to this 7-day window.
The area surveyed shall include all clearing/construction areas, as well as areas within 100
feet of the boundaries of these areas, or as otherwise determined by the biologist. If no active
bird nests are identified on, or within 100 feet of the limits of the proposed disturbance area,
no further action is necessary and construction activities could commence. For any off-site
areas that are inaccessible, the qualified biologists may survey the off-site area with
binoculars to capture the full 100-foot survey area.
If active nests are found during pre-construction surveys or at any time throughout the course of
construction activities during the nesting bird season, all clearing/construction activities within a minimum
of 100 feet of the nest shall be postponed until a wildlife biologist has identified the nesting species. If the
bird species is not protected under the MBTA and/or the California Fish and Game Code, no further action
is required and construction activities may proceed. If the avian species is protected under the MBTA
and/or the California Fish and Game Code, a minimum buffer zone shall be established by the qualified
biologist based on the type of bird/raptor species identified and the construction buffer shall be established
on site through the erection of cones/flagging/fencing to clearly delineate the protection zone.
All construction activities shall avoid this protection zone until a qualified biologist has confirmed that the
nest(s) is no longer active and the nest is vacated, and there is no evidence of second nesting attempts.
Upon completion of any site survey for nesting birds conducted by a qualified biologist, documentation of
the survey activity, findings, and any resulting actions taken shall be prepared and submitted to the City.
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With implementation of MM BIO-1, the proposed Project would have less than significant impact with
mitigation incorporated on the movement of native resident or migratory fish or wildlife species and
established native resident or migratory wildlife corridors, and would not impede the use of native wildlife
nursery sites.
e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a
tree preservation policy or ordinance?
Less Than Significant Impact. Vegetation on the Project site includes 38 trees; four of which are within the
public sidewalk between the Project site and San Rafael Road and which would be protected in place during
Project construction, per
Comprehensive Tree Management Program. The proposed Project would not impact any trees in the adjacent
public ROW and would therefore not impact any trees subject to this chapter of the Municipal Code.
On-site trees along the property line with the adjacent single-family homes would not be removed or
otherwise impacted by proposed Project activities. The 34 on-site trees are dispersed throughout the
existing surface parking lot would be removed under the proposed Project. The Project would be subject to
the Article IX, Chapter 7, Section 9701, Tree Preservation, which recognizes oaks,
sycamores, and certain mature trees as significant aesthetic and ecological resources. Per the Tree Survey
Report prepared for the Project, and included as Appendix B, the four public City trees would be protected
in place under the proposed Project, per Section 9701, Tree Preservation As
such, Municipal Code, Section 9701, Tree Preservation, the Project would
have a less than significant impact to local policies or ordinances protecting biological resources, including
mitigation is required.
f)Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. According to the General Plan EIR, there are no adopted, approved, or proposed Habitat
Conservation Plans, or other approved local, regional, or state habitat conservation plans that cover
habitats located within the City (City of Arcadia 2010a). Given this, the proposed Project would not conflict
with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or
other approved local, regional, or state habitat conservation plan. No impact would occur and no mitigation
is required.
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3.5 Cultural Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to §15064.5?
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant
to §15064.5?
No Impact. On May 7, 2019, Dudek completed a search of the California Historical Resources Information
System (CHRIS) at the South Central Coastal Information Center (SCCIC), located on the campus of
California State University, Fullerton of the proposed Project site and a 1.0-mile records search buffer. This
search included previously documented prehistoric and historic archaeological resources and historic built-
environment resources; Department of Parks and Recreation (DPR) site records; technical reports; archival
resources; and ethnographic references. Additional consulted sources included historical maps of the
proposed Project site, the NRHP, the CRHR, the California Historic Property Data File, the lists of California
State Historical Landmarks, California Points of Historical Interest, and the Archaeological Determinations
of Eligibility.
The SCCIC records indicate that 25 previous cultural resources technical investigations have been
conducted within 1.0-mile of proposed Project site between 1984 and 2015. Of these, two studies overlap
a portion of the proposed Project site.
Plan Environmental Impact Report analysis (i.e., Report No. 6859 [LA-06859] in 1996 and Report No.
12497 [LA-1244797] in 2010).
LA-06859.
which was originally adopted in 1972. The General Plan included historical research and a records search.
The records search identified seven historical sites and one archaeological site within the City of Arcadia.
The General Plan also defined a significant cultural value in the City of Arcadia. No resources were identified
to be intersecting or overlapping the current proposed Project site.
LA-1244797. Draft Program Environmental Impact Report, City of Arcadia, 2010 General Plan Update
Project (BonTerra Psomas 2010) reports the results of a records search for the City of Arcadia and a 1.0-
mile buffer, Native American consultation, and background research. The records search found 70
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including one historic refuse deposit and four built-environment resources. No resources from the 2010
study were identified within the current proposed Project site. The General Plan update proposed two goals.
The first, Goal PR-8, is
d the second, Goal PR-9, is the
resources were proposed. In addition, five Implementation Actions were proposed to reduce impacts on
cultural resources including:
Implementation Action 6-11: Cultural Resource Protection
Implementation Action 6-12: Discovery of Archaeological Resources or Human Remains
Implementation Action 7-12: Sponsorship and Support of Cultural Events
Implementation Action 7-13: Provision of Places for Cultural Events
Implementation Action 7-14: Inventory of Local Historic Resources
Implementation Action 7-15: Support Private Efforts to Promote
Additionally, this General Plan update included three mitigation measures that should be implemented in
order to avoid impacts to cultural resources. The three measures are as follows: 1.) requires architectural
historians to assess any structure that is over 50 years old that may be demolished, 2.) undertaking a
Phase I archaeological study for projects that are located on or near cultural resources, and 3.) conducting
a paleontological study for any project that would include excavation in to Older Quaternary Alluvium.
The CHRIS records search did not identify any previously recorded historical resources within the proposed
Project site. The record search identified 167 cultural resources that have been recorded within 1.0-mile
of the proposed Project site; none of these resources intersect or are adjacent to the proposed Project site.
The resources include 166 historic buildings and one historic refuse scatter. According to the County
within the Project site was originally built between 1978 and 1979;
as such, the existing structure would not qualify as a historical resource. Due to the fact that no historical
resources are present within the proposed Project site, the proposed Project would have a less than
significant impact on historical resources and no resource specific mitigation is proposed.
b) Would the project cause a substantial adverse change in the significance of an archaeological resource
pursuant to §15064.5?
Less Than Significant With Mitigation Incorporated. The CHRIS records search did not identify any previously
recorded archaeological resources within the proposed Project site. The record search identified one
resource (a historic refuse scatter) within the 1.0-mile buffer, or study area, of the proposed Project site.
Historic aerials indicate that the proposed Project site was first developed in the 1950s and then was
redeveloped with the existing structure between 1978 and 1979. Site development activities, including
trenching for utilities and excavations for footings and basements, could have significantly impacted
surficial deposits within the proposed Project site, and in some areas, subsurface deposits may have also
been adversely affected. For example, beneath Building C, which contains a small basement, buried
cultural deposits may have been more severely impacted. However, there still may be intact deposits that
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Sacred Lands File Search
As part of the records review process, Dudek also requested that the Native American Heritage Commission
(NAHC) conduct a search of its Sacred Lands File (SLF) to determine if cultural resources important to
Native Americans have been recorded in the project area. In addition, Dudek requested a list of Native
American individuals and/or tribal organizations who may have knowledge of cultural resources in or near
the proposed Project site. The NAHC emailed a response to this letter on April 5, 2019, stating that the
result of the SLF search was positive. Because the SLF search does not include an exhaustive list of Native
American cultural resources, the NAHC recommended contacting six (6) tribal representatives who may
have direct knowledge of cultural resources in or near the proposed Project. These included the Gabrieleno
Band of Mission Indians Kizh Nation, the Gabrieleno/Tongva San Gabriel Band of Mission Indians, the
Gabrieleno/Tongva Nation, the Gabrieleno Tongva Indians of California Tribal Council, the Gabrieleno-
Tongva Tribe, and the San Fernando Band of Mission Indians. No additional tribal outreach was conducted
by Dudek; however, in compliance with Assembly Bill (AB) 52, the City has contacted all NAHC-listed
traditionally geographically affiliated tribal representatives that have requested Project notification, which
is addressed in Section 3.18, Tribal Cultural Resources.
No newly or previously recorded archaeological resources were identified within the proposed Project site as
a result of the cultural resources study. Although no archaeological resources were identified within the
proposed Project site, there is the potential to encounter unanticipated cultural resources during the course
of construction. Within areas of the Project site proposed for new development, specifically the construction
of Building D and associated swimming pool, the chance of discovering archaeological deposits is greater
than in areas with no soil disturbance (Building C) or superficial redesign of the surface parking lot. As such,
MM CUL-1 is required to ensure that potential impacts would be reduced if archaeological resources were
discovered on site. Implementation of MM CUL-1 would ensure that potential impacts to archaeological
resources due to Project implementation would be less than significant.
MM-CUL-1. In the event that archaeological resources are unearthed during ground-disturbing
activities, the construction contractor shall immediately cease all earth-disturbing activities
within 100 feet of the discovery and shall retain a qualified archaeologist that meets the
continue in other areas outside of the designated protection zone, which shall be
delineated with cones, flagging, or fencing. The archaeologist shall evaluate the
he California Public
CEQA Guidelines.
If an unanticipated archaeological discovery is determined to be a resource, the archaeologist shall
formulate a Mitigation Plan in consultation with the City of Arcadia that satisfies the requirements of the
above-listed Code Sections. Upon approval of the Mitigation Plan by the City, the Project shall be
implemented in compliance with the Plan. If the Archaeologist determines that the resource is not
significant, s/he shall record the evaluation and submit the recordation form to the CHRIS at the SCCIC.
The archaeologist shall prepare a report of the results of any study prepared as part of a testing or Mitigation
Plan, following accepted professional practice. Copies of the report shall be submitted to the City and to
the CHRIS at the SCCIC.
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c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
Less Than Significant Impact. There is no indication that human remains are present within the proposed
Project site. However, in the unlikely event that excavation activities inadvertently discover buried human
remains, recovery activities must be conducted in accordance with Section 7050.5 of the California Health
and Safety Code regarding the potential discovery of human remains. In accordance with Section 7050.5
of the California Health and Safety Code, if human remains are found, the Los Angeles County Coroner must
be notified within 24 hours of the discovery. No further excavation or disturbance of the site or any nearby
area reasonably suspected to overlie adjacent remains may occur until the County Coroner has determined,
within two working days of notification of the discovery, the appropriate treatment and disposition of the
human remains. If the County Coroner determines that the remains are, or are believed to be, Native
American, s/he must notify the NAHC in Sacramento within 48 hours. In accordance with California Public
Resources Code, Section 5097.98, the NAHC must immediately notify those persons it believes to be the
Most Likely Descendant of the deceased Native American. The Most Likely Descendant must complete their
inspection within 48 hours of being granted access to the site. The designated Native American
representative would then determine, in consultation with the property owner, the proper treatment of the
human remains. Therefore, compliance with state law (California Public Resources Code and Health and
Safety Code) would ensure that potential impacts related to the disturbance of any human remains would
be less than significant, and no mitigation is required.
3.6 Energy
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Result in potentially significant environmental impact
due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant Impact. The short-term construction and long-term operation of the proposed Project
would require the consumption of energy resources in several forms. Construction energy consumption
includes: (1) temporary direct electrical service provided by Southern California Edison (SCE), which includes
construction site lighting; computer equipment; and temporary construction trailer operation; and (2) fossil
fuels (diesel and gasoline), which includes off-road construction equipment, diesel-fired electric generators,
and worker vehicles, vender trucks, and haul trucks. Operational Energy Consumption includes: (1) direct
electrical service provided by SCE, which includes, Building heating, ventilation, and air-conditioning (HVAC),
lighting: interior and exterior facilities, computer, audio and video equipment; and, appliances; (2) indirect
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energy consumption, which includes supply, distribution, and treatment of water, wastewater; and solid waste;
and (3) fossil fuels (diesel and gasoline) transportation, which includes hotel guests and visitors; employees,
delivery, and customers; and restaurant employees, delivery, and customers.
Construction Energy Use
Electricity. Temporary electric power for as-necessary lighting and electronic equipment (such as computers
inside temporary construction trailers) would be provided by SCE. The electricity used for such activities
would be temporary and would be substantially less than that required for Project operation and would
Natural Gas. Natural gas is not anticipated to be required during construction of the proposed Project. Fuels
used for construction would primarily consist of diesel and gasoline, which are discussed below under the
Project construction would be substantially less than that required for operation and would have a negligible
Petroleum. Heavy-duty construction equipment associated with demolition and construction activities
would rely on diesel fuel, as would vendor trucks involved in delivery of materials to the proposed Project
site. Construction workers would travel to and from the Project site throughout the duration of construction.
It is assumed in this analysis that construction workers would travel in gasoline-powered light-duty vehicles.
Heavy-duty construction equipment of various types would be used during each phase of Project
construction. Appendix A lists the assumed equipment usage for each phase of construction. The proposed
equipment is estimated to operate a total combined 13,809 hours.
Fuel consumption from construction equipment was estimated by converting the total carbon dioxide (CO 2)
emissions from each construction phase to gallons using the conversion factors for CO 2 to gallons of
gasoline or diesel. Construction is estimated to occur in 2020 through 2021 based on the construction
phasing schedule. The analysis assumes a construction start date of May 2020, which represents the
earliest date construction would initiate. In the event construction is started later than May 2020, the
analysis performed represents the worst-case scenario for energy consumption, because equipment and
vehicle efficiencies for later years would be slightly greater due to more stringent standards for in-use off-
road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in
later years. The conversion factor for gasoline is 8.78 kilograms per metric ton CO 2 per gallon, and the
conversion factor for diesel is 10.21 kilograms per metric ton CO 2 per gallon (The Climate Registry 2018).
The estimated diesel fuel usage from construction equipment is shown in Table 9, Construction Equipment
Diesel Demand for Off-Road Equipment.
Table 9. Construction Equipment Diesel Demand for Off-Road Equipment
Phase
Pieces of
Equipment
Equipment
CO2 (MT) kg/CO2/Gallon Gallons
Demolition 5 28.62 10.21 2,803.54
Site Prep 3 7.62 10.21 746.76
Grading 3 6.87 10.21 672.81
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Table 9. Construction Equipment Diesel Demand for Off-Road Equipment
Phase
Pieces of
Equipment
Equipment
CO2 (MT) kg/CO2/Gallon Gallons
Building Construction 7 325.53 10.21 31,883.51
Paving 3 11.86 10.21 1,161.43
Architectural Coating 1 2.56 10.21 250.50
Total 37,518.54
Sources: Pieces of equipment and equipment CO2 (Appendix A); kg/CO2/Gallon (The Climate Registry 2018).
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Fuel consumption from worker, vendor, and haul truck trips are estimated by converting the total CO 2
emissions from each construction phase to gallons using the conversion factors for CO 2 to gallons of
gasoline or diesel. Worker vehicles are assumed to be gasoline and vendor/hauling vehicles are assumed
to be diesel. Calculations for total worker, vendor, and haul truck fuel consumption are provided in Tables
10, 11, and 12.
Table 10. Construction Worker Gasoline Demand
Phase Trips Vehicle MT CO2 kg/CO2/Gallon Gallons
Demolition 378 1.93 8.78 220.03
Site Prep 80 0.41 8.78 46.57
Grading 88 0.45 8.78 51.23
Building Construction 27,846 139.84 8.78 15,927.37
Paving 280 1.39 8.78 157.80
Architectural Coating 320 1.58 8.78 180.34
Total 16,583.35
Sources: Trips and vehicle CO2 (Appendix A); kg/CO2/Gallon (The Climate Registry 2018).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
Table 11. Construction Vendor Diesel Demand
Phase Trips
Vehicle
MT CO2 kg/CO2/Gallon Gallons
Demolition 0 0 10.21 0
Site Prep and Grading 0 0 10.21 0
Trenching 0 0 10.21 0
Building Construction 10,71 0 132.67 10.21 12,994.54
Paving 0 0 10.21 0
Architectural Coating 0 0 10.21 0
Total 12,994.54
Sources: Trips and vehicle CO2 (Appendix A); kg/CO2/Gallon (The Climate Registry 2018).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
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Table 12. Construction Haul Truck Diesel Demand
Phase Trips
Vehicle
MT CO2 kg/CO2/Gallon Gallons
Demolition 185 7.14 10.21 699.5
Site Prep and Grading 0 0 10.21 0
Trenching 170 6.56 10.21 642.8
Building Construction 0 0 10.21 0
Paving 0 0 10.21 0
Architectural Coating 0 0 10.21 0
Total 1,342.34
Sources: Trips and vehicle CO2 (Appendix A); kg/CO2/Gallon (The Climate Registry 2018).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
In summary, construction of the proposed Project is conservatively anticipated to consume 16,583 gallons
of gasoline and 51,855
consumption of petroleum is approximately 74.8 million gallons per day. (EIA 2017). Building C would be
renovated in accordance with current building code requirements, which are more stringent and energy
efficient than those that were in effect in 1978-79 when the building was constructed. All construction
activities must be conducted in accordance with applicable regulations related to the recycling of
construction and demolition debris. Therefore, -term construction activities would not
result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during Project construction, and no mitigation is required.
Operation Energy Use
Electricity. Operation of the proposed Project upon buildout would require electricity for multiple purposes,
including cooling, lighting, appliances, and various equipment. Additionally, the supply, conveyance,
treatment, and distribution of water and wastewater would indirectly result in electricity usage. Electricity
consumption associated with proposed Project operation is based on CalEEMod outputs presented in
Appendix A of this IS/MND.
CalEEMod default values for energy consumption for each land use were applied for the Project analysis.
The energy use from non-residential land uses is calculated in CalEEMod based on the California
Commercial End-Use Survey database. For parking lots, CalEEMod includes calculation of energy use from
lighting, ventilation and elevators in parking lots and structures and is based on the type of parking lot
selected by the user. Energy use in buildings (both natural gas and electricity) is divided by the program
into end use categories subject to California Building Standards Code (Title 24) requirements (end uses
associated with the building envelope, such as the HVAC system, water heating system, and integrated
lighting) and those not subject to California Building Standards Code requirements (such as appliances,
-
Title 24 of the
standards. The most recent amendments to Title 24, Part 6, referred to as the 2016 standards, became
effective on January 1, 2017. Although not accounted for in the modeling, energy consumption of the
proposed Project would also be reduced through installation of high-efficiency lighting, per Title 24, Part 6
of the California Code of Regulations. According to these estimations, the proposed Project would consume
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approximately 1,369,238 kilowatt-hours per year during operation. For comparison, in 2017 the total
residential and non-residential electricity demand in Los Angeles County was 67,569,242,472 kilowatt-
hours (CEC 2018). For these reasons, the electricity consumption of the propose Project would not be
considered inefficient or wasteful, and impacts would be less than significant.
Natural Gas. Project operation would require natural gas for various purposes, including water heating and
natural gas appliances. Natural gas consumption associated with operation is based on the CalEEMod
outputs. According to these estimations, the proposed Project would consume approximately 5,104,001
kilo-British Thermal Units per year. For comparison, in 2017 the non-residential natural gas use within Los
Angeles County was 295,601,223,219 kilo-British Thermal Units (CEC 2018). Since the proposed Project
would comply with applicable Title 24 requirements the proposed Project would not be considered
inefficient or wasteful, and impacts would be less than significant.
Petroleum. During operations, the majority of fuel consumption resulting from the proposed Project would
involve the use of motor vehicles traveling to and from the Project site including hotel guests, retail and
restaurant customers, deliveries, and employees. Petroleum fuel consumption associated with motor
vehicles traveling to and from the Project site is a function of the vehicle miles traveled (VMT) as a result of
proposed Project operation. The annual VMT attributable to the proposed Project is expected to be
6,047,824 VMT. Similar to the construction worker and vendor trips, fuel consumption from operational
trips are estimated by converting the total CO2 emissions from operation of the proposed Project to gallons
using the conversion factors for CO2 to gallons of gasoline or diesel. Based on the annual fleet mix provided
in CalEEMod, 92.2% of the fleet range from light-duty to medium-duty vehicles and motorcycles are
assumed to run on gasoline. The remaining 7.8% of vehicles represent medium-heavy duty to heavy-duty
vehicles and buses and are assumed to run on diesel. Calculations for annual mobile fuel consumption are
provided in Table 13.
Table 13. Annual Mobile Source Demand (Gasoline and Diesel)
Vehicle MT CO2 kg/CO2/Gallon Gallons
Gasoline: Operations 2,480.21 8.78 282,484.28
Diesel: Operations 210.25 10.21 20,593.03
Sources: Trips and vehicle CO2 (Appendix A; kg/CO2/Gallon (The Climate Registry 2018).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram
Over the lifetime of the proposed Project, the fuel efficiency of on-road vehicles of hotel guests, retail and
restaurant customers, deliveries, and employees, commuting to the site is expected to increase. As such,
the amount of petroleum consumed as a result of vehicular trips to and from the Project site during
operation would decrease over time. There are numerous regulations in place that require and encourage
increased fuel efficiency. For example, the CARB has adopted an approach to passenger vehicles by
combining the control of smog-causing pollutants and greenhouse gas (GHG) emissions into a single,
coordinated package of standards. The approach also includes efforts to support and accelerate the
number of plug-in hybrids and zero-emissions vehicles in California (CARB 2013). Additionally, in response
to Senate Bill 375, CARB adopted the goal of reducing per-capita GHG emissions from 2005 levels by 8%
by 2020, and 18% by 2035 for light-duty passenger vehicles in the planning area for the SCAG. As such,
operation of the proposed Project is expected to use decreasing amounts of petroleum over time due to
advances in fuel economy.
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In summary, although the proposed Project would increase petroleum use during operation as a result of hotel
guests, retail and restaurant customers, deliveries, and employees commuting to the site, the use would be
a fraction of the state- and County-wide use and, due to efficiency increases, would diminish over time. Given
these considerations, petroleum consumption associated with the proposed Project would not be considered
inefficient or wasteful and would result in a less-than-significant impact. No mitigation is required.
b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact. Part 6 of Title 24 of the California Code of Regulations was established in
andards. Part 6 establishes energy
efficiency standards for residential and non-residential buildings constructed in California to reduce energy
demand and consumption. Part 6 is updated periodically (every 3 years) to incorporate and consider new
energy efficiency technologies and methodologies. Title 24 also includes Part 11, the California Green
Building Standards Code (CALGreen). CALGreen institutes mandatory minimum environmental
performance standards for all ground-up, new construction of commercial, low-rise residential, and state-
owned buildings, as well as schools and hospitals. The 2016 CALGreen standards became effective on
January 1, 2017. The proposed Project would meet Title 24 and CALGreen standards to reduce energy
demand and increase energy efficiency.
In 2012, 27 of the 31 San Gabriel Valley Council of Governments member agencies, including the City of
Arcadia, participated in the Energy Action Plan project, which is funded by California utility ratepayers and
administered by SCE. The funding was awarded to the San Gabriel Valley Council of Governments to
implement activities to achieve statewide energy efficiency goals. The City of Arcadia developed resource
protection and sustainability goals and policies within the Natural Resource and Sustainability Element of the
-5. Relevant RS-5 policy are summarized as follows:
Goal RS-5: Wise and creative energy use that incorporates new technologies for energy
generation and new approaches to energy conservation
Policy RS-5.3: Require that all new development meets or exceeds the state and local
energy conservation requirements.
Policy RS-5.8: Promote innovative building, site design, and orientation techniques which
minimize energy use.
Policy RS-5.17: Investigate providing incentives for LEED certifiable or equivalent for new
The proposed Project would follow applicable energy standards and regulations during construction. In
addition, the proposed Project would be built and operated in accordance with all existing, applicable
regulations at the time of construction. As such, the proposed Project would not conflict with existing energy
standards and regulations; therefore, impacts during construction and operation of the proposed Project
would be less than significant. No mitigation is required.
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3.7 Geology and Soils
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Directly or indirectly cause 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.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of topsoil?
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- or off-site landslide, lateral
spreading, subsidence, liquefaction or collapse?
d) Be located on expansive soil, as defined in Table 18-1-
B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property?
e) Have soils incapable of adequately supporting the use
of septic tanks or alternative waste water disposal
systems where sewers are not available for the
disposal of waste water?
f) Directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature?
a) Would the project directly or indirectly cause 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.
Less Than Significant Impact. The City of Arcadia is located at the base of the east-west trending
San Gabriel Mountains, which are part of the Transverse Ranges. The Project site is located in the
northwest portion of the San Gabriel Valley, which is bound on the north by the San Gabriel
Mountains, on the west by the Repetto and Merced Hills, on the south by the Puente Hills, and on
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the east by the San Jose Hills (City of Arcadia 2010a). The Project site is located on a gentle,
southern sloping gradient and is underlain by Quaternary gravel and sand deposited from major
stream channels and alluvium. Like all of Southern California, the Project site is subject to potential
moderate to strong seismic ground shaking as a result of movement along major regional faults.
The closest fault to the Project site is the Raymond Fault, located approximately 2,000 feet to the
northwest (CGS 2010). The Alquist-Priolo Fault Zone associated with this fault is located
approximately 1,200 feet from the Project site, at the closest point (CGS 2017).
The Project site is not located within an Alquist-Priolo Earthquake Fault Zone and there are no
known faults beneath the site. Therefore, the risk of fault rupture in the immediate vicinity of the
Project site is low. The proposed Project would not directly or indirectly cause or exacerbate existing
fault rupture risks that could directly or indirectly cause loss, injury, or death involving rupture of a
known earthquake as a result of construction of the new buildings on the site. Therefore, impacts
would be less than significant and no mitigation is required.
ii) Strong seismic ground shaking?
Less Than Significant Impact. The City of Arcadia is located in a seismically active area. Movement
along major faults in proximity to the City, as well as along buried blind thrust faults, can occur
across the greater Los Angeles Area. These faults, as well as numerous other regional faults, are
capable of producing moderate to large earthquakes that could affect the City. However, the
proposed Project would be constructed in accordance with state and City building standards. As
with all development within the City, the proposed Project is required to comply with the California
Building Code. Proper engineering and compliance with Title 24 of the California Building Code
would ensure the maximum feasible protection of the buildings and occupants. The Building Code
includes requirements to ensure that new development does not cause or exacerbate geological
and soil hazards, including seismic ground shaking. In addition, measures to minimize the risk of
loss, injury, and death from the construction of new buildings are included in the Arcadia General
Plan, Safety Element, with specific provisions for seismic design. The proposed Project would not
directly or indirectly cause or exacerbate adverse effects involving seismic ground shaking. As a
result, impacts would be less than significant and no mitigation is required.
iii) Seismic-related ground failure, including liquefaction?
