HomeMy WebLinkAbout5-10-22 Agenda Packet Revised Part 2 of 2 - Attachment No. 6 for Item No. 2 Alexan Mixed Use
Attachment No. 6
Final EIR: Preface, Comment letters on
Draft EIR, Response to Comments,
Proposed Changes to the Draft EIR,
Findings of Fact, and MMRP
185
Alexan Mixed-Use Development Project
Final Environmental Impact Report
State Clearinghouse No.2021070271
Prepared for:
City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Prepared by:
38 North Marengo Avenue
Pasadena, California 91101
MAY 2022
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Printed on 30% post-consumer recycled material.
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Table of Contents
Section Page No.
1 PREFACE .................................................................................................................................................... 1-1
1.1 Purpose ............................................................................................................................................... 1-1
1.2 Format of the Final EIR ...................................................................................................................... 1-1
1.3 Environmental Review Process ......................................................................................................... 1-2
1.3.1 Notice of Preparation ............................................................................................................ 1-2
1.3.2 Noticing and Availability of the Draft ................................................................................... 1-2
1.3.3 Final EIR ................................................................................................................................ 1-3
1.4 Revisions to the Draft EIR .................................................................................................................. 1-3
2 RESPONSES TO COMMENTS ..................................................................................................................... 2-1
2.1 Introduction......................................................................................................................................... 2-1
3 CHANGES TO THE DRAFT EIR ..................................................................................................................... 3-1
3.1 Introduction......................................................................................................................................... 3-1
3.2 Errata ................................................................................................................................................... 3-1
4 MITIGATION MONITORING AND REPORTING PROGRAM ........................................................................... 4-1
Table
4-1 Mitigation Monitoring and Reporting Program ............................................................................................... 4-2
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1 Preface
1.1 Purpose
This Final Environmental Impact Report (EIR) has been prepared by the City of Arcadia (City) for the Alexan Mixed-
Use Development Project (proposed Project). This Final EIR has been prepared in conformance with the California
Environmental Quality Act of 1970 (CEQA) statutes (Cal. Pub. Res. Code, Section 21000 et. seq., as amended) and
implementing guidelines (Cal. Code Regs., Title 14, Section 15000 et. seq.).
Before approving a project, CEQA requires the lead agency to prepare and certify a Final EIR. The City has the
principal responsibility for approval of the proposed Project and is therefore considered the lead agency under CEQA
Section 21067. According to the CEQA Guidelines, Section 15132, the Final EIR shall consist of:
The Draft EIR or a revision of the Draft EIR
Comments and recommendations received on the Draft EIR either verbatim or in summary
A list of persons, organizations, and public agencies commenting on the Draft EIR
The responses of the lead agency to significant environmental points raised in the review and consultation
process; and
Any other information added by the lead agency
1.2 Format of the Final EIR
This Final EIR consists of the February 2022 Draft EIR and the following four chapters:
1 Preface. This chapter summarizes the contents of the Final EIR and the environmental review process.
2 Response to Comments. During the 45-day public review period for the Draft EIR, four comment letters were
received. This chapter contains these comment letters, which have been bracketed to organize the responses,
and the Citys responses to the comments.
3 Changes to the Draft EIR . Comments that are addressed in Chapter 2 may have resulted in minor revisions
to the information contained in the February 2022 Draft EIR. Where necessary, deletions to the text are
shown in bold strikeout and additions to the text are shown in bold underline in all applicable sections of
the Draft EIR. Additionally, through the certification of this Final EIR, where the term Draft EIR is used in
the text, this is now deemed to be Final EIR.
4 Mitigation Monitoring and Reporting Program. This chapter of the Final EIR provides the mitigation monitoring
and reporting program (MMRP) for the proposed Project. The MMRP is presented in table format and identifies
mitigation measures for the proposed Project, the implementation period for each measure, the implementing
party, and the enforcing agency. The MMRP also provides a section for recordation of mitigation reporting.
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1.3 Environmental Review Process
1.3.1 Notice of Preparation
CEQA requires preparation of an EIR when there is substantial evidence supporting a fair argument that a proposed
project may have a significant effect on the environment. The purpose of an EIR is to provide decision makers,
public agencies, and the general public with an objective and informational document that fully discloses the
environmental effects of the proposed project. The EIR process is intended to facilitate the objective evaluation of
potentially significant direct, indirect, and cumulative impacts of the proposed project, and to identify feasible
mitigation measures and alternatives that would reduce or avoid the proposed projects significant effects. In
addition, CEQA requires that an EIR identify adverse impacts determined to be significant after mitigation.
In accordance with the CEQA Guidelines, a Notice of Preparation (NOP) was circulated for a 30-day public review
starting on July 19, 2021, to public agencies, organizations, and interested individuals. The purpose of the NOP was
to provide notification that the City plans to prepare an EIR and to solicit input on the scope and content of the EIR.
Additionally, a notice announcing the availability of the NOP was also published in the Arcadia Weekly on July 14,
2021. Copies of the NOP were made available for electronic download on the Citys website at www.arcadiaca.gov/
shape/development_services_department/current_projects.php. Comments on the NOP were received from three
agencies, three letters/emails from individuals or groups, which are provided in Appendix A-2 to the Draft EIR.
A scoping meeting was held on August 5, 2021. Rather than conducting an in-person meeting, the Governors
Executive Order N-25-20 allowed local governments to hold meetings via teleconferencing while still meeting State
transparency requirements. As such, the Projects Scoping Meeting was held online, through a webinar type format.
The City hosted one Scoping Meeting on Thursday, August 5, 2021, from 6:00 p.m. to 7:00 p.m. and was made
available through the Citys website at http://www.arcadiaca.gov/projects. The purpose of this meeting was to seek
input from public agencies and the general public regarding the potential environmental impacts of the proposed
Project. The City received no comments/questions with environmental concerns during the Scoping Meeting.
1.3.2 Noticing and Availability of the Draft
The Draft EIR was made available for public review and comment pursuant to CEQA Guidelines Section 15087. The
45-day public review period for the Draft EIR started on February 24, 2022 and ended on April 11, 2022. At the
beginning of the public review period, an electronic copy of the Draft EIR and an electronic copy of the Notice of
Completion (NOC) and Notice of Availability (NOA) were submitted to the State Clearinghouse. Relevant State
agencies received electronic copies of the documents. An NOA was distributed to interested parties and filed with
the Los Angeles County Clerk as well as published in the Arcadia Weekly. The NOA described where the document
was available and how to submit comments on the Draft EIR. A hardcopy of the Draft EIR was available at the
Arcadia Planning Division located at 240 West Huntington Drive, Arcadia, CA 91066 and at the Arcadia Library
located at 20 West Duarte Rd, Arcadia, CA 91006. Additionally, the NOA and the Draft EIR were available to be
viewed on the City website at:
www.arcadiaca.gov/shape/development_services_department/current_projects.php.
The 45-day public review period provided interested public agencies, groups, and individuals the opportunity to
comment on the contents of the Draft EIR. A total of four agency, organization, and individual comment letters
were received and are included in Chapter 2, Responses to Comments, of this Final EIR.
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1.3.3 Final EIR
The Final EIR addresses the comments received during the public review period and includes minor changes to the
text of the Draft EIR in accordance with comments that necessitated revisions. This Final EIR will be presented to
City decision-makers for potential certification as the environmental document for the proposed project. All agencies
who commented on the Draft EIR will be provided with a copy of the Final EIR, pursuant to CEQA Guidelines
Section 15088(b). The Final EIR will also be posted on the Citys website at:
www.arcadiaca.gov/shape/development_services_department/current_projects.php.
Pursuant to CEQA Guidelines Section 15091, the City shall make findings for each of the significant effects
identified in this EIR and shall support the findings with substantial evidence in the record. After considering the
Final EIR in conjunction with making findings under Section 15091, the lead agency may decide whether or how
to approve or carry out the Project. When a lead agency approves a project that will result in the occurrence of
significant effects that are identified in the Final EIR but are not avoided or substantially lessened, the agency is
required by CEQA to state in writing the specific reasons to support its action based on the Final EIR and/or other
information in the record. Because the Project would not result in significant and unavoidable impacts, a
statement of overriding considerations is not required to be prepared.
1.4 Revisions to the Draft EIR
The comments received during the public review period for the Draft EIR resulted in minor clarifications and
modifications in the text of the February 2022 Draft EIR, as shown in Chapter 3, Changes to the Draft EIR. These
changes are included as part of the Final EIR, to be presented to City decision makers for review and
consideration of certification and Project approval.
CEQA Guidelines Section 15088.5 identifies when a lead agency must recirculate an EIR. A lead agency is
required to recirculate an EIR when significant new information is added to the EIR after public notice is given of
the availability of the Draft EIR but before certification of the Final EIR. Information includes changes in the
project or environmental setting as well as additional data or other information. New information added to an
EIR is not considered significant unless the EIR is changed in a way that deprives the public of a meaningful
opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to
mitigate or avoid such an effect (including a feasible project alternative) that the projects proponents have
declined to implement. As defined in CEQA Guidelines Section 15088.5(a), significant new information requiring
recirculation includes the following:
1. A new significant environmental impact would result from the project or from a new mitigation measure
proposed to be implemented.
2. A substantial increase in the severity of an environmental impact would result unless mitigation measures
are adopted that reduce the impact to a level of insignificance.
3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would
clearly lessen the environmental impacts of the project, but the projects proponents decline to adopt it.
4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful
public review and comment were precluded.
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The minor clarifications, modifications, and editorial corrections that were made to the Draft EIR are shown in
Chapter 3, Changes to the Draft EIR, of this Final EIR. None of the revisions that have been made to the Draft EIR
resulted in new significant impacts; none of the revisions resulted in a substantial increase in the severity of an
environmental impact identified in the Draft EIR; and, none of the revisions brought forth a feasible project
alternative or mitigation measure that is considerably different from those set forth in the Draft EIR. Furthermore,
the revisions do not cause the Draft EIR to be flawed such that it precludes meaningful public review. As none of
the CEQA criteria for recirculation have been met, recirculation of the EIR is not warranted. As stated in CEQA
Guidelines Section 15088.5(b), recirculation is not required where the new information added to the EIR merely
clarifies or amplifies or makes insignificant modifications in an adequate EIR.
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2 Responses to Comments
2.1 Introduction
A draft version of the Environmental Impact Report (EIR) for the proposed Alexan Mixed-Use Development Project
(Project) was circulated for a 45-day public review from February 24, 2022, to April 11, 2022. This chapter of the
Final EIR includes a copy of each comment letter provided during the 45-day public review period for the Draft EIR.
The City of Arcadia (City) has prepared responses to each comment, which are included in this chapter. The
comments are ordered numerically, and the individual issues within each comment letter are bracketed and
numbered. The Citys responses to comments on the Draft EIR represent a good-faith, reasoned effort to address
the environmental issues identified by the comments. Under the CEQA Guidelines, the Lead Agency is required to
evaluate and provide written responses to comments received on the Draft EIR (CEQA Guidelines, Section 15088).
As shown in Table 2-1, the City received four comment letters from one agency, two organizations, and one letter
from the public. In accordance with the requirements of CEQA Guidelines Section 15088(b), the City will provide a
written response on comments submitted by public agencies to each respective public agency at least 10 days prior
to certifying the Final EIR.
Table 2-1. List of Commenters
Comment Letter No. Commenter Type Date Page No.
Agencies
A1 Caltrans Regional Agency April 4, 2022 2-3
Organizations
O1 Supporters Alliance for
Environmental Responsibility
(SAFER) Lozeau Drury LLP
Organization April 11, 2022 2-11
O2 Southwest Regional Council of
Carpenters (SWRCC)
Mitchell M. Tsai Attorney at Law
Organization April 11, 2022 2-15
Individuals
I1 David Fu and Associates Individual April 6, 2022 2-305
The changes to the analysis contained in the Draft EIR represent only minor clarifications/ amplifications and do
not constitute significant new information. In accordance with CEQA Guidelines, Section 15088.5, recirculation of
the Draft EIR is not required.
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Comment Letter A1
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Response to Comment Letter A1
California Department of Transportation
April 4, 2022
A1-1 The comment summarizes the proposed Projects characteristics and location. The comments
summary of the Projects characteristics and location are correctly recorded. The comment does not
contain any specific concerns related to the adequacy or accuracy of the environmental analysis in the
Draft EIR; therefore, no further response is required and no additional analyses or changes to the Draft
EIR are required.
A1-2 The comment notes that the metric to evaluate impacts to transportation is an increase in vehicle miles
traveled (VMT).
The Draft EIR evaluates transportation and circulation in Section 4.13. The analysis uses the VMT
metric to evaluate potential impacts, but as explained starting on page 4.13-10, the Project screens
out of having to prepare a project-level VMT assessment. The comment does not contain any specific
concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR; therefore,
no further response is required and no additional analyses or changes to the Draft EIR are required.
A1-3 The comment is generally discussing Caltrans support for encouraging and promoting alternative
modes of transportation, including complete streets and pedestrian safety measures. The comment
requests the Draft EIR ensures all modes of transportation are well served.
The Draft EIR addresses the potential for the Project to conflict with any program, plan, ordinance or policy
that addresses alternative transportation modes under Threshold 4.13a starting on page 4.13-9. As
noted in the analysis, the Project is consistent with the goals and policies contained in the 20202045
RTP/SCS and the Citys General Plan. The Project site is also located within a transit priority area (TPA)
due to close access to the Arcadia Metro L Line Station and access to bus service provided by LA Metro
Routes 79 and 287, along with Foothill Transit Route 187. The comment does not contain any specific
concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR; therefore,
no further response is required and no additional analyses or changes to the Draft EIR are required.
A1-4 The comment is requesting the City evaluate the potential of including transportation demand
management (TDM) strategies and intelligent transportation systems (ITS) application to manage the
Citys transportation network including transit, bicycle and pedestrian access.
This comment is acknowledged and will be taken into consideration by the Citys decision makers as
part of the Final EIR. The Draft EIR did not identify any transportation impacts requiring mitigation and
the City is not requiring the Project include TDM measures. The comment does not contain any specific
concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR; therefore
no further response is required and no additional analyses or changes to the Draft EIR are required.
A1-5 The comment includes an excerpt from the Draft EIR regarding the findings of the VMT screening assessment.
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The comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required and no additional
analyses or changes to the Draft EIR are required.
A1-6 The comment is requesting a post-development VMT analysis be conducted with all necessary
mitigation measures.
The City will take into consideration the need to conduct a post-development VMT analysis; however,
the Project would not result in any significant VMT impacts. As noted in Comment A1-5 above, the
Project is screened from conducting a VMT analysis and was determined to have a less-than-significant
impact. Therefore, no mitigation is required, and no mitigation is proposed. The Project also meets the
intent of Senate Bill 743 and the Office of Planning and Research (OPR) Technical Advisory on
Evaluating Transportation Impacts in CEQA (OPR 2018) because the Project:
Is an infill development (in part, replacing an existing surface parking lot and underutilized buildings
in downtown Arcadia)
Contains a mix of land uses (new residential and local serving café, adjacent to an existing
office building)
Is a high-density development
Has access to high-quality transit (the project is located across the street from the Metro L Line
Station, and near regional and local bus service)
Includes 26 affordable housing units
Includes project design features to reduce vehicle trips, including:
o A new pedestrian and bicycle paseo to facilitate connectivity between the Metro L Line Station
and the Citys downtown amenities
o Secure bicycle parking
o On site-amenities such as an outdoor pool area, fire pit, barbeque dining area, game lounge,
lawn area, outdoor plaza, and outdoor passive court
The Citys Guidelines also include three types of VMT screening criteria to determine it a project is
required to perform a project-level VMT assessment: Within a Transit Priority Area (TPA); Low VMT Area
Screening; and Project Type. The analysis under Threshold 4.11b starting on page 4.13-10 in the Draft
EIR addresses if the Project would meet any of the Citys screening criteria. The Project was screened
out of the Citys Guidelines because the Project is:
Located within a TPA
Based on the San Gabriel Valley Council of Governments screening tool the Project is located in a
low VMT-generating area
Within a TPA and in a low VMT-generating area; thus, a project-level VMT assessment is not required
under the Citys Guidelines.
Based on the OPR Technical Guidance and the Citys VMT screening criteria it was determined a project-
level VMT analysis is not required and impacts to VMT would be less than significant.
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A1-7 The comment notes the transport of over-sized construction vehicles or equipment will need a
Caltrans transportation permit and Caltrans recommends large trucks be scheduled during off-
peak commute times.
The Project applicant will obtain all required permits from Caltrans and will strive to ensure the transport
of any large trucks or equipment would occur outside of peak commute times. In addition, to ensure
adequate safeguards for pedestrian, bicycle, and vehicular circulation as well as emergency vehicle
access during short-term construction activities, compliance with MM-TRA-1 is required. MM-TRA-1
requires preparation and implementation of a Construction Traffic Control Plan in accordance with City
guidelines to address pedestrian, bicycle, and vehicular circulation during construction activities. The
Traffic Control Plan would be reviewed and approved by the City.
The comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required
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Comment Letter O1
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Response to Comment Letter O1
Supporters Alliance for Environmental Responsibility (SAFER)
April 11, 2022
01-1 The comment establishes the letter is on behalf of the Supporters Alliance for Environmental
Responsibility (SAFER). The comment does not contain any specific concerns related to the adequacy
or accuracy of the environmental analysis in the Draft EIR; therefore. no further response is required
and no additional analyses or changes to the Draft EIR are required.
01-2 The comment states an opinion that the Draft EIR fails to adequately disclose potential Project impacts
and identify feasible mitigation measures and requests the Draft EIR be revised and recirculated.
The commenter fails to identify any deficiencies of the Draft EIR related to the adequacy of the
environmental analysis. Therefore, the commenters assertion that the Draft EIR must be revised and
recirculated is not based on substantial evidence. CEQA Guidelines Section 15088.5, Recirculation
of an EIR Prior to Certification, describes the thresholds for recirculation of an EIR. Pursuant to
Section 15088.5, a lead agency is required to recirculate an EIR when significant new information is
added to the EIR after public notice is given of the availability of the Draft EIR but before certification.
New information can include a disclosure showing that a new significant environmental impact would
result from the project or from a new mitigation measure proposed to be implemented, a substantial
increase in the severity of an environmental impact, a feasible project alternative or mitigation
measure considerably different from others previously analyzed would clearly lessen the
environmental impacts of the project (but the projects proponents decline to adopt it), or the Draft
EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public
review and comment were precluded.
The Draft EIR describes the Project at length, in full compliance with Section 15121 of the CEQA
Guidelines, to inform public agency decision makers and the public of the significant environmental
effects of the Project, identify possible ways to minimize (or mitigate) the significant effects, and
describe reasonable alternatives to the Project. Regarding the commenters opinion the Draft EIR
needs to be recirculated, significant new information, as defined in CEQA Guidelines Section 15088.5,
has not been added to this EIR subsequent to its release for public review. No changes have been
made to the Project, and no changes have occurred in the environmental setting such that a new
significant impact would occur or such that a substantial increase in the severity of an impact would
occur. No additional data or other information has been added such that a new significant impact would
occur or such that a substantial increase in the severity of an impact would occur. Additionally, no
feasible Project alternatives or mitigation measures considerably different from those in the Draft EIR
that would clearly lessen the environmental impacts of the Project have been identified. Lastly, the
Draft EIR is not fundamentally and basically inadequate and conclusory in nature. The Draft EIR
includes extensive environmental analysis that was conducted by qualified professionals. The Draft EIR
discloses a number of significant impacts that would result from the proposed Project and identifies
feasible mitigation that would reduce these significant impacts below a level of significance. As such,
the Draft EIR is not required to be revised and recirculated, and the commenter has not presented
substantial evidence to support a need for recirculation.