Less Than Significant Impact. Included within A City
of Arcadia 2010b) is a map of liquefaction zones and regional groundwater levels for the City.
Based on historical highest groundwater levels, the City is generally underlain by groundwater
levels approximately 100 feet below ground surface (City of Arcadia 2010c). These underlying soils
would not be prone to liquefaction and associated lateral spreading during the ground motion
expected during a major seismic event. As a result, both the California Geological Survey and the
City of Arcadia has determined that the Project site is not located in a zone of liquefaction (CGS
2017). Furthermore, as with all development within the City, the proposed Project is required to
comply with the California Building Code. The California Building Code includes requirements to
ensure that new development does not cause or exacerbate geological and soil hazards, including
seismic ground shaking and seismically related ground failure. Measures to minimize the risk of
loss, injury, and death from the construction of new buildings are included in the California Building
Code, with specific provisions for seismic design. The proposed Project would not directly or
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indirectly cause or exacerbate adverse effects involving seismic-related ground failure, such as
liquefaction. As a result, impacts would be less than significant and no mitigation is required.
iv) Landslides?
Less Than Significant Impact. The proposed Project is located on a gently sloping, relatively flat region in
central Arcadia. Both the California Geological Survey (CGS General
Safety Element (City of Arcadia 2010b) have determined that the P
region susceptible to landslides. The closest earthquake-induced landslide zone is located approximately
1.5 miles to the northeast of the Project site (CGS 2017). As such, impacts would be less than significant
and no mitigation is required.
b) Would the project result in substantial soil erosion or the loss of topsoil?
Less Than Significant Impact. The Project site is not located in a hillside development area or agricultural zone
that could be susceptible to eroding soils or the loss of topsoil due to site development. The Project site is
fully developed and paved, with negligible amounts of soil exposed in areas of ornamental landscaping.
Development of the Project site would not require the export of soils. During construction, erosion-control
measures would be implemented as part of the Stormwater Pollution Prevention Plan (SWPPP) for the Project.
Prior to the start of construction activities, the Contractor is required to file a Permit Registration Document
with the State Water Resources Control Board (SWRCB) in order to obtain coverage under the National
Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with
the Construction and Land Disturbance Activities (Order No 2009-009-DWQ as amended by 2010-0014-DWQ
and 2012-0006-DWQ, NPDES No. CAS000002) or the latest approved general permit. This permit is required
for earthwork that result in the disturbance of one acre or more of total land area. The required SWPPP will
mandate the implementation of BMPs to reduce or eliminate construction-related pollutants in the runoff,
including sediment. Implementation of the erosion control BMPs in the SWPPP would reduce construction-
related soil erosion and there would be no loss of topsoil associated with Project implementation. Impacts
would be less than significant and no mitigation is required.
c) Would the project 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- or off-site landslide, lateral spreading, subsidence,
liquefaction or collapse?
Less Than Significant Impact. According to the State of California Seismic Hazard Zones map for the Mount
Wilson Quadrangle (CGS 2017) City of Arcadia 2010b),
the site is not located in an area potentially susceptible to earthquake induced landslides, lateral spreading,
or liquefaction. Based on the relatively flat topography, Project construction would not initiate a landslide
or increase the potential for landslides to occur. Additionally, liquefaction is unlikely due to historic
groundwater depths at the Project site exceeding 100 feet. The San Gabriel Valley is not an area of historic
or recent groundwater subsidence due to groundwater withdrawal (Luhdorff & Scalmanini 2014).
Therefore, potential impacts associated with landslides, lateral spreading, liquefaction, collapse and
subsidence would be less than significant, and no mitigation is required.
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d) Would the project be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code
(1994), creating substantial direct or indirect risks to life or property?
Less Than Significant Impact. Expansive soils are clay-rich soils that shrink when dry and swell when wet.
This change in volume can exert substantial pressure on foundations, resulting in structural distress and/or
DA 2019). These soils
typically contain very little clay material and are usually not subject to expansion. Project construction would
not increase or exacerbate the potential for expansive soils to create substantial direct or indirect risks to
life or property. Additionally, the proposed Project would be constructed according to the mandatory seismic
and structural design guidelines established in the California Building Code, Chapter 16, Section 1601 et
seq.8 As such, impacts would be less than significant.
e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative
waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. The proposed Project is currently served by sewer infrastructure. No septic tanks or alternative
wastewater disposal is proposed; therefore, the proposed Project would have no impacts related to soils
supporting the use of septic tanks or alternative wastewater disposal systems.
f)Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant with Mitigation Incorporated. The Project area is located in the City of Arcadia, within
the San Gabriel Valley of Los Angeles County, southwest of the San Bernardino Mountains (Dibblee and
Ehrenspeck 1998). The Project area is underlain by Quaternary gravel and sand (map unit Qg; <11,700
years old), derived as alluvial fans and major stream channels (Dibblee and Ehrenspeck 1998). Quaternary
older alluvial fan deposits (map unit Qof; ~2.58 million to 11,700 years old) are mapped nearby, and are
comprised of sand and gravel (Dibblee and Ehrenspeck 1998). The alluvial fan deposits in this area are
may be encountered at an unknown depth beneath surficial Holocene age deposits (Dibblee and
Ehrenspeck 1998).
Although no fossils are recorded from within the Project area itself, they are documented nearby from
similar sedimentary deposits as those underlying the Project area. According to the records search results
received from the Natural History Museum of Los Angeles County (LACM), a fossil specimen of mastodon
(Mammut) was recovered approximately 4.7 miles northwest of the Project site, south of the intersection
between Washington Boulevard and Allen Avenue in Pasadena, near the western end of Brigden Road from
an unknown depth below the ground surface (McLeod 2019). Another fossil locality, located southeast of
the Project area, south of Arrow Highway and east of Irwindale Boulevard, and north of Dalton Wash,
included a fossil specimen of mastodon (Mammut americanum) recovered from a gravel pit between 115
and 120 feet below the original ground surface at LACM 1807 (McLeod 2019). In Eagle Rock, east of I-110
(Pasadena Freeway) and Eagle Rock Boulevard, south of York Boulevard, locality LACM (CIT) 342 yielded
fossil specimens of turkey (Parapavo californicus) and mammoth (Mammuthus) at a depth of 14 feet below
the ground surface (McLeod 2019). Both specimens were documented in scientific publications (Miller
1942; Roth 1984). The LACM recommended paleontological monitoring of substantial excavations into
8 California Building Code, Chapter 16, Section 1601 et seq. Structural Design.
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Quaternary older alluvial fan deposits at depth within the Project area and sediment sample collection to
determine the presence of microvertebrate specimens.
No paleontological resources were identified within the Project area as a result of the institutional records search
or desktop geological review. As such, the Project site is not anticipated to be underlain by unique geologic
features. If intact paleontological resources are located on site, ground-disturbing activities associated with
construction of the Project, such as grading during site preparation and excavations for the swimming pool, have
the potential to destroy a unique paleontological resource or site. As such, the Project area is considered to be
potentially sensitive for paleontological resources. Given the proximity of past fossil discoveries in the
surrounding area and potential for underlying, Pleistocene-age older alluvial fan deposits, the sedimentary
deposits within the Project area are considered to be highly sensitive for supporting paleontological resources.
Younger, Holocene age alluvial fan deposits within the Project area have low potential to yield paleontological
resources, and thus, requires no mitigation during excavation. Implementation of MM-GEO-1 would ensure that
potential impacts would be reduced to less than significant levels.
MM-GEO-1 Prior to commencement of any grading activity on-site, the Applicant shall retain a qualified
paleontologist per the Society of Vertebrate Paleontology (SVP) (2010) guidelines. The
paleontologist shall prepare a Paleontological Resources Impact Mitigation Program (PRIMP) for
the project. The PRIMP shall be consistent with the SVP (2010) guidelines and should outline
requirements for preconstruction meeting attendance and worker environmental awareness
training, where monitoring is required within the project area based on construction plans and/or
geotechnical reports, procedures for adequate paleontological monitoring and discoveries
treatment, and paleontological methods (including sediment sampling for microvertebrate fossils),
reporting, and collections management. The qualified paleontologist shall attend the
preconstruction meeting and a paleontological monitor shall be on-site during all rough grading
and other significant ground-disturbing activities in previously undisturbed, fine-grained older
Quaternary alluvial fan deposits. These deposits may be encountered at depths as shallow as 5-10
feet below ground surface. In the event that paleontological resources (e.g., fossils) are unearthed
during grading, the paleontological monitor will temporarily halt and/or divert grading activity to
allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot
radius buffer. Once documentation and collection of the find is completed, the monitor will remove
the rope and allow grading to recommence in the area of the find.
3.8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Generate greenhouse gas emissions, either directly or
indirectly, that may have a significant impact on the
environment?
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Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
b) Conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions of
greenhouse gases?
a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a
significant impact on the environment?
Less Than Significant Impact. Climate change refers to any significant change in measures of climate, such
as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer).
and many factors (natural and human) can cause change
is the trapping and build-
creates
a livable environment on Earth. Human activities that emit additional GHGs to the atmosphere increase the
amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the
ce temperature to rise. Global climate change is a
cumulative impact; a project contributes to this impact through its incremental contribution combined with
the cumulative increase of all other sources of GHGs. Thus, GHG impacts are recognized exclusively as
cumulative impacts (CAPCOA 2008).
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the
atmosphere. As defined in California Health and Safety Code Section 38505(g) for purposes of administering
many 2), methane
(CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride
(see also CEQA Guidelines Section 15364.5). The three GHGs evaluated herein are CO2, CH4, and N2O
because these are the only GHG gases would be emitted during project construction and/or operations.
The Intergovernmental Panel on Climate Change developed the global warming potential (GWP) concept to
compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The reference gas
used is CO2; therefore, GWP-weighted emissions are measured in metric tons (MT) of CO 2 equivalent (CO2e).
Consistent with CalEEMod Version 2016.3.2, this GHG emissions analysis assumed the GWP for CH 4 is 25
(i.e., emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO 2), and the GWP for N2O is 298,
based on the Intergovernmental Panel on Climate Change Assessment Report (IPCC 2007).
As discussed in Section 3.3, Air Quality, of this IS/MND, the proposed Project is located within the jurisdictional
boundaries of the SCAQMD. In October 2008, the SCAQMD proposed recommended numeric CEQA
significance thresholds for GHG emissions for lead agencies to use in assessing GHG impacts of residential
and commercial development projects as presented in its Draft Guidance Document Interim CEQA
Greenhouse Gas (GHG) Significance Threshold (SCAQMD 2008). This document, which builds on the previous
guidance prepared by the California Air Pollution Control Officers Association, explored various approaches
for establishing a significance threshold for GHG emissions. The draft interim CEQA thresholds guidance
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document was not adopted or approved by the Governing Board. However, in December 2008, the SCAQMD
adopted an interim 10,000 MT CO2e per-year screening level threshold for stationary source/industrial
projects for which the SCAQMD is the lead agency (see SCAQMD Resolution No. 08-35, December 5, 2008).
The 10,000 MT CO2e per-year threshold, which was derived from GHG reduction targets established in
Executive Order (EO) S-3-05, was based on the conclusion that the threshold was consistent with achieving
an emissions capture rate of 90% of all new or modified stationary source projects.
The SCAQMD formed a GHG CEQA Significance Threshold Working Group to work with SCAQMD staff on
developing GHG CEQA significance thresholds until statewide significance thresholds or guidelines are
established. From December 2008 to September 2010, the SCAQMD hosted working group meetings and
revised the draft threshold proposal several times, although it did not officially provide these proposals in
a subsequent document. The SCAQMD has continued to consider adoption of significance thresholds for
residential and general land use development projects. The most recent proposal issued by SCAQMD,
issued in September 2010, uses the following tiered approach to evaluate potential GHG impacts from
various uses (SCAQMD 2010):
Tier 1. Determine if CEQA categorical exemptions are applicable. If not, move to Tier 2.
Tier 2. Consider whether or not the proposed project is consistent with a locally adopted GHG reduction
plan that has gone through public hearing and CEQA review, that has an approved inventory, includes
monitoring, etc. If not, move to Tier 3.
Tier 3. Consider whether the project generates GHG emissions in excess of screening thresholds for
individual land uses. The 10,000 MT CO2e per-year threshold for industrial uses would be recommended
for use by all lead agencies. Under option 1, separate screening thresholds are proposed for residential
projects (3,500 MT CO2e per year), commercial projects (1,400 MT CO2e per year), and mixed-use projects
(3,000 MT CO2e per year). Under option 2, a single numerical screening threshold of 3,000 MT CO 2e per
year would be used for all non-industrial projects. If the project generates emissions in excess of the
applicable screening threshold, move to Tier 4.
Tier 4. Consider whether the project generates GHG emissions in excess of applicable performance
standards for the project service population (population plus employment). The efficiency targets were
established based on the goal of Assembly Bill (AB) 32 to reduce statewide GHG emissions to 1990 levels
by 2020. The 2020 efficiency targets are 4.8 MT CO 2e per-service population for project-level analyses and
6.6 MT CO2e per-service population for plan-level analyses. If the project generates emissions in excess of
the applicable efficiency targets, move to Tier 5.
Tier 5. Consider the implementation of CEQA mitigation (including the purchase of GHG offsets) to reduce
the project efficiency target to Tier 4 levels.
ificant
-use land
use type quantitative threshold of 3,000 MT CO2e per year. Per the SCAQMD guidance, construction
emissions should be amortized over the operational life of the proposed Project, which is assumed to be
30 years (SCAQMD 2008). Thus, this impact analysis compares estimated operational emissions plus
amortized construction emissions to the proposed SCAQMD threshold of 3,000 MT CO 2e per year.
Construction Emissions. Construction of the proposed Project would result in GHG emissions primarily
associated with the use of off-road construction equipment, on-road trucks, and worker vehicles. A
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depiction of expected construction schedules (including information regarding phasing, equipment used
during each phase, truck trips, and worker vehicle trips) assumed for the purposes of emissions estimation
is provided in Appendix A of this IS/MND. On-site sources of GHG emissions include off-road equipment;
off-site sources include trucks and worker vehicles. Table 14 presents construction GHG emissions for the
proposed Project from on-site and off-site emissions sources.
Table 14. Estimated Annual Construction GHG Emissions
Year
CO2 CH4 N2O CO2e
Metric Tons per Year
2020 331.23 0.05 0 332.39
2021 341.60 0.04 0 342.66
Total 675.05
Amortized Over 30 Years 22.50
Source: See Appendix A for complete results.
Notes: GHG = greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
As shown in Table 14, the estimated total GHG emissions in 2020 through 2021 would be approximately
675 MT CO2e. Amortized over 30 years, construction GHG emissions would be approximately 23 MT CO 2e
per year. In addition, as with Project-generated construction criteria air pollutant emissions, GHG emissions
generated during proposed construction activities would be short-term, lasting only for the duration of the
construction period, and would not represent a long-term source of GHG emissions. Because there is no
separate GHG threshold for construction, the evaluation of significance is discussed in the operational
emissions analysis in the following text.
Operational Emissions. Operation of the proposed Project would generate GHG emissions through motor
vehicle trips to and from the project site; landscape maintenance equipment operation; energy use (natural
gas and generation of electricity consumed by the project); solid waste disposal; and generation of
electricity associated with water supply, treatment, and distribution; wastewater treatment; and natural gas
consumed by the emergency generator. GHG emissions would also be generated through intermittent
maintenance and testing of the diesel emergency generator, limited to 50 hours per year. CalEEMod was
used to calculate the annual GHG emissions. GHG emission estimates were based on the mobile source,
area source, and energy (natural gas) operational assumptions described in Section 3.3(b), within the air
quality analysis. CalEEMod default values were used to estimate GHG emissions associated with energy
(electricity) consumption, solid waste, and water and wastewater.
The estimated operational (2022) Project-generated GHG emissions from area sources, energy usage,
motor vehicles, solid waste generation, water usage and wastewater generation, and stationary sources
are shown in Table 15, Estimated Annual Operational GHG Emissions. As discussed in Section 3.3, an
emission netting analysis has been performed to account for existing emissions associated with the existing
operation of Building C.
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Table 15. Estimated Annual Operational GHG Emissions
Emission Source
CO2 CH4 N2O CO2e
Metric Tons Per Year
Proposed Project
Area 0.01 0.00 0.00 0.01
Energy 659.62 0.02 0.01 662.75
Mobile 2,686.73 0.15 0.00 2,690.47
Stationary 4.77 0.01 0.00 5.02
Solid waste 22.04 1.32 0.00 55.14
Water supply and wastewater 22.96 0.01 0.00 26.34
Total 3,396.11 1.51 0.01 3,439.73
Existing Operation (Building C)
Area 0.00 0.00 0.00 0.00
Energy 262.01 0.01 0.00 263.11
Mobile 575.64 0.03 0.00 575.51
Solid waste 5.74 0.34 0.00 14.22
Water supply and wastewater 65.75 0.02 0.01 68.80
Total 909.14 0.40 0.01 922.64
Net Change in Emissions
Area 0.01 0.00 0.00 0.01
Energy 397.61 0.01 0.01 399.64
Mobile 2,111.08 0.012 0.00 2,113.96
Stationary 4.77 0.01 0.00 5.02
Solid waste 16.30 0.98 0.00 40.92
Water supply and wastewater (42.79) (0.01) 0.00 (42.46)
Total 2,486.98 1.11 0.01 2,517.09
Amortized Construction Emissions 22.50
Operation + Amortized Construction Total 2,539.59
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent
See Appendix A for detailed results.
These emissions reflect operational year 2022.
As shown in Table 15, estimated annual net Project -generated GHG emissions would be approximately
2,517 MT CO2e per year as a result of proposed Project operations only. Estimated annual Project -
generated operational emissions in 2022 (2,517 MT CO2e per year) plus amortized Project construction
emissions (23 MT CO2e per year) would be approximately 2,540 MT CO2e per year, which would not exceed
the recommended SCAQMD threshold of 3,000 MT CO 2e per year. Therefore, in relation to the generation
significant. No mitigation is required.
b) Would the project generate conflict with an applicable plan, policy or regulation adopted for the purpose
of reducing the emissions of greenhouse gases?
Less Than Significant Impact. The City addresses GHG-reducing goals in the General Plan. The City has not
adopted a comprehensive climate action plan, and there is currently no local guidance that would be
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applicable to the proposed Project other than the General Plan. At this time, no mandatory GHG plans,
policies, regulations, or finalized agency guidelines would apply to the proposed Project. Nonetheless,
goals for 2030 or 2050 identified in EO S-3-05 and Senate Bill (SB) 32, is discussed below.
City of Arcadia General Plan Policies
-reducing
goals and policies as follows:
Goal RS-2:
Policy RS-2.1: Cooperate with the state to implement AB 32, which calls for reducing
greenhouse gas emissions to 1990 levels by 2020, and Executive Order S-3-05, which
calls for 1990 levels by 2020 and 80% below 1990 levels by 2050.
Policy RS-2.2: Reduce per capita greenhouse gas emissions to 15% below 2005 levels by
2020, and total municipal greenhouse gas emissions to 15% below 2005 levels by 2020.
Policy RS-2.3: Participate in regional strategies and plan to implement SB 375, and in
particular, use the legislatively authorized incentives, such as grants and
transportation funding and waivers to environmental assessments, to encourage infill
and transit-oriented development.
Policy RS-2.4: Pursue the strategies in the Land Use and Community Design Element
to encourage transit-oriented development in established focused areas.
Policy RS-2.5: Pursue the enhancement of bicycle and pedestrian infrastructure set
forth in the Circulation and Infrastructure Element to help decrease vehicle miles
traveled and vehicle trips.
Policy RS-2.6: Coordinate land use, circulation, and infrastructure improvement efforts
with the West San Gabriel Valley Planning Council, regional planning agencies, and
surrounding municipalities.
Goal RS-3:
carbon footprint
Policy RS-3.1: Develop a City fleet that to the extent feasible uses clean, alternative
fuel and consists of energy-efficient vehicles.
Policy RS-3.2: Incorporate energy-
Policy RS-3.3: Educate residents on methods of sustainable driving techniques such
as: reducing excessive speeding, preventing car idling, regular car maintenance for
maximizing fuel efficiency, and carpooling.
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Policy RS-3.4:
effect on air pollution and help create voluntary programs that
reduce traffic throughout the City.
-2 and RS-3. The proposed
3,000 MT CO2e per year. In addition, the proposed
Project does not prevent the City from promoting and utilizing clean forms of transportation to reduce the
-mile from the Gold Line Station
would facilitate the use of public transportation given its close proximity and pedestrian connectivity.
Southern California Association of Governments 2016 RTP/SCS
The SCAG 2016 RTP/SCS is a regional growth-management strategy that targets per capita GHG reduction
from passenger vehicles and light-duty trucks in the Southern California region pursuant to Senate Bill 375.
to attain and exceed the GHG emission-reduction targets
set forth by CARB, the 2016 RTP/SCS outlines a series of actions and strategies for integrating the
transportation network with an overall land use pattern that responds to projected growth, housing needs,
changing demographics, and transportation demands. Thus, successful implementation of the 2016
RTP/SCS would result in more complete communities with a variety of transportation and housing choices,
while reducing automobile use. With regard to individual developments, such as the proposed Project, the
strategies and policies set forth in the 2016 RTP/SCS can be grouped into the following three categories:
(1) reduction of vehicle trips and VMT; (2) increased use of alternative fuel vehicles; and (3) improved
energy efficiency. The P
Consistency with VMT Reduction Strategies and Policies.
aspect of the 2016 RTP/SCS is demonstrated via the P
with the regional growth forecast assumed in the 2016 RTP/SCS for the City. As discussed in Section 2.2
zoning for the Project site is General Commercial (C-G) with a Downtown Overlay. The proposed Project
would be compatible with the C-
result of the proposed Project are concluded to have been anticipated in the SCAG 2016 RTP/SCS growth
Increased Use of Alternative Fueled Vehicles Policy Initiative. This 2016 RTP/SCS policy initiative focuses
on accelerating fleet conversion to electric or other near zero-emission technologies. The proposed Project
would comply with the applicable 2016 CALGreen standards and would provide 37 preferred parking
spaces for fuel-efficient vehicles and 15 parking spaces for electric vehicle parking.
Energy Efficiency Strategies and Policies. The 2016 RTP/SCS goal is to actively encourage and create
incentives for energy efficiency, where possible. The proposed Project would comply with the applicable
2016 CALGreen standards.
Based on the analysis above, the proposed Project would be consistent with the SCAG 2016 RTP/SCS.
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California Air Resources Board Scoping Plan and Reduction Goals
The Climate Change Scoping Plan, approved by CARB in 2008 and updated in 2014 and 2017, provides a
adopt regulations and other initiatives to reduce GHGs. The Scoping Plan is not directly applicable to specific
projects, and it is not intended to be used for project-level evaluations.9 Under the Scoping Plan, however, there
are several state regulatory measures aimed at identifying and reducing GHG emissions. CARB and other state
agencies have adopted many of the measures identified in the Scoping Plan. Most of these measures focus on
area source emissions (e.g., energy usage, and high-GWP GHGs in consumer products) and changes to the
vehicle fleet (e.g., hybrid, electric, and more fuel-efficient vehicles) and associated fuels, among others.
Regarding consistency with Senate Bill 32 (goal of reducing GHG emissions to 40% below 1990 levels by
2030) and Executive Order S-3-05 (goal of reducing GHG emissions to 80% below 1990 levels by 2050),
there are no established protocols or thresholds of significance for that future-year analysis. However, CARB
has expressed optimism with regard to both the 2030 and 2050 goals. It states in the First Update to the
ia is on track to meet the near-term
2020 GHG emissions limit and is well positioned to maintain and continue reductions beyond 2020 as
1990 levels, CARB (2014) states the following:
This level of reduction is achievable in California. In fact, if California realizes the expected benefits of
existing policy goals (such as 12,000 megawatts of renewable distributed generation by 2020, net zero
energy homes after 2020, existing building retrofits under Assembly Bill 758, and others) it could reduce
emissions by 2030 to levels squarely in line with those needed in the developed world and to stay on track
to reduce emissions to 80% below 1990 levels by 2050.
In other words, CARB believes that the state is on a trajectory to meet the 2030 and 2050 GHG reduction
targets set forth in AB 32, Senate Bill 32, and Executive Order S-3-05. This is confirmed in the 2017 Climate
Change Scoping Plan Update, which states (CARB 2017):
The Proposed Plan builds upon the successful framework established by the Initial Scoping Plan and First
Update, while also identifying new, technologically feasibility and cost-effective strategies to ensure that
California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to
foster economic growth, and delivers improvements to the environment and public health, including in
disadvantaged communities. The Proposed Plan is developed to be consistent with requirements set forth
in AB 32, SB 32, and AB 197.
The proposed Project would not interfere with implementation of GHG reduction goals for 2030 or 2050
2e per year. In
additio
toward future GHG reductions. Therefore, the proposed Project would not conflict with an applicable plan,
policy, or regulation adopted for the purpose of reducing the emissions of GHGs; therefore, impact would
be less than significant and no mitigation is required.
9 The Final Statement of Reasons for the amendments to the CEQA Guidelines reiterates the statement in the Initial Statement of
use in determining the significance of individual projects because it
is conceptual at this stage and relies on the future development of regulations to implement the strategies identified in the
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3.9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
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?
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
d) Be located on a site that 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?
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 or excessive noise for
people residing or working in the project area?
f) Impair implementation of or physically interfere with an
adopted emergency response plan or emergency
evacuation plan?
g) Expose people or structures, either directly or indirectly,
to a significant risk of loss, injury or death involving
wildland fires?
a) Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Less Than Significant Impact. Construction would include removal and grading of existing paved surfaces,
remodeling of the existing three-story Building C, construction of a new five-story Building D, repaving
parking areas and driveways, and installation of new landscaped areas and concrete sidewalks.
Construction would require the use of heavy machinery and equipment. Potentially hazardous materials
used during construction may include gasoline, diesel fuel, lubricating oil, grease, adhesive materials,
solvents, paints, architectural coatings, and other materials that potentially contain hazardous substances.