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01-3 The comment indicates their comments can be supplemented during review of the Final EIR and at any
public hearings on the Project.
The comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required and no additional
analyses or changes to the Draft EIR are required.
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Comment Letter O2
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Response to Comment Letter O2
Southwest Regional Council of Carpenters
April 11, 2022
O2-1 The comment establishes the letter is on behalf of the Southwest Regional Council of Carpenters
(SWRCC) and provides general background on the members of the SWRCC and notes the SWRCC
incorporates by reference all comments submitted on the Draft EIR. The comment does not contain
any specific concerns related to the adequacy or accuracy of the environmental analysis in the Draft
EIR; therefore, no further response is required and no additional analyses or changes to the Draft EIR
are required.
02-2 The comment requests notification of any and all notices referring or related to the Project issued under
CEQA. Any designated contacts for the SWRCC requesting notice and the law firm of Mitchell M. Tsai
will be included in all future notices of actions or hearings related to the proposed Project. The comment
does not contain any specific concerns related to the adequacy or accuracy of the environmental
analysis in the Draft EIR; therefore, no further response is required and no additional analyses or
changes to the Draft EIR are required.
02-3 The comment provides an overview of the perceived benefits to hiring local workers to work on the
Project and requests the City consider using the local workforce. The comment does not contain any
specific concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR;
therefore, no further response is required and no additional analyses or changes to the Draft EIR are
required. The comment is acknowledged and will be taken into consideration by the Citys decision
makers as part of the Final EIR.
However, the following response is provided to address the intent of the comment that the City consider
requiring the Project hire local construction workers, citing economic benefits and benefits to
greenhouse gas, air quality, and transportation impacts. As stated in Draft EIR Sections 4.2, Air
Quality, 4.6, Greenhouse Gas Emissions, and 4.13, Transportation, there are no significant short-term
construction-related or long-term operational environmental impacts that are related to the length of
vehicle trips or the proximity of workers to the Project site. Therefore, there is no obligation under CEQA
to consider hiring from the local workforce, and no changes to the EIR are required.
02-4 The comment requests the City should require the Project be constructed to standards that exceed the
2019 California Green Building Code to further the states environmental goals.
The proposed Project would be built in accordance with the current Building Energy Efficiency
Standards (Title 24) at the time building permits are submitted for approval. Title 24 includes robust
requirements for energy efficiency. Draft EIR Sections 4.4, Energy and 4.6, Greenhouse Gas Emissions,
determined impacts would be less than significant and no mitigation was required. Table 4.6-5, 2019
CALGreen Mandatory Measures Relevant to Greenhouse Gas Emissions starting on page 4.6-29,
demonstrates that the proposed Project would be consistent with the mandatory CalGreen
requirements. Notably, 2022 Title 24, which is more stringent than 2019 Title 24, will take effect on
January 1, 2023, and the Project likely would be subject to these more stringent standards because
building permits are likely to be submitted after January 1, 2023. Table 4.6-6 on page 4.6-31
demonstrates the Projects consistency with the California Air Resources Board greenhouse gas
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emission reduction strategies. The commenters request to go beyond state requirements is
acknowledged and will be taken into consideration by the Citys decision makers as part of the Final
EIR. The comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required and no additional
analyses or changes to the Draft EIR are required.
02-5 The comment provides general information on CEQA requirements including the requirements under
CEQA relevant to the definition of significant new information and when this new information would trigger
recirculation of an EIR. The comment does not contain any specific concerns related to the adequacy or
accuracy of the environmental analysis in the Draft EIR; therefore, no further response is required and
no additional analyses or changes to the Draft EIR are required.
02-6 The comment is requesting the City adopt additional mitigation measures to address public health risks
to construction workers from COVID-19 and lists a number of design features.
The CEQA Guidelines do not expressly require public health effects from COVID-19 or any other
communicable virus (i.e., influenza, legionnaires disease) be evaluated as potential impacts to the
environment. Such viruses are not caused by construction projects. CEQA also does not require analysis
of the Project on itself, including its construction workers and future users. If approved, the Projects
construction contractor can impose requirements for construction personnel to minimize the spread of
COVID-19 or any other communicable virus consistent with their company policy and any local or state
requirements that may be in place at the time. The comment does not contain any specific concerns
related to the adequacy or accuracy of the environmental analysis in the Draft EIR. Therefore, no
changes or additions to the Draft EIR are required in response to this comment.
02-7 The comment is discussing the Infection Control Risk Assessment (ICRA) the United Brotherhood of
Carpenters and the Carpenters International Training Fund have developed and requests the City
require the Project be constructed consistent with these protocols. The comment does not contain any
specific concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR.
However, the following response is provided.
The potential for Project construction to cause COVID-19 to spread through worker exposure is not an impact
on the environment under CEQA, rather it is a public health concern under the purview of federal, state, and
local public health agencies. CEQA requires the consideration of significant changes in the environment
caused by a project; therefore, an existing adverse environmental condition that a project does not create
or exacerbate is not responsible for mitigating that adverse condition. Implementation of the proposed
Project would not create or exacerbate an existing environmental hazard or an existing public health hazard,
and therefore, no mitigation is required. Compliance with existing mandates from federal, state, and local
public health agencies, including California Occupational Safety and Health Administrations (Cal/OSHA)
COVID-19 Prevention Emergency Temporary Standards (ETS) are specifically intended to address workplace
health and safety (OSHSB 2021). Policy mandates from public health agencies are consistently updated to
address rapidly changing circumstances and provide the most appropriate methods for protecting worker
safety. Employers are required by the General Duty Clause, Section 5(a)(1) of the OSH Act, to provide a safe
and healthful workplace free from recognized hazards that are causing or likely to cause death or serious
physical harm (OSHA 2021).
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Therefore, compliance with mandatory federal, state, and local public health agency regulations in
effect at the time would ensure adequate and appropriate protections for workplace safety and the
proposed Project would not create or exacerbate an existing environmental or public health hazard.
There is no aspect of the proposed Project that would prevent or interfere with the United Brotherhood
of Carpenters providing the Carpenter union members with additional trainings related to COVID-19.
Therefore, no additional analyses or changes to the Draft EIR are required.
02-8 The comment provides background on the Phase I and Phase II ESA, with special note to
regulations and requirements. The comment does not specifically address the adequacy or
accuracy of the Draft EIR.
Although the comment does not raise any specific concerns with the adequacy or accuracy of the Draft
EIR analysis, the following information is provided to clarify the comments. The comment indicates that
ASTM E1903 notes that data gaps in a Phase I ESA indicates the need to prepare a Phase II ESA, even
in the absence of any identified recognized environmental concerns (RECs). This is not accurate,
ASTM E 1903-19, Section 1.2 states the practice is intended for use where a user desires to obtain
sound scientifically valid data concerning actual property conditions, whether or not such data relate
to property conditions previously identified as RECs or data gaps in the Phase I ESA. As such, it is not
the intention to complete a Phase II ESA when data gaps are identified in the Phase I ESA.
The comment also states that the due diligence process should include emerging contaminants. This
is also inaccurate. ASTM E1527-21 X6.10 specifically states emerging contaminants and other
materials not identified as hazardous substances by CERCLA are not included in the 1527 scope. State-
regulated hazardous substances may be evaluated as non-scope considerations under E1527, but it
is not required. The contaminants identified in this comment are neither state- or federally-regulated
hazardous substances, and therefore do not require consideration in the Phase I ESA. Therefore, no
additional analyses or changes to the Draft EIR are required.
02-9 The comment states that a Phase II ESA was not prepared as required, and therefore the Draft EIR
failed to establish the proper existing setting for the Project. It also reiterates the lack of impacts with
regard to emerging contaminants.
As stated in ASTM E1903-19, a Phase II assessment may be undertaken in order to qualify for and
maintain the three types of CERCLA landowner liability protection (LLP). All three LLPs require that a
prospective purchaser undertake all appropriate inquiries (AAI) into the condition of a property before
purchase. That level of inquiry is defined by federal rule, 40 C.F.R. Part 312, and by Practice E1527
and Practice E2247 for Phase I ESAs, all of which expressly provide that they do not require sampling
or chemical testing of environmental media. As such, a Phase II ESA, as defined by 1903-19, is not
required. It is an optional additional investigation to better understand and evaluate potential
hazardous materials/petroleum products on a subject property.
Three separate investigations were conducted to evaluate RECs identified on the site, an asbestos
survey, a lead-based paint survey, and a subsurface soil and soil vapor investigation (Phase II ESA).
These are provided in the Draft EIR Appendices F2 through F4. These investigations appropriately
established the existing setting for the Project, and evaluate potential RECs identified in the Phase
I ESA. The results of these investigations clearly identified existing conditions, and as such the
Project is designed/mitigated such that the Project would not exacerbate hazards. Soil vapor
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conditions are understood, and construction of the project would not increase existing
contamination, nor exacerbate the existing condition of contamination. Excavation would
ultimately remove contaminated soils, thereby reducing existing contamination on site. Existing
conditions on areas of the site to remain in place would not be exacerbated by the proposed
construction and operation of the project. As noted in Response to Comment 02-8, evaluation of
emerging contaminants is not required. Therefore, no additional analyses or changes to the Draft
EIR are required.
02-10 The comment states that the de minimis condition defined in the Draft EIR with regards to the existing
Above Ground Storage Tank (AST) or diesel generator was unsubstantiated.
As noted in the comment and in the Draft EIR and also in the appendices, the Phase I ESA site
reconnaissance identified two emergency backup generators outside the bank building at 150 N. Santa
Anita Avenue. According to the Project site representative, the generators operate on natural gas;
however, each generator includes a diesel fuel reservoir at the base, one generator was placed within
secondary containment, and one generator also included a diesel fuel label (DEIR p. 4.7-1). All diesel
generators are required to be permitted and regularly inspected by the LA County Fire Department. The
definition of a REC is the presence or likely presence of hazardous substances or petroleum products
due to a release to the environment, a likely release to the environment, or material threat of a future
release to the environment. As the generator is permitted and inspected by the regulatory agency, and
is continuously operated by the site owner, there is no evidence of a release to the environment
associated with this generator, therefore there is no evidence of a REC. A de minimis condition is defined
as a release that does not present a threat to human health or the environment and that generally would
not be subject to enforcement action. As noted above, the AST is permitted, inspected, and regularly
operated; therefore, any release of a REC if any, of which there was no evidence, would be considered de
minimis, as defined above as it has not been previously identified as a REC. As such, the de minimis
condition is substantiated.
02-11 The comment refers to backup generators and states the project description must include backup
generators and the health effects of diesel particulate matter are identified as toxic air contaminants.
It is not clear what the commenter is referring to because the Project does not propose installing backup
diesel generators. If the Project were to include generators it would be identified in the project
description and any impacts associated with the generators evaluated, but the Project does not include
backup generators. The commenter may be referring to the presence of two existing emergency backup
generators that were observed outside the southeast corner of the bank building at 150 N. Santa Anita
Avenue during the Phase I ESA site reconnaissance. These generators are not part of the Project. As
noted above, these generators operate on natural gas; however, each generator includes a diesel fuel
reservoir at the base (DEIR p. 4.7-3). These generators are not part of the Project; therefore, an analysis
of the health effects of these generators is not required. Impacts of the environment on a project or
plan (as opposed to impacts of a project or plan on the environment) are beyond the scope of required
CEQA review. [T]he purpose of an EIR is to identify the significant effects of a project on the
environment, not the significant effects of the environment on the project. (Ballona Wetlands Land
Trust v. City of Los Angeles (2011) 201 Cal.App.4th 455, 473.) However, a health risk assessment
(HRA) was prepared to evaluate potential health risks associated with construction in accordance with
Office of Environmental Health Hazard Assessment (OEHHA) risk assessment methodology. The
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analysis in the Draft EIR starting on page 4.2-25 demonstrates that Project impacts would be less than
significant. Therefore, no additional analyses or changes to the Draft EIR are required.
02-12 The comment provides general background on indoor air quality impacts and parameters. The
comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required and no additional
analyses or changes to the Draft EIR are required.
02-13 The comment provides general background on vapor intrusion impacts. The comment does not contain
any specific concerns related to the adequacy or accuracy of the environmental analysis in the Draft
EIR; therefore, no further response is required and no additional analyses or changes to the Draft EIR
are required.
02-14 The comment states the Draft EIR failed to evaluate the health risks of Toxic Air Contaminants (TACs)
contributed by the Project.
The Draft EIR evaluates health effects associated with air emissions in Section 4.2, Air Quality. The
commenter incorrectly states that the Draft EIR fails to properly evaluate health risk impacts of toxic
air contaminants. As provided on under Threshold 4.2b starting on page 4.2-28, the Projects direct
and indirect air emissions associated with both Project construction and operation are quantified. In
addition, a health risk assessment was prepared in for construction emissions in accordance with
Office of Environmental Health Hazard Assessment (OEHHA) risk assessment methodology for the
project. The analysis provided demonstrates that project impacts would be less than significant. Please
see Response to Comment 02-11.
02-15 The comment states that the Draft EIR fails to evaluate risks associated with vapor forming chemicals
(VFC) and also logistics regarding testing, soil remediation, and the location where excavated soils
would be disposed. The comment goes on to state the Draft EIR should be revised to include a vapor
intrusion assessment to evaluate and mitigate the potential risks associated with vapor intrusion,
including contaminant/vapor mobility over time.
With regards to contaminated soils that would be moved during grading and also exported off the site,
the Draft EIR recognizes the historical uses on the Project site (and potentially other surrounding
industrial activities) has resulted in soil and soil vapor contamination. Based on the analysis,
concentrations of contaminants of concern in soils do not exceed the Department of Toxic Substances
Control (DTSC) screening levels for residential use; however, these soils are regulated as non-
hazardous waste subject to state regulations for the transportation and disposal (DEIR p. 4.7-20). To
address this potentially significant impact, mitigation MM-HAZ-2 requires preparation of a soil
management plan (SMP) that outlines the proper screening, handling, characterization, transportation,
and disposal procedures for contaminated soils as well as health and safety procedures for breathing
zone monitoring in accordance with applicable regulations covering handling of VOC-contaminated soils
(DEIR p. 4.7-23).
With regards to a vapor intrusion assessment, a Soil and Soil Vapor Investigation (DEIR Appendix F-4) was
performed to determine the existing conditions of soil vapor contamination on the site as compared to
residential screening levels (DEIR p. 4.7-21). The Investigation indicated a potential vapor intrusion risk
to proposed residential structures to be constructed on the Project site. To address this underlying
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condition, MM-HAZ-3 requires vapor mitigation design features be implemented in accordance with the
DTSC Vapor Intrusion Mitigation Advisory for all future residential buildings and enclosed structures. The
mitigation also requires during Project operation semiannual indoor air monitoring be performed for one
year to evaluate the effectiveness of the engineered vapor barriers also required by MM-HAZ-3. Results
would be submitted to the City and modifications are required if the vapor mitigation system is not
properly reducing indoor air contaminants to below applicable acceptable thresholds. Compliance with
this mitigation would address continued protection of Project residents over time. Therefore, no
additional analyses or changes to the Draft EIR are required.
02-16 The comment suggests mitigation measure MM-HAZ-3 fails to identify or mention any mitigation design
features and is therefore to be considered deferred mitigation. The comment goes on to state the Draft
EIR should be revised to properly mitigate vapor intrusion impacts.
As discussed above under Response to Comment 02-15, the Draft EIR includes MM-HAZ-3 which states
vapor mitigation design features will be implemented in accordance with DTSCs Vapor Intrusion
Mitigation Advisory conducted prior to issuance of a grading permit. DTSCs Vapor Intrusion Mitigation
Advisory, intended to be used in conjunction with the DTSC Vapor Intrusion Guidance, are documents
designed to provide state-wide consistency for screening, evaluating, and mitigating vapor intrusion.
These documents have been developed in collaboration with multiple disciplines, including California
Environmental Protection Agency and State Water Quality Control Board. These documents provide
agency-recommended practices, screening levels, and remediation techniques based on agency data
and experience. MM-HAZ-3 also requires review/approval by the relevant permitting agencies prior to
construction. Lastly, MM-HAZ-3 also requires semiannual air monitoring to verify the efficacy of the
vapor barrier system. Results of monitoring would be submitted to the City, and, if required,
modifications shall be made to the system if acceptable levels are not met. As such, standards have
been established, and mitigation is not deferred. See also Response to Comment 02-17.
02-17 The comment is stating the Draft EIR fails to identify the design features noted in mitigation measure
MM-HAZ-3 and should be revised to properly mitigate vapor intrusion impacts.
The DTSC has recently issued a draft Supplemental Guidance: Screening and Evaluating Vapor
Intrusion (DTSC 2020) that provides details on methods to address vapor intrusion. Therefore, to
address the comment MM-HAZ-3 has been revised to include examples of design features that could
be used to address vapor intrusion and meet the required performance standard. Please see Chapter 3
for the revised mitigation measure. Also, please see Responses to Comments 02-15 and 02-16.
02-18 The comment states the Draft EIR improperly relies on existing local, state and/or federal regulations
to mitigate potential impacts and specifically refers to compliance with the Citys Stormwater
Management requirements to protect water quality.
Section 4.8, Hydrology and Water Quality includes a detailed summary of all relevant federal, state, and
local laws, regulations, policies and requirements adopted to oversee the protection and management
of water quality. If the Project is approved, construction and operation must comply with all laws
specifically adopted to protect water quality as well as be consistent with the Citys General Plan goals
and policies, and all City ordinances adopted to ensure projects do not adversely impact water quality.
Because projects are required to comply with any and all laws such requirements are described in the
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analysis but are not identified as mitigation. The comment does not provide any evidence that this is
improper and contradicts CEQA.
02-19 The comment includes excerpts from Section 4.8 of the Draft EIR but does not contain any specific
concerns related to the adequacy or accuracy of the environmental analysis in the Draft EIR; therefore,
no further response is required and no additional analyses or changes to the Draft EIR are required.
02-20 The comment states reliance on consistency with regulatory standards to conclude an impact is less
than significant is not adequate and CEQA requires facts and analysis must be provided to enable the
decision-makers and the public the ability to understand the potential impacts.
As explained under Response to Comment 02-18, the analysis in the EIR describes how compliance
with a particular law, regulation or policy would provide the decision makers and the public with the
understanding of how a potential impact would be mitigated. The analysis in the Draft EIR does not
simply state compliance with a specific law would mitigate an impact without providing a detailed
assessment that explains what the impact would be and how compliance with a specific law, regulation
or policy has been designed to mitigate the impact. If, with adherence to a specific law, regulation or
policy it is determined the impact could not be mitigated this would be disclosed and mitigation
provided to address the impact. This approach does not mean that the City has failed to provide
detailed information about the effects a project could have on the environment. On the contrary, all
conclusions in the Draft EIR, including impacts to hydrology and water quality, are supported by
substantial evidence (including facts, reasonable assumptions predicated upon facts, and expert
opinion supported by facts), as defined in Section 15384 of the CEQA Guidelines.