The materials used would not be in such quantities or stored in such a manner as to pose a significant
safety or environmental hazard. Proper use, handling, and storage of materials must be conducted in
Activities at the Project site, including those conducted
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by a contractor, must comply with existing federal, state, and local regulations regarding hazardous material
use, storage, disposal, and transport to prevent Project-related risks to public health and safety. All on-site
generated waste that meets hazardous criteria shall be stored, manifested, transported, and disposed of
in accordance with federal and state requirements, inc
Rule 1403, and the California Code of Regulations, Title 22.10
Based on the age of the structures, there is a potential for hazardous building materials (i.e., asbestos-
containing materials (ACM), lead-based paint and universal wastes) to be present. Renovation of the
Building C, as well as transportation and disposal of the building materials, could cause a release of such
materials to the environment if they are present in the existing building. However, all projects that involve
commercial building renovations are required to comply with applicable federal, state, and local
requirements, as summarized below.
1. For asbestos: California Code of Regulations, Article 4, Section 1529, pertaining to Asbestos
Construction Safety Orders; SCAQMD Rule 1403; Cal/OSHA Asbestos and Carcinogen Unit; California
Department of Public Health; California Department of Resources, Recycling, and Recovery
(CalRecycle); and EPA National Emission Standards for Hazardous Air Pollutants (NESHAP).
2. For lead: California Labor Code Sections 6716 to 6717; CCR, Title 8, Section 1532.1 et seq.; CCR,
Title 17, Section 35001 et seq.; Los Angeles County Environmental Health Lead Program; California
Department of Public Health; and EPA Lead Renovation, Repair, and Painting Rule.
3. For universal wastes: Department of Toxic Substances Control (DTSC) universal waste rules;
CalRecycle; and EPA Solid Waste Rules (40 CFR Part 273)
Operation of the proposed Project would include use of minor quantities of commercially available
hazardous materials, such as paints, lubricants, pool cleaners/chlorine, and cleaning materials. These
materials are not considered acutely hazardous and are used routinely throughout urban environments for
operation of commercial businesses. Handling, storage, and disposal of these hazardous materials would
comply with all federal, state, and local requirements, including training of operational staff on proper
handling. The proposed Project would not create a significant hazard to the public or the environment
through the routine transport, use, or disposal of hazardous materials, and no mitigation is required.
b) Would the project 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?
Less Than Significant Impact. Building C on the Project site would be renovated to convert from office uses
to hotel uses. Based on information obtained from Los Angeles County Office of the Assessor (LA County
2019), Building C was constructed in 1978-1979. Based on a review of historic aerials and topographic
maps (NETR 2019a, 2019b, 2019c), Colorado Place is part of the historic Route 66, which was constructed
adjacent to the Project site in 1941. The Project site appears to have been developed as early as 1941,
with various commercial structures. Two small structures were previously located on the eastern portion of
the Project site beginning in the 1940s; these were removed in the 1970s to accommodate construction
of the current Building C. The western portion of the Project site was developed with a commercial structure
beginning in the 1950s, which was removed in 2009, with subsequent construction of the existing medical
office buildings and parking structure in 2015.
10 California Code of Regulations, Title 22, Division 4.5 Environmental Health Standards for the Management of Hazardous Waste.
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California Government Code Section 65962.5 requires that information regarding environmental impacts
of hazardous substances and wastes be maintained and provided at least annually to the Secretary for
Environmental Protection. Commonly referred to as the Cortese List, this information must include the
following: sites impacted by hazardous wastes, public drinking water wells that contain detectable levels of
contamination, underground storage tanks with unauthorized releases, solid waste disposal facilities from
which there is migration of hazardous wastes, and all cease and desist and cleanup and abatement orders.
While the Cortese List is no longer maintained as a single list, the following databases provide information
that meet the Cortese List requirements:
List of Hazardous Waste and Substances sites from DTSC Envirostor database (Health and Safety
Codes 25220, 25242, 25356, and 116395);
List of Leaking Underground Storage Tank (LUST) Sites by County and Fiscal Year from the State Water
Resources Control Board (Water Board) GeoTracker database (Health and Safety Code 25295);
List of solid waste disposal sites identified by the Water Board with waste constituents above
hazardous waste levels outside the waste management unit (Water Code Section 13273
subdivision (e) and California Code of Regulations Title 14 Section 18051));
(Water Code Sections 13301 and 13304); and
List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the
Health and Safety Code, identified by DTSC.
Dudek conducted a search of the online databases that provide information on Cortese List sites. The
Project site was not identified in any of the Cortese List databases. Nearby properties were identified on
the DTSC and Water Board databases, and are discussed in the subsections below. No nearby properties
were identified on the active Cease and Desist Orders/Cleanup and Abatement Orders list, nor on the
corrective action list created by DTSC, and no solid waste disposal sites were identified on GeoTracker
within one half mile of the Project site.
DTSC EnviroStor Database. Dudek identified one site located within 0.5-mile of the Project site. The former
Santa Anita Ordnance Training Center, a Former Used Defense Site, which was formerly located near the
Project site to the west, in the location of the existing horse race track, Westfield Santa Anita mall, and
residential properties. An assessment completed in 1995 determined that no action was required to
evaluate the potential for threat of former ordnances, based on the fact that the site has been fully
redeveloped and is extensively used by the public (DERP 1995). Based on this information, it is unlikely
that this site has impacted the environmental conditions of the Project site.
Water Board GeoTracker Database. Five LUST sites were identified within 0.5- mile of the Project site. Four
of the sites have been closed and received a No Further Action (NFA) designation from the Regional Water
Quality Control Board. The remaining open case file is for the Santa Anita Park, 285 West Huntington Drive.
While the site address (i.e., site entrance) is located 0.3-mile southeast of the Project site, the actual former
LUST is located 0.65-mile west of the Project site. The site has been fully investigated, remediated, and site
closure was requested in November 2018 (GSI 2018). Based on the information provided, it is unlikely that
the environmental condition of the Project site has been impacted by these nearby sites.
In addition to the Cortese List databases, Dudek consulted available online databases that provide
environmental information on facilities and sites in the State of California. These databases include the
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CalEPA Regulated Site Portal; National Pipeline Mapping System; and California Division of Oil, Gas, and
Geothermal Resources (DOC DOGGR) online well finder. Five sites were identified on the CalEPA Site Portal
within 0.5- mile of the Project site. Of these sites, one was identified as a LUST, which was also identified
on the Water Board GeoTracker database as discussed above. The remaining listings appeared to be for
administrative and permitting purposes, and do not necessarily indicate a release of hazardous materials
to the environment. No findings were identified on the National Pipeline Mapping System database within
one mile of the Project site. One idle oil and gas well was identified on DOC DOGGR within one mile of the
Project site, approximately 0.85-mile to the southeast (DOC DOGGR 2019). Reportedly, the well was
abandoned in 1926. Based on the information provided, it is unlikely that the environmental condition of
the Project site has been impacted by these nearby sites.
As discussed under Section 3.9(a), construction would involve relatively small amounts of commonly used
hazardous substances such as gasoline, diesel fuel, lubricating oil, grease, adhesive materials, solvents,
and architectural coatings. These materials are not considered acutely hazardous and are used routinely
throughout urban environments for both construction projects and building renovation projects. Further,
these materials would be transported, stored, and handled in accordance with all federal, state, and local
laws regulating the management and use of hazardous materials. In addition, construction staff would be
trained in spill and release response, as applicable. For these reasons, construction of the proposed Project
is not anticipated to release hazardous materials into the environment that would pose a threat to human
health or the environment.
Operation of the proposed Project would include use of minor quantities of commercially available
hazardous materials, such as paints, lubricants, and cleaning materials. These materials are not
considered acutely hazardous and are used routinely throughout urban environments for operation of
commercial businesses. Handling, storage, and disposal of these hazardous materials would comply with
all federal, state, and local requirements, including training of operational staff on use, handling, and spill
response. The proposed Project would not create a significant hazard to the public or the environment
through the reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment, and no mitigation is required.
c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school?
Less Than Significant Impact. There are three schools within the general vicinity of the Project site: Barnhart
School, located approximately 0.15-mile north of the Project site; Excelsior School, located approximately
0.16-mile east of the Project site; and First Avenue Middle School, located approximately 0.37-mile
southeast of the Project site. None of these schools are located adjacent to the Project site. As discussed
in Section 3.9(a), Project construction would involve relatively small amounts of commonly used hazardous
substances such as gasoline, diesel fuel, lubricating oil, grease, adhesive materials, solvents, paints and
architectural coatings. In the event of an accidental release of fuels, oils, lubricants, or other hazardous
materials associated with construction, hazardous emissions could occur within a quarter mile of a school.
All spills would be quickly contained and cleaned up. Potential effects would be temporary and localized.
Hazardous substances would be transported and handled in accordance with all federal, state, and local
laws regulating the management and use of hazardous materials. Use of these materials for their intended
purpose and in accordance with applicable safety laws would not pose a significant risk to nearby schools.
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As discussed in previous sections, operation of the proposed Project would include use of minor quantities of
commercially available hazardous materials, which are not considered acutely hazardous and are used
routinely throughout urban environments for operation of commercial businesses. Handling, storage, and
disposal of these hazardous materials would comply with all federal, state, and local requirements.
Operational staff would be trained in handling, storage, and spill response techniques to avoid a release that
would impact surrounding properties, including nearby schools. Therefore, Project operations would not pose
a hazard to schools involving hazardous emissions or the handling of hazardous or acutely hazardous
materials, substances, or waste. Impacts would be less than significant and no mitigation is required.
d) Would the project be located on a site that 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?
No Impact. As explained in Section 3.9(b) above, the Project site is not located on or adjacent to a
hazardous material site as described in Government Code Section 65962.5. Therefore, no hazardous
materials are expected to be present, and no impact would occur.
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 or excessive
noise for people residing or working in the project area?
No Impact. The Project site is not located within two miles of a public or public use airport, nor is it located
within an airport land use plan. Therefore, no safety hazard or excessive noise risk would be present, and
no impact would occur.
f)Would the project impair implementation of or physically interfere with an adopted emergency response
plan or emergency evacuation plan?
No Impact. The City of Arcadia General Plan includes a Safety Element Chapter, which addresses community
safety for environmental hazards, human caused hazards, threats to national security, emergency services,
and emergency preparedness (City of Arcadia 2010b). In addition, Los Angeles County Department of Public
Works (LADPW) has designated disaster evacuation routes for the City of Arcadia. Colorado Place and
Huntington Drive, both located adjacent to the Project site, are designated disaster routes. Construction of
the proposed Project would not require road closures in public right-of-ways of Colorado Place or Huntington
Drive. Therefore, emergency service response times and disaster evacuation routes would not be affected.
Prior to operation, the proposed Project would receive all required permits and certificates for occupancy and
operation, including those issued by the City of Arcadia Fire Department, which is the agency in charge of
emergency response at the Project site. Therefore, no interference or impairment of the emergency response
or emergency evacuation plans would occur, and no impact would occur.
g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury,
or death involving wildland fires?
No Impact. The Project site is not located within a Very High Fire Hazard Severity Zone (VHFHSZ). The
nearest VHFHSZ is located approximately one mile north of the Project site. Additionally, the Project site is
located in an urbanized environment with little potential for wildland fires. Therefore, no exposure to
wildland fires would be present, and no impact would occur.
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3.10 Hydrology and Water Quality
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
c) Substantially alter the existing drainage pattern of the
site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on or
off site;
ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on or off site;
iii) 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; or
iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk release
of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
a) Would the project violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality?
Less Than Significant Impact. A significant impact would occur if the proposed Project would discharge
water that did not meet the water quality standards established by the SWRCB NPDES and waste discharge
requirement permit programs, and the Los Angeles Regional Water Quality Control LARWQCB) Los
Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan;
LARWQCB 2019). The proposed Project is not anticipated to violate any water quality standard or waste
discharge requirement during construction and operation, for the reasons described below.
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Construction
Construction General Permit. Renovation and remodeling of the three-story structure (Building C) and the
construction of a new five-story structure (Building D) would disturb a large portion of the Project site.
Grading and excavation activities would result in soil disturbance, which could potentially increase
sediment loads in stormwater runoff by eroding soils newly loosened by construction activities. Additionally,
the proposed Project could adversely affect water quality through the accidental spills and leaks of
construction-related pollutants such as petroleum products from construction vehicles.
However, the proposed Project would comply with the provisions of the Construction General Permit (CGP),
which is NPDES General Permit for Storm Water Associated with Construction Activities (Order No 2009-
009-DWQ as amended by 2010-0014-DWQ and 2012-0006-DWQ, NPDES No. CAS000002). Because the
proposed Project is greater than 1 acre in size, the Applicant would be required to submit a Notice of Intent
to the LARWQCB in order to obtain approval to complete construction activities under the CGP. This permit
would include a number of design, management, and monitoring requirements for the protection of water
quality and the reduction of construction phase impacts related to stormwater (and some non-stormwater)
discharges. Permit requirements would include the preparation of a SWPPP, implementation and
monitoring of BMPs, implementation of best available technology for toxic and non-conventional pollutants,
implementation of best conventional technology for conventional pollutants, and periodic submittal of
performance summaries and reports to the LARWQCB. The SWPPP would apply to the Project as a whole
and would include reference to the major construction areas, materials staging areas, and haul roads.
Typical BMPs that could be incorporated into the SWPPP include the following:
Diverting off-site runoff away from the construction site
Vegetating landscaped/vegetated swale areas as soon as feasible following grading activities
Placing perimeter straw wattles to prevent off-site transport of sediment
Using drop inlet protection (filters and sand bags or straw wattles), with sandbag check dams within
paved areas
Regular watering of exposed soils to control dust during demolition and construction
Implementing specifications for demolition/construction waste handling and disposal
Using contained equipment wash-out and vehicle maintenance areas
Maintaining erosion and sedimentation control measures throughout the construction period
Stabilizing construction entrances to avoid trucks from imprinting soil and debris onto City roadways
Training, including for subcontractors, on general site housekeeping
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A Municipal Code, Chapter 8, Part 2, Section
7827 and 7828, which requires that each operator of any construction activity submit evidence to the City
that all applicable permits have been obtained, including but not limited to the State Water Board's CGP and
a Low Impact Development (LID) plan.11 Given the above, the proposed Project would have a less than
significant impact on water quality standards and waste discharge requirements and would not otherwise
substantially degrade surface or groundwater quality during construction. As a result, no mitigation is required.
Operations
Stormwater Management and Discharge Control. The purpose of th
Section 7800 of the Municipal Code, is to ensure the future health, safety, and general welfare of citizens
by: (a) eliminating non-stormwater discharges to the municipal separate storm drain; (b) controlling the
discharge from spills, dumping or disposal of materials other than stormwater to municipal separate storm
drains; and (c) reducing pollutants in stormwater discharges to the maximum extent practicable. Section
7820 of the Municipal Code prohibits the discharge of non-
The proposed Project would
a
anticipated to violate any water quality standard or waste discharge requirement during operation.
Low Impact Development Features. In the City of Arcadia, all development and redevelopment projects
must comply with the latest County of Los Angeles Department of Public Works LID Standards Manual
(County of Los Angeles 2004). The LID Standards Manual complies with the requirements of the NPDES
Municipal Separate Storm Sewer System (MS4) Permit for stormwater and non-stormwater discharges from
the MS4, within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012-0175),
referred to as the 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation
of stormwater quality control measures in new development and redevelopment projects with the intention
of improving water quality and mitigating potential water quality impacts from stormwater and non-
stormwater discharges (County of Los Angeles 2014). A preliminary LID Plan, included as Appendix D, was
prepared for the Project in July 2019 by Lin Consulting.
According to the LID Plan (Appendix D), the Project site is comprised of roughly 5% pervious and 95% impervious
area under existing conditions. Upon operation of the proposed Project, the site would be approximately 15%
pervious and 85% impervious, which would result in increased stormwater infiltration and groundwater
percolation and less surface runoff. Therefore, this Project falls into redevelopment of a previously developed
site in an urbanized area that does not increase the effective impervious area or decrease the infiltration
capacity of pervious areas compared to the pre-project conditions. Project design, construction, and operation
would be completed in accordance with the LID Standards Manual and with the Project-specific LID Plan, with
the goal of reducing the amount of pollutants in stormwater and urban runoff. The LID Plan includes permanent
control measures to reduce the long-term impacts of the Project on water quality and the tributary waterways.
The LID Plan would use site design and storm -development
-development hydrology by
11 City of Arcadia Municipal Code, Chapter 8, Part 2, Section 7800 Stormwater Management and Discharge Control
City of Arcadia Municipal Code, Chapter 8, Part 2, Section 7827 Control of Runoff Required Construction Activity.
City of Arcadia Municipal Code, Chapter 8, Part 2, Section 7828 Low Impact Development Control of Runoff Required for
Planning Priority Projects.
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using design techniques that filter, store, evaporate, and detain runoff close to the source of rainfall. Some
examples of these LID measures that would be incorporated into the Project include:
Utilizing the existing 35- and 44-unit stormwater filtration chambers so as to retain and treat
stormwater resulting from the design storm (i.e., 85th percentile, 24-hour rain event), until it is
infiltrated into the ground.
Providing new biofiltration areas for existing and proposed site drainages so as to capture and treat
surface runoff.
Utilizing permeable pavement so as to increase the volume of rainwater percolation (thereby
reducing surface runoff), prior to discharge into the existing stormwater filtration chambers.
Per the LID Manual, the Project must retain the stormwater quality design volume (on site through
infiltration, evapotranspiration, stormwater runoff harvest and reuse, or a combination thereof, unless it is
demonstrated that it is technically infeasible to do so. The stormwater quality design volume is defined as
the greater of the 0.75-inch, 24-hour rain event, or the 85th percentile, 24-hour rain event, as determined
from the Los Angeles County 85th percentile precipitation isohyetal map.
Compliance with the SWPPP and the Project-specific recommended LID features (Appendix D) would ensure
that the Project would not violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or groundwater quality. As such, Project impacts would be less than
significant and no mitigation is required.
b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater
recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact. The proposed Project is consistent with the General Plan and does not require
a General Plan Amendment;
anticipated in local and regional planning documents, including the Urban Water Management
Plan (UWMP). As stated in the UWMP (City of Arcadia 2016b), the projected populations used in the UWMP
demographic trends, existing land use, general plan land use policies, and input and projections from the
Department of Finance and the U.S. Census Bureau.
As stated in the UWMP, the Main Basin and Raymond Basin have been well managed for the full period of
their respective adjudications, resulting in a stable and reliable water supply for the City during average,
single-dry, and multiple-dry water years (City of Arcadia 2016b). Additionally, imported water from
Metropolitan Water District of Southern California (MWD) can be utilized as a supplemental source of
supplies. City water conservation efforts will continue into the future to reduce water demands within the
City due to the recently implemented tiered water rate and Water Smart program, which are intended to
encourage conservation, thereby making local supplies more reliable.
According to the UWMP, the City can sustainably pump 19,500 gallons per minute (gpm) from available
groundwater supplies (15,200 gpm from the Main Basin and 4,300 gpm from the Raymond Basin). If the City
pumps more water than the allotted amount, replacement water must be purchased from the MWD for
spreading and recharging the Main San Gabriel Groundwater Basin; however, the City has not had to rely on
any imported water supplies since the 2009-2010 fiscal year (City of Arcadia 2016b). In addition to
groundwater and imported water supplies, the City may pre-purchase water for cyclic storage for later use.
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Furthermore, according to the UWMP, the Main Basin has the capacity to store approximately 8.7 million acre-
feet of water, while historic basin operations have only ever reached a maximum of one million acre-feet
(UWMP 2016a). Per the UWMP, the City does not experience water supply constraints or deficiencies and
projects having adequate supply through the planning year 2040. The proposed Project would not include any
through 2040. As such, the proposed Project would not substantially decrease groundwater supplies such
that the project may impede sustainable groundwater management of the basin.
Because the Project site is currently fully developed with impervious paving, with only negligible areas of
pervious surfaces for ornamental landscaping, the addition of the new development would have a nominal
impact on groundwater recharge; if anything, the proposed Project would result in a slight increase in
groundwater recharge due to the anticipated 10% increase in pervious area anticipated under the proposed
Project. Therefore, the proposed Project would have a less than significant impact to groundwater supplies,
would not interfere substantially with groundwater recharge, and no mitigation is required.
c) Would the project substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would:
i) result in substantial erosion or siltation on or off site;
Less Than Significant Impact. The proposed Project is currently fully (95%) developed with
impervious paving, with only negligible areas (5%) of pervious surfaces for ornamental landscaping.
The addition of the new development would not substantially alter the existing drainage pattern of
the site or area and would increase the amount of pervious surfaces by 10%, thus resulting in
decreased runoff. The Project site currently includes minor parking lot drainage swales, with no
creeks or major drainages traversing the site. As previously discussed, during construction, erosion-
control measures would be implemented as part of the SWPPP for the Project, consistent with the
requirements of the CGP (Order No 2009-009-DWQ as amended by 2010-0014-DWQ and 2012-
0006-DWQ, NPDES No. CAS000002) or the latest approved general permit.
As stated above, for the long-
Municipal Code Sections 7800 et seq., which would address stormwater runoff and water quality.
Stormwater flows from the Project site would continue to flow into the existing storm drain
infrastructure adjacent to the Project site.
As stated in Section 3.10(a) above, Project design, construction, and operation would be completed
in accordance with the LID Standards Manual and with the Project LID Plan (Appendix D), with the
goal of reducing the amount of pollutants in stormwater and urban runoff. The LID Plan includes
permanent control measures to reduce the long-term impacts of the Project on water quality and
the tributary waterways. The LID Plan would use site design and stormwater management in order
-development runoff rates and volumes. The goal of the LID Plan would
-development hydrology by using design techniques that filter, store,
evaporate, and detain runoff close to the source of rainfall. With adherence to the SWPPP and the
Project LID Plan, on- and off-site erosion and siltation would be reduced to a less-than-significant
level. No mitigation is required.
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ii) substantially increase the rate or amount of surface runoff in a manner which would result in
flooding on or off site;
Less Than Significant Impact. The new Building D would implement the BMPs outlined in the LID
Plan, which are intended -development hydrology by using design techniques
that filter, store, evaporate, and detain runoff close to the source of rainfall. The recommended LID
features would, as much as feasibly possible, minimize impervious surfaces, use landscape a
drainage feature, and improve drainage facilities to decrease the potential of flooding on and off
site. With these features implemented, the development of Building D is not anticipated to result
in an increase of surface runoff and associated likelihood of flooding. In regards to the renovation
and remodeling of Building C, the development would minimally alter the drainage patterns of the
site and thus would not increase the rate or amount of surface runoff or flooding on or off site.
Rather, the proposed Project would result in an overall 10% increase in pervious area on site, and,
as such, would increase the volume of stormwater infiltration and percolation, as well as decrease
the rate and volume of surface runoff on the Project site, thereby reducing the likelihood for
flooding on or off site when compared to existing conditions. As such, the Projects impacts related
to runoff that could result in flooding on site or off site would be less than significant, and no
mitigation is required.
iii) 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; or
Less Than Significant Impact. As previously discussed, during construction, erosion-control measures
would be implemented as part of the SWPPP for the Project, consistent with the requirements of the
CGP (Order No 2009-009-DWQ as amended by 2010-0014-DWQ and 2012-0006-DWQ, NPDES No.
CAS000002) or the latest approved general permit. The site-specific SWPPP would ensure that runoff
during construction would not exceed the capacity of existing or planned stormwater infrastructure.
In addition, implementation of the Project LID Plan (Appendix D) would mitigate and minimize post-
-development hydrology by filtering,
storing, evaporating, and detaining water. With these features, the proposed Project would not create
or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage
systems or provide substantial additional sources of polluted runoff. Project impacts would be less
than significant and no mitigation is required.
iv) impede or redirect flood flows?
No impact. There are no drainages, creeks, or streams on the Project site and no flows would be
diverted, impeded, or redirected due to the proposed Project.
d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
Less Than Significant Impact. No areas within the City of Arcadia are designated 100-year flood zones (City
of Arcadia 2010a). According to the Federal Emergency Management Agency (FEMA), the Project is located
within Zone X, which is an area of Minimal Flood Hazard (FEMA 2008). Therefore, the Project site is not
located within an area that would be subject to flooding.
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The Project is, however, located in the Santa Anita Dam flood inundation zone. Approximately half of the
City of Arcadia is located within the dam inundation zone. Failure of the Santa Anita Dam would lead to
inundation of a large eastern section of the City. At capacity, floodwaters from the dam would travel down
Santa Anita Canyon to about Orange Grove Avenue and then spread across the eastern half of the city from
Arcadia Wash. To comply with state dam safety regulations, the water level behind the dam is restricted to
be no higher than an elevation of 1,230 feet above mean sea level, to meet the California Division of Safety
of Dams seismic safety requirements and to reduce the potential magnitude of downstream flooding (City
of Arcadia 2010a). Seismic retrofit of the Santa Anita Dam, which was built in 1927, was scheduled to
begin in 2019 to improve public safety and prevent flood damage to downstream communities (LADPW
2018b). Dam failure potential is low and the extent of inundation would depend on the amount of water
stored at the time of failure. Seismic upgrades will reduce the potential for flooding at the Project site.
The Project site is not located near a body of water or close to the ocean and as a result, is not susceptible to
tsunamis or seiches. In the unlikely event that the site were to be flooded as a result of dam failure, the risk of
release of pollutants due to inundation is low, as the proposed site uses (i.e., hotel) would not include storage of
hazardous materials or hazardous waste. Therefore, Projects impacts would be less than significant.
e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan?
Less Than Significant Impact. The Basin Plan for the Coastal Watersheds of Los Angeles and Ventura
Counties is the Water Quality Control Plan (WQMP) for the Los Angeles Region, which includes the City of
Arcadia. The Basin Plan: (i) identifies beneficial uses for surface waters and groundwaters, (ii) includes the
narrative and numerical water quality objectives that must be attained or maintained to protect the
designated beneficial uses and conform to the state's anti-degradation policy, and (iii) describes
implementation programs and other actions that are necessary to achieve the water quality objectives
established in the Basin Plan (LARWQCB 2019). The existing, potential or intermittent beneficial uses for
the Arcadia Wash, the Santa Anita Wash, and the Rio Hondo Channel, where stormwaters from the City are
discharged and for the underlying groundwater basins in the City (Raymond and San Gabriel Valley
groundwater basins) include: domestic water supply (MUN); industrial activities (IND); industrial process
dependent upon water quality (PROC); agricultural supply (AGR); groundwater recharge (GWR); Water
Recreation (REC-1, REC-2); warm water ecosystems (WARM); cold water ecosystems (COLD); terrestrial
ecosystems (WILD); rare, threatened or endangered species (RARE); and wetland ecosystems (WET)
(LARWQCB 2019).
With compliance with applicable regulations, the proposed Project does not include any facilities or land
uses that could generate pollutants that could result in substantial water quality impacts. As discussed in
Threshold 3.10(a), compliance with t the
water quality of watercourses in a manner pursuant to and consistent with the Federal Clean Water Act,
and pursuant to the NPDES CGP No. 2009-0009-DWQ. Restrictions in this Ordinance are applicable to both
construction activities and operations. Additionally, compliance with CGP issued by the SWRCB would
require implementation of BMPs during construction to address the potential for pollutants from entering
violate any water quality standards or waste discharge
requirements or otherwise substantially degrade surface water or groundwater quality would be less than
significant and no mitigation is required.
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groundwater basin prioritization in accordance with the requirements of the Sustainable Groundwater
Management Act and related laws. The act requires that groundwater resources be managed sustainably
for long-term reliability and multiple benefits for current and future beneficial uses. The Sustainable
Groundwater Management Act applies to all California groundwater basins and requires that high- and
medium-priority groundwater basins form Groundwater Sustainability Agencies (DWR 2019). DWR is
required to pri
very low. The San Gabriel Basin Valley, which underlies the City of Arcadia, was determined by DWR to be
rements to form a Groundwater Sustainability
Agency and to develop a Groundwater Sustainability Plan.
As previously discussed, the SWPPP and LID features would reduce in
accordance with all applicable federal, state, and local requirements. Additionally, the Project would be
consistent with the assumptions set forth in UWMP, as discussed in section (a). As a
result, the Project would not conflict with or obstruct implementation of a water quality control plan or
and no mitigation is required.
3.11 Land Use and Planning
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Physically divide an established community?
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
a) Would the project physically divide an established community?
No Impact. The proposed Project would include the conversion of an existing building to a 76,754 square-
foot hotel and the construction of one new 61,538-square-foot hotel annex building. The Project site is
surrounded by low density residential to the north; commercial land uses to the east, recreational, hotel,
and commercial land uses to the south, and horse racing land uses to the south and west. The proposed
Project would not include the construction of any buildings, roads, or other infrastructure that would
physically divide an established community, nor would it impede access between existing neighborhoods
and other areas of the City by creating physical barriers. Rather, the proposed Project would redevelop a
portion of an existing commercial site and would provide hospitality amenities to the surrounding
community and to the City at large. As such, the proposed Project would not divide an established
community and no impact would occur. No mitigation is required.
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b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy,
or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant Impact. Land use plans and policies applicable to the proposed Project are set forth
through which development in the City is organized and carried out. The Project site is zoned General
Commercial (G-C) with a Downtown Overlay. Permitted uses under the Commercial land use designation
consist of an array of commercial enterprises, including restaurants, durable goods sales, food stores,
lodging and professional offices (City of Arcadia 2010b).
The C-G Zone is intended to provide areas for the development of retail and service uses, offices,
restaurants, public uses, and similar and compatible uses (City of Arcadia 2016a). The maximum Floor Area
Ratio (FAR) permitted under the C-G Zone and under the Downtown Overlay Zone is 1.0 for new
development and the maximum height permitted for new buildings is 48 feet. The proposed Project would
have a FAR of 0.85 and thus would be compatible with the C-
However, the proposed Project would include a five-story, building (Building D), which would be in
height above average grade. Given the 48-foot height restriction, the Project would be subject to a height
variance, to be reviewed concurrently with Project approvals. Additionally, Project approval would be subject
to a CUP, which is required in order to develop hotel land uses in the C-G Zone.
land use and zoning designations and would have a less than significant impact on any land use plan,
policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. No mitigation
is required.
3.12 Mineral Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
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?
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?
a) Would the project 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?
No Impact. Historically, the City has mined aggregate mineral resources, namely sand, gravel and crushed
-
Consumption region, where more than 10 million tons of aggregate resources were produced in 2005 (City
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of Arcadia 2010a
is on the continued reclamation of prior quarries and the protection of properties in Arcadia from mining
operations in adjacent communities (City of Arcadia 2010a). Per the Surface Mining and Reclamation Act
of 1975, which mandated the classification of mineral lands by the State Geologist, the Project site is
classified as a Mineral Resource Zone (MRZ-) 4. MRZ-4 zones are classified as areas where there is
insufficient data to assign another designation. Additionally, only one idle oil and gas well, approximately
0.85-mile to the southeast of the Project site was identified on DOC
the well was abandoned in 1926 (DOC DOGGR 2019).
The Project site is fully developed and paved under existing conditions, and, as such, does not support any
mineral or oil and natural gas
the proposed Project site is within an MRZ-4 Zone, which is defined as an area where there is not enough
information to assign another designation. Additionally,
Element maintains that no properties in Arcadia will be subject to mining activities in the future and, as
rties in
Arcadia from mining operations in adjacent communities (City of Arcadia 2010b).
Given that: the proposed Project site and surrounding land uses are fully developed; the City does not
anticipate future mining activities in the City; and, given the absence of known, significant mineral
resources as mapped by the state, project implementation would not result in the loss of availability of a
known mineral resource. The Project would not 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 and no mitigation is required.
b) Would the project 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?
No Impact. -4 zone, which is defined
as an area where there is not enough information to assign another designation. The Project site is zoned
C-G, which d
Sustainability Element maintains that no properties in Arcadia will be subject to mining activities in the
ed reclamation of prior quarries and the protection of
properties in Arcadia from mining operations in adjacent communities (City of Arcadia 2010b). Given the
above, the proposed Project would not result in the loss of availability of a locally important mineral resource
recovery site delineated on a local general plan. The Project would not 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 and no mitigation is required.
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3.13 Noise
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the
project in excess of standards established in the local
general plan or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private
airstrip or 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?
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise
levels in the vicinity of the project in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies?
Less Than Significant Impact. n,
the established maximum exterior noise standard for residential land use areas is 65 dBA CNEL [decibel
(dB) level as measured with a sound-level meter using the A weighting network]. No exterior noise standard
is set for hotels; however, the interior noise standard is 45 dBA CNEL (Community Noise Equivalent Level).
The Arcadia Municipal Code addresses noise in several sections. In Article IV, Part 1, General Provisions,
from stationary noise
sources within residential land uses from 7:00 a.m. to 10:00 p.m.; from 10:00 p.m. to 7:00 a.m., the noise
limit is 50 dBA
Municipal Code stipulates that nighttime construction between the hours of 6:00 p.m. and 7:00 a.m. of any
weekday, 5:00 p.m. and 8:00 a.m. on Saturday, and anytime on Sunday and holidays is prohibited.
Existing Noise Conditions
Noise measurements were conducted on and near the Project site in June 2019 to characterize the existing
noise levels. Noise measurements were conducted at four locations on the Project site and at nearby noise-
sensitive land uses to determine the approximate ambient daytime noise levels. One additional noise
measurement was conducted to approximate the ambient daytime and nighttime noise levels for the
Project location. The locations of the short-term monitoring on 24-hour monitoring locations are shown in
Figure 7, Noise Measurement Locations.
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The short-term noise measurements were conducted on June 11, 2019 between 10:46 a.m. and 12:10
p.m. and are included in Appendix E of this IS/MND. These four daytime, short-term (1 hour or less)
attended sound level measurements were taken with a Piccolo SoftdB sound-level meter. This sound-level
meter meets the current American National Standards Institute standard for a Type 2 (general-purpose)
sound-level meter. The sound-level meter was positioned at a height of approximately 5 feet above the
ground. The measured daytime average sound levels ranged from 54 to 69 dBA, as depicted in Table 16,
Ambient Measured Noise Levels. The measurement results are in terms of the time-averaged equivalent
noise level (Leq).
Table 16. Ambient Measured Noise Levels
Site Location
Sound Level
(dBA Leq) Noise Sources
Daytime Short-Term Noise Measurements
ST1 On-Site: Existing parking lot on
east side of proposed Project
site (near proposed pool area
and Building D).
61.9 Traffic noise, birds
ST2 Single-family residential north of
Project site; 101 Santa Cruz Road
58.9 Traffic noise, distant traffic,
birds
ST3 Single-family residential north-
northwest of Project site; 117
Santa Cruz Road
54.4 Traffic noise, distant traffic,
distant landscaping activities,
birds
ST4 Northwest corner of Arcadia Park,
near intersection of West
Huntington Drive and Santa Clara
Street
66.2 Traffic noise, birds
Daytime and Nighttime 24-Hour Noise Measurements
LT1 Project site; near façade of
proposed Building C
Daytime Noise Measurementsa
Range: 59.8 65.2
Average: 62.8
Attendant was not present;
however, based on daytime
observations noise could be
attributed primarily to traffic
Attendant was not present;
however, based on daytime
observations noise could be
attributed primarily to traffic
Nighttime Noise Measurementsb
Range: 45.3 62.3
Average: 55.5
Overall Weighted-Average Noise
Level; 64.6 dBA CNEL
Source: See Appendix E for complete results.
Notes: dBA = A-weighted decibels; Leq = time-averaged equivalent noise level.
a Nighttime noise measurements were taken from 10:00 p.m. to 7:00 a.m.
b Daytime noise measurements were taken from 7:00 a.m. to 10:00 p.m.
The 24-hour noise measurement was conducted from June 11 to June 12, 2019. The non-attended sound
level measurements were taken with a SoftdB Piccolo sound-level meter. The sound-level meter meets the
current American National Standards Institute standard for a Type 2 (general purpose) sound-level meter.
The sound-level meter was placed on a tree located on site at a height of approximately 5 feet above the
ground. The measured daytime average sound levels (7:00 a.m. to 10:00 p.m.) ranged from approximately
60 to 65 dBA Leq, with an overall average of approximately 63 dBA L eq, as depicted in Table 16. The
measured nighttime average sound levels (10:00 p.m. to 7:00 a.m.) ranged from approximately 45 to 62
dBA Leq, with an overall average of 58 dBA Leq, as depicted in Table 16. The 24-hour weighted average
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noise level at Site LT4 was approximately 65 dBA CNEL. The measurement results are in terms of the time-
averaged sound level.
Anticipated on-site noise-generating activities associated with the proposed Project would include short-
term construction and long-term operational noise of the proposed Project, as follows:
Construction (Short-Term Impacts)
Construction noise and vibration are temporary phenomena. Construction noise and vibration levels vary
from hour to hour and day to day, depending on the equipment in use, the operations being performed,
and the distance between the source and receptor.
Construction of the overall proposed Project is anticipated to take approximately 20 months, beginning in
May 2020. Construction of the proposed Project would include demolition, site preparation, grading,
building construction, paving, and application of architectural coatings.
Equipment that would be in operation during construction would include graders, backhoes, bulldozers,
loaders, forklifts, compressors, welders, and paving equipment. The typical maximum noise levels for
various pieces of construction equipment at a distance of 50 feet are presented in Table 17 below.
Table 17. Construction Equipment Maximum Noise Levels
Equipment Type
dBA at 50 feet
dBA at 50 feet
Air compressor 81 71
Backhoe 85 80
Concrete pump 82 80
Concrete vibrator 76 70
Crane 83 75
Truck 88 80
Dozer 87 83
Generator 78 71
Loader 84 80
Paver 88 80
Pneumatic tools 85 75
Water pump 76 71
Power hand saw 78 70
Shovel 82 80
Trucks 88 83
Source: U.S. DOT 2018.
* Estimated levels obtainable by selecting quieter procedures or machines and implementing noise-control features requiring no
major redesign or extreme cost.
Note that the equipment noise levels presented in Table 17 are maximum noise levels. Typically, construction
equipment operates in alternating cycles of full power and low power, producing average noise levels less
than the maximum noise level. The average sound level of construction activity also depends on the amount
of time that the equipment operates and the intensity of construction activities during that time.
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The maximum noise levels at 50 feet for typical construction equipment would be 88 dB for the equipment
typically used for this type of development project, although the hourly noise levels would vary. Construction
noise in a well-defined area typically attenuates at approximately 6 dB per doubling of distance. Project
construction would take place both near and far from adjacent, existing noise-sensitive uses. For example,
demolition of existing pavement and re-paving activities would take place as near as approximately 25 feet
from existing residential property line (building construction would take place approximately 70 feet away),
but during construction of other components, construction would be several hundred feet away from noise
sensitive receptors and potentially shielded from direct view. Most construction activities associated with
the proposed Project would occur at distances of approximately 130 feet or more from existing noise-
sensitive uses.
was used to estimate construction noise levels at the nearest occupied noise-sensitive land use (although
the model was funded and promulgated by the FHWA, the RCNM is often used for non-roadway projects,
because the same types of construction equipment used for roadway projects are often used for other
types of construction). Input variables for the RCNM consist of the receiver/land use types, the equipment
type and number of each (e.g., two graders, a loader, a tractor), the duty cycle for each piece of equipment
(e.g., percentage of hours the equipment typically works per day), and the distance from the noise-sensitive
receiver. A conservative amount of noise reduction (5 decibels) provided by the intervening solid masonry
boundary wall (between the Project site and the residences to the north) was assumed for the construction
noise analysis. The RCNM has default duty-cycle values for the various pieces of equipment, which were
derived from an extensive study of typical construction activity patterns. Those default duty-cycle values
were used for this noise analysis.
r of
construction equipment by phase), the estimated noise levels from construction were calculated for a
representative range of distances, as presented in Table 18, Construction Noise Model Results Summary,
below. The RCNM inputs and outputs are provided in Appendix E.
Table 18. Construction Noise Model Results Summary
Construction Phase
Construction Noise at Representative Receiver Distances (dBA Leq)
Nearest Residence - Construction
Demolition and Paving, 70' Away for
other phases)
Typical Residence - Construction
Distance (Approximately 130' Away)
Demolition 86 73
Site Preparation 76 72
Grading 75 73
Building Construction 75 71
Paving 80 69
Architectural Coating 66 60
Source: Appendix E
Notes: Leq = equivalent continuous sound level
As presented in Table 18, the highest noise levels are predicted to occur during demolition activities when
noise levels from construction activities would be as high as 86 dBA Leq at the nearest existing residences,
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approximately 25 feet away. At more typical distances of approximately 130 feet, construction noise would
range from approximately 60 to 73 dBA Leq.
6:00 p.m. and
7:00 a.m. Monday Friday, 5:00 p.m. and 8:00 a.m. on Saturday, and anytime on Sunday and holidays.
Although nearby off-site residences would be exposed to elevated construction noise levels, the noise levels
would not be high enough to pose a hazard to human health12; furthermore, the exposure would be short-
term and would cease upon completion of construction.
construction activities associated with the proposed Project would take place between 7:00 a.m. and 7:00
p.m. and would not take place on Sundays or public holidays. Therefore, the proposed Project construction
would be in compliance with applicable noise regulations, and therefore construction noise would be less
than significant.
However, construction noise levels would be higher than existing ambient daytime noise levels, which could
cause temporary annoyance at nearby residential land uses. The implementation of the best practices
listed in MM-NOI-1 are provided, given the proximity to residences. The best practices included in MM-NOI-
1 would reduce the potential for annoyance from the temporary construction activities. Effectiveness of
these measures would vary from several decibels (which in general is a relatively small change) to ten or
more decibels (which subjectively would be perceived as a substantial change), depending upon the
specific equipment and the original condition of that equipment, the specific locations of the noise sources
and the receivers, etc. For example, installation of construction equipment silencers could range from
several decibels to well over 10 decibels. Reduction of idling equipment could reduce overall noise levels
from barely any reduction to several decibels. Cumulatively, the implementation of several different best
practices for noise reduction, as set forth in a site-specific Construction Noise Control Plan (CNCP) would
result in substantial decreases in the noise from construction.
MM-NOI-1 Prior to the issuance of a grading permit, the Project Applicant shall provide a Construction Noise
Control Plan (CNCP) to the City for review and approval. The CNCP shall include best management
practices to reduce short-term construction noise. Enforcement of the CNCP shall be accomplished
by field inspections during construction activities and/or documentation of compliance, to the
satisfaction of the City Development Services Department. Recommended best management
practices may include, but not be limited to, the following:
All construction equipment, fixed or mobile, shall be equipped with properly operating and
maintained mufflers .
Construction noise reduction methods such as shutting off idling equipment, maximizing the
distance between construction equipment staging areas and adjacent residences, and use of
electric air compressors and similar power tools, rather than diesel equipment, should be used
where feasible.
12 The most highly studied type of human exposure is occupational noise. Within the State of California, the Division of Occupational
Safety and Health (DOSH), better known as Cal/OSHA, protects and improves the health and safety of working men and women
in n
-hour day, which when reached or
exceeded requires the implementation of actions to reduce the risk of noise-
-hour day, 40-hour week at which
nearly all employees may be exposed without adverse health effects. Note however that these levels assume a career-long
exposure; in the case of nearby residents, the noise exposure during construction activities would be quite brief.
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Stationary equipment should be placed as far away from the adjacent residential property
boundary as feasible and positioned such that emitted noise is directed away from or shielded
from sensitive receptors. Acoustically attenuating shields, shrouds, or enclosures may be
placed over stationary equipment.
During all Project site construction, the construction contractor shall limit all construction-
related activities, including maintenance of construction equipment and the staging of haul
trucks, to between the hours of 7:00 a.m. to 6:00 p.m. Monday through Friday and 8:00 a.m.
to 5:00 p.m. on Saturday.
Construction hours, allowable workdays, and the phone number of the job superintendent
should be clearly posted at all construction entrances to allow surrounding property owners to
contact the job superintendent, if necessary. In the event the City receives a complaint,
appropriate corrective actions should be implemented and a report of the action provided to
the reporting party City Development Services Department.
Operational Noise (Long-Term Impacts)
Long-term operational noise associated with the proposed Project includes noise from the proposed hotel
uses. Long-term operational noise also includes Project-generated traffic and overall traffic noise at the
Project site. Each of these is addressed below.
On-Site Stationary Noise. The proposed Project would redevelop the eastern portion of the site with the
Building D, as well as surface parking and sidewalk/pedestrian improvements. These uses would be in
keeping with the commercial and residential character of the neighboring land uses, and no external noise
sources are planned or proposed, save for HVAC equipment, suitably sized for the Project, an emergency
generator, and a pool area. The pool area, balcony and patio areas would be surrounded on the north, east
and west sides by the 3- to 5-story hotel structures; therefore, nearby residences would not be exposed to
poolside, patio or balcony noise or mechanical equipment noise from the pool area. The parking lot area
would be utilized in effectively the same fashion as it is currently and thus, there would be no change in
regard to parking lot noise.
HVAC equipment would be located on the rooftops of the proposed buildings and would be screened from
direct view by nearby residences by parapet walls and/or mechanical equipment screen walls. The specific
details (location, size, manufacturer, and model) of the equipment have not yet been determined. However,
ications for
representative models (details of which are provided in Appendix E), the dimensionless sound power levels
were found to range from approximately 68 dBA to 92 dBA.
mechanical equipment would be located within approximately 150 feet of the residences. Assuming a
sound power level of 92 dBA, the noise level at a distance of 150 feet from one HVAC unit would be
approximately 51 dBA at the nearest existing residential property. If additional units were operating
simultaneously, the resultant noise level at the nearest existing residences would be greater. Therefore,
the HVAC equipment would have the potential to generate noise levels which could exceed City of Arcadia
municipal noise standards (55 dBA Leq daytime, 50 dBA Leq nighttime).
Similarly, the details (i.e., location, equipment specifications) of the proposed emergency backup generator
have not yet been developed; however, assuming a 250 kW natural gas-powered generator, and utilizing
sound level outputs provided by the manufacturer for various configurations, the distances within which
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the generator would exceed City of Arcadia daytime noise standards were calculated. The daytime noise
standard was used based upon the assumption that the generator would be tested during daytime hours.
noise standard would range from approximately 820 feet (if no enclosure was used) to approximately 130
feet (with a Level 3 acoustic enclosure). Thus, the noise from the generator also would have the potential
As described above, operation of the proposed Project
standards. However, implementation of mitigation measure MM-NOI-2 would reduce noise impacts from
HVAC equipment and the emergency generator to a less than significant level. For these reasons, noise
impacts from on-site stationary noise sources during operation are considered less than significant with
mitigation incorporated. No further mitigation is required.
MM-NOI-2 The Project Applicant shall retain an acoustical specialist to review
construction level plans to ensure that the equipment specifications and plans for
HVAC and emergency backup generator incorporate features to ensure that operational
noise will not exceed relevant noise standards at nearby noise-sensitive land uses (e.g.,
residential). Such features could include, but not be limited to, the specification of
quieter equipment, relocation of facilities to be of further distance from residential
homes, and/or the provision of acoustical enclosures. The acoustical specialist shall
certify in writing to the City that the equipment specifications and plans will achieve
the relevant noise limits.
Off-Site Traffic Noise
The proposed Project would generate traffic along adjacent arterial roadways (primarily West Huntington
Drive and Colorado Place). The City does not have a specific criterion for evaluating the significance of
Project-related increases in off-site traffic noise levels at residences or noise-sensitive areas. For the
purposes of this analysis, traffic noise level increases are considered significant if they exceed ambient
traffic noise levels by 5 dB or more, or cause noise levels to exceed a 65 dBA CNEL noise threshold. An
increase or decrease in noise level of 5 dBA is the minimum before any noticeable change in community
response would be expected (Caltrans 2013). Therefore, a clearly perceptible increase (+5 dB) in noise
exposure of sensitive receptors or a Project-related exceedance of the 65 dBA Ldn noise threshold could be
considered significant.
The noise levels associated with roadway traffic were determined based on the Project
Study (Appendix F) and using the FHWA TNM 2.5 Traffic Noise Model version 2.5 (FHWA 2004). The results
of the traffic modeling at the nearby off-site noise-sensitive receivers (represented by modeled receivers
ST2, ST3 and ST4) for the existing and existing plus project scenarios during both weekday and weekend
conditions are summarized in Table 19; the traffic noise model data files are attached to this document in
Appendix E. As shown, the Project-related traffic would result in a noise level increase of zero (0) dB CNEL
(when rounded to whole numbers) along the studied roadways in the vicinity of the Project site. Noise levels
at receiver ST3 are projected to decrease by approximately 3 dB as a result of the proposed Project; this is
because of the acoustical shielding that would be provided by the proposed Building D. The proposed
Project and Project-related
traffic would not substantially increase the existing noise levels in the Project vicinity. Therefore, operational
traffic-related noise impacts would be less than significant. No mitigation is required.
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Table 19. Off-Site Traffic Noise (Existing and Existing-with-Project)
Modeled Off-Site
Receiver
Weekdays Saturdays
Existing
Noise
(dBA CNEL)
Existing
plus Project
Noise
(dBA CNEL)
Noise
Increase
(dB)
Existing
Noise (dBA
CNEL)
Existing
plus Project
Noise (dBA
CNEL)
Noise
Increase
(dB)
ST2 Residential
north of Project site
55 55 0 54 54 0
ST3 Residential
north northwest of
Project site
51 48 -3 50 47 -3
ST4 Arcadia Park,
northwest corner
68 68 0 67 67 0
The noise level increases associated with additional traffic volumes under future (Year 2021) with Project
traffic conditions and future without Project traffic conditions are summarized in Table 20. The noise level
increases associated with the Project under future traffic conditions would be zero (0) dB CNEL (when
rounded to whole numbers) along the studied roadways in the vicinity of the Project site. Noise levels at
receiver ST2 (during typical Saturday traffic conditions) and ST3 are projected to decrease as a result of
the proposed Project; this is because of the acoustical shielding that would be provided by the proposed
Building D. Increases would be below the significance threshold of 5 dB. Additionally, the proposed Project
the proposed Project would not substantially increase the existing noise levels in the Project vicinity, and
operational traffic-related noise impacts would be less than significant. No mitigation is required.
Table 20. Off-Site Traffic Noise (Future and Future-with-Project)
Modeled Off-Site
Receiver
Weekdays Saturdays
Future
Noise
(dBA CNEL)
Future
plus Project
Noise
(dBA CNEL)
Noise
Increase
(dB)
Future
Noise (dBA
CNEL)
Future
plus Project
Noise (dBA
CNEL)
Noise
Increase
(dB)
ST2 Residential
north of Project site
55 55 0 55 54 -1
ST3 Residential
north northwest of
Project site
51 48 -3 50 47 -3
ST4 Arcadia Park,
northwest corner
68 68 0 67 67 0
b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less Than Significant with Mitigation Incorporated. Construction activities that might expose persons to
excessive ground-borne vibration or ground-borne noise could cause a potentially significant impact.
Ground-borne vibration information related to construction activities has been collected by the California
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Department of Transportation (Caltrans 2004). Information from Caltrans indicates that continuous
vibrations with a peak particle velocity of approximately 0.1 inch/second begin to annoy people. The heavier
pieces of construction equipment, such as bulldozers, would have peak particle velocities of approximately
0.089 inch/second or less at a distance of 25 feet (U.S. DOT 2018). At the distance from the nearest
residence to the nearest construction activity (approximately 25 feet, during demolition of existing
pavement and subsequent re-paving) and with the anticipated construction equipment, the peak particle
velocity would be approximately 0.089 inch/second. Ground-borne vibration is typically attenuated over
short distances; thus, at the distance from the nearest residence to other construction phases
(approximately 70 feet), the peak particle velocity would be approximately 0.019 inch/second or less.
Vibration is very subjective, and some people may be annoyed at continuous vibration levels near the level
of perception (or approximately a peak particle velocity of 0.01 inch/second). Although construction
activities would not use construction equipment that would result in continuous vibration levels that
typically annoy people, since some residences are as near as 25 feet from the construction area, residents
could be temporarily annoyed with the use of some construction equipment. Implementation of MM-NOI-1
would ensure residents are notified of construction activities and provided contact information in the event
they wish to report a noise- or vibration-related complaint.
Building damage can also result from construction vibration. However, construction vibration from the
proposed Project would not result in structural building damage, which typically occurs at vibration levels
of 0.5 inch/second or greater for buildings of reinforced-concrete, steel, or timber construction. As stated
above, the peak particle velocity anticipated during proposed Project construction would be approximately
0.019 inch/second. The heavier pieces of construction equipment used for the Project would include
excavators, graders, dump trucks, and vendor trucks. Pile driving, blasting, or other special construction
techniques would not be used for construction of the proposed Project; therefore, excessive ground-borne
vibration and ground-borne noise would not be generated. Ground-borne vibration would not be associated
with the proposed Project during operation. Impacts related to ground-borne vibration are therefore
considered less than significant with mitigation incorporated. No further mitigation is required.
c) For a project located within the vicinity of a private airstrip or 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?