02-21 The comment states, once again, compliance with regulations alone is insufficient to conclude the
project would not have an impact.
Please see Response to Comment 02-20.
02-22 The comment is stating the Draft EIR does not identity potential impacts because the analysis of the
Projects hydrology and noise impacts are compressed into a single issue, inconsistent with CEQA.
It is not clear from the comment how the Draft EIR compresses the analysis of impacts and
mitigation measures into a single issue. The Draft EIR includes a detailed analysis of the Projects
direct and indirect impacts to all of the issue areas where it was determined the Project could
potentially result in an impact on the environment. The analysis does not rely on special construction
techniques for example, to negate the Citys responsibility to fully evaluate and disclose any
potential impact. All conclusions in the Draft EIR are supported by substantial evidence (including
facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts), as
defined in Section 15384 of the CEQA Guidelines. Further, [a]n agency may rely on generally
applicable regulations to conclude an environmental impact will not be significant and therefore does
not require mitigation. (San Francisco Beautiful v. City and County of San Francisco (2014) 226
Cal.App.4th 1012, 1033.)
02-23 The comment is requesting the Draft EIR be recirculated to address the concerns included in their letter.
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The commenters assertion that the Draft EIR must be revised and recirculated is inaccurate. CEQA
Guidelines Section 15088.5, Recirculation of an EIR Prior to Certification, describes the thresholds for
recirculation of an EIR. Pursuant to Section 15088.5, a lead agency is required to recirculate an EIR
when significant new information is added to the EIR after public notice is given of the availability of
the Draft EIR but before certification. New information can include a disclosure showing that a new
significant environmental impact would result from the project or from a new mitigation measure proposed
to be implemented, a substantial increase in the severity of an environmental impact, a feasible project
alternative or mitigation measure considerably different from others previously analyzed would clearly
lessen the environmental impacts of the project (but the projects proponents decline to adopt it), or
the Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful
public review and comment were precluded.
Significant new information, as it is defined in CEQA Guidelines Section 15088.5, has not been added
to this EIR subsequent to its release for public review. No changes have been made to the Project, and
no changes have occurred in the environmental setting such that a new significant impact would occur
or such that a substantial increase in the severity of an impact would occur. No additional data or other
information has been added such that a new significant impact would occur or such that a substantial
increase in the severity of an impact would occur. Additionally, no feasible project alternatives or
mitigation measures considerably different from those in the Draft EIR that would clearly lessen the
environmental impacts of the Project have been identified. Lastly, the Draft EIR is not fundamentally
and basically inadequate and conclusory in nature. As described above, the Draft EIR includes
extensive environmental analysis that was conducted by qualified professionals. The Draft EIR
discloses a number of significant impacts that would result from the proposed Project and identifies
mitigation that would reduce these significant impacts below a level of significance. As such, the Draft
EIR is not required to be revised and recirculated, and the commenter has not presented substantial
evidence to support a need for recirculation.
02-24 The comment includes an example analysis from another project in the City of Claremont of using a
local workforce to reduce construction related GHG emissions. This analysis is not performed for the
proposed Project and furthermore not even prepared for a project in the City of Arcadia. The comment
does not contain any specific concerns related to the adequacy or accuracy of the environmental
analysis in the Draft EIR; therefore, no further response is required and no additional analyses or
changes to the Draft EIR are required.
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Comment Letter I1
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INTENTIONALLY LEFT BLANK
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Response to Comment Letter I1
David Fu and Associates
April 6, 2022
I1-1 The comment provides background on the history of the adjacent medical office building owned by
Dong L. Chang, M.D. and requests his concerns be addressed by the Project applicant. The comment
does not contain any specific concerns related to the adequacy or accuracy of the environmental
analysis in the Draft EIR; therefore, no further response is required and no additional analyses or
changes to the Draft EIR are required.
I1-2 The comment is a general introduction to concerns raised in this comment letter. The comment does
not contain any specific concerns related to the adequacy or accuracy of the environmental analysis in
the Draft EIR; therefore, no further response is required and no additional analyses or changes to the
Draft EIR are required. Please see the responses below that address these concerns.
I1-3 The comment is addressing the Geotechnical Investigation prepared for the Project and is requesting
the Project applicant pay for the commenter to conduct the same investigation for the adjacent medical
office building due to its proximity to the Project site. The comment also raises a concern regarding
tiebacks anchors and if these anchors would impact the adjacent building.
The Geotechnical Investigation (see DEIR Appendix D-1) and Draft EIR discuss features needed to
ensure the adjacent property is not adversely impacted by Project construction. The commenter
expresses many concerns about soil stability, including differential settlement due to vibration during
construction, the need for the commenter to supervise pre-construction surveys of their property,
whether tieback anchors would impact the commenters property, and the need for monitoring during
construction to prevent damage to commenters property. Each of these concerns is addressed below.
Construction vibration. The Draft EIR addresses construction vibration in Section 4.10, Noise, on
pages 4.10-194.10-20. Groundborne vibration attenuates rapidly, even over short distances. According
to the Draft EIR analysis, at the adjacent medical office building (Dr. Changs office), construction vibration
would peak at approximately 0.067 in/sec in PPV, which is below the level that studies have found would
cause damage to buildings, including building foundations due to differential settlement of soil.
Specifically, the Federal Transit Administration guidelines show that a vibration level of up to 0.5 in/sec
in PPV (FTA 2018) is considered safe for buildings consisting of reinforced concrete, steel, or timber, and
would not result in any construction vibration damage. For a nonengineered timber and masonry building,
the construction building vibration damage criterion is 0.2 in/sec in PPV. The vibration from construction
at the commenters property (0.067 in/sec in PPV) is well below even the 0.2 in/sec in PPV threshold.
Pre-construction surveys and construction monitoring. The Geotechnical Investigation recommends
that prior to excavation the existing improvements on adjacent properties be inspected and their
present condition be documented. The Geotechnical Investigation also recommends monitoring of
adjacent properties during drilling and pile installation. The commenters engineer can participate in
the preconstruction survey and monitoring on the commenters property, but this extra oversight is not
required to reduce impacts to a less-than- significant level. Accordingly, the City cannot require the
Project applicant to pay for the commenters engineer. The commenter and Project applicant are free
to enter into a private agreement that addresses this issue.
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Excavation and tiebacks. The Geotechnical Investigation provides recommendations that would prevent
impacts to adjacent properties during the construction of the Projects building foundation. For example,
where off-site structures are within the shoring surcharge area, the design engineer should limit beam
deflection to less than ½ inch at the elevation of the adjacent off-site foundation. Caving of the holes for
the foundation could be prevented by formwork or casing. In addition, vertical excavations greater than 5
feet or where surcharged by existing structures would have sloping or shoring measures to provide a
stable excavation. Where space is limited, shoring measures would be required to prevent caving. One
method of shoring would consist of steel soldier piles, placed in drilled holes, and backfilled with concrete.
Where excavations exceed 12 feet or are surcharged, soldier piles may require lateral bracing using drilled
tie-back anchors or raker braces to maintain an economical steel beam size and prevent excessive
deflection. As the commenter notes, temporary tie-back anchors may be used with the solider pile wall
system to resist lateral loads. The locations and depths of all off-site utilities would be thoroughly checked
and incorporated into the drilling angle design for the tieback anchors to avoid damage to adjacent
properties. Tieback anchors would not be installed under or affect the commenters property.
Monitoring. The commenter is concerned about a lack of clear responsibility to monitor construction or
create a design-level geotechnical plan. The geotechnical recommendations, which will be incorporated
as Project conditions of approval, require a design-level plan and monitoring of structures on adjacent
properties to ensure they are not damaged by Project construction.
I1-4 The comment is addressing the Transportation Technical Memorandum (TTM) prepared for the Project
and notes the TTM does not address the parking easement or potential parking impacts with the
adjacent medical office building.
An evaluation of impacts to parking is not required to be evaluated under CEQA. The CEQA Guidelines
were updated in 2009 and a review of parking availability was removed. Recent case law has confirmed
CEQA does not consider the adequacy of a projects parking or its impacts on parking unless it would
result in significant secondary effects on the physical environment.
I1-5 The comment is referencing the Sewer Study conducted for the Project and notes the sewer
infrastructure that services the adjacent property runs under the Project site and would be impacted
by the Project. The comment also notes the adjacent property has a history of issues with the existing
sewer system due to its design.
Based on City building records, the commenters sewer line does not run under the Project site.
Accordingly, the sewer line would not be interrupted by Project construction.
I1-6 The comment states that the noise modeling output data does not address the substantial noise
conditions which would be experienced by the adjacent dermatological practice, and that both noise
and vibration are matters of concern.
As stated in Section 4.10.1 of the EIRs noise section, residences, schools, and hospitals are typical
examples of noise and vibration-sensitive land uses, with other sensitive uses dependent on what the
local jurisdiction may have defined or established. Based on the Citys Noise Ordinance and General Plan
Noise Element summarized in Section 4.10.2 of the EIR, sensitive receptors include residences, schools,
hospitals, hotels and motels, places of worship, and open space/recreation uses. Residences, a school
and recreational uses are the nearest noise-sensitive land uses in the vicinity of the Project site.
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Medical facilities are typically considered as sensitive receptors if they involve continuing care, such as
a hospital or convalescent home. Medical offices are typically not considered a sensitive receptor for
the purposes of CEQA noise analysis. The medical office building adjacent to the Project site is a
dermatologists office and therefore was not considered a sensitive receptor. Nonetheless, noise and
vibration levels at the medical office building from construction and operation of the Project were
provided in the analysis for informational purposes. This information is provided under Threshold 4.10a
starting on page 4.10-13. As shown in Tables 4.10-9 through 4.10-12 (DEIR pp. 4.10-15, 4.10-17,
4.10-18, 4.10-19) noise associated with construction would be as high as 88 dBA L eq at the adjacent
medical office building (see Table 4.10-9); however, the Citys Municipal Code allows construction work
to occur between the hours of 7:00 a.m. and 6:00 p.m. Monday Friday, and 8:00 a.m. and 5:00 p.m.
on Saturday, and any time on Sunday and holidays. Tables 4.10-10 through 4.10-12 show the noise
levels of stationary equipment and noise associated with Project traffic under existing plus Project and
cumulative conditions at the nearest receivers would be well below the applicable noise standards.
Therefore, impacts would be less than significant. Threshold 4.10b on page 4.10-19 addresses
vibration from construction activities. Based on guidance provided by Caltrans the Project would not
exceed the guidance-based annoyance threshold of 0.2 ips PPV. At the adjacent medical office building
vibration is predicted at approximately 0.067 ips PPV, which is be well below the guidance limit of 0.3
ips PPV for preventing structural damage. Because the predicted vibration levels are less than both the
annoyance and building damage risk thresholds, vibration from construction activities would be less
than significant. The City appreciates the commenters engagement and the Citys decision makers will
consider these comments when reviewing the proposed Project.
I1-7 The comment notes additional comments may be submitted to the City and appreciates the opportunity
to comment on the Draft EIR.
The comment does not contain any specific concerns related to the adequacy or accuracy of the
environmental analysis in the Draft EIR; therefore, no further response is required and no additional
analyses or changes to the Draft EIR are required.
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References
DTSC (Department of Toxic Substances Control. 2020. Supplemental Guidance: Screening and Evaluating Vapor
Intrusion. Draft for Public Comments. February 2020. Accessed April 19, 2022. https://dtsc.ca.gov/wp-
content/uploads/sites/31/2020/02/Public-Draft-Supplemental-VI-Guidance_2020-02-14.pdf.
FTA (U.S. Department of Transportation, Federal Transit Administration). 2018. Transit Noise and Vibration Impact
Assessment Manual. September 2018.
OPR (California Governors Office of Planning and Research). 2018. Technical Advisory on Evaluating
Transportation Impacts in CEQA. December 2018. Accessed June 2020. http://opr.ca.gov/
docs/20190122-743_Technical_Advisory.pdf.
Occupational Safety and Health Administration (OSHA). 2021. Protecting Workers: Guidance on Mitigating and
Preventing the Spread of COVID-19 in the Workplace. The Roles of Employers and Workers in
Responding to COVID-19. Guidance posted January 29, 2021; Updated June 10, 2021; Summary of
changes August 13, 2021. https://www.osha.gov/coronavirus/safework#role-employers-workers.
Occupational Safety & Health Standards Board (OSHSB). 2021. California Occupational Safety and Health
Administrations (Cal/OSHA) COVID-19 Prevention Emergency Temporary Standards (ETS). Standards
Presentation to California Occupational Safety and Health Standards Board. Title 8, Division 1, Chapter 4.
December 16, 2021. https://www.dir.ca.gov/OSHSB/documents/Dec162021-COVID-19-Prevention-
Emergency-apprvdtxt-2nd-Readoption.pdf.
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3 Changes to the Draft EIR
3.1 Introduction
The comments received on Alexan Mixed-Use Development Project during the public review period for the Draft EIR
included information that has resulted in several minor revisions to the text of the Draft EIR. Additionally,
typographical errors have been identified in the Draft EIR. These revisions are shown below and are categorized by
section number and page number. Errors which require multiple revisions throughout the Draft EIR are categorized
at the beginning of Section 3.2, Errata, below, with a summary of the change and subsequent section number and
page number provided. Text from the Draft EIR that has been removed is shown in bold strikethrough (i.e.,
strikethrough), and text that has been added as part of the Final EIR is shown as bold underlined (i.e., u nderline).
Revisions are shown with surrounding sentences for context. These errata merely clarify and corrects minor facts
and does not constitute substantial revisions or significant new information, that in accordance with CEQA
Guidelines, Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR.
3.2 Errata
Executive Summary, Section ES.4, Summary of Environmental Impacts and Mitigation Measures, Pages ES-9 and ES-10
Table ES-1 is revised to read:
Environmental Topic Impact? Mitigation Measure(s)1
Level of
Significance
After
Mitigation
Cultural Resources
Would the project cause
a substantial adverse
change in the
significance of an
archaeological resource
pursuant to §15064.5?
Potentially
Significant
Impact
MM-CUL-1
Prior to commencement of construction activities,
an inadvertent discovery clause, written by an
archaeologist, shall be added to all construction
plans associated with ground disturbing activities
and the Project applicant shall retain a qualified
archaeologist, meeting the Secretary of the
Interiors Professional Qualification Standards for
Archaeology, to prepare a Worker Environmental
Awareness Program (WEAP). The WEAP shall be
submitted to the City of Arcadia Planning and
Community Development Services dDepartment
(City) for review and approval. All construction
personnel and monitors shall be presented the
WEAP training prior to the start of construction
activities. The WEAP shall be prepared to inform all
personnel working on the proposed Project about
the archaeological sensitivity of the area, to
provide specific details on the kinds of
archaeological materials that may be identified
during construction, to explain the importance of
and legal basis for the protection of significant
Less Than
Significant
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Environmental Topic Impact? Mitigation Measure(s)1
Level of
Significance
After
Mitigation
archaeological resources, and to outline the
actions to be taken in the event of a discovery of
cultural resources. Each worker shall also learn
the proper procedures to follow in the event that
cultural resources or human remains are
uncovered during ground-disturbing activities.
These procedures include work curtailment or
redirection, and the immediate contact of the site
supervisor and archaeological monitor.
The WEAP shall require that a qualified archaeologist
be retained and on-call to respond to and address
any inadvertent discoveries identified during initial
excavation in native soils, which underly the 2-4 feet
below ground surface (bgs) of artificial fill soils. As it
pertains to archaeological monitoring, this definition
excludes movement of sediments after they have
been initially disturbed or displaced by project-related
construction.
If potential archaeological resources (i.e., sites,
features, or artifacts) are exposed during
construction activities for the proposed Project, the
City shall be notified and all construction work
occurring within 50 feet of the find shall
immediately stop until a qualified archaeologist,
meeting the Secretary of the Interiors Professional
Qualification Standards for Archaeology, can
evaluate the significance of the find and determine
whether or not additional study is warranted. The
archaeologist shall be empowered to temporarily
stop or redirect grading activities to allow removal
of abundant or large artifacts. Depending upon the
significance of the find under the California
Environmental Quality Act (CEQA) (14 CCR
15064.5[f]; PRC, Section 21082), the
archaeologist may simply record the find and allow
work to continue. If the discovery proves significant
under CEQA, additional work, such as preparation
of an archaeological treatment plan and data
recovery, may be warranted. The archaeologist
shall also be required to curate any discovered
specimens in a repository with permanent
retrievable storage and submit a written report to
the City of Arcadia for review and approval prior to
occupancy of the first building on the site. Once
approved, the final report shall be filed with the
South Central Coastal Information Center (SCCIC).
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Environmental Topic Impact? Mitigation Measure(s)1
Level of
Significance
After
Mitigation
Hazards and Hazardous Resources
Would the project create
a significant hazard to
the public or the
environment through the
routine transport, use, or
disposal of hazardous
materials?
Potentially
Significant
Impact
MM-HAZ-1
Demolition and Abatement Procedures. Prior to the
issuance of a demolition permit, the Project
applicant/developer or their designated contractor
shall ensure that the demolition contractors
contract specifications incorporate abatement
procedures for the removal of materials containing
asbestos, as identified in previous surveys, and
identification and removal of polychlorinated
biphenyls, hazardous material, hazardous wastes,
and universal waste items. All abatement work shall
be done in accordance with federal, state, and local
regulations, including those of the U.S.
Environmental Protection Agency (which regulates
disposal), Occupational Safety and Health
Administration, U.S. Department of Housing and
Urban Development, California Occupational
Safety and Health Administration (which
regulates employee exposure), and the South Coast
Air Quality Management District. Confirmation of
adequate removal of such materials shall be
provided to the City prior to the issuance of a
building permit.
Less Than
Significant
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?
Potentially
Significant
Impact
MM-HAZ-3
Vapor Mitigation. Prior to the issuance of a grading
permit, vapor mitigation design features shall be
implemented in accordance with the Department
of Toxic Substances Control (DTSC) Vapor Intrusion
Mitigation Advisory for all future residential
buildings and enclosed structures. Draft
Supplemental Guidance issued by DTSC indicates
long term mitigation may include subslab venting
or depressurization systems with or without vapor
barriers (subslab liners), and sewer VI mitigation
such as venting, check valves, and sewer pipe
linings. The construction contractor shall
incorporate vapor mitigation design features into
building plans that reduce potential vapor
intrusion in buildings and enclosed structures on
the Project site below DTSC Screening Levels.