No Impact. The Project is not located within the vicinity of a private airstrip, and the nearest airport (El
Monte Airport) is located approximately 3.7 miles south of the Project site. The Project is not located within
the planning area for this airport, nor is it located within two miles of this airport or any other airport
(Airnav.com 2019; County of Los Angeles 2004). Therefore, the Project would not expose people residing
or working in the Project area to excessive noise related to public airports. No impact would occur.
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3.14 Population and Housing
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Induce substantial unplanned 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)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
a) Would the project induce substantial unplanned population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for example, through extension of ro ads
or other infrastructure)?
Less Than Significant Impact.
population in 2018 was 58,610 people, with an average of 2.97 people per household (U.S. Census Bureau
2018). According to the C
estimates that the City can expect a population of 65,704 people by 2035, as well as, 23,045 households
and 30,356 employment opportunities by 2035 (City of Arcadia 2010a).
The proposed Project includes the conversion of an existing building (Building C) into a 76,754-sf hotel and
the construction of a new 61,538-sf hotel annex building (Building D). Substantial population growth in any
particular area is usually associated with a significant increase in available housing stock and/or
employment opportunities. The proposed Project would not include a housing component, and, as such,
would not result in any unplanned population growth through the provision of new homes. Furthermore, the
proposed Project would not include the construction of any roads or other infrastructure, the
implementation of which would result in substantial, indirect population growth.
Using employment generation factors from the LEED Reference Guide for Green Building Design and
Construction (LEED 2009), the proposed Hotel Indigo would reduce the overall number of employees at the
Project site when compared to the potentially full occupancy of Building C (former Worley Parsons Office
Building). It is estimated that the new hotel, including spa and restaurant land uses, would generate
approximately 111 new employees13. At full occupancy, the existing Building C office is estimated to support
up to 269 employees14. The reduced employment at the Project site is not expected to substantively alter
13 Building C + Building D: 124,079 sf of hotel at 1,500 square feet/employee (124,079/1,500 = 82.7 employees); 7,466 sf of Spa
at 600 square feet/employee (7,466/600 = 12.4 employees); 6,747 sf of restaurant/café at 438 square feet/employee
(6,747/435 = 15.4 employees)
14 Per Traffic Report in Appendix F, Building C = 67,213 sf of Office, at 1 employee per each 250 square feet (67,213/250 =
269 employees)
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the SCAG projected 2040 population growth estimates for the City. Population in the City is estimated to reach
65,900 people by 2040, an approximate increase of 7,209 people when compared to existing conditions
(SCAG 2016).15 Although some new employees associated with the proposed Project could relocate from
outside of the City, it is more likely that these new hotel employment opportunities would be filled by people
already residing within the City of Arcadia and the surrounding Los Angeles Metropolitan area. The proposed
Project would not result in any new residents or otherwise result in substantial, unplanned population growth.
Given the above, the proposed Project would have a less than significant impact on population growth and no
mitigation is required.
b) Would the project displace substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere?
No Impact. The proposed Project would include the conversion of an existing building (Building C) into a
76,754-sf hotel and the construction of a new 61,538-sf hotel annex building (Building D). The proposed
Project would entail the redevelopment of an existing commercial property, and would not include the take
or acquisition of any existing housing, the demolition of which would displace substantial numbers of people
or housing and necessitate the construction of replacement housing elsewhere. Instead, upon operation,
the Hotel Indigo would provide hospitality amenities to the local and regional community. As such, no impact
would occur and no mitigation is required.
3.15 Public Services
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
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?
15 Projected 65,900 people in 2040 estimated 58,610 people = 7,209 population growth.
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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?
Less Than Significant Impact. The Arcadia Fire Department, is a full-service fire department that provides
fire suppression, urban search and rescue, paramedic ambulance service, fire prevention
inspections/permits, public fire education programs, emergency preparedness planning, fire cause and
origin investigation, fire patrols, and other services based on community needs. The Fire Department
consists of the Administration, Buildings and Grounds, Fire Prevention Bureau, Paramedics, Suppression,
and Emergency Services Divisions (City of Arcadia 2010a). Fire Station 105 is the closest fire station to the
Project site. Fire Station 105 is located 0.6-mile southeast of the Project site at 710 South Santa Anita
Avenue. According to the General Plan EIR, Fire Station 105 is equipped, as follows (City of Arcadia 2010a):
16 firefighter personnel, including a Fire Chief, Deputy Fire Chief, Senior Management Analyst, Fire
Administrative Specialist, Duty Battalion Chief, six firefighters and two firefighter paramedics, one
Fire Marshal, one Administrative Assistant and one Fire Inspector.
Fire truck 105 with a 100-foot ladder.
Two fire engines, including Engine 105 (staffed with three firefighters) and a state fire engine.
A rescue ambulance (staffed with two firefighter/paramedics).
The need for new or altered fire station facilities is usually associated with substantial population growth,
such that existing facilities cannot meet the increased demand for fire protection services. As stated in
Section 3.14, Population and Housing, the proposed Project is a hotel development project, and would not
include any permanent housing, the construction of which would result in significant population growth.
Project implementation has the potential to add new residents to the local population through the provision
of new employment opportunities at the hotel at buildout; however, any population growth related to the
proposed Project would be minor (as described in Section 3.14). Additionally, the proposed Project would
adhere to the California Fire Cod Fire Code (Municipal Code, Section
3122.7).16 As such, the proposed Project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered fire protection facilities, need for new or physically
altered fire protection facilities, the construction of which could cause significant environmental impacts,
in order to maintain acceptable service ratios, response times, or other performance objectives for fire
protection services. Impacts would be less than significant and no mitigation is required.
Police protection?
Less Than Significant Impact. The Arcadia Police Department (APD) is located 0.3-mile south of the Project
site at 250 West Huntington Drive. The APD is comprised of two divisions, namely the Operations Division
and the Administration Division. The Operations Division, led by Captain Larry Goodman, responds to
various calls for service received from the community, conducts preliminary investigations of criminal
offenses, prepares police reports, provides high visibility patrol to reduce crime, participates in traffic
education and enforcement programs, and coordinates parking enforcement. Patrol team officers also
16 California Code of Regulations, Title 24, Part 9 Fire Code. City of Arcadia Municipal Code, Section 3122.7 Fire Code.
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conduct special enforcement actions to combat violations such as alcohol sales to minors, street drug
activities, and disorderly conduct (APD 2019).
The need for new or altered police station facilities is usually associated with substantial population growth,
such that existing facilities cannot meet the increased demand for police protection services. As stated in
Section 3.14, the proposed Project is a hotel development project, and would not include any permanent
housing, the construction of which would result in significant population growth. Project implementation
has the potential to add new residents to the local population through the provision of new employment
opportunities at the hotel at buildout; however, any population growth related to the proposed Project would
be minor. As such, the proposed Project would not induce substantial population growth such that new or
physically altered APD facilities would be needed. Impacts would be less than significant and no mitigation
is required.
Schools, Parks, Other Public Facilities?
No Impact. The Arcadia Unified School District serves approximately 10,000 children in 11 schools
throughout the City. There are three schools within the general vicinity of the Project site: Barnhart School,
located approximately 0.15-mile north of the Project site; Excelsior School, located approximately 0.16-mile
east of the Project site; and First Avenue Middle School, located approximately 0.37-mile southeast of the
Project site.
The City of Arcadia Recreation and Community Services Department manages the Cit
recreational facilities and is also responsible for overseeing a broad spectrum of public recreational
activities and programs. The City maintains 15 public parks, of which the Arcadia County Park is the closest
to the Project site and is located immediately south across Huntington Drive. Amenities at Arcadia County
Park include: 12 lighted tennis courts, an Olympic size swimming pool, three lighted ball diamonds, a play
area, two large group picnic areas and barbeques (City of Arcadia 2019a).
The need for new or altered school facilities is usually associated with substantial population growth, such
that existing school facilities cannot meet the increased demand for educational services. As stated in
Section 3.14, the proposed Project is a hotel development project, and would not include any permanent
housing, the construction of which would result in significant population growth. Project implementation
may generate several new students through the provision of new employment opportunities at the hotel at
buildout; however, any population growth related to the proposed Project would be minor and would not
significantly affect the demand for educational services. Furthermore, the Applicant would be required to
pay a school mitigation fee, per SB 50, which would be deemed full and complete mitigation for any indirect
impacts to schools that may occur as a result of Project implementation. As such, no impact would occur
and no mitigation is required.
The need for new or altered park facilities is usually associated with substantial population growth, such that
existing park facilities cannot meet the increased demand for recreational services. As stated in Section 3.14,
the proposed Project is a hotel development project, and would not include any permanent housing, the
construction of which would result in significant population growth. Project implementation has the potential
to add new residents to the local population through the provision of new employment opportunities at the
hotel at buildout; however, any population growth related to the proposed Project would be minor. As such,
the proposed Project would not induce substantial population growth such that new or physically altered parks
would be needed. Impacts would be less than significant and no mitigation is required.
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The need for new or altered public facilities, including libraries, is usually associated with substantial
population growth, such that existing facilities cannot meet the increased demand for public/government
services. As stated in Section 3.14, the proposed Project is a hotel development project, and would not
include any permanent housing, the construction of which would result in significant population growth.
Project implementation has the potential to add new residents to the local population through the provision
of new employment opportunities at the hotel at buildout; however, any population growth related to the
proposed Project would be minor. As such, the proposed Project would not induce substantial population
growth such that new or physically altered public/government facilities, including libraries, would be
needed. No impacts would occur and no mitigation is required.
3.16 Recreation
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
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?
b) Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
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?
No Impact. s
and recreational facilities and is also responsible for overseeing a broad spectrum of public recreational
activities and programs. The City maintains 15 public parks, of which the Arcadia County Park is the closest
to the Project site and is located immediately south across Huntington Drive.
The physical deterioration of neighborhood and regional parks occurs when the number of residents utilizing
cannot keep up with the maintenance demands of over utilized park facilities. As stated in Section 3.14, the
proposed Project would not induce significant population growth. Project implementation has the potential to
add new residents to the local population through the provision of new employment opportunities at the hotel
at buildout; however, any population growth related to the proposed Project would be minor. As such, the
proposed Project would not induce substantial population growth such that physical deterioration of parks
and recreational facilities would occur. No impact would occur and no mitigation is required.
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b) Does the project include recreational facilities or require the construction or expansion of recreational
facilities, which might have an adverse physical effect on the environment?
No Impact. As stated above in 3.16(a), the proposed Project would include approximately 12,775 square
feet of landscaping, which would include exterior planter beds, event turf/lawn, a swimming pool and
ornamental trees and shrubs. This landscaping is included as part of the proposed Project and, therefore,
has been analyzed for its potential environmental effects in this IS/MND. As substantiated throughout this
document, no significant, adverse environmental effects would occur as a result of the proposed Project.
As described above in Section 3.16(a), the proposed Project would not require construction or expansion
of recreational facilities. No impact would occur and no mitigation is required.
3.17 Transportation
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
a) Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadway, bicycle, and pedestrian facilities?
Less Than Significant Impact. The City does not have adopted street segment analysis threshold criteria;
segments operating at Level of Service (LOS) D or better are considered to be at acceptable levels (City of
Arcadia 2010b). LOS E is permitted on roadway segments adjacent to: 1) freeway ramps; 2) Santa Anita
Park and all roadway links intended to carry seasonal race-related traffic; and, 3) the Downtown, Baldwin
Avenue, and Live Oak Avenue commercial and mixed-use districts. The following analysis shows that the
proposed Project would be consistent with the threshold criteria outlined by the City.
Existing Conditions
The proposed Project is generally bounded by Santa Cruz Road to the north, San Rafael Road to the east,
San Juan Drive to the west, and West Huntington Drive and Colorado Place to the south. As shown in Figure
8, Vicinity Map, regional access to the Project site is provided via the I-210 Freeway, which is located
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approximately 0.5-mile north of the Project site, while immediate access is provided via San Rafael Road,
San Juan Road, and Colorado Place under existing conditions. A review of the key roadways in the Project
site vicinity and study area is summarized below:
Huntington Drive is an east-west oriented roadway that borders a portion of the Project site to the south. In the
Arcadia General Plan Circulation and Infrastructure Element, Huntington Drive is classified as a major arterial
west of Santa Clara Street and as a primary arterial east of Santa Clara Street. Huntington Drive is also a
designated truck route, as well as a principal travel corridor and a planned primary transit corridor within the
City. The number of through travel lanes in each direction on Huntington Drive varies from 4 through lanes west
of Holly Avenue, to 3 through lanes between Holly Avenue and Santa Clara Street, to 2 through lanes east of
Santa Clara Street. Exclusive left-turn lanes are provided on Huntington Drive at major intersections. On-street
parking is generally not provided along Huntington Drive in the immediate Project vicinity.
Santa Clara Street is an east-west oriented roadway that is located east of the Project site. Santa Clara
Street extends from the intersection of Huntington Drive and West Colorado Place to the city boundary at
5th Avenue where Santa Clara Street becomes Chestnut Avenue in the adjacent City of Monrovia. In the
Arcadia General Plan Circulation and Infrastructure Element, Santa Clara Street is classified as a secondary
arterial between Huntington Drive and Santa Anita Avenue and as an enhanced collector east of Santa
Anita Avenue. Santa Clara Street is also designated as a secondary travel corridor between Huntington
Drive and Santa Anita Avenue and a local travel corridor east of Santa Anita Avenue. Santa Clara Street is
also planned to serve as a primary transit corridor. Two through travel lanes are provided in each direction
on Santa Clara Street between Huntington Drive and Santa Anita Avenue while one through travel lane is
provided in each direction on Santa Clara Street east of Santa Anita Avenue.
Colorado Place is a north-south oriented roadway that borders the Project site to the west. In the Arcadia
General Plan Circulation and Infrastructure Element, Colorado Place is classified as a primary arterial
between Colorado Boulevard and Huntington Drive. Colorado Place is also a designated truck route, as well
as a secondary travel corridor and a planned secondary transit corridor within the City. Two through travel
lanes are provided in each direction on Colorado Place in the Project vicinity. On-street parking is generally
not provided along Colorado Place in the immediate Project vicinity.
Santa Anita Avenue is a north-south oriented roadway that is located east of the Project site. In the Arcadia
General Plan Circulation and Infrastructure Element, Santa Anita Avenue is classified as a primary arterial
from the southern city boundary to Foothill Boulevard and as an enhanced corridor north of Foothill
Boulevard. South of Foothill Boulevard, Santa Anita Avenue is also a designated truck route and a principal
travel corridor. North of Foothill Boulevard, Santa Anita Avenue is designated as a secondary travel corridor.
Santa Anita Avenue is also planned to serve as a primary transit corridor south of the I-210 Freeway and a
secondary transit corridor north of the I-210 Freeway. Two through travel lanes are provided in each
direction on Santa Anita Avenue south of Foothill Boulevard while 1 through travel lane is provided in each
direction on Santa Anita Avenue north of Foothill Boulevard. Exclusive left-turn lanes are provided on Santa
Anita Avenue at major intersections. The speed limit on Santa Anita Avenue varies from 35 MPH north of
Foothill Boulevard to 40 MPH south of Foothill Boulevard.
Other roadways that provide regional access to the Project site include Hollenbeck Avenue, Barranca
Avenue, Covina Boulevard, Cypress Street, Front Street, College Street, and Badillo Street. Roadways and
lane configurations in the Project area are shown in Figure 9, Existing Lane Configurations.
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al
(C-G) with a Downtown Overlay. As such, the proposed Project site is well-located to encourage the use of
public transit and active transportation modes.
Public Bus Transit Service
Public bus transit service in the Project area is provided by Foothill Transit, Metro, and Arcadia Transit.
Foothill Transit provides bus transit service along major roadways within the transportation analysis study
area: Huntington Drive and Santa Anita Avenue. Foothill Transit currently operates one transit route (Route
187) in the vicinity of the Project site. This bus line provides headways of four buses during the weekday
morning peak hour and four buses during the weekday afternoon peak hour. Metro provides bus transit
service along major roadways within the transportation analysis study area: Huntington Drive and Santa
Anita Avenue. Metro currently operates two local Metro bus transit routes (Routes 487/489) in the vicinity
of the Project site. The Metro bus transit routes provide headways of two to three buses during the morning
and afternoon peak hours.
Arcadia Transit provides fixed-route general public transit service with three lines (i.e., Green, Blue and Red
Lines). Two of the three lines operate in the vicinity of the project site. These lines provide headways of
generally one to two buses during the weekday morning peak hour and two to three buses during the
weekday afternoon peak hour. Arcadia Dial-A-Ride is a demand-response service providing curb-to-curb
transportation to seniors and persons with disabilities to and from any destination within the Arcadia city
boundaries, including all shopping areas, commercial centers, the Methodist Hospital, medical centers, the
civic center, parks, the racetrack, libraries, etc. The service is provided based on space availability and is
open Monday through Friday from 7:00 a.m. to 9:00 p.m. and Saturday/Sunday from 7:00 a.m. to 7:00
p.m. Trip requests can be made the same day or up to seven days in advance.
Regional Rail Service
The Metro Gold Line Arcadia Station is also located approximately 0.5-mile northeast of the Project site, at
the northwest corner of First Avenue and Santa Clara Street. Arcadia Transit provides fixed-route general
public transit service with three lines (i.e., Green, Blue and Red Lines). Two of the three lines operate in the
vicinity of the Project site. These lines provide headways of generally one to two buses during the weekday
morning peak hour and two to three buses during the weekday afternoon peak hour.
Traffic Impact Study
The traffic impact study for the proposed Project
with the traffic impact assessment guidelines set forth in the Caltrans Highway Capacity Model (HCM).
The traffic analysis evaluates potential Project-related impacts at eight study intersections and six street
segments in the vicinity of the Project site. These study locations were considered as they have the greatest
potential to experience traffic impacts as a result of the proposed Project. The intersections were evaluated
during the weekday morning and afternoon peak hours. Figure 8 illustrates the Project site location and
the location of the study area intersections. The eight intersections are as follows:
1. Gate 3-Holly Avenue/Huntington Drive-Campus Drive
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2. Colorado Place/San Juan Drive
3. Colorado Place/Huntington Drive
4. Santa Clara Street/Huntington Drive
5. Santa Anita Avenue/I-210 Freeway Westbound (WB) Ramps
6. Santa Anita Avenue/I-210 Freeway Eastbound (EB) Ramps
7. Santa Anita Avenue/Santa Clara Street
8. Santa Anita Avenue/Huntington Drive
The six study street segments are as follows:
1. Colorado Place between San Juan Drive and Colorado Boulevard
2. Huntington Drive EB between Santa Clara Street and Centennial Way
3. Huntington Drive WB between Colorado Place and Centennial Way
4. Huntington Drive between Santa Clara Street and Santa Anita Avenue
5. Santa Anita Avenue between Santa Clara Street and Huntington Drive
6. Santa Anita Avenue south of Huntington Drive
Traffic Impact Analysis Methodology
In order to estimate the traffic impact characteristics of the proposed Project, a multistep process was
utilized, as follows:
1. Forecasting trip generation, which estimates the total arriving and departing traffic volumes from
the proposed Project on a peak hour and daily basis. The traffic generation potential is typically
forecast by applying the appropriate vehicle trip generation equations or rates to the Project
development tabulation.
2. Forecasting trip distribution, which identifies the origins and destinations of inbound and outbound
Project traffic volumes. These origins and destinations are typically based on demographics and
existing/anticipated travel patterns in the study area.
3. Forecasting traffic assignment, which involves the allocation of Project traffic to study area streets
and intersections. Traffic assignment is typically based on minimization of travel time, which may
or may not involve the shortest route, depending on prevailing operating conditions and travel
speeds. Traffic distribution patterns are indicated by general percentage orientation, while traffic
assignment allocates specific volume forecasts to individual roadway links and intersection turning
movements throughout the study area.
With the forecasting process complete and Project traffic assignments developed, the impact of the
proposed Project is evaluated by comparing LOS conditions at the study area intersections using existing
and expected future traffic volumes with and without anticipated Project traffic. Based on the outcome of
determine their significance.
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Impact Criteria and Thresholds
As the City of Arcadia does not have adopted street segment analysis threshold criteria, the analysis was
conducted in order to compare the overall roadway LOS without and with the proposed Project. Roadway
LOS is based on capacity per lane per day and is assigned LOS A through F similar to the intersection LOS
based on a volume-to-capacity (v/c) ratio. As indicated in the Circulation and Infrastructure Element of the
City of Arcadia General Plan 2010, roadway segments operating at LOS D or better are considered to be at
acceptable levels (City of Arcadia 2010b). Furthermore, LOS E is permitted on roadway segments adjacent
to: 1) freeway ramps; 2) to Santa Anita Park and all roadway links intended to carry seasonal race-related
traffic; and 3) the Downtown, Baldwin Avenue, and Live Oak Avenue commercial and mixed-use districts.
The relative impact of the added Project traffic volumes generated by the proposed Project during the
weekday AM and PM peak hours was evaluated based on analysis of existing and future operating
conditions at the study intersections, without and with the proposed Project. The previously discussed
capacity analysis procedures were utilized to evaluate the future v/c or delay relationships and LOS
characteristics at each study intersection.
The significance of the potential Project-generated traffic impacts was identified using the traffic impact
significant transportation impact is determined based on LOS. LOS calculations were prepared for the study
intersections under the following scenarios:
a) Existing Conditions.
a) Existing With Project Conditions.
b) Future Pre-Project Conditions (existing plus ambient growth and related projects traffic).
c) Future with Project Conditions.
d) Future with Project and Mitigation Conditions, if necessary.
The traffic volumes for each new condition were added to the volumes in the prior condition to determine
the change in capacity utilization at the study intersections. Summaries of the v/c ratios, delays, and
corresponding LOS values for the study intersections during the weekday AM, weekday PM, and Saturday
PM peak hours are shown in Table 21 and data worksheets for the analyzed intersections are contained in
Appendix F, Traffic Study, of this IS/MND
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Table 21. Summary of Volume to Capacity Ratios/Delays and Levels of Service Weekday AM, PM, and Saturday PM Peak Hours
No. Intersection
Peak
Hour
Existing
Existing With
Project Difference
Future Without
Project
Future with
Project Difference
V/C or
Delay LOS1
V/C or
Delay LOS1
V/C or
Delay
Sig.
Impact2
V/C or
Delay LOS1
V/C or
Delay LOS1
V/C or
Delay
Sig.
Impact2
1 Gate 3-Holly
Avenue/Huntington
Drive-Campus Drive
AM 0.588 A 0.589 A 0.001 No 0.608 B 0.609 B 0.001 No
PM 0.582 A 0.582 A 0.000 No 0.598 A 0.598 A 0.000 No
SAT 0.492 A 0.492 A 0.000 No 0.509 A 0.509 A 0.000 No
2 Colorado Place/San
Juan Drive AM 20.8 C 20.8 C 0.045 No 15.6 C 20.1 C 0.045 No
PM 10.3 B 10.6 B 0.019 No 16.2 C 16.6 C 0.008 No
SAT 11.9 B 11.9 B 0.031 No 11.9 B 12.5 B 0.011 No
AM 0.453 -- 0.498 -- -- -- 0.471 -- 0.516 -- -- --
PM 0.501 -- 0.520 -- -- -- 0.625 -- 0.633 -- -- --
SAT 0.293 -- 0.324 -- -- -- 0.376 -- 0.387 -- -- --
3 Colorado
Place/Huntington Drive
(unsignalized
Intersection)
AM 0.501 A 0.508 A 0.007 No 0.536 A 0.544 A 0.008 No
PM 0.788 C 0.796 C 0.008 No 0.873 D 0.881 D 0.008 No
SAT 0.440 A 0.463 A 0.023 No 0.495 A 0.517 A 0.022 No
4 Santa Clara
Street/Huntington Drive AM 0.692 B 0.712 C 0.020 No 0.765 C 0.785 C 0.020 No
PM 0.582 A 0.586 A 0.004 No 0.633 B 0.648 B 0.015 No
SAT 0.460 A 0.482 A 0.022 No 0.538 A 0.560 A 0.022 No
5 Santa Anita Avenue/I-
210 Freeway
Westbound (WB)
Ramps
AM 0.949 E 0.949 E 0.000 No 0.971 E 0.971 E 0.000 No
PM 0.808 D 0.808 D 0.000 No 0.828 D 0.828 D 0.000 No
SAT 0.599 A 0.599 A 0.000 No 0.615 B 0.615 B 0.000 No
6 Santa Anita Avenue/I-
210 Freeway
Eastbound (EB) Ramps
AM 0.631 B 0.636 B 0.005 No 0.663 B 0.668 B 0.005 No
PM 0.611 B 0.616 B 0.005 No 0.665 B 0.669 B 0.004 No
SAT 0.547 A 0.551 A 0.004 No 0.583 A 0.590 A 0.007 No
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Table 21. Summary of Volume to Capacity Ratios/Delays and Levels of Service Weekday AM, PM, and Saturday PM Peak Hours
No. Intersection
Peak
Hour
Existing
Existing With
Project Difference
Future Without
Project
Future with
Project Difference
V/C or
Delay LOS1
V/C or
Delay LOS1
V/C or
Delay
Sig.
Impact2
V/C or
Delay LOS1
V/C or
Delay LOS1
V/C or
Delay
Sig.
Impact2
7 Santa Anita
Avenue/Santa Clara
Street
AM 0.637 B 0.651 B 0.014 No 0.678 B 0.691 B 0.013 No
PM 0.682 B 0.688 B 0.006 No 0.788 C 0.794 C 0.006 No
SAT 0.615 B 0.623 B 0.008 No 0.702 C 0.710 C 0.008 No
8 Santa Anita
Avenue/Huntington
Drive
AM 0.921 E 0.938 E 0.017 No 0.993 E 1.010 F 0.017 No
PM 0.861 D 0.864 D 0.003 No 0.915 E 0.918 E 0.003 No
SAT 0.625 B 0.632 B 0.007 No 0.671 B 0.677 B 0.006 No
Source: Appendix F.
Notes:
1 Level of Service (LOS) is based on the reported ICU value for signalized intersections.
2 According to the City of Arcadia threshold of significance, a transportation impact at a signalized intersection shall be deemed significant in accordance with the following:
Addition of project trips causes the peak hour level of service of the intersection to change from LOS D or better to LOS E or F.
Addition of project trips causes an increase in the volume/capacity ratio of 0.02 or greater at LOS E or F.
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Existing Traffic Volumes
As indicated in column [1] of Table 21, six of the eight study intersections are presently operating at LOS D
or better during the weekday AM, weekday PM, and Saturday PM peak hours. The following study
intersections are anticipated to operate at LOS E for the peak hour shown below:
Int. No. 5: Santa Anita Ave./I-210 WB Ramps (AM Peak Hour: v/c=0.949, LOS E)
Int. No. 8: Santa Anita Ave./Huntington Dr. (AM Peak Hour: v/c=0.921, LOS E)
As previously mentioned, the existing traffic volumes at the study intersections during the weekday AM,
weekday PM, and Saturday PM peak hours are displayed in Figures 10, 11, and 12, respectively.
Cumulative Development Projects
A forecast of on-street traffic conditions prior to occupancy of the proposed Project was prepared by
incorporating the potential trips associated with other known development projects (related projects) in the
area. With this information, the potential impact of the proposed Project can be evaluated within the context
of the cumulative impact of all ongoing development. The related projects research was based on
information on file at the City of Arcadia. It should be noted that the re-occupancy of the prior office building
on the Project site has been accounted for. Additionally, subsequent to the completion of the Transportation
Impact Analysis, the Santa Anita Park North Barn project was withdrawn based on City staff confirmation;
however, the cumulative analysis considers the project as part of the transportation assumptions and thus,
represents a conservative scenario. The related projects in the study area are presented in Figure 13 and
in Table 22 below.
Traffic volumes expected to be generated by the related projects were calculated using rates provided in
the ITE Trip Generation Manual
PM peak hours, as well as on a daily basis for a typical weekday, is summarized in Table 22. As shown in
Table 22, the related projects are expected to generate a combined total of 1,485 daily peak hour trips
during a typical weekday, 565 vehicle trips (316 inbound trips and 249 outbound trips) during the weekday
AM peak hour, and 920 vehicle trips (397 inbound trips and 523 outbound trips) during the weekday PM
peak hour. Refer to Appendix F for details. Additionally, the proposed Project would generate approximately
851 Saturday PM peak hour trips (443 inbound trips and 408 outbound trips).
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Table 22. Related Projects List and Trip Generation
Map
No. Project Status Project Address
Proposed Land
Use
Daily
Trips
AM Peak Hour (Total)
PM Peak Hour
(Total)
Saturday (PM Peak
Hour Total)
In Out Total In Out Total In Out Total
City of Arcadia
A1 Proposed 323 325 N. 1st Avenue Medical Office 196 10 3 13 5 14 19 11 9 20
Retail 77 1 1 2 3 4 7 5 4 9
A2 Pending 117-129 E. Huntington Drive Apartment 924 14 57 71 56 30 86 35 30 65
124, 126, and 134 E. Wheeler
Avenue
Retail 476 7 4 11 20 21 41 28 26 54
A3 Under
Construction
56 E. Duarte Road Condominium 215 3 13 16 13 6 19 9 8 17
Retail 827 12 7 19 35 37 72 48 45 93
A4 Under
Construction
57 Wheeler Avenue Apartment 252 4 15 19 16 8 24 10 10 20
Retail 308 4 3 7 13 14 27 18 16 34
Office 58 7 1 8 1 7 8 1 1 2
A5 Under
Construction
501 N. Santa Anita Avenue Condominium 116 2 7 9 7 3 10 5 4 9
A6 Proposed 415 California Street Condominium 116 2 7 9 7 3 10 5 4 9
A7 Under
Construction
Santa Anita Inn Redevelopment
Project
Hotel 2,774 65 64 129 114 109 223 141 120 261
Condominium
Retail
A8 Under
Construction
22-26 E. Colorado Boulevard Condominium 46 1 3 4 3 1 4 2 2 4
A9 Under
Construction
288 N. Santa Anita Avenue Medical Office 842 44 12 56 23 60 83 48 37 85
Retail 301 4 3 7 12 14 26 18 16 34
A10 Proposed 141-145 Alice Street Condominium 46 1 3 4 3 1 4 2 2 4
A11 Pending 230 California Street Condominium 29 0 2 2 0 1 3 1 1 2
A12 Pending 414 Fairview Avenue Condominium 35 1 2 3 2 1 3 2 1 3
A13 Pending 405 S. 1st Avenue Condominium 23 0 2 2 1 1 2 2 1 3
Retail 25 1 0 1 1 1 2 2 1 3
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Table 22. Related Projects List and Trip Generation
Map
No. Project Status Project Address
Proposed Land
Use
Daily
Trips
AM Peak Hour (Total)
PM Peak Hour
(Total)
Saturday (PM Peak
Hour Total)
In Out Total In Out Total In Out Total
A14* Proposed
285 W.
Huntington Drive
Santa Anita Park North Barn
Project
Stables
Expansion
1,469 62 20 82 18 96 114 43 39 82
Dormitories 210 0 0 0 21 21 42 0 21 21
Canteen 50 2 2 4 2 2 4 0 1 1
A15 Existing 125 W. Huntington Drive Office 655 67 11 78 12 65 77 19 17 36
City of Monrovia
M1 Under
Construction
530 Fano Street Condominium 70 1 4 5 4 2 6 3 3 6
M2 In Planning 717-721 W. Duarte Road Condominium 46 1 3 4 3 1 4 2 2 4
Total 10,186 316 249 565 397 523 920 459 421 880
Notes:
* the transportation assumptions represents a
conservative scenario.
Source: Appendix F
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Project Trip Generation
Traffic generation is expressed in vehicle trip ends, defined as one-way vehicular movements, either
entering or exiting the generating land use. Trip generation rates provided in the ITE Trip Generation Manual
publication were utilized to forecast Project-related trips. The ITE document contains trip rates for a variety
of land uses which have been derived based on traffic counts conducted at existing sites throughout
California and the United States. Trip generation forecasts for the proposed Project are as follows:
Weekday Project Trip Generation Summary
The proposed Project weekday trip generation rates and traffic volume forecasts are summarized in Table 23,
Project Trip Generation, and illustrated in Figures 7-2 and 7-3 in Appendix F. As presented in Table 23, the
proposed Project is expected to generate 178 net new vehicle trips (73 inbound trips and 105 outbound trips)
during the weekday AM peak hour. During the weekday PM peak hour, the proposed Project is expected to
generate 147 net new vehicle trips (104 inbound trips and 43 outbound trips). Over a 24-hour period, the
proposed Project is forecast to generate approximately 2,442 daily trip ends during a typical weekday.
Weekend Project Trip Generation Summary
The Saturday trip generation forecast for the proposed Project is also summarized in Table 23. As
summarized in Table 23 and illustrated in Figure 7-4 in Appendix F, the proposed Project is expected to
generate a net increase of 245 vehicle trips (123 inbound trips and 122 outbound trips) during the
Saturday PM peak hour. Over a 24-hour weekend period, the proposed Project is forecast to generate a net
increase of 3,012 vehicle trips.
Existing with Project Conditions
Existing with Project LOS and traffic volumes are shown in Table 21, and illustrated in Figures 14, 15, and
16, respectively, for the weekday AM and PM peak hours and Saturday PM peak hour. Application of the
significant impacts at any of the study intersections. Incremental, but not significant, impacts are noted at
the study intersections. Because there are no significant impacts, no traffic mitigation measures are
Future without Project Conditions
The future year 2021 pre-Project conditions were forecast based on the addition of traffic expected to be
generated by the related projects, as well as the growth in traffic due to the combined effects of continuing
development, intensification of existing developments and other factors (i.e., ambient growth). The v/c
ratios at the study intersections appropriately reflect the addition of traffic generated by the related projects
listed in Table 22 and growth in ambient traffic.
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Table 23. Project Trip Generation
Proposed Land Use Size
Daily Trip
Volumes
AM Peak Hour Volumes
PM Peak Hour
Volumes Saturday
Daily Trip
Volumes
Saturday Peak Hour
Volumes
In Out Total In Out Total In Out Total
Hotel 165 keys 2,018 59 43 102 59 61 120 1,733 72 72 144
Coffee Shop without Drive-
Through
1,568 sf 570 81 78 159 29 28 57 930 46 47 93
Less 25% Internal
Capture/Pass-by
(142) (20) (20) (40) (7) (7) (14) (232) (12) (12) (24)
Spa 7,466 sf 282 4 3 7 13 15 28 344 18 16 34
Less 25 % Internal
Capture/Pass-by
(70) (1) (1) (2) (3) (4) (7) (86) (5) (4) (9)
Restaurant 4,146 sf 465 23 18 41 25 16 41 507 23 23 46
Less 25 % Internal
Capture/Pass-by
(110) (5) (5) (10) (6) (4) (10) (126) (6) (5) (11)
Bar 1,033 sf 120 Nom. Nom Nom. 8 4 12 120 8 4 12
Less 25 % Internal
Capture/Pass-by
(30) Nom. Nom Nom. (2) (1) (3) (30) (2) (1) (3)
Subtotal Proposed Project 3,097 140 116 256 116 108 224 3,160 142 139 281
Less Prior Use (General
Office)
67,213 sf (655) (67) (11) (78) (12) (65) (77) (148) (19) (17) (36)
Net Increase 2,442 73 105 178 104 43 147 3,012 123 122 245
Source: Appendix F
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As presented in column [3] of Table 21, six of the eight study intersections are expected to continue to
operate at LOS D or better during the weekday AM, weekday PM, and Saturday PM peak hours. The following
study intersections are anticipated to operate at LOS E for the peak hour/s shown below with the addition
of related projects traffic and ambient traffic:
Int. No. 5: Santa Anita Ave./I-210 WB Ramps AM Peak Hour: v/c=0.971, LOS E
Int. No. 8: Santa Anita Ave./Huntington Dr.AM Peak Hour: v/c=0.993, LOS E/PM Peak Hour:
v/c=0.915, LOS E
The future pre-Project (existing, ambient growth and related projects) traffic volumes at the study
intersections during the weekday AM, weekday PM, and Saturday PM peak hours are presented in Figures
10-4, Figure 10-5, and Figure 10-6 in Appendix F, respectively.
Future with Project Conditions
Future with project traffic volumes for the weekday AM and PM peak hours, and the Saturday PM peak hour
are shown in Table 21 and illustrated in Figures 10-7, 10-8, and 10-9 in Appendix F, respectively for the
AM and PM peak hours, ap
proposed Project is not expected to create significant impacts at any of the study intersections. Incremental,
but not significant, impacts are noted at the study intersections. Because there are no significant impacts,
Street Segment Transportation Impact Analysis
The forecast traffic conditions at the analyzed street segments for existing, existing with Project, future year
2021 pre-Project (i.e., existing traffic volumes and ambient traffic growth) and future year 2021 with Project
analysis scenarios are summarized in Table 24. The existing weekday and Saturday roadway segment
traffic volumes and their corresponding LOS are summarized in column [1]. As presented in column [3], the
proposed Project weekday and Saturday daily trips were added to the existing volumes. As shown in column
[6] of Table 24, a 1% annual ambient growth rate through the year 2021 was applied to the existing
weekday and Saturday daily volumes in order to estimate the future pre-Project traffic volumes. As
presented in column [7] of Table 24, the proposed Project weekday trips are expected to incrementally
increase future traffic volumes on the analyzed street segments. It is noted that the Project trips are based
on the Project trip generation forecasts and the Project trip distribution patterns.
As indicated in Table 24 below, all of the study street segments analyzed are anticipated to operate at LOS
C or better with the addition of the proposed Project weekday and Saturday daily traffic. As noted previously
in the Circulation and Infrastructure Element of the City of Arcadia General Plan 2010, roadway segments
operating at LOS D or better are considered to be at acceptable levels. Thus, the Project is not anticipated
to significantly impact the analyzed street segments under either the existing or future year 2021
conditions. Therefore, no mitigation measures are required or recommended.
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Table 24. Street Segment Analysis Summary Existing and Future Weekday and Weekend Conditions
Street Segment Time CAP1
[1]
2019 Existing
Conditions [2]
Net Daily Project
Build-Out Trip Ends
[3]
Existing with project [4]
% ADT Increase
with project
[5]
Existing with Project
Segment Impact
[6]
Year 2021 Future
Pre-Project
[7]
Year 2021 with Project [8]
% ADT Increase
with project
[9]
Future with Project
Segment Impact VOL V/C LOS VOL V/C LOS VOL V/C LOS VOL V/C LOS
Colorado Place between San
Juan Drive and Colorado
Boulevard
Wk. 40,000 13,902 0.35 A 952 14,854 0.37 A 6.8% No 14,180 0.35 A 15,132 0.38 A 6.7% No
Sat. 40,000 9,804 0.25 A 1076 10,880 0.27 A 11% No 10,000 0.25 A 11,076 0.28 A 10.8% No
Huntington Drive (EB) between
Santa Clara Street and
Centennial Way
Wk. 30,000 14,530 0.48 A 73 14,603 0.49 A 0.5% No 14,821 0.49 A 14,894 0.50 A 0.5% No
Sat. 30,000 12,384 0.41 A 139 12,523 0.42 A 1.1% No 12,632 0.42 A 12,771 0.43 A 1.1% No
Huntington Drive (WB) between
Santa Clara Street and
Centennial Way
Wk. 30,000 16,732 0.56 A 73 16,796 0.56 A 0.4% No 17,057 0.57 A 17,130 0.57 A 0.4% No
Sat. 30,000 14,597 0.49 A 139 14,736 0.49 A 1.0% No 14,889 0.50 A 15,028 0.50 A 0.9% No
Huntington Drive between Santa
Clara Street Santa Anita Avenue
Wk. 40,000 28,251 0.71 C 976 29,227 0.73 C 3.5% No 28,816 0.72 C 29,792 0.74 C 3.4% No
Sat. 40,000 24,090 0.60 A 1204 25,294 0.63 B 5.0% No 24,572 0.61 B 25,776 0.64 B 4.9% No
Santa Anita Avenue between
Santa Clara Street and
Huntington Drive
Wk. 40,000 29,514 0.74 C 588 30,102 0.75 C 2.0% No 30,104 0.75 C 30,692 0.77 C 2.0% No
Sat. 40,000 26,293 0.66 B 624 26,917 0.67 B 2.4% No 26,819 0.67 B 27,443 0.69 B 2.3% No
Santa Anita Avenue south of
Huntington Drive
Wk. 40,000 30,709 0.77 C 22 30,731 0.77 C 0.1% No 31,323 0.78 C 31,345 0.78 C 0.1% No
Sat. 40,000 27,018 0.68 B 128 27,146 0.68 B 0.5% No 27,558 0.69 B 27,686 0.69 B 0.5% No
Source: Appendix F
Notes:
1 Daily capacity is based on 10,000 vehicles per day per lane.
[1] The existing daily traffic volumes were determined based on counts conducted by City Traffic Counters in April 2019 (provided in Appendix A).
[2] Net project build out daily trip ends include inbound and outbound trips based on the project trip generation forecasts in Table 21.
[3] Total of columns [1] and [2].
[4] Percent project-related increase based on column [2] divided by column [1].
[5]/[9] According to the General Plan, Circulation and Infrastructure Element, roadway segments operating at LOS A through LOS D are considered acceptable levels and LOS E at roadways adjacent to 1) freeway ramps; 2) Santa Anita Park and linked roadways; and 3) the Downtown, Baldwin
Avenue, and Live Oak Avenue commercial and mixed-use districts.
[6] An ambient growth rate of 1% per year was assumed to derive the year 2021 future pre-project traffic volumes
[7] Total of columns [2] and [6]
[8] Percent project-related increase based on column [2] divided by column [6]
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Freeways
Each of the two Santa Anita Avenue off-ramp intersection approaches were reviewed in terms of expected
maximum vehicle queues (i.e., 95th percentile queues) which represent the maximum back of vehicle
queues with 95th percentile traffic volumes. The corresponding maximum vehicle queue lengths were then
compared with the 85th percentile ramp storage lengths (i.e., 85% of the available storage length as
measured from the applicable freeway/frontage road gore areas to the respective off-ramp lane
merges/approach limit lines).
Both the I-210 Freeway Westbound Off-Ramp at the Santa Anita Avenue intersection and the I-210 Freeway
Eastbound Off-Ramp at the Santa Anita Avenue intersection are controlled by traffic signals. As shown in
Table 11-2 of Appendix F, adequate 85th percentile storage lengths are provided to accommodate the
forecast 95th percentile queues under the year 2021 with project build-out conditions. Therefore, based
on a review of the queuing analyses and the storage lengths, vehicle queuing back onto the I-210 Freeway
mainline travel lanes is not expected. The corresponding weekday AM, weekday PM, and Saturday PM peak
hour HCM worksheets for purposes of determining the 95th percentile vehicle queues are contained in
Appendix C. In addition, based on the HCM delay based methodology, both ramp intersections identified
above are operating at acceptable Levels of Service (LOS).
Caltrans Analysis
a supplemental
analysis was prepared based on the HCM (Transportation Research Board 2016) operational analysis
of Traffic Impact Studies (Appendix F). Based on recent coordination with Caltrans, analyses of Caltrans
facilities should be conducted when and if a proposed project is expected to add 50 or more peak hour
trips in either direction on a freeway mainline segment (Appendix F).
The proposed Project at build-out is not expected to generate 50 or more vehicle trips, during either the
weekday AM or PM commute peak hours, at any freeway mainline location. Thus, any freeway mainline
location would not exceed the threshold for preparation of a Caltrans freeway mainline analysis. However,
the proposed Project is expected to contribute traffic generation at two ramp intersections and they have
been analyzed based on Caltrans methodology during the weekday AM, weekday PM, and Saturday PM
commute peak hours. The following Caltrans study intersections have been identified for analysis based on
their proximity to the Project site:
Intersection No. 5 Santa Anita Avenue/I-210 Freeway Westbound Ramps
Intersection No. 6 Santa Anita Avenue/I-210 Freeway Eastbound Ramps
According to the Caltrans document, the LOS for operating state highway facilities is based upon measures
of effectiveness (MOEs). For state-controlled signalized study intersections, the MOE is determined based
on control delay in seconds per vehicle
transition between LOS C and LOS D on s
maintained. However, Caltrans acknowledges that this may not always be feasible and recommends that
the lead agency consult with Caltrans to determine the appropriate target LOS. If an existing state highway
facility is operating at less than the appropriate target LOS, the existing MOE should be maintained. For this
analysis, LOS D is the target level of service standard and will be utilized to assess the project impacts at
the Caltrans study intersections. For signalized intersections, Caltrans considers a location to be impacted
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if the target MOE is not maintained and a corresponding change in control delay in seconds per vehicle
(sec/veh) is 1.0 second or more.
Based on the HCM operations method of analysis, level of service for signalized intersections is defined in terms
of control delay, which is a measure of driver discomfort, frustration, fuel consumption, and lost travel time. The
delay experienced by a motorist is made up of a number of factors that relate to control, geometries, traffic, and
incidents. Total delay is the difference between the travel time actually experienced and the reference travel
time that would result during ideal conditions: in the absence of traffic control, in the absence of geometric delay,
in the absence of any incidents, and when there are no other vehicles on the road.
The HCM signalized methodology calculates the control delay for each of the subject traffic movements and
determines the level of service for each constrained movement. The control delay for any particular
movement is a function of the capacity of the approach and the degree of saturation. The overall control
delay is measured in seconds per vehicle and the level of service is then determined. The term Level of
Service is used to describe intersection operations. Intersection LOS vary from LOS A (free flow) to LOS F
(jammed condition). The six qualitative categories of Level of Service that have been defined along with the
corresponding HCM control delay value range for signalized intersections are shown in Appendix F.
Intersection and queuing analyses were prepared utilizing the Synchro 10 software package which
implements the HCM operational methods. A Synchro network was created based on existing conditions
field reviews at the above two (2) Caltrans study intersections. In addition, specifics such as lane
configurations, storage lengths, crosswalk locations, posted speed limits, traffic signal phasing, and traffic
volumes, were coded to complete the existing network.
Table 11-1 in Appendix F summarizes the intersection analyses for the existing, existing with project, and
future conditions both without and with the proposed project. As shown in Table 11-1 in Appendix F,
application of the Caltrans LOS standards and guidelines to the existing with project and future with project
conditions indicate that the proposed Project is not expected to adversely impact either of the Caltrans
study intersections. The corresponding weekday AM, weekday PM, and Saturday PM peak hour HCM
worksheets are contained in Appendix F.
Public Transit
As previously discussed, existing transit service is provided in the vicinity of the proposed Project.
As shown in Table 23, during the weekday PM peak hour, the proposed Project is anticipated to generate
demand for 7 net new transit trips. Over a 24-hour weekday period, the proposed Project is forecast to
generate demand for 120 daily transit trips. During the Saturday PM peak hour, the proposed Project is
anticipated to generate demand for 12 net new transit trips. Over a 24-hour Saturday period, the proposed
Project is forecast to generate demand for 148 daily transit trips. The calculations are as follows:
Weekday AM Peak Hour = 178 * 1.4 * 0.035 = 9 Transit Trips
Weekday PM Peak Hour = 147 * 1.4 * 0.035 = 7 Transit Trips
Weekday Daily Trips = 2,442 * 1.4 * 0.035 = 120 Transit Trips
Saturday PM Peak Hour = 245 * 1.4 * 0.035 = 12 Transit Trips
Saturday Daily Trips = 3,012 * 1.4 * 0.035 = 148 Transit Trips
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As explained in Section 3.17(a) and shown in Table 25, Existing Transit Routes, below, Metro, Foothill, and
Arcadia Transit bus routes are provided adjacent to or in close proximity to the Project site. As outlined in
Table 25
an average of the directional number of buses during the peak hours) of approximately 39 buses/trains
serving the project area during the weekday AM peak hour, 43 buses/trains serving the project area during
the weekday PM peak hour, and 27 buses/trains during the Saturday PM peak hour. Therefore, based on
the above calculated weekday AM, weekday PM, and Saturday PM peak hour transit trips, this would
correspond to an average of less than one new transit rider per bus due to the proposed project. It is
anticipated that the existing transit service in the project area will adequately accommodate the project-
generated transit trips. Thus, given the low number of generated transit trips per bus, no impacts on existing
or future transit services in the project area are expected to occur as a result of the proposed project.
Table 25. Existing Transit Routes
Route Destinations Roadways Near Site
Number of Buses/ Trains During
peak hour
DIR
Weekday Saturday
AM PM PM
Arcadia
Transit
Blue Line
City of Arcadia Santa Anita Avenue,
Huntington Drive, Arcadia
Gold Line Station
EB 1 2 1
WB 1 2 1
Arcadia
Transit
Green
Line
City of Arcadia Holly Drive, Huntington
Drive, Arcadia Gold Line
Station
Clockwise 2 3 3
C/Clockwise 2 3 3
Foothill
Transit
187
Azusa to Pasadena via Duarte,
Monrovia, Arcadia, and Sierra
Madre
Santa Anita Avenue, Santa
Clara Street, Holly Avenue,
and Huntington Drive
EB 4 4 2
WB 4 4 2
Metro 79 Downtown Los Angeles to
Arcadia via El Sereno,
Alhambra, and South Arcadia
Santa Anita Avenue, Santa
Clara Street, Holly Avenue,
and Huntington Drive
EB 2 2 2
WB 3 2 1
Metro
487
El Monte to Los Angeles via
Arcadia, Pasadena, San
Marino, Temple City, San
Gabriel, and Downtown Los
Angeles
Santa Anita Avenue, and
Huntington Drive
EB 2 3 1
WB 2 2 1
Metro
Gold Line
Azusa to East Los Angeles via
Irwindale, Duarte, Monrovia,
Arcadia, Sierra Madre,
Pasadena, South Pasadena,
Highland Park, Lincoln
Heights, Chinatown, and Union
Station
Arcadia Gold Line Station NB 8 8 5
SB 8 8 5
Total 39 43 27
Source: Appendix F
Conclusion
As shown in Table 21,
expected to create significant impacts at any of the study intersections under the Existing with Project or
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Future with Project scenarios. Incremental, but not significant, impacts are noted at the study intersections.
All study intersections would remain at LOS D or better in both peak hours, and, as such, the proposed
. As such, the proposed Project would not conflict with
a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle,
and pedestrian facilities. Impacts would be less than significant. No mitigation is required.
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less Than Significant Impact. CEQA Guidelines Section 15064.3, subdivision (b), lists the criteria that must
be used for applying VMT analysis to development Project and for determining the significance of
transportation impacts under VMT criteria. Section 15064.3, subdivision (b) is further divided into four
subdivisions: (1) land use projects, (2) transportation projects, (3) qualitative analysis, and (4) methodology.
The proposed Project is hospitality project, which would include the conversion of an existing 76,754-sf
building (Building C) into a hotel and the construction of a new 61,538-square-foot hotel annex building
(Building D). The proposed Project would comprise: 165 hotel rooms, a 1,568 sf coffee shop, 7,466 sf spa,
4,146 sf restaurant, and 1,033 sf bar. The proposed Project would generate temporary construction-related
traffic and would generate 2,442 daily trips ends during typical weekday operation (refer to Appendix F).
As previously stated, the guidelines shall applied by all lead agencies, statewide, by July 1, 2020, and at
this time, the City has not yet implemented VMT as a primary traffic evaluation methodology. As such, the
current guidelines (based on LOS). Because the City has not adopted the use of VMT pursuant to SB 743,
the proposed Project would be evaluated according to CEQA Guidelines Section 15064.3, subdivision
(b)(3), qualitative analysis. This guideline recognizes that lead agencies may not be able to quantitatively
estimate VMT for every project type. In those circumstances, this subdivision encourages lead agencies to
evaluate factors such as the availability of transit, proximity to other destinations, and other factors that
may affect the amount of driving required by the Project.
As stated above in Section 3.17(a), the proposed Project is located in close proximity to both public bus
and rail service. Public bus transit service in the Project area is provided by Foothill Transit, Metro, and
Arcadia Transit. Foothill Transit provides bus transit service along major roadways within the transportation
analysis study area: Huntington Drive and Santa Anita Avenue. Foothill Transit currently operates one transit
route in the vicinity of the Project site. This bus line provides headways of four buses during the weekday
morning peak hour and four buses during the weekday afternoon peak hour. Metro provides bus transit
service along major roadways within the transportation analysis study area: Huntington Drive and Santa
Anita Avenue. Metro currently operates two local Metro bus transit routes in the vicinity of the Project site.
The Metro bus transit routes provide headways of two to three buses during the morning and afternoon
peak hours.