Vapor mitigation systems may be passive or active
in nature, so long as they are designed to prevent
vapor contamination on the Project site in
accordance with applicable DTSC regulations at
the time the systems are designed. Vapor
mitigation systems shall be designed, built,
installed, operated, and maintained in
conformance with standard geologic, engineering,
Less Than
Significant
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Environmental Topic Impact? Mitigation Measure(s)1
Level of
Significance
After
Mitigation
and construction principles and practices by
appropriately licensed professionals and Vapor
mitigation systems must shall be reviewed and
approved by the permitting agency(ies) (City of
Arcadia, County of Los Angeles) prior to
construction and prior to issuance of certificate of
occupancy. Operation of the Project shall maintain
functionality of these features as required to
continue protection from vapor intrusion. Following
completion of construction and occupancy of the
buildings, indoor air monitoring will occur
semiannually for one year to verify implemented
measures are functioning properly and adequately
mitigating vapor intrusion to below residential
DTSC Screening Levels. Results shall be submitted
to the City of Arcadia for confirmation of the
adequacy of the designed systems. If indoor air
samples reveal vapor intrusion occurring at levels
above applicable DTSC Screening Levels,
modifications shall be made, as necessary, to the
designed system to improve the efficacy in
reducing vapor intrusion to below applicable
screening levels.
Tribal Cultural Resources
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?
Potentially
Significant
Impact
MM-TCR-1
The project applicant shall retain a Native
American Monitor from or approved by the
Gabrieleño Band of Mission Indians Kizh Nation
(Tribe or Kizh). The monitor shall be retained
prior to the commencement of any ground-
disturbing activity for the subject project at all
project locations (i.e., both on-site and any off-site
locations that are included in the project
description/definition and/or required in
connection with the project, such as public
improvement work). Ground-disturbing activity
shall include, but is not limited to, demolition,
pavement removal, potholing, auguring, grubbing,
tree removal, boring, grading, excavation, drilling,
and trenching. Ground-disturbing activity refers
to ground disturbance occurring from 1 foot above
native soils and below, and it does not include
movement of sediments after they have been
initially disturbed or displaced by current Project-
related construction.
A copy of the executed monitoring agreement shall
be submitted to the lead agency prior to the earlier
of the commencement of any ground-disturbing
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Environmental Topic Impact? Mitigation Measure(s)1
Level of
Significance
After
Mitigation
activity, or the issuance of any permit necessary to
commence a ground-disturbing activity.
The monitor will complete daily monitoring logs
that will provide descriptions of the relevant
ground-disturbing activities, the type of
construction activities performed, locations of
ground-disturbing activities, soil types, cultural-
related materials, and any other facts, conditions,
materials, or discoveries of significance to the
Tribe. Monitor logs will identify and describe any
discovered TCRs, including but not limited to,
Native American cultural and historical artifacts,
remains, places of significance, etc., (collectively,
tribal cultural resources, or TCR), as well as any
discovered Native American (ancestral) human
remains and burial goods. Copies of monitor logs
will be provided to the project applicant/lead
agency upon written request to the Tribe.
On-site tribal monitoring shall conclude upon the
earlier of the following (1) written confirmation to
the Kizh from a designated point of contact for the
project applicant or lead agency that all ground-
disturbing activities as defined in TCR-1.A above
and phases that may involve ground-disturbing
activities on the project site or in connection with
the project are complete; or (2) a determination
and written notification by the Kizh to the project
applicant or lead agency that no future, planned
construction activity and/or development/
construction phase at the project site possesses
the potential to impact Kizh TCRs.
Upon discovery of any Kizh TCRs, all construction
activities in the immediate vicinity of the discovery
shall cease (i.e., not less than the surrounding 50
feet) and shall not resume until the Kizh recovers
and retains all discovered Kizh TCRs in the form
and/or manner the Tribe deems appropriate, in
the Tribes sole discretion, and for any purpose the
Tribe deems appropriate, including for
educational, cultural and/or historic purposes.
The Tribe shall have up to 48 hours to recover and
retain any discovered Kizh TCRs, after which time
construction activities in the immediate vicinity of
the discovery may continue.
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Section 4.3, Cultural Resources, Section 4.3.6, Mitigation Measures, Pages 4.3-29 and 4.3-30
The first paragraph under mitigation measure MM-CUL-1 is revised to read:
MM-CUL-1 Prior to commencement of construction activities, an inadvertent discovery clause, written by an
archaeologist, shall be added to all construction plans associated with ground disturbing activities
and the Project applicant shall retain a qualified archaeologist, meeting the Secretary of the
Interiors Professional Qualification Standards for Archaeology, to prepare a Worker Environmental
Awareness Program (WEAP). The WEAP shall be submitted to the City of Arcadia Planning and
Community Development Services dDepartment (City) for review and approval. All construction
personnel and monitors shall be presented the WEAP training prior to the start of construction
activities. The WEAP shall be prepared to inform all personnel working on the proposed Project
about the archaeological sensitivity of the area, to provide specific details on the kinds of
archaeological materials that may be identified during construction, to explain the importance of
and legal basis for the protection of significant archaeological resources, and to outline the actions
to be taken in the event of a discovery of cultural resources. Each worker shall also learn the proper
procedures to follow in the event that cultural resources or human remains are uncovered during
ground-disturbing activities. These procedures include work curtailment or redirection, and the
immediate contact of the site supervisor and archaeological monitor.
Section 4.7, Hazards and Hazardous Materials, Section 4.7.6, Mitigation Measures, Page 4.7-23
Mitigation measure MM-HAZ-1 is revised to read:
MM-HAZ-1 Demolition and Abatement Procedures. Prior to the issuance of a demolition permit, the Project
applicant/developer or their designated contractor shall ensure that the demolition contractors
contract specifications incorporate abatement procedures for the removal of materials containing
asbestos, as identified in previous surveys, and identification and removal of polychlorinated
biphenyls, hazardous material, hazardous wastes, and universal waste items. All abatement work
shall be done in accordance with federal, state, and local regulations, including those of the U.S.
Environmental Protection Agency (which regulates disposal), Occupational Safety and Health
Administration, U.S. Department of Housing and Urban Development, California Occupational
Safety and Health Administration (which regulates employee exposure), and the South Coast Air
Quality Management District. Confirmation of adequate removal of such materials shall be provided
to the City prior to the issuance of a building permit.
Section 4.7, Hazards and Hazardous Materials, Section 4.7.6, Mitigation Measures, Page 4.7-24
Mitigation measure MM-HAZ-3 is revised to read:
MM-HAZ-3 Vapor Mitigation. Prior to the issuance of a grading permit, vapor mitigation design features shall
be implemented in accordance with the Department of Toxic Substances Control (DTSC) Vapor
Intrusion Mitigation Advisory for all future residential buildings and enclosed structures. Draft
Supplemental Guidance issued by DTSC indicates long term mitigation may include subslab
venting or depressurization systems with or without vapor barriers (subslab liners), and sewer VI
mitigation such as venting, check valves, and sewer pipe linings. The construction contractor shall
incorporate vapor mitigation design features into building plans that reduce potential vapor
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3 - Changes to the Draft EIR
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intrusion in buildings and enclosed structures on the Project site below DTSC Screening Levels.
Vapor mitigation systems may be passive or active in nature, so long as they are designed to
prevent vapor contamination on the Project site in accordance with applicable DTSC regulations at
the time the systems are designed. Vapor mitigation systems shall be designed, built, installed,
operated, and maintained in conformance with standard geologic, engineering, and construction
principles and practices by appropriately licensed professionals and Vapor mitigation systems must
shall be reviewed and approved by the permitting agency(ies) (City of Arcadia, County of Los
Angeles) prior to construction and prior to issuance of certificate of occupancy. Operation of the
Project shall maintain functionality of these features as required to continue protection from vapor
intrusion. Following completion of construction and occupancy of the buildings, indoor air
monitoring will occur semiannually for one year to verify implemented measures are functioning
properly and adequately mitigating vapor intrusion to below residential DTSC Screening Levels.
Results shall be submitted to the City of Arcadia for confirmation of the adequacy of the designed
systems. If indoor air samples reveal vapor intrusion occurring at levels above applicable DTSC
Screening Levels, modifications shall be made, as necessary, to the designed system to improve
the efficacy in reducing vapor intrusion to below applicable screening levels.
Section 4.14, Tribal Cultural Resources, Section 4.14.6, Mitigation Measures, Page 4.14-12
The first sentence in the fourth paragraph of MM-TCR-1 is revised to read:
MM-TCR-1 On-site tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to
the Kizh from a designated point of contact for the project applicant or lead agency that all ground-
disturbing activities as defined in TCR-1.A above and phases that may involve ground-disturbing
activities on the project site or in connection with the project are complete; or (2) a determination
and written notification by the Kizh to the project applicant or lead agency that no future, planned
construction activity and/or development/construction phase at the project site possesses the
potential to impact Kizh TCRs.
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4 Mitigation Monitoring and
Reporting Program
California Public Resources Code Section 21081.6 requires that, upon certification of an EIR, the public agency
shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval,
adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program
shall be designed to ensure compliance during project implementation.
This chapter contains the mitigation monitoring and reporting program (MMRP) that has been developed for
the Alexan Mixed-Use Development Project (Project). This MMRP has been developed in compliance with Public
Resources Code Section 21081.6 and Section 15097 of the CEQA Guidelines. The mitigation measures in the
table are coded by alphanumeric identification consistent with the EIR. The following items are identified for
each mitigation measure:
Mitigation Monitoring. This section of the MMRP lists the stage of the proposed project during which the
mitigation measure would be implemented and the stage during which proper implementation would be
monitored and verified. It also lists the agency that is responsible for ensuring that the mitigation measure
is implemented and that it is implemented properly.
Verification of Compliance. This section of the MMRP provides a location for the implementing party
and/or enforcing agency to make notes and to record their initials and the compliance date for each
mitigation measure.
The City of Arcadia (City) must adopt this MMRP, or an equally effective program, if it approves the proposed
project with the mitigation measures that were adopted or made conditions of project approval.
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Cultural Resources
MM-CUL-1
Prior to commencement of construction activities, an
inadvertent discovery clause, written by an archaeologist, shall
be added to all construction plans associated with ground
disturbing activities and the Project applicant shall retain a
qualified archaeologist, meeting the Secretary of the Interiors
Professional Qualification Standards for Archaeology, to prepare
a Worker Environmental Awareness Program (WEAP). The WEAP
shall be submitted to the City of Arcadia Development Services
Department (City) for review and approval. All construction
personnel and monitors shall be presented the WEAP training
prior to the start of construction activities. The WEAP shall be
prepared to inform all personnel working on the proposed
Project about the archaeological sensitivity of the area, to
provide specific details on the kinds of archaeological materials
that may be identified during construction, to explain the
importance of and legal basis for the protection of significant
archaeological resources, and to outline the actions to be taken
in the event of a discovery of cultural resources. Each worker
shall also learn the proper procedures to follow in the event that
cultural resources or human remains are uncovered during
ground-disturbing activities. These procedures include work
curtailment or redirection, and the immediate contact of the site
supervisor and archaeological monitor.
The WEAP shall require that a qualified archaeologist be retained
and on-call to respond to and address any inadvertent
discoveries identified during initial excavation in native soils,
which underly the 2-4 feet below ground surface (bgs) of artificial
fill soils. As it pertains to archaeological monitoring, this
definition excludes movement of sediments after they have been
Prior to
commencement of
construction activities;
During construction
activities
Project applicant; Project
archaeologist for preparation
of a Worker Environmental
Awareness Program (WEAP)
City of Arcadia Planning
Division
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
initially disturbed or displaced by project-related construction. If
potential archaeological resources (i.e., sites, features, or
artifacts) are exposed during construction activities for the
proposed Project, the City shall be notified and all construction
work occurring within 50 feet of the find shall immediately stop
until a qualified archaeologist, meeting the Secretary of the
Interiors Professional Qualification Standards for Archaeology,
can evaluate the significance of the find and determine whether
or not additional study is warranted. The archaeologist shall be
empowered to temporarily stop or redirect grading activities to
allow removal of abundant or large artifacts. Depending upon the
significance of the find under the California Environmental
Quality Act (CEQA) (14 CCR 15064.5[f]; PRC, Section 21082), the
archaeologist may simply record the find and allow work to
continue. If the discovery proves significant under CEQA,
additional work, such as preparation of an archaeological
treatment plan and data recovery, may be warranted. The
archaeologist shall also be required to curate any discovered
specimens in a repository with permanent retrievable storage
and submit a written report to the City of Arcadia for review and
approval prior to occupancy of the first building on the site. Once
approved, the final report shall be filed with the South Central
Coastal Information Center (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 shall outline
requirements for preconstruction meeting attendance and
Prior to any grading
activity; During
grading activities
Project applicant; Project
paleontologist for preparation
of a Paleontological
Resources Impact Mitigation
Program (PRIMP) and
preconstruction meeting
City of Arcadia Planning
Division
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
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, Pleistocene
alluvial 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.
Hazards and Hazardous Materials
MM-HAZ-1
Prior to the issuance of a demolition permit, the Project
applicant/developer or their designated contractor shall ensure
that the demolition contractors contract incorporate abatement
procedures for the removal of materials containing asbestos, as
identified in previous surveys, and identification and removal of
polychlorinated biphenyls, hazardous material, hazardous
wastes, and universal waste items. All abatement work shall be
done in accordance with federal, state, and local regulations,
including those of the U.S. Environmental Protection Agency
(which regulates disposal), Occupational Safety and Health
Prior to the issuance
of a demolition permit
Project applicant; Project
contractor
City of Arcadia Planning and
Building Divisions
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Administration, U.S. Department of Housing and Urban
Development, California Occupational Safety and Health
Administration (which regulates employee exposure), and the
South Coast Air Quality Management District. Confirmation of
adequate removal of such materials shall be provided to the
City prior to the issuance of a building permit.
MM-HAZ-2
Prior to the issuance of a grading permit, the Project
applicant/developer or their designated contractor shall
prepare a soil management plan (SMP) that outlines the proper
screening, handling, characterization, transportation, and
disposal procedures for contaminated soils on site. The SMP
shall include health and safety and training procedures for
workers who may come in contact with contaminated soils. The
health and safety procedures shall also include periodic
breathing zone monitoring and monitoring for VOCs using a
handheld organic vapor analyzer and include required actions
to be taken if concentrations of VOCs exceed applicable
screening levels for health and safety of onsite workers. The
SMP will be based on the findings of the Soil and Soil Vapor
Investigation prepared for the Project, will outline areas of
known or suspected soil contamination, and will be
implemented by the applicant or their designated contractor for
all confirmed and suspected contaminated soils which require
excavation and offsite disposal. Contaminated soil shall be
managed and disposed of in accordance with applicable
federal, state, and local regulations.
Prior to the issuance
of a grading permit
Project applicant; Project
contractor for preparation of a
Soil Management Plan (SMP)
City of Arcadia Planning and
Building Divisions
MM-HAZ-3
Prior to the issuance of a grading permit, vapor mitigation
design features shall be implemented in accordance with the
Department of Toxic Substances Control (DTSC) Vapor Intrusion
Mitigation Advisory for all future residential buildings and
Prior to issuance of a
grading permit; Prior
to construction and
prior to issuance of
certificate of
Project applicant; Construction
contractor
City of Arcadia Planning and
Building Divisions; County of
Los Angeles Department of
Public Works
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
enclosed structures. Draft Supplemental Guidance issued by
DTSC indicates long term mitigation may include subslab
venting or depressurization systems with or without vapor
barriers (subslab liners), and sewer VI mitigation such as
venting, check valves, and sewer pipe linings. The construction
contractor shall incorporate vapor mitigation design features
into building plans that reduce potential vapor intrusion in
buildings and enclosed structures on the Project site below
DTSC Screening Levels. Vapor mitigation systems may be
passive or active in nature, so long as they are designed to
prevent vapor contamination on the Project site in accordance
with applicable DTSC regulations at the time the systems are
designed. Vapor mitigation systems shall be designed, built,
installed, operated, and maintained in conformance with
standard geologic, engineering, and construction principles and
practices by appropriately licensed professionals and shall be
reviewed and approved by the permitting agency(ies) (City of
Arcadia, County of Los Angeles) prior to construction and prior
to issuance of certificate of occupancy. Operation of the Project
shall maintain functionality of these features as required to
continue protection from vapor intrusion. Following completion
of construction and occupancy of the buildings, indoor air
monitoring will occur semiannually for one year to verify
implemented measures are functioning properly and adequately
mitigating vapor intrusion to below residential DTSC Screening
Levels. Results shall be submitted to the City of Arcadia for
confirmation of the adequacy of the designed systems. If indoor
air samples reveal vapor intrusion occurring at levels above
applicable DTSC Screening Levels, modifications shall be made,
as necessary, to the designed system to improve the efficacy in
reducing vapor intrusion to below applicable screening levels.
occupancy with
respect to vapor
mitigation systems
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Transportation
MM-TRA-1
Prior to the issuance of demolition or grading permits, the
Project applicant/developer shall develop and implement a City-
approved Construction Traffic Control Plan. The Plan shall be
prepared in accordance with applicable City guidelines and shall
address the potential for construction-related vehicular traffic,
as well as pedestrian and bicycle circulation disruption in the
public right-of-way. The Plan shall describe safe detours and
shall include protocols for implementing the following:
temporary traffic controls (e.g., a flag person during heavy truck
traffic for soil export) to maintain smooth pedestrian and traffic
flow; dedicated on-site turn lanes for construction trucks and
equipment leaving the site; scheduling of peak construction
truck traffic that affects traffic flow on the arterial system to off-
peak hours; consolidation of truck deliveries; and/or rerouting
of construction trucks away from congested streets or sensitive
receptors.
Prior to the issuance
of demolition or
grading permits
Project Applicant for the
preparation of a Construction
Traffic Control Plan
City of Arcadia Planning and
Engineering Divisions
Tribal Cultural Resources
MM-TCR-1.
The project applicant shall retain a Native American Monitor
from or approved by the Gabrieleño Band of Mission Indians
Kizh Nation (Tribe or Kizh). The monitor shall be retained
prior to the commencement of any ground-disturbing activity
for the subject project at all project locations (i.e., both on-site
and any off-site locations that are included in the project
description/definition and/or required in connection with the
project, such as public improvement work). Ground-disturbing
activity shall include, but is not limited to, demolition,
pavement removal, potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and trenching. Ground-
Prior to the
commencement of
any ground-
disturbing activity for
the subject project at
all project locations,
or prior to issuance of
any permit necessary
to commence a
ground-disturbing
activity; During
Construction contractor; Native
American Monitor from or
approved by the Gabrieleño
Band of Mission Indians Kizh
Nation
City of Arcadia Planning
Division
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
disturbing activity refers to ground disturbance occurring from
1 foot above native soils and below, and it does not include
movement of sediments after they have been initially disturbed
or displaced by current Project-related construction.
A copy of the executed monitoring agreement shall be
submitted to the lead agency prior to the earlier of the
commencement of any ground-disturbing activity, or the
issuance of any permit necessary to commence a ground-
disturbing activity.
The project applicant shall retain a Native American Monitor
from or approved by the Gabrieleño Band of Mission Indians
Kizh Nation (Tribe or Kizh). The monitor shall be retained
prior to the commencement of any ground-disturbing activity
for the subject project at all project locations (i.e., both on-site
and any off-site locations that are included in the project
description/definition and/or required in connection with the
project, such as public improvement work). Ground-disturbing
activity shall include, but is not limited to, demolition,
pavement removal, potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and trenching. Ground-
disturbing activity refers to ground disturbance occurring from
1 foot above native soils and below, and it does not include
movement of sediments after they have been initially disturbed
or displaced by current Project-related construction. A copy of
the executed monitoring agreement shall be submitted to the
lead agency prior to the earlier of the commencement of any
ground-disturbing activity, or the issuance of any permit
necessary to commence a ground-disturbing activity.