Arcadia Dial-A-Ride is a demand-response service providing curb-to-curb transportation to seniors and
persons with disabilities to and from any destination within the Arcadia city boundaries, including all
shopping areas, commercial centers, the Methodist Hospital, medical centers, the civic center, parks, the
racetrack, libraries, etc. The service is provided based on space availability and is open Monday through
Friday from 7:00 a.m. to 9:00 p.m. and Saturday/Sunday from 7:00 a.m. to 7:00 p.m. Trip requests can be
made the same day or up to seven days in advance.
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The Metro Gold Line Arcadia Station is also located approximately one-half mile northeast of the Project
site, at the northwest corner of First Avenue and Santa Clara Street. Arcadia Transit provides fixed-route
general public transit service with three lines (i.e., Green, Blue and Red Lines). Two of the three lines
operate in the vicinity of the Project site. These lines provide headways of generally one to two buses during
the weekday morning peak hour and two to three buses during the weekday afternoon peak hour.
In addition to readily available public transit, the proposed Project would provide enhanced pedestrian and
bicycle amenities. The proposed Project would provide a combination of landscape and hardscape
improvements that would facilitate internal accessibility and encourage active transportation. The Project
site is accessible from surrounding land uses and nearby public transportation as well as via public
sidewalks on Colorado Place, W. Huntington Drive and San Rafael Road. The Project is well located to
further facilitate and encourage bicycling as a mode of transportation as these facilities are built throughout
the City.
In summary, the proposed Project is conveniently located in close proximity to public transit and would provide
opportunities for increased pedestrian and bicycle activity, all of which would contribute to reducing the
the proposed Project would not conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b). Impacts would be less than significant and no mitigation is required.
c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less Than Significant Impact. The proposed Project would not modify any other existing roadways leading
to the site and would not involve construction of structures that would cause transportation hazards. All
, Development Code, and
Design Standards. Therefore, the proposed Project would not substantially increase roadway hazards due
to design features. The proposed Project would involve construction of a hotel development in a commercial
area that has been designated and planned for such uses. As such, development of the proposed Project
would not introduce incompatible uses to the Project area having the potential to contribute to hazardous
roadway conditions. Impacts would be less than significant. No mitigation is required.
d) Would the project result in inadequate emergency access?
No Impact. The City of Arcadia General Plan includes a Safety Element Chapter, which addresses community
safety for environmental hazards, human caused hazards, threats to national security, emergency services,
and emergency preparedness (City of Arcadia 2010b). In addition, Los Angeles County Department of Public
Works has designated disaster evacuation routes for the City of Arcadia. Colorado Place and Huntington Drive,
both located adjacent to the Project site, are designated disaster routes. Construction of the proposed Project
would not require road closures in public right-of-ways of Colorado Place or Huntington Drive. Therefore,
emergency service response times and disaster evacuation routes would not be affected. Prior to operation,
the proposed Project would receive all required permits and certificates for occupancy and operation,
including those issued by the City of Arcadia Fire Department, which is the agency in charge of emergency
response at the Project site. Therefore, no interference or impairment of the emergency response or
emergency evacuation plans would occur, and no impact would occur.
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3.18 Tribal Cultural Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California
Native American tribe, and that is:
a) Listed or eligible for listing in the California Register
of Historical Resources, or in a local register of
historical resources as defined in Public Resources
Code section 5020.1(k), or
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe?
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource,
defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural
value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register
of historical resources as defined in Public Resources Code section 5020.1(k)?
Less Than significant Impact. As described under Section 3.5 , Cultural Resources, of this
document, a CHRIS records search and SLF was conducted for the proposed Project site. No
previously recorded tribal cultural resources (TCRs) listed in the CRHR or a local register were identified
within the proposed Project site. Further, no TCRs have been identified by California Native American
tribes as part of the Ci ssembly Bill (AB) 52 notification and consultation process (see Section
3.18(a)(ii) below for a description of this process). Therefore, the proposed Project would not adversely
affect TCRs that are listed or eligible for listing in the state or local register Impacts are considered less
than significant. No mitigation is required.
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ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1,
the lead agency shall consider the significance of the resource to a California Native American tribe?
Less Than Significant with Mitigation Incorporated. There are no resources in the proposed Project
site that have been determined by the City to be significant pursuant to the criteria set forth in
Public Resources Code Section 5024.1. Further, no specific TCRs were identified in the proposed
Project site through the CHRIS records search, by the NAHC, or by the City as part of the AB 52
notification and consultation process.
In an effort to proactively reach out to tribes with a cultural affiliation to the proposed Project site,
the City sent notification of the proposed Project to California Native American tribal
representatives identified by the NAHC as being traditionally or culturally affiliated with the
geographic area pursuant to AB 52 on July 9, 2019. Of the six (6) affiliated or interested tribes,
two responded: Gabrieleno Band of Mission Indians Kizh Nation and Gabrieleno-Tongva
Tribe. Furthermore, only one requested consultation; the response from representative,
Andrew Salas, of the Gabrieleno Band of Mission Indians Kizh Nation was received with a
request for consultation (July 16, 2019). After several calls and emails, consultation between
the City and the Gabrieleno Band of Mission Indians Kizh Nation was scheduled for October
17, 2019; however, the meeting was cancelled (via email) by the Gabrieleno Band of Mission
Indians Kizh Nation (Tribe) on October 15, 2019. City Staff responded to email informing the
Tribe that several attempts to consult were made by Staff and that the meeting should be
rescheduled. No response was received. To date, no additional correspondence has occurred
and consultation is considered complete.
The AB 52 government-to-government consultations initiated by the City have not resulted in the
identification of a geographically defined TCR within or near the proposed Project site. As no
information regarding TCRs that could be impacted by the proposed Project has been received by the
City, the City has determined that no TCRs are present in the proposed Project site. However, there is
still a potential for unknown subsurface TCRs to be impacted by the proposed Project, which could
result in a potentially significant impact. Therefore, protocols for the inadvertent discovery of TCRs
are included as mitigation measure MM-TCR-1, which when implemented, will reduce the potentially
significant impact to a less than significant impact with mitigation incorporated.
The following mitigation measure would ensure that the proposed Project has a less-than-
significant impact on TCRs.
MM-TCR-1 Should a possible TCR be encountered, construction activities within 50 feet of the
discovery shall be temporarily halted and the City notified. The City will notify Native
American tribes that have been identified by the NAHC to be traditionally and
culturally affiliated with the geographic area of the Project. If the potential resource
is archaeological in nature, appropriate management requirements shall be
implemented as outlined in MM-CUL-1. If the City determines that the potential
resource is a TCR (as defined by PRC, Section 21074), tribes consulting under AB
52 would be provided a reasonable period of time, typically 5 days from the date
of a new discovery is made, to conduct a site visit and make recommendations
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regarding future ground disturbance activities as well as the treatment of any
discovered TCRs. A qualified archaeologist shall implement a plan for the
treatment and disposition of any discovered TCRs based on the nature of the
resource and considering the recommendations of the tribe(s). Implementation of
proposed recommendations will be made based on the determination of the City
that the approach is reasonable and feasible.
3.19 Utilities and Service Systems
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or construction of new
or expanded water, wastewater treatment, or storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve the
project and reasonably foreseeable future development
during normal, dry, and multiple dry years?
c) Result in a determination by the wastewater treatment
provider, which serves or may serve the project that it
has adequa
commitments?
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management and
reduction statutes and regulations related to solid
waste?
a) Would the project require or result in the relocation or construction of new or expanded water, wastewater
treatment, or storm water drainage, electric power, natural gas, or telecommunications fac ilities, the
construction or relocation of which could cause significant environmental effects?
Less Than Significant Impact.
Water. According to the General Plan EIR, the City of Arcadia is its own water supplier, and provides water to
approximately 96%
from the San Gabriel Valley and Raymond Groundwater Basins and from water imported from the Upper San
ibution infrastructure comprises 164.6 miles of
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water lines (City of Arcadia 2010a). No water infrastructure improvements are required and no off-site impacts
are necessary. The proposed Project would connect to the existing water utility infrastructure and would be
to water infrastructure improvements in the City.
and size of the meters and the number of fire hydrants required to serve the Project site.
Wastewater.
through which the City manages and operates sewer system demand, supply, and associated infrastructure
(City of Arcadia 2014). Sewer lines in the City convey wastewater into trunk lines that are maintained by
the Sanitation District of Los Angeles County (LACSD)
138 miles of sewer pipelines. According
infrastructure needs to be upgraded to accommodate anticipated growth through 2026 (City of Arcadia
2010a
The Whittier Narrows Water Reclamation Plant (WRP), located near the City of South El Monte, with
a design capacity of 15 million gallons per day (mgd) and an average flow of 5.4 mgd.
The San Jose Creek WRP, located adjacent to the City of Industry, with a design capacity of 100
mgd and an average flow of 77.1 mgd.
The Los Coyotes WRP, located in the City of Cerritos, with a design capacity of 37.5 mgd and an
average flow of 27 mgd.
The Project site is currently served by existing 10-inch and 12-inch sewer lines in Colorado Place, San Rafael
Road, and San Juan Drive. Wastewater from the Project area is transported to the San Jose Creek Water
Reclamation Plant, which is operated by the LACSD.
n, sewer system fees and
permits.17 The proposed Project would be connected to the existing 12-inch high-density polyethylene pipe
(HDPE) line in Colorado Place and the existing 8-inch HDPE pipe in San Rafael Road, and would be
transported to the San Jose Creek Water Reclamation Plant. -2016 Capital
Improvement Project Form, improvements to the sewer lines in Huntington Drive were funded and approved
in 2015. To date, the 10-inch sewer pipe on Huntington Drive (from Colorado Place to Centennial Way) has
been replaced with a 14-inch sewer pipe, and the 12-inch sewer pipe (from Centennial Way to the LACSD
connection point) was replaced with a 16-inch sewer pipe. These improvements, including phase III of the
Huntington Drive Sewer Capacity Improvement Project have been completed (City of Arcadia 2018).
The proposed Project would adhere to City of Arcadia Municipal Code, Article VII, Chapter 4, Part 4, Fees
and Deposits, which requires that the proposed Project pay development impact
fair share contribution to sewer infrastructure improvements. Any additional sewer infrastructure
improvements or expansions
would constitute its fair share contribution towards any needed future capital improvements. As such,
implementation of the proposed Project would have a less than significant impact on wastewater
infrastructure. No mitigation is required.
Stormwater. The proposed Project is not expected to generate increased stormwater runoff. As described
under Section 3.10, the drainage patterns of the Project site would not substantially change relative to
17 City of Arcadia Municipal Code, Article VII, Chapter 4, Part 1 through 8 Sewers.
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existing conditions. As previously discussed under Section 3.10, all development and redevelopment
projects must comply with the latest LID Standards Manual, which complies with the requirements of the
NPDES 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation of
stormwater quality control measures in new development and redevelopment projects with the intention of
improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater
discharges (LA County 2014). Project design, construction, and operation would be completed in
accordance with the LID Standards Manual and the Project-specific LID Plan. The LID Plan would use site
design and stormwater management in order to maintain -development runoff rates and
-development hydrology by using design
techniques that filter, store, evaporate, and detain runoff close to the source of rainfall. Compliance with
storm drain system and would ensure that stormwater is retained on site, to the extent feasible. As such,
the proposed Project would not require the construction or expansion of off-site stormwater drainage
facilities, as the project would not contribute a substantial amount of new stormwater runoff relative to
existing conditions.
Solid Waste. The California Solid Waste Reuse and Recycling Access Act of 1991 (AB 341) declared that
cities and counties must divert 50% of all solid waste by 2000 and aims to reduce 75% of all solid waste
by 2020, through source reduction, recycling and composting activities, as well as, provide adequate areas
for collecting and loading recyclable materials. Under the California Solid Waste Reuse and Recycling
Access Act of 1991, each local agency must adopt an ordinance for collecting and loading recyclable
materials.18 s act by reference.19 The proposed Project
would adhere to the Solid Waste Reuse and Recycling Act through adherence with City Municipal Code,
Article V, and, as such, solid waste generated under the proposed Project would be less than significant.
Electricity and Natural Gas. SCE provides electricity to the City, and operates four substations within the
and yard easements, and high-voltage transmission lines exist along the I-605 freeway (City of Arcadia
2010a). Electricity to the Project site is provided by SCE via four 66-kilovolt transmission lines located on
ed in place during
construction-related activities. No off-site improvements for electric power infrastructure are anticipated
with the implementation of the proposed Project.
Sempra Utilities provides natural gas to the City via distribution lines and laterals within the City streets and
easements. A high-pressure gas line lies approximately 42 inches belowground and crosses the City along
Duarte Road, from Holly Avenue to Mountain Avenue in Monrovia (City of Arcadia 2010a). These gas lines
would be protected in place during construction-related activities. No off-site improvements for natural gas
infrastructure are anticipated with the implementation of the proposed Project.
Telecommunication Facilities. The proposed Project would not require new or expanded
telecommunication facilities.
In summary, the proposed Project would adhere to state and local legislation pertaining to the payment of
-share contribution to increased demand for utility
18 Public Resources Code, Division 30, Part 3, Chapter 18, Section 42910 through 42912 - California Solid Waste Reuse and
Recycling Access Act of 1991.
19 City of Arcadia Municipal Code, Article V, Chapter 1, Part 2, Division 1, Section 5121 Recyclables Collection.
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infrastructure and services. As such, the Project would have a less than significant impact to the environment
as a result of the relocation or construction of new or expanded water, wastewater treatment, or stormwater
drainage, electric power, natural gas, or telecommunications facilities. No mitigation is required.
b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable
future development during normal, dry, and multiple dry years?
Less Than Significant Impact. As stated above, according to the General Plan EIR, the City of Arcadia is its
sphere of influence. The City sources its water from the San Gabriel (Main) Valley and Raymond
Groundwater Basins and from water imported from the Upper San Gabriel Valley Municipal Water District.
a).
The proposed Project is consistent with the General Plan and does not require a General Plan Amendment;
Urban Water Management Plan (UWMP). As stated in the
obtained from the SCAG. The SCAG data incorporates demographic trends, existing land use, general plan
land use policies, and input and projections from the Department of Finance and the U.S. Census Bureau.
As stated in the UWMP, the Main Basin and Raymond Basin have been well managed for the full period of
their respective adjudications, resulting in a stable and reliable water supply for the City during average, single-
dry, and multiple-dry water years (City of Arcadia 2016b). Additionally, imported water from MWD can be
utilized as a supplemental source of supplies. City water conservation efforts will continue into the future to
reduce water demands within the City due to the recently implemented tiered water rate and Water Smart
program, which are intended to encourage conservation, thereby making local supplies more reliable.
According to the UWMP, the City can sustainably pump 19,500 gpm from available groundwater
supplies (15,200 gpm from the Main Basin and 4,300 gpm from the Raymond Basin). If the City pumps
more water than the allotted amount, replacement water must be purchased from the MWD for spreading
and recharging the Main San Gabriel Groundwater Basin; however, the City has not had to rely on any
imported water supplies since the 2009-2010 fiscal year (City of Arcadia 2016b). In addition to
groundwater and imported water supplies, the City may pre-purchase water for cyclic storage for later use.
Furthermore, according to the UWMP, the Main Basin has the capacity to store approximately 8.7 million
acre-feet of water, while historic basin operations have only ever reached a maximum of one million acre-
feet (UWMP 2016a). Per the UWMP, the City does not experience water supply constraints or deficiencies
and projects having adequate supply through the planning year 2040 (UWMP). The proposed Project would
not include any wells that would directly deplete groun
adequate supply through 2040.
Additionally, Arcadia operates in accordance with Phase I Mandatory Water Conservation Prohibitions, which are
Code sets forth the water conservation measures that are applicable to all customers and properties served by
the Water Division. Restrictions include but are not limited to prohibitions on outdoor watering of sidewalks,
limits on scheduling of outdoor landscape irrigation, and restrictions on provision of water to guests at
restaurants, hotels, cafes, unless expressly requested by the customer, among other restrictions.
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The proposed Project would adhere to the water conservation methods established in Title 24 of the
Efficient Landscaping Ordinance, per Article VII, Chapter 5, Part 5, Division 3 and 4 of the C
Code.20 Additionally, the proposed Project would be subject to a development impact/connection fee, which
such, the proposed Project would have sufficient water supplies available to serve the Project and
reasonably foreseeable future development during normal, dry, and multiple dry years. Impacts would be
less than significant and no mitigation is required.
c) Would the project result in a determination by the wastewater treatment provider, which serves or may
serve the project that it has adequate capacity
Less Than Significant Impact. As stated in Section 3.19(a), the proposed Project would be connected to the
existing 12-inch HDPE wastewater line in Colorado Place and the existing 8-inch HDPE pipe in San Rafael
Road, and would be transported to the San Jose Creek Water Reclamation Plant (San Jose Creek WRP).
According to the LACSD, the San Jose Creek WRP provides primary, secondary and tertiary treatment for
100 million gallons of wastewater per day (mgd), 42 mgd of which is reused at different reclaimed water
reuse sites (LACSD 2019). Based on the capacities of the San Jose Creek WRP, the wastewater generated
by the proposed Project would be nominal (less than 0.01%) of capacity. As such, the proposed Project
would not exceed current capacities of the wastewater treatment system and would not significantly impact
existing wastewater treatment systems such that new facilities would be required.
d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity
of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant Impact. -residential solid waste is disposed of through contracts with
Republic Services, Waste Management Inc., and Valley Vista Services (City of Arcadia 2019b). These waste
management services offer waste and recycling collection, green waste recycling programs, organics waste
composting, special waste transportation, and transfer and materials recovery services to the City as well
as many other areas in Southern California.
Based on the CalEEMod solid waste generation rates, the proposed Project would generate approximately
354 pounds of solid waste per day (Appendix A). Solid waste generated by the proposed Project would be
collected by Republic Services, Waste Management Inc., and Valley Vista Services and transported to a
local or regional landfill. The increase in solid waste generation from implementation of the proposed
Project would be minimal. Regional landfills in the Los Angeles area are anticipated to have sufficient
capacity to accommodate the minor increase in solid waste generation attributable to the proposed Project.
Additionally, the City adheres to the states Solid Waste Reuse and Recycling Access Act of 1991 (AB 341),
which declares that cities and counties must divert 50% of all solid waste by 2000 and 75% of all solid
waste by 2020, through source reduction, recycling and composting. Required compliance with this
asons, solid
waste impacts resulting from the construction and operation of the proposed Project would be considered
less than significant. No mitigation is required.
20 City of Arcadia Municipal Code. Article VII, Chapter 5, Part 5, Division 3 (Water Conservation Plan) and 4 (Water Efficient Landscaping).
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e) Would the project comply with federal, state, and local management and reduction statutes and
regulations related to solid waste?
No Impact. The project Applicant is required to comply with all local, state, and federal requirements for
integrated waste management (e.g., recycling, green waste) and solid waste disposal. The Project would be
required to comply with the Integrated Waste Management Act of 1989, which requires that at least 75%
of all annual solid waste materials, including building and demolition materials (wood, metal, electrical,
piping, glass, drywall, asphalt, concrete), be diverted from landfills by 2020 (CalRecycle 2019). Republic
Services, Waste Management Inc., and Valley Vista Services all adhere to AB 341, and, as such, the
proposed Project would comply with federal, state, and local management and reduction statutes and
regulations related to solid waste. No impact would occur.
3.20 Wildfire
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the
project:
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency
water sources, power lines, or other utilities) that may
exacerbate fire risk or that may result in temporary or
ongoing impacts to the environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
a) Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact. According to the General Plan EIR, the City has incorporated two emergency
preparedness plans, namely: the Natural Hazard Mitigation Plan and the ACTION Plan. The Natural Hazard
Mitigation Plan serves to protect life and property; increase public awareness; balance natural resource
management with hazard mitigation; ensure adequate emergency services; and strengthen communication
and coordination in hazard management activities (City of Arcadia 2010a). The City ACTION (Arcadians
Caring Together Improves Our Neighborhoods) is a cooperative program between the Arcadia Fire
Department, other City departments, and the community and has three main goals: a) to educate Arcadians
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on emergency preparedness and what to do after a major disaster; b) to help with crime prevention; and c)
to help with fire prevention (City of Arcadia 2010a).
According to the County of Los Angeles Department of Public Works, Colorado Place, which abuts the Project
-210 is a freeway disaster route
(LADPW 2008).
the
adopted emergency response plan or emergency evacuation plan. No short-term construction street
closures are anticipated and there would be no impairment of evacuation roadways. Upon operation of the
proposed Project, emergency access would be provided via the driveways on Colorado Place and San Juan
Drive. As such, the proposed Project would not substantially impair an adopted emergency response plan
or emergency evacuation plan and impacts would be less than significant. No mitigation is required.
b) Due to slope, prevailing winds, and other factors, would the project exacerbate wildfire risks, and thereby
expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less Than Significant Impact. The Project site is located within an urban setting and is surrounded by
developed land uses, including developed open space (for outdoor recreation), horse racing, and
public/institutional land uses to the west and south and single-family residential development to the north
and east. According to the California Department of Forestry and Fire Protection FHSZ Map, the City is not
located within a VHFHSZ (CAL FIRE 2011). The nearest wildland areas are located at the bottom of the San
Gabriel Mountains, approximately 2.6 miles north of the Project site. The proposed Project would be
constructed in adherence to the requirements set forth in the California Fire Code (Title 24, Part 9). The
proposed Project would not include the construction of any buildings or infrastructure that would
exacerbate wildfire risks. In the unlikely event of a fire emergency at the Project site due to wildland fires,
the City of Arcadia Fire Department would respond. Specifically, Fire Station 105, located at 710 S. Santa
Anita Avenue, is the closest fire station, located approximately 0.6-mile southeast of the Project site. As
such, impacts would be less than significant. No mitigation is required.
c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may
result in temporary or ongoing impacts to the environment?
Less Than Significant Impact. As stated above, the proposed Project would not include the construction of
any buildings or infrastructure that would exacerbate fire risks. The proposed Project would be constructed
in adherence to the requirements set forth in the Fire Code (Title 24, Part 9 of the California Building Code).
During construction of the proposed Project, emergency access to the Project site and surrounding area
would be maintained. Furthermore, new access routes would be built according to California Building Code
ingress/egress for emergency vehicles. In the unlikely event of a fire emergency at the Project site, the City
of Arcadia Fire Department would respond. Specifically, Fire Station 105, located at 710 S. Santa Anita
Avenue, is the closest fire station, located approximately 0.6-mile southeast of the Project site. Given the
above, the proposed Project would not include the installation or maintenance of associated infrastructure
(such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate
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fire risk or that may result in temporary or ongoing impacts to the environment. Impacts would be less than
significant and no mitigation is required.
d) Would the project expose people or structures to significant risks, including downslope or downstream
flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The proposed Project is located within a fully developed, urban area and is located on relatively
flat terrain. Construction of the proposed Project would result in ground surface disruption that could
temporarily alter on-site drainage patterns. However, runoff at the Project site would be managed through
implementation of the BMPs described in Section 3.10. Implementation of Project-specific BMPs would
ensure that the risk of flooding on or off site is minimized, to the extent practicable, during construction.
The Project site as a whole would maintain the general existing drainage pattern and would remain fully
developed. Given the above, the proposed Project would not expose people or structures to significant risks,
including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability,
or drainage changes. No impact would occur and no mitigation is required.
3.21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a) Does the project have the potential to substantially
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, substantially 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?
b) Does the project have impacts that are individually
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)?
c) Does the project have environmental effects which will
cause substantial adverse effects on human beings,
either directly or indirectly?
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a) Does the project have the potential to substantially 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, substantially 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?
Less Than Significant with Mitigation Incorporated. As discussed in Section 3.4, Biological Resources, of
this IS/MND, the Project site is located in a completely developed and urbanized area, and does not support
sensitive vegetation, sensitive wildlife species, or sensitive habitat. Additionally, the project area does not
function as a corridor for the movement of native or migratory wildlife. All activities associated with the
proposed Project would be conducted in the highly urbanized environment of the project area. Construction
noise has the potential to disturb nesting birds potentially nesting in the trees and sparsely distributed
ornamental vegetation on the Project site
nature and would be reduced to below a level of significance with implementation of MM-BIO-1. As such,
impacts to biological resources resulting from the proposed Project would be less than significant with
mitigation incorporated. No further mitigation is required.
As described in Section 3.5 of this IS/MND, the Project site does not support any important examples of
major periods in California history or prehistory. However, the presence of Gabrielino villages in the
surrounding area indicates that the project area may be sensitive for buried cultural resources (refer to
Appendix C). As such, there is a possibility of encountering previously undiscovered cultural resources at
subsurface levels during ground-disturbing activities associated with the proposed project. Implementation
of mitigation measure MM-CUL-1 and MM-TCR-1 would ensure that any uncovered archaeological
resources and/or tribal cultural resources are protected. As such, after mitigation, the proposed Project
would not substantially 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, substantially 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.
Impacts would be less than significant with mitigation incorporated. No further mitigation is required.
b) ively
the effects of past projects, the effects of other current projects, and the effects of probable future projects)?
Less Than Significant with Mitigation Incorporated. The proposed Project would result in potentially
significant project-level impacts involving Biological Resources, Cultural Resources, Geology and Soils, and
Tribal Cultural Resources. However, mitigation measures have been identified that would reduce these
impacts to less than significant levels. Furthermore, the transportation analysis presented in Section 3.17,
Transportation, of this IS/MND has quantitatively assessed cumulative impacts and have determined that
cumulative traffic impacts would less than significant. All reasonably foreseeable future development in the
City would be subject to the same land use and environmental regulations that have been described
throughout this document. Furthermore, all development projects are guided by the policies identified in
compliance with applicable land use and environmental regulations would ensure that environmental
effects associated with the proposed Project would not combine with effects from reasonably foreseeable
future development in the City to cause cumulatively considerable significant impacts. Cumulative impacts
would therefore be less than significant with mitigation incorporated. No further mitigation is required.
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c) Does the project have environmental effects which will cause substantial adverse effects on human beings,
either directly or indirectly?
Less Than Significant with Mitigation Incorporated. As detailed throughout this IS/MND, the proposed
Project would not exceed any significance thresholds or result in significant impacts in the environmental
categories typically associated with indirect or direct effects to human beings, such as aesthetics, air
quality, hazards and hazardous materials, public services, or transportation. However, as described in
Section 3.13, Noise, the proposed Project could result in potentially significant impacts in the category of
noise, during both construction and operation of the project. With implementation of MM-NOI-1 and MM-
NOI-2, this impact would be reduced to a less than significant level. As such, impacts would be less than
significant with mitigation incorporated. No further mitigation is required.
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4 References and Preparers
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manual-preparation-health-risk-0.
Roth, V.L., 1984. How Elephants Grow: Heterochrony and the Calibration of Developmental Stages in Some Living
and Fossil Species. Journal of Vertebrate Paleontology, 4(1):126-145.
SCAG (Southern California Association of Governments). 2016. 2016 2040 Regional Transportation
Plan/Sustainable Communities Strategy. Adopted April 7, 2016. Accessed March 2017.
http://scagrtpscs.net/Pages/FINAL2016RTPSCS.aspx.
SCAG (Southern California Association of Governments). 2019. Transit Priority Area (TPA) 2045 SCAG Region
[GIS database]. Accessed, November 26, 2019. http://gisdata-scag.opendata.arcgis.com/
datasets/c9249b6bba0f49829b67ce104f81ef20_1?geometry=-118.048%2C34.140%2C-
118.027%2C34.143.
SCAQMD (South Coast Air Quality Management District). 1993. CEQA Air Quality Handbook.
SCAQMD (South Coast Air Quality Management District). 2003. White Paper on Potential Control Strategies to Address
Cumulative Impacts from Air Pollution. August 2003. http://www.aqmd.gov/docs/default-source/Agendas/
Environmental-Justice/cumulative-impacts-working-group/cumulative-impacts-white-paper.pdf?sfvrsn=2.
SCAQMD (South Coast Air Quality Management District). 2005. Rule 403: Fugitive Dust. Adopted May 7, 1976.
Amended June 3, 2005.
SCAQMD (South Coast Air Quality Management District). 2008. Draft Guidance Document Interim CEQA
Greenhouse Gas (GHG) Significance Threshold. October 2008.
SCAQMD (South Coast Air Quality Management District). 2009. Final Localized Significance Threshold
Methodology. -
2009. http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-
thresholds/final-lst-methodology-document.pdf?sfvrsn=2.
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SCAQMD (South Coast Air Quality Management District). 2010. Greenhouse Gas CEQA Significance Threshold
Stakeholder Working Group Meeting #15. September 28, 2010. http://www.aqmd.gov/docs/default-
source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/
ghg-meeting-15/ghg-meeting-15-main-presentation.pdf?sfvrsn=2.
SCAQMD (South Coast Air Quality Management District)
Originally published in CEQA Air Quality Handbook, Table A9-11-A. Revised March 2015.
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-
thresholds.pdf?sfvrsn=2
SCAQMD (South Coast Air Quality Management District). 2017. Final 2016 Air Quality Management Plan. March
16, 2017. Accessed October 2017. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-
quality-management-plans/2016-air-quality-management-plan/final-2016-
aqmp/final2016aqmp.pdf?sfvrsn=15.
SVP (Society of Vertebrate Paleontology). 2010. Standard Procedures for the Assessment and Mitigation of
Adverse Impacts to Paleontological Resources. 11 p. Available; http://vertpaleo.org/Membership/
Member-Ethics/SVP_Impact_Mitigation_Guidelines.aspx.
SWRCB (California State Water Resources Control Board). 2019. State Wetland Definition and Procedures for Discharges
of Dredged or Fill Material to Waters of the State. Accessed, July 1, 2019. https://www.waterboards.ca.gov/
board_info/agendas/2019/apr/040219_10_procedures_clean_v032219.pdf.
The Climate Registry. 2018. Default Emission Factors. May 1. Accessed January 2019.
https://www.theclimateregistry.org/wp-content/uploads/2018/06/The-Climate-Registry-2018-Default-
Emission-Factor-Document.pdf.
Transportation Research Board. 2016. Highway Capacity Manual. 6th ed. October 2016.
U.S. Census Bureau. 2018. Quick Facts: Arcadia City, California. Accessed, May 28, 2019.
https://www.census.gov/quickfacts/arcadiacitycalifornia.
U.S. DOT (U.S. Department of Transportation). 2018. Transit Noise and Vibration Impact Assessment Manual.
DOT, Federal Transit Administration. September 2018.
USDA (U.S. Department of Agriculture). 2019. Natural Resource Conservation Service Web Soil Survey. Accessed
May 21, 2019. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx
USFWS (United States Fish and Wildlife Service). 2017. Migratory Bird Treaty Act of 1918. Accessed, May 29,
2019. https://www.fws.gov/laws/lawsdigest/MIGTREA.HTML.
USFWS and NWI (National Wetlands Inventory) (Surface Water and Wetlands Mapper). 2019. Accessed, May 29,
2019. https://www.fws.gov/wetlands/data/mapper.html.
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4.2 List of Preparers and Contributors
Lead Agency
City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Luis Torrico, Senior Planner
Dudek
38 North Marengo Avenue
Pasadena, California 91101
Kristin Starbird, Senior Project Manager
Tamseel Mir, Senior Project Manager
Terrileigh Pellarin, CEQA/NEPA Associate Analyst
Jennifer Reed, Senior Air Quality Specialist
David Larocca, Air Quality Specialist
Linda Kry, Senior Archaeologist
Ted Roberts, Senior Archaeologist
Michael Williams, Archaeologist
Michael Cady, Senior Biologist
Glenna McMahon, Principal Engineer
Michael Greene, INCE, Senior Noise Specialist
Perry Russell, Environmental Technical Group Planner
Ryan Munnikhuis, Environmental Technical Group Associate Analyst
Christopher Starbird, GIS Specialist
Amy Seals, Senior Technical Editor
Kara Murphy, Publications Specialist
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Response to Comments on the
Initial Study/Mitigated Negative Declaration &
Mitigation Monitoring and Reporting Program
Arcadia Hotel and Annex
(Hotel Indigo) Project
Prepared for:
City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Prepared by:
38 N. Marengo Avenue
Pasadena, California 91101
MARCH 2020
Printed on 30% post-consumer recycled material.
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Table of Contents
SECTION PAGE NO.
ACRONYMS AND ABBREVIATIONS ............................................................................................................................. III
PREFACE ..................................................................................................................................................................... V
1 RESPONSE TO COMMENT RECEIVED ........................................................................................................... 1
Response to Comment Letter A .......................................................................................................................... 5
2 ERRATA ......................................................................................................................................................... 8
3 MITIGATION MONITORING AND REPORTING PROGRAM ............................................................................. 10
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Acronyms and Abbreviations
Acronym/Abbreviation Definition
CHRIS California Historical Resources Information System
CEQA California Environmental Quality Act
City City of Arcadia
IS/MND Initial Study/Mitigated Negative Declaration
GHG greenhouse gas
HVAC heating, ventilation, and air conditioning
MBTA Migratory Bird Treaty Act
MM mitigation measure
NAHC Native American Heritage Commission
TCR tribal cultural resource
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Preface
The Initial Study/Mitigated Negative Declaration (IS/MND) is an informational document intended to disclose to the
City of Arcadia (City) and to the public the environmental consequences of approving and implementing the Arcadia
Hotel and Annex Project (Hotel Indigo or proposed Project). The IS/MND for the proposed Project was released for
public review and comment on February 13, 2020. The public review period ended on March 5, 2020. One comment
letter was received by the City during the public review period.
public comment received during the review
period, to show minor changes that have been made to the IS/MND since publication in February 2020 as a result
of these comments, and to set forth a mitigation monitoring and reporting program (MMRP) for the proposed
Project.
The comment letter and associated response is presented in Section 1.0 of this document. The minor changes that
have been made to the IS/MND as a result of the comment is shown in Section 2.0, and the MMRP constitutes
Section 3.0. The MMRP has been prepared pursuant to CEQA Guidelines, Section 15074(d), which requires that a
lead or responsible agency adopt a mitigation monitoring plan when approving or carrying out a project when an
MND identifies measures to mitigate or avoid significant environmental effects.
CEQA Guidelines Regarding Recirculation
Pursuant to CEQA Guidelines, Section 15073.5, the City is required to recirculate an IS/MND when the document
is substantially revised after public notice of its availability but prior to its adoption. A substantial revision is
identified as follows: (1) a new avoidable significant effect is identified and mitigation measures or project revisions
must be added in order to reduce the effect to insignificance or (2) the lead agency determines that the proposed
mitigation measures or project revisions will not reduce potential effects to less than significant and new measures
or revisions must be required.
The City has determined that based on CEQA Guidelines Section 15073.5, recirculation of the IS/MND prior to
adoption is not required. This conclusion is based on the fact that no new, avoidable significant effects have been
identified, no new mitigation measures were added, and the text of the document has not been substantially revised
in a manner requiring recirculation.
Record of Proceedings
The do
is based are located at the address below:
City of Arcadia, Planning Services Division
240 West Huntington Drive
Arcadia, California 91007
The City Planning Services Division is the custodian of such documents and other materials that constitute the
record of proceedings. The location of and custodian of the documents or other materials that constitute the record
of proceedings for the proposed Project is provided in compliance with CEQA Guidelines Section 15074(c).
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1 Response to Comment Received
This section includes a copy of the comment letter provided during the public review period of the IS/MND. The
comment letter received has been assigned a letter (e.g., A). The issue within the comment letter is bracketed and
numbered (e.g., A-1). The comment letter is followed by a response, which is lettered and numbered to correspond
with the bracketed comment.
s a good-faith, reasoned effort to address the
environmental issues identified by the comments. Pursuant to State CEQA Guidelines Section 15074(b), decision
makers will consider the IS/MND together with the comment received during the public review process.
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Response to Comment Letter A
Gabrieleno Band of Mission Indians - Kizh Nation
February 18, 2020
A-1 In this comment letter, the Gabrieleno Band of Mission Indians Kizh Nation (Tribe) requested the
retention of a Native American Tribal Consultant to monitor all ground disturbance conducted for the
Project. The letter did not identify any specific tribal cultural resources (TCRs) or other cultural resources
on the Project site, nor did it express any concerns regarding the environmental analysis or the impact
conclusions in the IS/MND.
As described in Sections 3.5 (Cultural Resources) and 3.18 (Tribal Cultural Resources) of the IS/MND,
encountering intact subsurface cultural resources or tribal cultural resources (TCRs) during Project
implementation is considered unlikely. Furthermore, previous development within the Project site such
as the construction of Building C, which contains a small basement, is likely to have impacted cultural
deposits, if any were present on the site. However, as stated in Sections 3.5 and 3.18 of the IS/MND,
there is still the potential to encounter unanticipated cultural resources or unknown subsurface TCRs
during construction, which could result in a potentially significant impact to those resources. Within
areas of the Project site proposed for new development, specifically the construction of Building D and
associated swimming pool, the chance of discovering archaeological deposits is greater than in other
areas of the site. Protocols for the inadvertent discovery of cultural resources and TCRs were included
as mitigation measures MM-CUL-1 and MM-TCR-1 in the IS/MND. The analysis in the IS/MND
determined that these measures would effectively reduce potentially significant impacts to below a
level of significance.
While no new impacts or specific on-site TCRs have been identified, the City has responded to the
-TCR-1. MM-TCR-1, as revised,
is provided below (new text is shown in underline). This additional monitoring provision has been added
in response to the aforementioned comment received during the public review period for the IS/MND
and has not been added as a result of any new significant effects or as a result of a determination that
the originally proposed MM-TCR-1 was insufficient at reducing impacts. Rather, this revision was made
to amplify the originally proposed measure in response to comments received during public review of
the IS/MND. This revision does not change any impact conclusions in the IS/MND, is not necessary to
mitigate a new significant effect, and would not create any new significant environmental effects. For
these reasons, the revisions to MM-TCR-1 do not require recirculation of this IS/MND under CEQA
Guidelines Section 15073.5 and per CEQA Guidelines Section 15074.1.
MM-TCR-1: Prior to commencement of construction activities for the Project, a regionally appropriate
Native American monitor/consultant shall be retained to monitor ground disturbing activities.
Notification to the tribes will be provided 30 days prior to issuance of a grading permit or any ground
disturbance activities. If a tentative date is not set by the Tribe, the City has the ability to have another
qualified monitor complete this task and submit the final logs to the tribe after all ground disturbance
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activities have been completed. The Native American monitor/consultant will only be present on site
during the construction phases that involve ground disturbing activities within the areas of Building D,
the associated swimming pool, and paved areas within the Project site. The frequency and duration of
monitoring shall be based on observations made by the Native American monitor(s) in coordination
with the City. The on-site monitoring shall end when the ground disturbance activities at these specific
locations are completed. The Native American Monitor/consultant shall complete daily monitoring logs
that will include descriptions of daily construction activities, location of activities, soil, and any identified
cultural materials or potential tribal cultural resources (TCRs). Should a possible TCR be encountered,
construction activities within 50 feet of the discovery shall be temporarily halted and the City notified.
The City will notify Native American tribes that have been identified by the NAHC to be traditionally and
culturally affiliated with the geographic area of the Project. If the potential resource is archaeological
in nature, appropriate management requirements shall be implemented as outlined in MM-CUL-1. If
the City determines that the potential resource is a TCR (as defined by PRC, Section 21074), tribes
consulting under AB 52 would be provided a reasonable period of time, typically 5 days from the date
of a new discovery is made, to conduct a site visit and make recommendations regarding future ground
disturbance activities as well as the treatment of any discovered TCRs. A qualified archaeologist shall
implement a plan for the treatment and disposition of any discovered TCRs based on the nature of the
resource and considering the recommendations of the tribe(s). Implementation of proposed
recommendations will be made based on the determination of the City that the approach is reasonable
and feasible.
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2 Errata
The comment received by the City during the public review period for the IS/MND included information that has
resulted in minor revisions to the text of the IS/MND. These revisions are shown below and are categorized by
section number and page number. Text has been added is shown as underlined (i.e., underline).
This errata shows changes to MM-TCR-1, as described in Section 1.0, above. These changes do not require
recirculation of the IS/MND pursuant to Section 15073.5 of the CEQA Guidelines. Additionally, the City finds that
the revised MM-TCR-1 is equal to or more effective than the measure present in the IS/MND that was circulated for
public review in February 2020.
Section 1.4, Table 1, Mitigation Measures, Page 6
The following mitigation measure has been revised in the IS/MND. The changes shown below apply to each
instance that this mitigation measure appears in the IS/MND.
MM-TCR-1 Prior to commencement of construction activities for the Project, a regionally appropriate Native
American monitor/consultant shall be retained to monitor ground disturbing activities. Notification
to the tribes will be provided 30 days prior to issuance of a grading permit or any ground
disturbance activities. If a tentative date is not set by the Tribe, the City has the ability to have
another qualified monitor complete this task and submit the final logs to the tribe after all ground
disturbance activities have been completed. The Native American monitor/consultant will only be
present on site during the construction phases that involve ground disturbing activities within the
areas of Building D, the associated swimming pool, and paved areas within the Project site. The
frequency and duration of monitoring shall be based on observations made by the Native American
monitor(s) in coordination with the City. The on-site monitoring shall end when the ground
disturbance activities at these specific locations are completed. The Native American
Monitor/consultant shall complete daily monitoring logs that will include descriptions of daily
construction activities, location of activities, soil, and any identified cultural materials or potential
tribal cultural resources (TCRs). Should a possible TCR be encountered, construction activities
within 50 feet of the discovery shall be temporarily halted and the City notified. The City will notify
Native American tribes that have been identified by the NAHC to be traditionally and culturally
affiliated with the geographic area of the Project. If the potential resource is archaeological in
nature, appropriate management requirements shall be implemented as outlined in MM-CUL-1. If
the City determines that the potential resource is a TCR (as defined by PRC, Section 21074), tribes
consulting under AB 52 would be provided a reasonable period of time, typically 5 days from the
date of a new discovery is made, to conduct a site visit and make recommendations regarding
future ground disturbance activities as well as the treatment of any discovered TCRs. A qualified
archaeologist shall implement a plan for the treatment and disposition of any discovered TCRs
based on the nature of the resource and considering the recommendations of the tribe(s).
Implementation of proposed recommendations will be made based on the determination of the
City that the approach is reasonable and feasible.
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3 Mitigation Monitoring and
Reporting Program
The State CEQA Guidelines, Section 15074(d), requires that a lead or responsible agency adopt a mitigation
monitoring plan when approving or carrying out a project when an IS/MND identifies changes that the lead agency
has required in the project or made a condition of approval to mitigate or avoid significant environmental effects.
As lead agency for the project, the City is responsible for adoption and implementation of the mitigation monitoring
and reporting program (MMRP).
The MMRP is presented below in Table 3-1 and will be in place and effective throughout all phases of the Project.
The City will be responsible for administering the MMRP and ensuring that all parties comply with its provisions. The
City may delegate monitoring activities to staff, consultants, or contractors. The City will also ensure that monitoring
is documented through periodic reports and that deficiencies are promptly corrected. The designated
environmental monitor will track and document compliance with required measures, note any problems that may
result, and take appropriate action to rectify problems.
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Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
Biological Resources
MM-BIO-1: Commencement of construction activities shall
avoid the February 1 through August 31 bird nesting season
to the greatest extent feasible. If construction activities begin
within this nesting season, a survey for nesting birds shall be
conducted by a qualified biologist within 7 days of the
commencement of construction activities, but not prior to this
7-day window. The area surveyed shall include all
clearing/construction areas, as well as areas within 100 feet
of the boundaries of these areas, or as otherwise determined
by the biologist. If no active bird nests are identified on, or
within 100 feet of the limits of the proposed disturbance area,
no further action is necessary and construction activities
could commence. For any off-site areas that are inaccessible,
the qualified biologists may survey the off-site area with
binoculars to capture the full 100-foot survey area. If active
nests are found during pre-construction surveys or at any
time throughout the course of construction activities during
the nesting bird season, all clearing/construction activities
within a minimum of 100 feet of the nest shall be postponed
until a wildlife biologist has identified the nesting species. If
the bird species is not protected under the MBTA and/or the
California Fish and Game Code, no further action is required
and construction activities may proceed. If the avian species
is protected under the MBTA and/or the California Fish and
Game Code, a minimum buffer zone shall be established by
the qualified biologist based on the type of bird/raptor
species identified and the construction buffer shall be
established on site through the erection of
cones/flagging/fencing to clearly delineate the protection
zone.
Prior to
construction;
during
construction (if
active nests are
identified)
Contractor/
builder;
qualified
biologist
City of Arcadia
Planning
Services
Division
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Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
All construction activities shall avoid this protection zone until
a qualified biologist has confirmed that the nest(s) is no
longer active and the nest is vacated, and there is no
evidence of second nesting attempts. Upon completion of any
site survey for nesting birds conducted by a qualified biologist,
documentation of the survey activity, findings, and any
resulting actions taken shall be prepared and submitted to
the City.
Cultural Resources
MM-CUL-1: In the event that archaeological resources are
unearthed during ground-disturbing activities, the
construction contractor shall immediately cease all earth-
disturbing activities within 100 feet of the discovery and
shall retain a qualified archaeologist that meets the
Secr
Standards. Construction activities may continue in other
areas outside of the designated protection zone, which
shall be delineated with cones, flagging, or fencing. The
archaeologist shall evaluate the significance of the find
and determine whether the resource uncovered is a
of the California P
CEQA Guidelines. If the archaeological find is determined
to be a resource, the archaeologist shall formulate a
Mitigation Plan in consultation with the City of Arcadia
that satisfies the requirements of the above-listed Code
Sections. Upon approval of the Mitigation Plan by the City,
the Project shall be implemented in compliance with the
Ground-
disturbing
construction
activities
Project
applicant;
contractor/
builder;
qualified
archaeologist;
City of Arcadia
City of Arcadia
Planning
Services
Division
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Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
Plan. If the Archaeologist determines that the resource is
not significant, s/he shall record the evaluation and
submit the recordation form to the California Historical
Resources Information System (CHRIS) at the South
Central Coastal Information Center (SCCIC). The
archaeologist shall prepare a report of the results of any
study prepared as part of a testing or Mitigation Plan,
following accepted professional practice. The report shall
follow guidelines of the California Office of Historic
Preservation although format will be dependent on the
nature of the archaeological investigation required.
Copies of the report shall be submitted to the City and to
the CHRIS at the SCCIC.
Geology and Soils
MM-GEO-1: Prior to commencement of any grading activity
on-site, the Applicant shall retain a qualified paleontologist
per the Society of Vertebrate Paleontology (SVP) (2010)
guidelines. The paleontologist shall prepare a Paleontological
Resources Impact Mitigation Program (PRIMP) for the project.
The PRIMP shall be consistent with the SVP (2010) guidelines
and should outline requirements for preconstruction meeting
attendance and worker environmental awareness training,
where monitoring is required within the project area based on
construction plans and/or geotechnical reports, procedures
for adequate paleontological monitoring and discoveries
treatment, and paleontological methods (including sediment
sampling for microvertebrate fossils), reporting, and
collections management. The qualified paleontologist shall
attend the preconstruction meeting and a paleontological
monitor shall be on-site during all rough grading and other
significant ground-disturbing activities in previously
Prior to and
during grading
activity
Project
applicant;
contractor/
builder;
qualified
paleontologist
City of Arcadia
Planning
Services
Division
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Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
undisturbed, fine-grained older Quaternary alluvial fan
deposits. These deposits may be encountered at depths as
shallow as 5-10 feet below ground surface. In the event that
paleontological resources (e.g., fossils) are unearthed during
grading, the paleontological monitor will temporarily halt
and/or divert grading activity to allow recovery of
paleontological resources. The area of discovery will be roped
off with a 50-foot radius buffer. Once documentation and
collection of the find is completed, the monitor will remove
the rope and allow grading to recommence in the area of the
find.
Noise
MM-NOI-1.: Prior to the issuance of a grading permit, the
Project Applicant shall provide a Construction Noise Control
Plan (CNCP) to the City for review and approval. The CNCP
shall include best management practices to reduce short-
term construction noise. Enforcement of the CNCP shall be
accomplished by field inspections during construction
activities and/or documentation of compliance, to the
Development Services Department.
Recommended best management practices may include,
but not be limited to, the following:
All construction equipment, fixed or mobile, shall be
equipped with properly operating and maintained
specifications and standards.
Construction noise reduction methods such as shutting
off idling equipment, maximizing the distance between
construction equipment staging areas and adjacent
residences, and use of electric air compressors and
Prior to the
issuance of a
grading permit
Project
applicant;
contractor/
builder; City of
Arcadia
City of Arcadia
Planning
Services
Division
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Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
similar power tools, rather than diesel equipment, should
be used where feasible.
Stationary equipment should be placed as far away from
the adjacent residential property boundary as feasible
and positioned such that emitted noise is directed away
from or shielded from sensitive receptors. Acoustically
attenuating shields, shrouds, or enclosures may be
placed over stationary equipment.
During all Project site construction, the construction
contractor shall limit all construction-related activities,
including maintenance of construction equipment and
the staging of haul trucks, to between the hours of 7:00
a.m. to 6:00 p.m. Monday through Friday and 8:00 a.m.
to 5:00 p.m. on Saturday.
Construction hours, allowable workdays, and the phone
number of the job superintendent should be clearly
posted at all construction entrances to allow surrounding
property owners to contact the job superintendent, if
necessary. In the event the City receives a complaint,
appropriate corrective actions should be implemented
and a report of the action provided to the reporting party
Development Services Department.
MM-NOI-2: The Project Applicant shall retain an acoustical
level plans to
ensure that the equipment specifications and plans for HVAC
and emergency backup generator incorporate features to
ensure that operational noise will not exceed relevant noise
standards at nearby noise-sensitive land uses (e.g.,
residential). Such features could include, but not be limited
to, the specification of quieter equipment, relocation of
facilities to be of further distance from residential homes,
Prior to
construction
Project
applicant;
qualified
acoustical
specialist
City of Arcadia
Planning
Services
Division
ARCADIA HOTEL AND ANNEX (HOTEL INDIGO) PROJECT
RESPONSE TO COMMENTS & MITIGATION MONITORING AND REPORTING PROGRAM
11663.01
16 March 2020
Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
and/or the provision of acoustical enclosures. The acoustical
specialist shall certify in writing to the City that the equipment
limits.
Tribal Cultural Resources
MM-TCR-1: Prior to commencement of construction activities
for the Project, a regionally appropriate Native American
monitor/consultant shall be retained to monitor ground
disturbing activities. Notification to the tribes will be provided
30 days prior to issuance of a grading permit or any ground
disturbance activities. If a tentative date is not set by the
Tribe, the City has the ability to have another qualified monitor
complete this task and submit the final logs to the tribe after
all ground disturbance activities have been completed. The
Native American monitor/consultant will only be present on
site during the construction phases that involve ground
disturbing activities within the areas of Building D, the
associated swimming pool, and paved areas within the
Project site. The frequency and duration of monitoring shall
be based on observations made by the Native American
monitor(s) in coordination with the City. The on-site
monitoring shall end when the ground disturbance activities
at these specific locations are completed. The Native
American Monitor/consultant shall complete daily monitoring
logs that will include descriptions of daily construction
activities, location of activities, soil, and any identified cultural
materials or potential tribal cultural resources (TCRs). Should
a possible TCR be encountered, construction activities within
50 feet of the discovery shall be temporarily halted and the
City notified. The City will notify Native American tribes that
have been identified by the NAHC to be traditionally and
Prior to
construction;
during
construction
phases that
involve ground-
disturbing
activities
Project
applicant;
qualified tribal
monitor; City of
Arcadia
City of Arcadia
Planning
Services
Division
ARCADIA HOTEL AND ANNEX (HOTEL INDIGO) PROJECT
RESPONSE TO COMMENTS & MITIGATION MONITORING AND REPORTING PROGRAM
11663.01
17 March 2020
Table 3-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring Verification of Compliance
Implementing
Period
Implementing
Party
Enforcing
Agency Comments Date Initials
culturally affiliated with the geographic area of the Project. If
the potential resource is archaeological in nature,
appropriate management requirements shall be
implemented as outlined in MM-CUL-1. If the City determines
that the potential resource is a TCR (as defined by PRC,
Section 21074), tribes consulting under AB 52 would be
provided a reasonable period of time, typically 5 days from
the date of a new discovery is made, to conduct a site visit
and make recommendations regarding future ground
disturbance activities as well as the treatment of any
discovered TCRs. A qualified archaeologist shall implement a
plan for the treatment and disposition of any discovered TCRs
based on the nature of the resource and considering the
recommendations of the tribe(s). Implementation of
proposed recommendations will be made based on the
determination of the City that the approach is reasonable and
feasible.