On-site tribal monitoring shall conclude upon the earlier of the
following (1) written confirmation to the Kizh from a designated
point of contact for the project applicant or lead agency that all
ground-disturbing
activity
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
ground-disturbing activities as defined above and phases that
may involve ground-disturbing activities on the project site or in
connection with the project are complete; or (2) a determination
and written notification by the Kizh to the project applicant or
lead agency that no future, planned construction activity and/or
development/construction phase at the project site possesses
the potential to impact Kizh TCRs. Upon discovery of any Kizh
TCRs, all construction activities in the immediate vicinity of the
discovery shall cease (i.e., not less than the surrounding 50
feet) and shall not resume until the Kizh recovers and retains all
discovered Kizh TCRs in the form and/or manner the Tribe
deems appropriate, in the Tribes sole discretion, and for any
purpose the Tribe deems appropriate, including for educational,
cultural and/or historic purposes. The Tribe shall have up to 48
hours to recover and retain any discovered Kizh TCRs, after
which time construction activities in the immediate vicinity of
the discovery may continue.
MM-TCR-2
Native American human remains are defined in PRC 5097.98
(d)(1) as an inhumation or cremation, and in any state of
decomposition or skeletal completeness. Funerary objects,
called associated grave goods in Public Resources Code
Section 5097.98, are also to be treated according to this
statute.
In accordance with Health and Safety Code Section 7050.5, any
discoveries of human skeletal material shall be immediately
reported to the County Coroner and all ground-disturbing
activities shall immediately halt and shall remain halted until
the coroner has determined the nature of the remains. If the
coroner recognizes the human remains to be those of a Native
American or has reason to believe they are Native American, he
or she shall contact, by telephone within 24 hours, the Native
During ground-
disturbing activities
Construction contractor County Coroner; NAHC; City
of Arcadia Development
Services Department
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4 Mitigation Monitoring and Reporting Program
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
American Heritage Commission, and Public Resources Code
Section 5097.98 shall be followed.
Consistent with California Public Resources Code
section 5097.98(d)(2), any items associated with the human
remains that are placed or buried with the Native American
human remains are to be treated in the same manner as the
remains, but do not by themselves constitute human remains.
Preservation in place (i.e., avoidance) is the preferred manner
of treatment for discovered human remains and/or burial
goods.
Any discovery of human remains/burial goods shall be kept
confidential to prevent further disturbance.
MM-TCR-3
If the Tribe is designated by the Native American Heritage
Commission (NAHC) as the Most Likely Descendant (MLD),
the Koo-nas-gna Burial Policy shall be implemented. To the
Tribe, the term human remains encompasses more than
human bones. In ancient as well as historic times, Tribal
Traditions included, but were not limited to, the preparation of
the soil for burial, the burial of funerary objects with the
deceased, and the ceremonial burning of human remains.
Accordingly, if the Tribe is designated as the MLD for discovered
human remains, the prepared soil and cremation soils are to be
treated in the same manner as bone fragments that remain
intact. Associated funerary objects are objects that, as part of
the death rite or ceremony of a culture, are reasonably believed
to have been placed with individual human remains either at
the time of death or later; other items made exclusively for
burial purposes or to contain human remains can also be
considered as associated funerary objects. Cremations will
During ground-
disturbing activities
Construction contractor NAHCs Most Likely
Descendant Tribe; City of
Arcadia Development
Services Department
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
either be removed in bulk or by means as necessary to ensure
complete recovery of all sacred materials.
If the Tribe is designated by the NAHC as the MLD, the following
condition will apply: If the discovery of human remains includes
four or more burials, the discovery location shall be treated as a
cemetery and a separate treatment plan shall be created.
If the Tribe is designated by the NAHC as the MLD, the following
condition will apply: In the case where discovered human
remains cannot be fully documented and recovered on the
same day, the remains will be covered with muslin cloth and a
steel plate that can be moved by heavy equipment placed over
the excavation opening to protect the remains. If this type of
steel plate is not available, a 24-hour guard should be posted
outside of working hours. The Tribe will make every effort to
recommend diverting the project and keeping the remains in
situ and protected. If the project cannot be diverted, it may be
determined that burials will be removed.
If the Tribe is designated by the NAHC as the MLD, the following
condition will apply: In the event preservation in place is not
possible despite good faith efforts by the project
applicant/developer and/or landowner, before ground-
disturbing activities may resume on the project site, the
landowner shall arrange a designated site location within the
footprint of the project for the respectful reburial of the human
remains and/or ceremonial objects. If the Tribe is designated by
the NAHC as the MLD, the following condition will apply: Each
occurrence of human remains and associated funerary objects
will be stored using opaque cloth bags. All human remains,
funerary objects, sacred objects and objects of cultural
patrimony will be removed to a secure container on site if
possible. These items should be retained and reburied within
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Table 4-1. Mitigation Monitoring and Reporting Program
Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
six months of recovery. Where the Tribe is designated as the
MLD, the site of reburial/repatriation shall be on the project site
but at a location agreed upon between the Tribe and the
landowner at a site to be protected in perpetuity. There shall be
no publicity regarding any cultural materials recovered.
If the Tribe is designated by the NAHC as the MLD, the following
condition will apply: The Tribe will work closely with the projects
qualified archaeologist to ensure that the excavation is treated
carefully, ethically and respectfully. If data recovery is approved
by the Tribe, documentation shall be prepared and shall include
(at a minimum) detailed descriptive notes and sketches. All
data recovery and data recovery-related forms of
documentation shall be approved in advance by the Tribe. If any
data recovery is performed, once complete, a final report shall
be submitted to the Tribe and the NAHC. The Tribe does NOT
authorize any scientific study or the utilization of any invasive
and/or destructive diagnostics on human remains.
527
FINDINGS OF FACT
Alexan Mixed-Use Development Project Final EIR
(SCH No.2021070271)
Prepared for:
City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Contact: Lisa Flores, Planning and Community Development Administrator
Prepared by:
38 North Marengo Avenue
Pasadena, California 91101
Contact: Kristin Starbird, Senior Project Manager
MAY 2022
528
Printed on 30% post-consumer recycled material.
529
Alexan Mixed-Use Development Project Final EIR 11663.03
May 2022 i
Table of Contents
SECTION PAGE NO.
1 INTRODUCTION ............................................................................................................................................. 1
1.1 Purpose ................................................................................................................................................... 1
1.1.1 Record of Proceedings ............................................................................................................. 2
1.1.2 Custodian and Location of Records ......................................................................................... 2
2 CEQA FINDINGS OF INDEPENDENT JUDGEMENT ........................................................................................ 3
2.1 Independent Review and Analysis ......................................................................................................... 3
2.2 Impacts Determined to Be Less Than Significant with Mitigation ....................................................... 3
2.2.1 Cultural Resources ................................................................................................................... 4
2.2.2 Geology and Soils ..................................................................................................................... 6
2.2.3 Hazards and Hazardous Materials .......................................................................................... 8
2.2.4 Transportation ........................................................................................................................ 12
2.2.5 Tribal Cultural Resources ...................................................................................................... 13
2.3 Impacts Determined to Be Less Than Significant ............................................................................. 17
2.3.1 Aesthetics ............................................................................................................................... 17
2.4.2 Agriculture and Forestry Resources ...................................................................................... 21
2.4.3 Air Quality ............................................................................................................................... 21
2.3.4 Biological Resources ............................................................................................................. 26
2.4.5 Cultural Resources ................................................................................................................ 27
2.3.6 Energy ..................................................................................................................................... 30
2.3.7 Geology and Soils .................................................................................................................. 33
2.3.8 Greenhouse Gas Emissions .................................................................................................. 39
2.3.9 Hazards and Hazardous Materials ....................................................................................... 41
2.3.10 Hydrology and Water Quality ................................................................................................. 42
2.3.11 Land Use ................................................................................................................................ 49
2.3.12 Mineral Resources ................................................................................................................. 51
2.3.13 Noise ....................................................................................................................................... 52
2.3.14 Population and Housing ........................................................................................................ 56
2.3.15 Public Services and Recreation ............................................................................................ 60
2.3.16 Transportation ........................................................................................................................ 68
2.3.17 Tribal Cultural Resources ...................................................................................................... 73
2.3.18 Utilities and Service Systems ................................................................................................ 74
2.3.19 Wildfire ................................................................................................................................... 82
3 FINDINGS ON PROJECT ALTERNATIVES ...................................................................................................... 83
3.1 Alternatives Carried Forward for Consideration ................................................................................ 83
3.1.1 Alternative A - No Project/Existing Development ................................................................. 83
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3.1.2 Alternative B - Increased Commercial-Use Alternative: Conversion of Live/Work Units to
Commercial ............................................................................................................................ 85
3.2.2 Environmentally Superior Alternative ................................................................................... 86
4 GENERAL CEQA FINDINGS .......................................................................................................................... 87
4.1 Findings Regarding Recirculation ....................................................................................................... 87
4.2 Legal Effects of Findings ..................................................................................................................... 88
5 CONCLUSION ............................................................................................................................................... 89
6 REFERENCES CITED .................................................................................................................................... 91
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1 Introduction
This statement of Findings of Fact (Findings) addresses the environmental effects associated with the proposed
Alexan Mixed-Use Development Project (proposed Project), as described in the Draft Environmental Impact Report
(EIR). These Findings are made pursuant to the California Environmental Quality Act (CEQA) (California Public
Resources Code, Section 21000 et seq.), specifically California Public Resources Code, Sections 21081, 21081.5,
and 21081.6, and the CEQA Guidelines (14 CCR 15000 et seq.), specifically Sections 15091 and 15093. The Draft
EIR examines the full range of potential effects of construction and operation of the Project and identifies mitigation
practices that could be employed to reduce, minimize, or avoid those potential effects.
1.1 Purpose
California Public Resources Code, Section 21081, and CEQA Guidelines Section 15091 require that the lead agency, in
this case the City of Arcadia (City), prepare written findings for identified significant effects, accompanied by a brief
explanation of the rationale for each finding. Specifically, CEQA Guidelines Section 15091 states, in part, that:
a) No public agency shall approve or carry out a project for which an EIR has been certified
which identifies one or more significant environmental effects of the project unless the public
agency makes one or more written findings for each of those significant effects, accompanied
by a brief explanation of the rationale for each finding. The possible findings are:
1) Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effect as identified in the final EIR.
2) Such changes or alterations are within the responsibility and jurisdiction of another public
agency and not the agency making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other agency.
3) Specific economic, legal, social, technological, or other considerations, including provision
of employment opportunities for highly trained workers, make infeasible the mitigation
measures or project alternatives identified in the final EIR.
In accordance with California Public Resource Code, Section 21081, and CEQA Guidelines Section 15093,
whenever significant effects cannot be mitigated to below a level of significance, the decision making agency is
required to balance, as applicable, the benefits of the project against its unavoidable environmental risks when
determining whether to approve the project. If the benefits of a project outweigh the unavoidable adverse
environmental effects, the adverse effects may be considered acceptable. In that case, the decision-making
agency may prepare and adopt a Statement of Overriding Considerations (SOC), pursuant to the CEQA Guidelines.
The Project does not result in any impacts that cannot be mitigated to a level of less than significant; therefore, a
Statement of Overriding Considerations is not required.
The EIR identified potentially significant effects that could result from the Project. The City finds that the
inclusion of certain mitigation measures as part of the approval of the Project will reduce all impacts to less-
than significant levels.
As required by CEQA, the City, in adopting these Findings, also adopts a Mitigation Monitoring and Reporting Program
(MMRP) for the Project. The City finds that the MMRP, which is incorporated by reference and made a part of these
Findings, meets the requirements of California Public Resources Code, Section 21081.6, by providing for the
implementation and monitoring of measures intended to mitigate potentially significant effects of the Project.
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FINDINGS OF FACT
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In accordance with the CEQA Statutes and Guidelines, the City adopts these Findings for the Project. Pursuant to
California Public Resources Code, Section 21082.1(c)(3), the City also finds that these Findings reflect the Citys
independent judgment as the lead agency for the Project.
1.1.1 Record of Proceedings
For the purposes of CEQA and the Findings herein set forth, the record of proceedings for the Project consists of
those items listed in CEQA Section 21167.6(e). The record of proceedings for the Citys decision on the Project
consists of the following documents, at a minimum and without limitation, which are incorporated by reference and
made part of the record supporting these Findings:
(a) The Notice of Preparation, Notice of Availability, and all other public notices issued by the City in conjunction
with the Project
(b) The Draft EIR for the Project and all technical appendices and documents relied upon or incorporated
by reference
(c) All written comments submitted by agencies, organizations, or members of the public during the public
review comment period on the Draft EIR and the Citys responses to those comments
(d) The Final EIR for the Project
(e) The MMRP for the Project
(f) All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project
prepared by the City or consultants to the City with respect to the Citys compliance with the requirements
of CEQA and with respect to the Citys action on the Project
(g) All documents submitted to the City by other public agencies or members of the public in connection with
the Draft EIR
(h) Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public hearings
held by the City in connection with the Project
(i) Any documentary or other evidence submitted to the City at such information sessions, public meetings,
and public hearings
(j) All resolutions adopted by the City regarding the Project, and all staff reports, analyses, and summaries
related to the adoption of those resolutions
(k) Matters of common knowledge to the City, including, but not limited to federal, state, and local laws
and regulations
(l) Any documents expressly cited in these Findings, in addition to those cited above; and any other materials
required for the record of proceedings by CEQA Section 21167.6(e)
1.1.2 Custodian and Location of Records
The documents and other materials that constitute the Record of Proceedings for the Citys actions related to the
Project are located at the City of Arcadia, 240 W. Huntington Drive, California 91007. The City Clerk is the custodian
of the Record of Proceedings for the Project.
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2 CEQA Findings of
Independent Judgement
2.1 Independent Review and Analysis
Under CEQA, the lead agency must (1) independently review and analyze the EIR; (2) circulate draft documents that
reflect its independent judgment; (3) as part of the certification of an EIR, find that the report or declaration reflects
the independent judgment of the lead agency; and (4) submit copies of the documents to the State Clearinghouse
if there is state agency involvement or if the project is of statewide, regional, or area-wide significance (California
Public Resources Code, Section 21082.1[c]).
These Findings reflect the Citys independent judgment. The City has exercised independent judgment in
accordance with CEQA Section 21082.1(c)(3) in retaining its own environmental consultant in the preparation of
the EIR, as well as reviewing, analyzing, and revising material prepared by the consultant.
Having received, reviewed, and considered the information in the Final EIR, as well as any and all other information in the
record, the City hereby makes findings pursuant to and in accordance with CEQA Sections 21081, 21081.5, and 21081.6.
2.2 Impacts Determined to Be Less Than Significant
with Mitigation
This section identifies significant adverse impacts of the Project that require findings to be made under CEQA
Section 21081(a) and CEQA Guidelines Section 15091(a)(1). Based on substantial evidence, the City finds that
adoption of the mitigation measures set forth in this section will reduce the identified significant impacts to less-
than significant levels:
Cultural Resources
Archaeological Resources
Cumulative Effect
Geology and Soils
Paleontological Resources
Cumulative Effect
Hazards and Hazardous Materials
Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the
Potential for Upset Conditions
Reasonably Foreseeable Upset and Accident Conditions Involving the Release of Hazardous Materials
Cumulative Effect
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FINDINGS OF FACT
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Transportation
Inadequate Emergency Access
Tribal Cultural Resources
California Public Resource Code, Section 5024.1
Cumulative Effect
Other impacts addressed for Aesthetics, Agriculture and Forestry Resources, Air Quality, Biological Resources,
Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials,
Hydrology and Water Quality, Land Use, Mineral Resources, Population and Housing, Public Services and
Recreation, Transportation, Utilities and Service Systems, and Wildfire are addressed under Section 2.3, Impacts
Determined to Be Less Than Significant.
2.2.1 Cultural Resources
2.2.1.1 Potentially Significant Impacts to Cultural Resources
Archaeological Resources
The CHRIS records search identified 17 previously conducted cultural resources technical investigations within a 0.5-
mile radius records search area. Of these, four studies overlap the Project site; however, individual sites were not
identified within the current Project site as a result of these studies. Additionally, the South Central Coast Information
Center (SCCIC) records indicate that 63 previously recorded cultural resources exist within the surrounding 0.5-mile
search radius. Of the resources identified all are built environment resources with one historic-era archaeological site.
No previously recorded prehistoric or historic-era archaeological resources were identified within the Project site or 0.5-
mile records search radius. Additionally, the Native American Heritage Commission (NAHC) was contacted to request a
search of its Sacred Land Files (SLF), which were negative. The NAHC also suggested contacting two Native American
individuals and/or tribal organizations who may have direct knowledge of cultural resources in or near the Project site.
Based on the results provided above, the potential of encountering and impacting unknown archaeological resources
during Project implementation is low given the level of disturbance from the mid-twentieth century; however, it is always
possible that unanticipated discoveries could be encountered during ground-disturbing activities associated with the
proposed Project. Although the entirely of the Project site was previously investigated, none of these previous
investigations were completed prior to the development of the site, indicating that the opportunity to observe native or
undisturbed soils during the years of these previous investigations (1996 to 2010) was not possible. However, if such
unanticipated discoveries were encountered, impacts to encountered resources could be potentially significant.
However, with implementation of Mitigation Measure (MM-) CUL-1, which includes preparation and implementation of a
Worker Environmental Awareness Program (WEAP), all construction personnel will be appropriately informed of required
responses to unanticipated cultural resources, should these be encountered. Additionally, MM-CUL-1, requires an
inadvertent discovery clause, written by an archaeologist, to be added to all construction plans associated with ground
disturbing activities would ensure that a qualified archaeologist is retained and on-call to respond to any inadvertent
discoveries during Project construction; and requires that all construction work occurring within 50 feet of any find shall
immediately stop until a qualified archaeologist, meeting the Secretary of the Interiors Professional Qualification
Standards for Archaeology, can evaluate the significance of the find. Thus, potentially significant impacts to
archaeological resources would be reduced to less than significant levels with mitigation incorporated.
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FINDINGS OF FACT
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Cumulative Effect
For archaeological resources, cumulative projects may require extensive excavation in culturally sensitive areas, and
thus, may result in adverse effects to known or previously unknown, inadvertently discovered archaeological
resources. There is the potential for accidental discovery of other archaeological resources by the proposed Project as
well as by cumulative projects. Because all significant cultural resources are unique and non-renewable, all adverse
effects or negative impacts contribute to a dwindling resource base. Through implementation of MM-CUL-1, which
would require investigation and handling by a qualified archaeologist in the event that an unknown resource is
encountered, the project-level impact to archeological resources would be reduced to less than significant.
Further, other individual related projects occurring in the vicinity of the Project site that require discretionary review
would also be subject to the same requirements of CEQA as the proposed Project and any impacts to archaeological
resources would be mitigated, as applicable. These determinations would be made on a case-by-case basis, and
the effects of cumulative development on historical and archaeological resources would be mitigated to the extent
feasible in accordance with CEQA and other applicable legal requirements. Therefore, impacts on archaeological
resources would not be cumulatively considerable with mitigation incorporated (MM-CUL-1).
2.2.1.2 Mitigation Measures
MM-CUL-1 Prior to commencement of construction activities, an inadvertent discovery clause, written by an
archaeologist, shall be added to all construction plans associated with ground disturbing activities
and the Project applicant shall retain a qualified archaeologist, meeting the Secretary of the Interiors
Professional Qualification Standards for Archaeology, to prepare a Worker Environmental Awareness
Program (WEAP). The WEAP shall be submitted to the City of Arcadia Development Services
Department (City) for review and approval. All construction personnel and monitors shall be
presented the WEAP training prior to the start of construction activities. The WEAP shall be prepared
to inform all personnel working on the proposed Project about the archaeological sensitivity of the
area, to provide specific details on the kinds of archaeological materials that may be identified during
construction, to explain the importance of and legal basis for the protection of significant
archaeological resources, and to outline the actions to be taken in the event of a discovery of cultural
resources. Each worker shall also learn the proper procedures to follow in the event that cultural
resources or human remains are uncovered during ground-disturbing activities. These procedures
include work curtailment or redirection, and the immediate contact of the site supervisor and
archaeological monitor.
The WEAP shall require that a qualified archaeologist be retained and on-call to respond to and
address any inadvertent discoveries identified during initial excavation in native soils, which
underly the 2-4 feet below ground surface (bgs) of artificial fill soils. As it pertains to archaeological
monitoring, this definition excludes movement of sediments after they have been initially disturbed
or displaced by project-related construction.
If potential archaeological resources (i.e., sites, features, or artifacts) are exposed during
construction activities for the proposed Project, the City shall be notified and all construction work
occurring within 50 feet of the find shall immediately stop until a qualified archaeologist, meeting
the Secretary of the Interiors Professional Qualification Standards for Archaeology, can evaluate
the significance of the find and determine whether or not additional study is warranted. The
archaeologist shall be empowered to temporarily stop or redirect grading activities to allow removal
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of abundant or large artifacts. Depending upon the significance of the find under the California
Environmental Quality Act (CEQA) (14 CCR 15064.5[f]; PRC, Section 21082), the archaeologist may
simply record the find and allow work to continue. If the discovery proves significant under CEQA,
additional work, such as preparation of an archaeological treatment plan and data recovery, may
be warranted. The archaeologist shall also be required to curate any discovered specimens in a
repository with permanent retrievable storage and submit a written report to the City of Arcadia for
review and approval prior to occupancy of the first building on the site. Once approved, the final
report shall be filed with the South Central Coastal Information Center (SCCIC).
2.2.1.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse
impacts were developed for the potentially significant impacts described in Section 2.2.2.1. This feasible measure,
MM-CUL-1, is listed in Section 2.2.2.2.
The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential cultural resources
impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA
Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in or
incorporated into the Project that will mitigate or avoid potentially significant impacts on cultural resources.
2.2.1.4 Facts in Support of the Findings Related to Cultural Resources
Implementation of MM-CUL-1 would reduce potentially significant impacts to archaeological resources by
addressing the inadvertent discovery of archeological resources. There would be no significant, unavoidable
impacts related to cultural resources after implementation of this mitigation measure.
2.2.2 Geology and Soils
2.2.2.1 Potentially Significant Impacts to Geology and Soils
Paleontological Resource
The Project site is underlain by Quaternary gravel and sand (map unit Qg; <11,700 years old), derived as alluvial
fans and major stream channels and is not anticipated to be underlain by unique geological features. The Natural
History Museum of Los Angeles County (LACM) did not report any paleontological localities from within the Project
site, but they did report fossil specimens were recovered in the nearby area. In addition to the LACM localities,
desktop research for the Project area indicated there are additional paleontological deposits close to the Project
site. Given the proximity of past fossil discoveries in the surrounding area and the potential for significant vertebrate
fossils below any artificial fill present within the Project site, the proposed Project is considered potentially sensitive
for supporting paleontological resources at any depth. In the event that intact paleontological resources are located
on the Project site, ground-disturbing activities associated with construction of the Project, such as grading during
site preparation, excavations and trenching for pipelines or utilities, have the potential to destroy a unique
paleontological resource or site. Without mitigation, the potential damage to paleontological resources during
construction would be a potentially significant impact. However, upon implementation of Mitigation Measure
(MM)- GEO-1, impacts would be reduced to below a level of significance. MM-GEO-1 requires a preparation of a
Paleontological Resources Impact Mitigation Program that requires preconstruction meeting attendance and
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worker environmental awareness training, where monitoring is required within the Project site, procedures for
adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment
sampling for microvertebrate fossils), reporting, and collections management. With incorporation of MM-GEO-1,
impacts would be less than significant.
Cumulative Effect
Potential cumulative impacts on geology and soils would result from projects that combine to create geologic
hazards, including unstable geologic conditions, or contribute substantially to erosion. The majority of impacts from
geologic hazards, such as rupture of a fault line, liquefaction, landslides, expansive soils, and unstable soils, are
site-specific and are therefore generally mitigated on a project-by-project basis. Each cumulative project would be
required to adhere to required building engineering design per the most recent version of the California Building
Code or CBC in order to ensure the safety of building occupants and avoid a cumulative geologic hazard.
Additionally, as needed, projects would incorporate individual mitigation or geotechnical requirements for site-
specific geologic hazards present on each individual cumulative project site. Similarly, MM-GEO-1 would ensure
that potential impacts to paleontological resources would be less than significant and other cumulative projects
that would have a potential to impact soils that are sensitive for significant fossils would also require mitigation.
Therefore, a potential cumulative impact related to site-specific geologic hazards, such as seismically induced
ground failure, subsidence, soil collapse, and expansive soils, as well as paleontological resources, would not occur.
Therefore, the proposed Project, in combination with other cumulative projects, would not contribute to a significant
cumulative impact associated with geology and soils.
2.2.2.2 Mitigation Measures
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 shall 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, Pleistocene alluvial
deposits. These deposits may be encountered at depths as shallow as 510 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.
2.2.2.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), a feasible measure that can minimize significant adverse
impacts was developed for the potentially significant impacts described in Section 2.2.2.1. This feasible measure,
MM-GEO-1, is listed in Section 2.2.2.2.
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The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential paleontological
resources impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA
Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or
incorporated into, the Project that mitigate or avoid potentially significant paleontological related impacts of the
Project identified in the EIR.
2.2.2.4 Facts in Support of the Findings Related to Geology and Soils
Potential impacts to geology and soils would be less than significant. Incorporation of MM-GEO-1 would reduce
construction-related impacts to paleontological resources to a less-than-significant level. There would be no
significant, unavoidable impacts related to geology and soils after implementation of these mitigation measures.
2.2.3 Hazards and Hazardous Materials
2.2.3.1 Potentially Significant Impacts to Hazards and Hazardous Materials
Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the Potential for
Upset Conditions
Short-Term Construction Impacts
Construction would require the use of heavy equipment and machinery. Hazardous materials would be stored in
designated construction staging areas within the boundaries of the Project site and the construction contractor
must ensure that they would be transported, handled, used, stored, and disposed of in accordance with all
applicable federal, state, and local laws and regulations.
Three buildings on the Project site are scheduled for demolition as part of the proposed Project and an existing
building would be renovated. Based on information provided in the Phase I ESA and the asbestos survey, asbestos
is present in all the buildings proposed for demolition but no lead-based paint was identified. Universal wastes,
such as light fixtures and thermostats that may be present would require collection and off-site disposal prior to
demolition. Hazardous wastes, such as spent chemicals or petroleum, may also require collection and off-site
disposal prior to demolition and rehabilitation. Additionally, many commercial buildings contain small amounts of
(polychlorinated biphenyls) PCBs and mercury that would require proper management prior to demolition. Should
remaining hazardous materials and hazardous wastes associated with site maintenance be present, including
petroleum products and cleaning supplies, these would be disturbed during the demolition process if not removed.
These materials, if not properly removed, could be transported offsite with demolition debris, and therefore the
proposed Project has the potential to create a significant hazard to the public or the environment through the
routine transport or disposal of hazardous materials associated with demolition activities. In accordance with
mitigation measure MM-HAZ-1, demolition would include abatement procedures for the removal of materials
containing asbestos, as identified in previous surveys, and identification and removal of PCBs, hazardous material,
hazardous wastes, and universal waste items. Abatement must be conducted by licensed contractors, and materials
must be transported offsite for recycling and/or disposal by licensed transporters in accordance with federal, state,
and local laws. With implementation of MM-HAZ-1, impacts associated with the routine transport of asbestos, PCBs,
universal wastes, and hazardous materials for offsite disposal during construction would be less than significant
with mitigation incorporated.
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Reasonably Foreseeable Upset and Accident Conditions
Short-Term Construction Impacts
The proposed Project has the potential to expose the public and the environment to hazards associated with on-
site releases of hazardous materials including asbestos PCB-containing items, universal wastes, and other
hazardous materials and wastes present in the building scheduled for demolition. Management of hazardous
materials and waste during pre-demolition surveys and abatement activities would be addressed by MM-HAZ-1.
Hazardous materials present in the office building to be renovated, including the items identified for the existing
Verizon Wireless cell tower and dental offices, are not expected to be impacted by construction, as this building is
not scheduled for demolition, and renovation would only occur on the first floor lobby area which does not contain
these hazardous items. However, MM-HAZ-1 would be implemented in the areas scheduled for renovation.
Construction activities would not be conducted in areas where hazardous materials are stored, and impacts
associated with existing hazardous materials would be managed under MM-HAZ-1, therefore impacts would be less
than significant with mitigation incorporated.
The Soil and Soil Vapor Investigation identified elevated concentrations of benzene and Tetrachloroethylene (PCE)
in soil vapor above applicable residential and commercial/industrial screening levels. A potential accident condition
could occur during excavation and earth moving activities exposing onsite construction workers to contaminated
soil vapor. The soil management plan (SMP) required by MM-HAZ-2 will also include health and safety procedures,
including breathing zone monitoring, to prevent exposure of onsite workers to elevated concentrations of benzene
and PCE. Along with adherence to federal, state, and local laws and regulations, and implementation of MM-HAZ-1
and MM-HAZ-2, short-term construction impacts associated with potential upset and accident conditions involving
the release of hazardous materials to the environment would be less than significant with mitigation incorporated.
Long-Term Operational Impacts
The Soil and Soil Vapor Investigation identified concentrations of benzene and PCE in soil indicating a potential
vapor intrusion risk to proposed residential structures to be constructed on the Project site. PCE and benzene
concentrations were detected in soil vapor above the Department of Toxic Substances Control (DTSC) screening
levels for commercial exposure near the existing commercial buildings. These buildings would remain operational
and the current commercial use would not change as part of the proposed Project. Construction would include
excavation of soils and construction of new buildings; however, these activities are not anticipated to exacerbate
existing soil vapor conditions beneath the existing buildings to remain because the Project site is already completely
paved and covered with buildings, therefore pathways of soil vapor exposure in current buildings would not change.
MM-HAZ-3 requires vapor mitigation to be designed and implemented for new structures on the Project site, which
will reduce the potential for vapor intrusion to a less than significant level. In accordance with MM-HAZ-3 indoor air
monitoring following construction and occupancy is required to verify vapor intrusion is adequately mitigated. With
implementation of MM-HAZ-3 Project operational impacts are not anticipated to create a foreseeable upset or
accident condition that would release hazardous materials to the environment, and impacts would be less than
significant with mitigation incorporated.
Cumulative Effects
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There are a variety of hazardous material and public health and safety issues that are relevant and applicable to
the Project. Many potential impacts related to hazardous materials and public health and safety risks would be
minimized due to compliance with federal, state, and local regulatory requirements.
Cumulative Projects would also be subject to federal, state, and local regulations related to hazardous materials
and other public health and safety issues the same as the proposed Project. Adherence to these regulatory
requirements would reduce incremental impacts associated with public exposure to health and safety hazards in
each of the affected Project areas. Additionally, most hazardous material and safety-related risks are localized,
generally affecting a specific site and immediate surrounding area, thus minimizing the potential for an impact to
combine with another Project to create a cumulative scenario. Additionally, implementation of MM-HAZ-1 through
MM-HAZ-3 would ensure that Project-related activities would not result in significant impacts; therefore, the
proposed Project would not contribute to a cumulatively considerable environmental impact related to hazards and
hazardous materials.
2.2.3.2 Mitigation Measures
MM-HAZ-1 Prior to the issuance of a demolition permit, the Project applicant/developer or their designated
contractor shall ensure that the demolition contractors contract incorporate abatement
procedures for the removal of materials containing asbestos, as identified in previous surveys, and
identification and removal of polychlorinated biphenyls, hazardous material, hazardous wastes,
and universal waste items. All abatement work shall be done in accordance with federal, state, and
local regulations, including those of the U.S. Environmental Protection Agency (which regulates
disposal), Occupational Safety and Health Administration, U.S. Department of Housing and Urban
Development, California Occupational Safety and Health Administration (which regulates employee
exposure), and the South Coast Air Quality Management District. Confirmation of adequate removal
of such materials shall be provided to the City prior to the issuance of a building permit.
MM-HAZ-2 Prior to the issuance of a grading permit, the Project applicant/developer or their designated
contractor shall prepare a soil management plan (SMP) that outlines the proper screening,
handling, characterization, transportation, and disposal procedures for contaminated soils on site.
The SMP shall include health and safety and training procedures for workers who may come in
contact with contaminated soils. The health and safety procedures shall also include periodic
breathing zone monitoring and monitoring for VOCs using a handheld organic vapor analyzer and
include required actions to be taken if concentrations of VOCs exceed applicable screening levels
for health and safety of onsite workers. The SMP will be based on the findings of the Soil and Soil
Vapor Investigation prepared for the Project, will outline areas of known or suspected soil
contamination, and will be implemented by the applicant or their designated contractor for all
confirmed and suspected contaminated soils which require excavation and offsite disposal.
Contaminated soil shall be managed and disposed of in accordance with applicable federal, state,
and local regulations.
MM-HAZ-3 Prior to the issuance of a grading permit, vapor mitigation design features shall be implemented in
accordance with the Department of Toxic Substances Control (DTSC) Vapor Intrusion Mitigation
Advisory for all future residential buildings and enclosed structures. Draft Supplemental Guidance
issued by DTSC indicates long term mitigation may include subslab venting or depressurization
systems with or without vapor barriers (subslab liners), and sewer VI mitigation such as venting, check
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valves, and sewer pipe linings. The construction contractor shall incorporate vapor mitigation design
features into building plans that reduce potential vapor intrusion in buildings and enclosed structures
on the Project site below DTSC Screening Levels. Vapor mitigation systems may be passive or active
in nature, so long as they are designed to prevent vapor contamination on the Project site in
accordance with applicable DTSC regulations at the time the systems are designed. Vapor mitigation
systems shall be designed, built, installed, operated, and maintained in conformance with standard
geologic, engineering, and construction principles and practices by appropriately licensed
professionals and shall be reviewed and approved by the permitting agency(ies) (City of Arcadia,
County of Los Angeles) prior to construction and prior to issuance of certificate of occupancy.
Operation of the Project shall maintain functionality of these features as required to continue
protection from vapor intrusion. Following completion of construction and occupancy of the buildings,
indoor air monitoring will occur semiannually for one year to verify implemented measures are
functioning properly and adequately mitigating vapor intrusion to below residential DTSC Screening
Levels. Results shall be submitted to the City of Arcadia for confirmation of the adequacy of the
designed systems. If indoor air samples reveal vapor intrusion occurring at levels above applicable
DTSC Screening Levels, modifications shall be made, as necessary, to the designed system to
improve the efficacy in reducing vapor intrusion to below applicable screening levels.
2.2.3.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse
impacts were developed for the potentially significant impacts described in Section 2.3.4.1. These feasible measures,
MM-HAZ-1, MM-HAZ-2, and MM-HAZ-3 are listed in Section 2.2.3.2.
The City finds that these mitigation measures are feasible, are adopted, and will reduce the Projects potential
impacts related to hazards and hazardous materials to less than significant levels. Accordingly, the City finds that,
pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have
been required in or incorporated into the Project that will mitigate or avoid potentially significant impacts related to
hazards and hazardous materials.
2.2.3.4 Facts in Support of the Findings Related to Hazards and Hazardous Materials
The abatement of hazardous materials identified on the Project site would remove the potential for exposure of the
public and the environment to accidental release of hazardous materials, as required by MM-HAZ-1. Construction
and demolition activities would be completed in accordance with the Soils Management Plan, as required by
MM-HAZ- 2, and vapor mitigation design features will be implemented in accordance with the DTSC Vapor Intrusion
Mitigation Advisory for all future residential buildings and enclosed structures, required by MM-HAZ-3. Therefore,
impacts related to routine transport, use or disposal of hazardous materials and foreseeable upset and accident
conditions involving a release of hazardous materials to the environment would be mitigated to a less-than-
significant level. All other impacts would be less than significant. There would be no significant, unavoidable impacts
related to hazards and hazardous materials after implementation of these mitigation measures.
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2.2.4 Transportation
2.2.4.1 Potentially Significant Impacts to Transportation
Inadequate Emergency Access.
Construction
Short-Term Site Access
Short-term adverse traffic and parking impacts could occur in the Project vicinity during construction of the Project.
Additional trips generated by the truck deliveries and construction employees could affect traffic flow in the study
area; construction activity could impact traffic near the Project site; and pedestrian traffic flow near the Project site
could also be altered as a result of construction.
Although the influx of equipment and materials to the Project site could create temporary adverse effects
to the adjacent roadway, potential impacts associated with construction of the Project would be limited to
those locations immediately adjacent to the Project site. Pedestrian access to the existing office buildings
and bank uses on the Project site would be open, although temporary sidewalk closures around the portions
of the Project site may be required in specific locations for limited time periods. To ensure adequate
safeguards for pedestrian, bicycle and vehicular circulation and emergency vehicle access during short-
term construction activities, Mitigation Measure (MM-) TRA-1 is required. MM-TRA-1 requires preparation
of a Construction Traffic Control Plan to address pedestrian, bicycle, and vehicular circulation during
construction activities. Implementation of MM-TRA-1 would reduce potential impacts related to emergency
access to less than significant.
2.2.4.2 Mitigation Measures
MM-TRA-1 Prior to the issuance of demolition or grading permits, the Project applicant/developer shall
develop and implement a City-approved Construction Traffic Control Plan. The Plan shall be
prepared in accordance with applicable City guidelines and shall address the potential for
construction-related vehicular traffic, as well as pedestrian and bicycle circulation disruption in the
public right-of-way. The Plan shall describe safe detours and shall include protocols for
implementing the following: temporary traffic controls (e.g., a flag person during heavy truck traffic
for soil export) to maintain smooth pedestrian and traffic flow; dedicated on-site turn lanes for
construction trucks and equipment leaving the site; scheduling of peak construction truck traffic
that affects traffic flow on the arterial system to off-peak hours; consolidation of truck deliveries;
and/or rerouting of construction trucks away from congested streets or sensitive receptors.
2.2.4.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), a feasible measure that can minimize significant adverse
impacts was developed for the potentially significant impacts described in Section 2.2.4.1. This feasible measure,
MM-TRA-1, is listed in Section 2.2.4.2.
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The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential transportation-
related impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA
Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in or
incorporated into the Project that will mitigate or avoid potentially significant impacts related to transportation.
2.2.4.4 Facts in Support of the Findings Related to Transportation
With incorporation of MM-TRA-1, potential significant impacts related to short-term access to the Project site would
be reduced to less than significant. All other potential environmental impacts to Transportation would be less than
significant. There would be no significant, unavoidable impacts related to transportation after implementation of
this mitigation measure.
2.2.5 Tribal Cultural Resources
2.2.5.1 Potentially Significant Impacts to Tribal Cultural Resources
Register of Historical Resources and Public Resource Code Section 5024.1
Visual observation of the current conditions within the proposed Project site indicate that all areas have been
disturbed as a result of urban development. Neither the CHRIS records search nor the pedestrian survey was able
to identify any archaeological resources within the Project site. Pursuant to California Assembly Bill (AB) 52 and
Senate Bill (SB) 18, the City contacted the two NAHC Native American individuals and/or tribal organizations
provided on August 13, 2021; the Gabrieleño Band of Mission Indians Kizh Nation and the Gabrielino Tongva
Tribe. No response was received from the Gabrielino Tongva Tribe.
Two consultation meetings were held between the City and the Gabrieleño Band of Mission Indians - Kizh Nation
(Kizh Nation) by way of conference calls on September 28, 2021, and November 17, 2021. The Kizh Nation
expressed concerns regarding the potential for inadvertent finds of unknown TCRs during excavation activities for
the Project. However, no specific TCRs were identified by the Kizh Nation within or surrounding the Project site. The
Kizh Nation provided further information and documentation regarding the Project area, and expressed concerns
that construction ground disturbance and excavation associated with the Project may result in the inadvertent
discovery of and impacts to an unknown TCR buried within the Project site. They also stated their particular concern
if excavation is proposed within native soils. The City determined that the documents provided by the Kizh Nation
do not substantiate the presence of a specific, known TCR that could be determined significant pursuant to criteria
set forth in subdivision (c) of Public Resources Code Section 5024.1. Since no sufficient evidence was presented
to determine that a known TCR exists within or near the Project site, no significance determination could be made
based on importance to a California Native American tribe.
Consultation under AB 52 did not identify any specific, known TCRs within the Project site. However, because the
proposed Project would involve excavations to a depth of up to 26 feet below ground surface, Project construction
would involve some disturbance to native soils whether intact or previously disturbed. While no known
archaeological and/or TCRs are located on the Project site, there remains some potential for a previously
undiscovered resource to be encountered during excavation, particularly within native soils. In consideration of the
information provided by the Kizh Nation during tribal consultation and in an abundance of caution, mitigation
measures MM-TCR-1 through MM-TCR-3 have been incorporated to ensure anticipatory measures are taken in the
event that unknown TCRs are inadvertently encountered during Project construction-related earthwork activities.
Therefore, impacts to TCRs would be less than significant with mitigation incorporated.
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MM-TCR-1 requires the project applicant to retain a Native American Monitor from or approved by the Gabrieleño Band
of Mission Indians Kizh Nation (Tribe or Kizh)prior to the commencement of any ground-disturbing activity for the
Project. Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery shall
cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers and retains all
discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in the Tribes sole discretion, and
for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.
MM-TCR- 2 requires compliance with Health and Safety Code Section 7050.5, in the event of any discoveries of human
skeletal material. MM-TCR-3 sets forth the procedure to follow in the event any human skeletal remains are unearthed
and determined to be Native American.
Cumulative Effects
Cumulative impacts on tribal cultural resources consider whether impacts of the proposed Project together with
other related projects identified within the vicinity of the Project site, when taken as a whole, substantially diminish
the number of such resources within the same or similar context or property type. There are no known tribal cultural
resources on the Project site and the area is considered to be of low potential to contain unanticipated cultural or
tribal cultural resources. No archaeological resources have been documented by the SCCIC within the Project site
or a surrounding 0.5-mile records search area.
Other individual related projects occurring in the vicinity of the Project site would also be subject to the same
requirements of CEQA as the proposed Project and any impacts to tribal cultural resources would be mitigated, as
applicable. These determinations would be made on a case-by-case basis, and the effects of cumulative
development on historical and archaeological resources would be mitigated to the extent feasible in accordance
with CEQA and other applicable legal requirements. Therefore, impacts on TCRs would not be cumulatively
considerable with mitigation incorporated as MM-TCR-1, MM-TCR-2, and MM-TCR-3.
2.2.5.2 Mitigation Measures
MM-TCR-1 The project applicant shall retain a Native American Monitor from or approved by the Gabrieleño
Band of Mission Indians Kizh Nation (Tribe or Kizh). The monitor shall be retained prior to the
commencement of any ground-disturbing activity for the subject project at all project locations
(i.e., both on-site and any off-site locations that are included in the project description/definition
and/or required in connection with the project, such as public improvement work). Ground-
disturbing activity shall include, but is not limited to, demolition, pavement removal, potholing,
auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. Ground-
disturbing activity refers to ground disturbance occurring from 1 foot above native soils and below,
and it does not include movement of sediments after they have been initially disturbed or displaced
by current Project-related construction.
A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the
earlier of the commencement of any ground-disturbing activity, or the issuance of any permit
necessary to commence a ground-disturbing activity.
The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-
disturbing activities, the type of construction activities performed, locations of ground-disturbing
activities, soil types, cultural-related materials, and any other facts, conditions, materials, or
discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs,
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including but not limited to, Native American cultural and historical artifacts, remains, places of
significance, etc., (collectively, tribal cultural resources, or TCR), as well as any discovered Native
American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to
the project applicant/lead agency upon written request to the Tribe.
On-site tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to
the Kizh from a designated point of contact for the project applicant or lead agency that all ground-
disturbing activities as defined above and phases that may involve ground-disturbing activities on
the project site or in connection with the project are complete; or (2) a determination and written
notification by the Kizh to the project applicant or lead agency that no future, planned construction
activity and/or development/construction phase at the project site possesses the potential to
impact Kizh TCRs.
Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery
shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers
and retains all discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in
the Tribes sole discretion, and for any purpose the Tribe deems appropriate, including for
educational, cultural and/or historic purposes. The Tribe shall have up to 48 hours to recover and
retain any discovered Kizh TCRs, after which time construction activities in the immediate vicinity
of the discovery may continue.
MM-TCR-2 Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or
cremation, and in any state of decomposition or skeletal completeness. Funerary objects,
called associated grave goods in Public Resources Code Section 5097.98, are also to be
treated according to this statute.
In accordance with Health and Safety Code Section 7050.5, any discoveries of human skeletal
material shall be immediately reported to the County Coroner and all ground-disturbing activities
shall immediately halt and shall remain halted until the coroner has determined the nature of
the remains. If the coroner recognizes the human remains to be those of a Native American or
has reason to believe they are Native American, he or she shall contact, by telephone within 24
hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98
shall be followed.
Consistent with California Public Resources Code section 5097.98(d)(2), any items associated with
the human remains that are placed or buried with the Native American human remains are to be
treated in the same manner as the remains, but do not by themselves constitute human remains.
Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human
remains and/or burial goods.
Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
MM-TCR-3 If the Tribe is designated by the Native American Heritage Commission (NAHC) as the Most Likely
Descendant (MLD), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term
human remains encompasses more than human bones. In ancient as well as historic times, Tribal
Traditions included, but were not limited to, the preparation of the soil for burial, the burial of
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funerary objects with the deceased, and the ceremonial burning of human remains. Accordingly, if
the Tribe is designated as the MLD for discovered human remains, the prepared soil and cremation
soils are to be treated in the same manner as bone fragments that remain intact. Associated
funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably
believed to have been placed with individual human remains either at the time of death or later;
other items made exclusively for burial purposes or to contain human remains can also be
considered as associated funerary objects. Cremations will either be removed in bulk or by means
as necessary to ensure complete recovery of all sacred materials.
If the Tribe is designated by the NAHC as the MLD, the following condition will apply: If the discovery
of human remains includes four or more burials, the discovery location shall be treated as a
cemetery and a separate treatment plan shall be created.
If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the case
where discovered human remains cannot be fully documented and recovered on the same day, the
remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment
placed over the excavation opening to protect the remains. If this type of steel plate is not available,
a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to
recommend diverting the project and keeping the remains in situ and protected. If the project
cannot be diverted, it may be determined that burials will be removed.
If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the event
preservation in place is not possible despite good faith efforts by the project applicant/developer
and/or landowner, before ground-disturbing activities may resume on the project site, the
landowner shall arrange a designated site location within the footprint of the project for the
respectful reburial of the human remains and/or ceremonial objects.
If the Tribe is designated by the NAHC as the MLD, the following condition will apply: Each
occurrence of human remains and associated funerary objects will be stored using opaque cloth
bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be
removed to a secure container on site if possible. These items should be retained and reburied
within six months of recovery. Where the Tribe is designated as the MLD, the site of reburial/
repatriation shall be on the project site but at a location agreed upon between the Tribe and the
landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural
materials recovered.
If the Tribe is designated by the NAHC as the MLD, the following condition will apply: The Tribe will
work closely with the projects qualified archaeologist to ensure that the excavation is treated
carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall
be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data
recovery and data recovery-related forms of documentation shall be approved in advance by the
Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the
Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any
invasive and/or destructive diagnostics on human remains.
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2.2.5.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse
impacts were developed for the potentially significant impacts described in Section 2.2.5.1. These feasible measures,
MM-TCR-1, as well as MM-TCR-2 and MM-TCR-3, are listed in Section 2.2.5.2.
The City finds that these mitigation measures are feasible, are adopted, and will reduce the potential tribal cultural
resource impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA
Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in or
incorporated into the Project that will mitigate or avoid potentially significant impacts on tribal cultural resources.
2.2.5.4 Facts in Support of the Findings Related to Tribal Cultural Resources
The implementation of MM-TCR-1, MM-TCR-2, and MM-TCR-3 would reduce potential impacts to tribal resources to
less-than-significant levels. There would be no significant, unavoidable impacts related to tribal cultural resources
after implementation of these mitigation measures.
2.3 Impacts Determined to Be Less Than Significant
Based on the analysis contained in the EIR, the following issue areas have been determined to fall within the
less-than-significant impact category for all thresholds: Aesthetics, Agriculture and Forestry Resources, Air
Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions,
Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use, Mineral Resources, Population and
Housing, Public Services and Recreation, Transportation, Utilities and Service Systems, and Wildfire.
Other impacts for Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Transportation, and
Tribal Cultural Resources not addressed below are addressed in Section 2.2.
2.3.1 Aesthetics
Scenic Vistas
The Project site is currently developed and located within a highly urbanized, relatively flat portion of the City, as
such, immediate views of and from adjacent and nearby parcels are not particularly scenic. The County of Los
Angeles General Plan does not identify any officially designated scenic vistas (County of Los Angeles 2014).
Likewise, the Citys General Plan does not identify any officially designated scenic vistas within City boundaries,
although they do indicate that unobstructed views of the historic Santa Anita Park Racetrack and the San Gabriel
Mountains are particularly important to the Citys aesthetic character and should be favored for preservation (City
of Arcadia 2010). The proposed Project would result in visual changes on the Project site due to increased intensity
of use; however, these changes would not adversely affect a scenic vista. Due to the urban, developed character of
the existing viewshed, the presence and proximity of existing developments, and existing topography in the area,
the proposed Project would not have a substantial adverse impact to existing scenic vistas, designated or otherwise.
The proposed Project is also located within a Transit Priority Area (TPA) and, as such, the proposed Projects impacts
on aesthetics would not be considered significant impacts pursuant to PRC Section 21099(d). The Project would
have no impact on any scenic views. No mitigation is required.
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Scenic Resource Damage within a State Scenic Highway
The proposed Project is not within the immediate vicinity of a state designated scenic highway. According to
Caltrans, the County of Los Angeles has two officially designated state scenic highways and 11 eligible scenic
highways (Caltrans 2019). Route 2 and Route 27, the County of Los Angeless two designated scenic highways, are
9 miles northwest and 30 miles west of the Project site, respectively. Caltrans classifies the I-210 as an Eligible
State Scenic Highway, but not officially designated, where it traverses the City (Caltrans 2019), and portions of the
highway are visible to the north and northeast from the upper floors of the existing 8-story office building. Likewise,
the existing office building located on the Project site is visible from portions of the highway. However, because the
I-210 has not been officially designated, this review is not obligated to consider any impacts to scenic resources
within its viewshed, significant or otherwise. The proposed Project is within a TPA and, as such, the proposed
Projects impacts on aesthetics would not be considered significant impacts pursuant to PRC Section 21099(d).
The Project would have no impact on any scenic resources within a state scenic highway. No mitigation is required.
Regulations Governing Scenic Quality
California Public Resources Code Section 21071 defines an urbanized area as (a) an incorporated city that
meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of
less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities
combined equals at least 100,000 persons. As further discussed in Section 4.11, Population and Housing, there
were an estimated 56,681 residents in the City in 2020 (U.S. Census Bureau 2021). The Southern California
Association of Governments (SCAG) forecasts 62,200 residents in the City by 2045 (SCAG 2020a). However, the
City is adjacent to the City of Pasadena to the west. The combined population of the City of Arcadia and Pasadena
is well over 100,000 persons.1 Therefore, the following analysis considers whether the proposed Project would
conflict with applicable zoning or other regulations governing scenic quality.
The City has adopted an update to the Design Guidelines for various development types, which was finalized in
October 2019. The Commercial and 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 Project site is located within the H Special Height Overlay Zone, specifically within the Zone H8 height district,
which allows for a maximum development height of 96 feet. The seven-story structure would be constructed to 80
feet in height. As previously noted, the existing eight-story office building located on the west end of the Project site
would remain intact. At a maximum height of seven stories, the proposed Project building would not exceed the
height of the existing adjacent office building and is therefore consistent with existing structures in regard to building
height. As noted above, the Project is also subject to Massing and Scale guidance included in the 2019 Commercial
and Mixed-Use Design Guidelines document.
The Project includes a Paseo corridor area that would include new paving, lighting, trees, and plantings in order to
provide an enhanced pedestrian experience that would link the existing buildings together with the new proposed
Project building. The second Corridor Alleyway is an existing alley for vehicular travel, but the Project would provide
1 The U.S. Census Bureau estimated that the residential population of Pasadena in 2019 was 141,029, resulting in a combined
population of 198,968 (using 2019 population estimates) (U.S. Census 2021).
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for pedestrian connectivity through the alley as well as signage for wayfinding and screen plantings or other artistic
vertical screens at the parking garage. The third area includes street trees and new parkway plantings, as well as
seating along Wheeler Avenue and Santa Clara Street. Lastly, the fourth, fifth, and sixth areas include the
recreational amenities for the residents.
The Project proposes landscaping throughout the exterior ground level, the Level 3 north and south courtyards
(further illustrated in Figure 3-3c, Level-3 and Levels-4/5/6), as well as the Level 7 roof deck. The landscape plan
would include the planting of approximately 56 new ornamental trees with low to medium water requirements
(including cork oak, yew pine, California sycamore, and Australian willow), approximately 7,848 square feet (sf) of
shrubs and ground cover with low to medium water requirements (including various species of manzanita, Turkish
sage, yellow yucca, and autumn moor grass), and the installation of approximately 2,015 sf of artificial turf.
The proposed Project would be consistent with the Citys General Plan policies, Development Code, and Municipal Code
Sections that pertain to the preservation of the aesthetic character of the City. The proposed Project would be in visual
agreement with the land uses of the surrounding area and consistent with the Citys land use and zoning designations.
Furthermore, when compared to existing conditions, the proposed Project design would add architectural and landscape
features that would improve the visual quality of the Project site and the surrounding Project area. The proposed Projects
exterior aesthetic qualities include an updated mid-century modern look with clean lines, the integration of neutral colors
and building materials, and a cohesive design scheme throughout the Project site. Finally, the proposed Project is within
a TPA and, as such, the proposed Projects impacts on aesthetics would not be considered significant impacts 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.
Lighting and Glare
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 area and is surrounded by existing mixed use and/or commercial development. Existing sources of
daytime and nighttime light include streetlights, business identification signs and lit windows from commercial and
mixed-use residential developments. Given the urban nature of the site vicinity and existing sources of interior and
exterior lighting and glare, any incremental increases from the proposed Project would be less than significant. Any
lighting that would be implemented as part of the proposed Project would adhere to the Citys Development Code,
Section 9103.01.120, which establishes the standards for exterior lighting in the City. In summary, the standards
require: lighting be shielded or recessed so that glare is contained within the property boundaries; lighting be
directed downward away from adjoining properties; 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 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. Additionally, the proposed Project is within a TPA and, therefore,
the proposed Projects impacts on aesthetics would not be considered significant impacts pursuant to PRC
Section 21099(d). As such, and in 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. For these reasons, the proposed Project would not result in significant impacts
related to adverse effects on day or nighttime views, and impacts would be less than significant.
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Cumulative Effects
Scenic Vistas/Scenic Quality
Despite being heavily built out, there are a number of scenic resources in the broader San Gabriel Valley as well as
in the City itself, including mountains, foothills, ridgelines, parks, open spaces, and sports venues such as the local
public golf courses and the historic Santa Anita Racetrack. The City General Plan cites unobstructed views of the
Racetrack and the San Gabriel Mountains as important contributors to its aesthetic character (City of Arcadia
2010). However, due to the existing urban, developed character of the City, the proposed Project site, and
surrounding Project site area, as well as the specific design protocols (Commercial and Mixed-Use Design
Guidelines, 2019) applicable to the proposed Project, the Project would not have a substantial adverse effect on
existing scenic views of the San Gabriel Mountains. The proposed Project site cannot be viewed from the Santa
Anita Park Racetrack, nor can the racetrack be viewed from the Project site, and modest views of and from the
northeast corner Arcadia County Park would not be further degraded due to existing obstructions form mature trees
and other urban, commercial, and mixed-use development.
Due to the built-out nature of the City, cumulative projects within the surrounding Project area would be considered
infill development. As these projects are implemented, a more dense and urban character would occur within the
Downtown Core and broader Downtown area. Land use intensification at these sites would not substantially
degrade the scenic quality of the viewshed. Further, these projects would be required to comply with the
development standards of the City Arcadia Development Code that include setbacks and height limits and may
similarly be subject to the Citys Site Plan and Design Review.
The proposed Project would be consistent with applicable City goals and policies concerning scenic quality, and
similar to the Project, future projects in the cumulative study area would be required to demonstrate compliance
with applicable scenic quality regulations. If non-compliance with a particular regulation would result in a significant
impact, mitigation would be required to reduce impacts to the extent feasible. Therefore, impacts would be less
than significant, and the Project would not result in a cumulatively considerable impact related to scenic vistas or
conflicts with scenic quality regulations. No mitigation is required.
Light or Glare
The existing urbanized Project setting supports numerous nighttime lighting sources and contains buildings and
facilities constructed of potentially reflective materials, including metal paneling and glass. The Project would have
the potential to result in an incremental increase in light associated with the new development. However, the
surrounding area is largely developed in nature and located in an urban environment. Thus, it currently includes
sources of interior and exterior lighting and glare, and any incremental increases from the proposed Project would
be less than significant. In addition, any lighting that would be implemented as part of the proposed Project and
cumulative projects would adhere to the Citys Development Code, Section 9103.01.120, In summary, due to the
existing urban conditions, and the less than significant impacts of the proposed Project, it would not result in a
cumulatively considerable impact related to light and glare. No mitigation is required.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on aesthetics as it relates to scenic vistas, scenic resource damage within a state scenic highway,
regulations governing scenic quality, lighting and glare, and cumulative aesthetic impacts; therefore, no mitigation
is required and no significant, unavoidable adverse impacts would occur.
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2.4.2 Agriculture and Forestry Resources
The Project site is located in an urban area on a site that is fully developed with buildings and asphalt paving and
is designated Downtown Mixed Use (DMU) in the Citys General Plan and is also zoned DMU. There are no existing
agriculture or forestry activities on the site. No readily available opportunities for agricultural or forestry operations
exist on site or in the surrounding area. According to the California Department of Conservations California
Important Farmland Finder, most of Los Angeles County, including the City of Arcadia, is not mapped as part of the
states Farmland Mapping and Monitoring Program; thus, the Project site does not contain Prime Farmland, Unique
Farmland, or Farmland of State Importance (collectively Important Farmland) (DOC 2020), nor does it contain any
parcels under a Williamson Act contract (DOC 2018). Additionally, the Project site nor the surrounding area contain
forestland or timberland. Therefore, impacts associated with agricultural and forestry resources would not occur.
Finding
Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to agriculture and
forestry resources; therefore, agriculture and forestry resources was not addressed in the Draft EIR. No mitigation
would be required and no significant, unavoidable adverse impacts would occur.
2.4.3 Air Quality
Conflict with or obstruct implementation of the applicable air quality plan
The Project site is located within the South Coast Air Basin (SCAB) under the jurisdiction of the Southern California
Air Quality Management District (SCAQMD), which is the local agency responsible for administration and
enforcement of air quality regulations for the area. The SCAQMD administers the Air Quality Management Plan
(AQMP) for the SCAB, which is a comprehensive document outlining an air pollution control program for attaining
all state and federal air quality standards. The most recent adopted AQMP is the 2016 AQMP (SCAQMD 2017),
which the SCAQMD Governing Board adopted in March 2017 (SCAQMD 2017).
The purpose of a consistency finding is to determine if a project is inconsistent with the assumptions and objectives
of the regional air quality plans, and, thus, if it would interfere with the regions 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, in the SCAQMD CEQA Air Quality Handbook. The criteria
are as follows (SCAQMD 1993):
Consistency Criterion No. 1: The project will not result in an increase in the frequency or severity of existing
air quality violations or cause or contribute to new violations, or delay the timely attainment of air quality
standards of the interim emissions reductions specified in the AQMP.
Consistency Criterion No. 2: The project will not exceed the assumptions in the AQMP or increments based
on the year of project buildout and phase.
Consistency Criterion No. 1
As discussed below, the proposed Project would not result in construction or operational criteria air pollutant
emissions that would exceed the SCAQMD mass daily thresholds. Because it would not exceed the SCAQMD criteria
air pollutant mass thresholds, the Project would not result in an increase in the frequency or severity of existing air
quality violations or cause or contribute to new violations, and thus, the proposed Project would not conflict with
Consistency Criterion No. 1 of the SCAQMD CEQA Air Quality Handbook (SCAQMD 1993).
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Consistency Criterion No. 2
The second criterion regarding the proposed Projects potential to exceed the assumptions in the AQMP is primarily
assessed by determining consistency between the proposed Projects land use designations and potential to
generate population growth. In general, a project would be consistent with, and would not conflict with or obstruct
implementation of, the AQMP if the growth in socioeconomic factors is consistent with the underlying regional plans
used to develop the AQMP (per Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook). The
SCAQMD primarily uses demographic growth forecasts for various socioeconomic categories (e.g., population,
housing, employment by industry) developed by the Southern California Association of Governments (SCAG) for its
RTP/SCS (SCAG 2016). SCAG bases its growth forecasts on general plans for cities and counties in the SCAB. The
SCAQMD uses these growth forecasts for the development of the AQMP emissions inventory (SCAQMD 2017). The
SCAG 2016 RTP/SCS, and associated Regional Growth Forecast, are generally consistent with the local plans;
therefore, the 2016 AQMP is generally consistent with local government plans. Note that although the Connect
SoCal (20202045 RTP/SCS) is the most recent RTP/SCS, the SCAQMD is still in the early stages of updating its
AQMP (anticipated to be released in 2022). Therefore, the SCAG 2016 RTP/SCS and associated Regional Growth
Forecast would be applicable in this analysis of the potential to conflict with the SCAQMD 2016 AQMP.
The Citys General Plan identifies the site as Downtown Mixed Use. According to the Citys General Plan, the
Downtown Mixed-Use designation permits service and retail uses, commercial businesses, professional offices, and
residential uses within the Citys downtown. Therefore, the proposed Project is consistent with the General Plan
land use designation for the Project site. The proposed Project would be consistent with downtown land uses and
would be in compliance with the Land Use Element goals an d policies of the Citys General Plan. The zoning for the
Project site is also Downtown Mixed Use, which permits the same use types as the Downtown Mixed Use land use
designation. As such, the proposed Project would be consistent with the current zoning and land use designation.
Accordingly, the project would meet Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook.
Therefore, implementation of the project would not result in a conflict with, or obstruct implementation of, the
applicable air quality plan (i.e., the 2016 AQMP).
The proposed Project would not result in an increase in the frequency or severity of existing air quality violations,
cause or contribute to new violations, or conflict with Consistency Criterion No. 1. In addition, implementation of
the project would not exceed the demographic growth forecasts in the SCAG 2016 RTP/SCS; therefore, the project
would also be consistent with the SCAQMD 2016 AQMP, which based future emission estimates on the SCAG
2016 RTP/SCS. Thus, the project would not conflict with Consistency Criterion No. 2. The project would not exceed
the SCAQMD significance thresholds during construction or operations; therefore, impacts related to the projects
potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant.
Cumulatively Considerable Net Increase of Criteria Pollutants
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, and VOC off-gassing) and
off-site sources (e.g., on-road haul trucks, vendor trucks, and worker vehicle trips). 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.
Criteria air pollutant emissions associated with temporary construction activity were quantified using CalEEMod.
Construction emissions were calculated for the estimated worst-case day over the construction period associated
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with each phase and reported as the maximum daily emissions estimated during the construction period spanning
2023 through 2025. Construction schedule assumptions, including phase type, duration, and sequencing, were
based on information provided by the applicant and CalEEMod default values, and is intended to represent a
reasonable scenario based on the best information available.
Implementation of the proposed Project would generate air pollutant emissions from entrained dust, off-road
equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Entrained dust results
from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10
and PM2.5 emissions. The proposed Project would be required to comply with SCAQMD Rule 403 to control dust
emissions generated during the grading activities. Standard construction practices that would be employed to
reduce fugitive dust emissions include watering of the active sites two times per day depending on weather
conditions. Internal combustion engines used by construction equipment, vendor trucks (i.e., delivery trucks), and
worker vehicles would result in emissions of VOCs, NO x, CO, PM10, and PM2.5. The application of architectural
coatings, such as exterior application/interior paint and other finishes, and application of asphalt pavement would
also produce VOC emissions.
In compliance with SCAQMD rules, daily construction emissions would not exceed the SCAQMD significance
thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5 during construction in all construction years. Construction-
generated emissions would be temporary and would not represent a long-term source of criteria air pollutant
emissions. As such, impacts would be less than significant.
Operational Emissions
Operation of the proposed Project would generate VOC, NO x, CO, SOx, PM10, and PM2.5 emissions from mobile
sources, including vehicle trips; area sources, including the use of consumer products, natural gas hearths, and
landscape maintenance equipment; and energy sources. As discussed in Section 4.2.4, pollutant emissions
associated with long-term operations were quantified using CalEEMod. Project-generated mobile source emissions
were estimated in CalEEMod based on Project-specific trip rates. CalEEMod default values generated from Project-
specific land use quantities were used to estimate emissions from area and energy sources for the proposed Project
and the existing operational land uses that will cease operation and for which the facilities will be demolished as
part of the proposed Project.
The Projects net combined daily area, energy, mobile, vehicle testing, and off-road emissions would not exceed the
SCAQMD operational thresholds for VOC, NOx, CO, SOx, PM10, and PM2.5. Impacts associated with Project-generated
operational criteria air pollutant emissions would be less than significant.
Air pollutant emissions associated with construction activity of future projects would be reduced through
implementation of control measures required by the SCAQMD. Cumulative PM 10 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 construction sites in the SCAQMD. The maximum daily PM 10 and PM2.5
emissions would not exceed the significance thresholds during proposed Project construction activities. Fugitive
dust, as well as vehicle and equipment exhaust, generated during Project construction would contribute to the
SCABs nonattainment designation for PM 10 and PM2.5; however, this contribution would not be considered
cumulatively considerable.
With regard to operational cumulative impacts associated with nonattainment pollutants, in general, if a project is
consistent with the community and/or general plans, it has been accounted for in the attainment demonstration
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contained within the state implementation plan and would therefore not cause a cumulatively significant impact on
the ambient air quality. As addressed above, the proposed Project would be consistent with the growth projections
anticipated in SCAQMDs 2016 AQMP. Accordingly, the proposed Project would not result in a cumulatively
considerable contribution to the nonattainment pollutants in the SCAB.
Based on the preceding considerations, 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.
Expose Sensitive Receptors to Substantial Pollutant Concentrations
Localized Significance Threshold
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).
The closest off-site sensitive receptors to the proposed Project are single-family residences approximately 900 feet
to the west and 650 to the south, as well as schools including: Excelsior School (41 West Santa Clara Street, Arcadia,
CA 91007) approximately 630 feet to the west and Arroyo Pacific Academy (325 North Santa Anita Avenue, Arcadia,
CA 91006) located approximately 655 feet to the north.
Construction activities associated with the proposed Project would result in temporary sources of on-site fugitive
dust and construction equipment emissions. To account for onsite operation of vendor trucks, haul trucks, and
worker vehicle trips a distance of 1,000 feet of on-site vehicle operation was included in the localized significance
threshold (LST) analysis. Based on the LST construction activities would not generate emissions in excess of site-
specific LSTs; therefore, site-specific impacts during construction and operation of the proposed Project would be
less than significant.
Carbon Monoxide Hotspots
CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected
daily traffic would be at least over 100,000 vehicles per day. Because the Project would generate a net increase in
909 residents, it is not anticipated to increase daily traffic volumes at any study intersection to more than 100,000
vehicles per day. The proposed Project would be considered growth-accommodating rather than growth-inducing in
that the proposed Projects 319 new residential units would accommodate 909 residents, which are anticipated to
be a mix of current and future residents to the City. If all 909 residents would be new to the City, the Project would
be within the overall population growth projections included in SCAGs Connect SoCal. In addition, the entire Project
would be screened from a project-level vehicle miles traveled (VMT) analysis because the Project is in a Low VMT
generating area within a TPA. Therefore, a VMT analysis is not required and impacts to VMT can be presumed to be
less than significant. For these reasons, a CO hotspot is not anticipated to occur and associated impacts would be
less than significant. 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
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Health Impacts of Other Criteria Air Pollutants
Construction and operation of the proposed Project would result in emissions that would not exceed the SCAQMD
thresholds for any criteria air pollutants, including NOx, CO, SOx, PM10, or PM2.5. Project-generated VOC emissions
during short-term construction would result in the exceedances of the SCAQMD threshold but compliance with
SCAQMD Rule 1113 would restrict the VOC content of coatings for construction applications.
VOCs and NOx are precursors to O3, for which SCAB is designated as nonattainment with respect to the NAAQS and
CAAQS. The health effects associated with O3 are generally associated with reduced lung function. The contribution
of VOCs and NOx to regional ambient O3 concentrations is the result of complex photochemistry. The increases in
O3 concentrations in SCAB due to O3 precursor emissions tend to be found downwind from the source location to
allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O3
concentrations would also depend on the time of year that the VOC emissions would occur because exceedances
of the O3 ambient air quality standards tend to occur April through October when solar radiation is highest. The
holistic effect of a single projects emissions of O3 precursors is speculative due to the lack of quantitative methods
to assess this impact. Nonetheless, the VOC and NO x emissions associated with Project construction and operation
could minimally contribute to regional O3 concentrations and the associated health impacts. Because of the minimal
contribution during construction and operation, health impacts would be considered less than significant.
Construction and operation of the proposed Project would also not exceed thresholds for PM 10 or PM2.5 and would
not contribute to exceedances of the NAAQS and CAAQS for particulate matter or would obstruct SCAB from coming
into attainment for these pollutants. The proposed Project would also not result in substantial DPM emissions
during construction and operation, and therefore would not result in significant health effects related to DPM
exposure. Additionally, the proposed Project would be required to comply with SCAQMD Rule 403, which limits the
amount of fugitive dust generated during construction. Due to the minimal contribution of particulate matter during
construction and operation, health impacts would be considered less than significant.
Construction and operation of the proposed Project would not contribute to exceedances of the NAAQS and CAAQS
for NO2. Health impacts that result from NO2 and NOx include respiratory irritation, which could be experienced by
nearby receptors during the periods of heaviest use of off-road construction equipment. However, Project
construction would be relatively short term, and off-road construction equipment would be operating at various
portions of the site and would not be concentrated in one portion of the site at any one time. In addition, existing
NO2 concentrations in the area are well below the NAAQS and CAAQS standards. Construction and operation of the
proposed Project would not create substantial, localized NO x impacts. Therefore, potential health impacts
associated with NO2 and NOx would be less than significant.
CO tends to be a localized impact associated with congested intersections. The associated potential for CO hotspots
was discussed previously and is determined to be a less than significant impact. Thus, the proposed Projects CO
emissions would not contribute to significant health effects associated with this pollutant.
In summary, construction and operation of the proposed Project would not result in exceedances of the SCAQMD
significance thresholds for criteria pollutants and potential health impacts associated with criteria air pollutants
would be less than significant.
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Health Impacts of Toxic Air Contaminants
Project construction activities would result in a Residential Maximum Individual Cancer Risk of 9.52 in 1
million, which is less than the significance threshold of 10 in 1 million. Project construction would result in a
Residential Chronic Hazard Index of 0.005, which is below the 1.0 significance threshold. Impacts would be
less than significant.
Other Emissions
Construction Impacts
Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the
proposed Project. Potential odors produced during construction would be attributable to concentrations of
unburned hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt pavement
application. Such odors would disperse rapidly from the Project site and generally occur at magnitudes that would
not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be
less than significant.
Operational Impacts
Land uses and industrial operations that typically are associated with odor complaints include agricultural uses,
wastewater treatment plants, food-processing plants, chemical plants, composting, refineries, landfills, dairies, and
fiberglass molding facilities (SCAQMD 1993). The proposed Project does not propose the aforementioned odor-
generating land uses during the operational phase of the proposed Project. Furthermore, the proposed Project would
comply with SCAQMD Rule 402, Nuisance, which prohibits the release of odors which may cause annoyance to a
considerable number of persons, as well as other SCAQMD rules related to odor generation from restaurant activities.
Therefore, the potential for the proposed Project to generate an odor impact is considered less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on air quality as it relates to criteria pollutants, sensitive receptors, and other emissions; therefore, no
mitigation is required and no significant, unavoidable adverse impacts would occur.
2.3.4 Biological Resources
Under the existing conditions, the Project site is almost entirely developed with paved surfaces and buildings. A
limited amount of landscaped areas is located within the Project site and along the public rights-of-way, consisting
of small areas of ornamental trees, shrubs, and turf. This vegetation is ornamental in nature, entirely surrounded
by urban development, and does not form a cohesive plant community that would provide quality suitable habitat
for candidate, sensitive or special status wildlife species, or would support wildlife movement. No wetlands or other
jurisdiction waters are within the Project site (USFWS 2020). Further, all development activities would be required
to comply with all applicable requirements set forth by the City, including the Citys street tree regulations. All
development activities are subject to the requirement to protect nesting birds, in compliance with the Migratory
Bird Treaty Act, which prohibits the accidental or incidental taking or killing of migratory birds (USC 2021).
Therefore, impacts associated with biological resources would not occur.
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Finding
Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to biological
resources; therefore, biological resources were not addressed in the Draft EIR. No mitigation would be required,
and no significant, unavoidable adverse impacts would occur.
2.4.5 Cultural Resources
Historical Resources
Three properties within the proposed Project site are developed with built environment resources over 45 years old
and were identified as requiring recordation and evaluation for historical significance: 150 N Santa Anita Avenue
(APN 5773-006-036), 31-33 Wheeler Avenue (APN 5773-006-005), and 25 Wheeler Avenue (APN 5773-006-004).
One property immediately adjacent to the Project site, 100 N Santa Anita Avenue (APN 5773-006-029), was
identified as a built environment resource that is over 45 years old. This property was identified as requiring
recordation and evaluation for historical significance.
NRHP/CRHR Statement of Significance
Criterion A/1: That are associated with events that have made a significant contribution to the broad patterns of
our history.
Archival research indicated that the buildings under evaluation within or immediately adjacent to the Project site
were constructed between 1959 and 1972, however, none of these buildings are associated with historical events
that have made a significant contribution to the broad patterns of our history. The 150 North Santa Anita Avenue
property seems to have been the culmination of years-long planning efforts to redevelop the portion of Santa Anita
Avenue north of Huntington Drives downtown commercial corridor into Towne Center. Despite the long planning
period, 150 N Santa Anita Avenue does not appear to have shaped the broader patterns of development of the City
of Arcadia or had any effect on the development of the downtown commercial corridor, which was full developed by
the 1950s. The 25 and 31-33 Wheeler Avenue properties appear related to the general trend of post-World War II
commercial growth in Arcadia. While specific associations must be considered, research did not reveal any reason
to believe the Wheeler Avenue properties specific associations with commercial growth were significant. In
addition, while the 100 North Santa Anita Avenue propertyadjacent to the Project site was designed in a Tudor
Revival style, association with a trend or style is not sufficient for historic significance. Therefore, the properties
within and/or adjacent to the Project site do not appear eligible under NRHP Criterion A, CRHR Criterion 1, or City
of Arcadia Historic Landmark Criterion 1.
Criterion B/2: That are associated with the lives of persons significant in our past.
To be found eligible under Criterion B/2, one or more of the properties must be directly tied to an important person
and the place where that individual conducted or produced the work for which he or she is known. Archival research
indicates that the 31-33 Wheeler Avenue was first owned by Thomas Cosentino, and subsequently by numerous
owners and occupants for short periods. Archival research did not provide any evidence that Cosentino, subsequent
occupants, or any person(s) associated any of the evaluated properties, were known to be historically important
figures at the national, state, or local level. Due to a lack of identified significant associations with important persons
in history, the properties under evaluation on and adjacent to the Project site do not appear eligible under NRHP
Criterion B, CRHR Criterion 2, or City of Arcadia Historic Landmark Criterion 2.
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Criterion C/3: That embody the distinctive characteristics of a type, per iod, or method of construction, or that
represent the work of a master, or that possess high artistic values, or that represent a significant and
distinguishable entity whose components may lack individual distinction.
Considered as individual parts and as a whole, the evaluated properties on and adjacent to the Project site do
not appear to be excellent examples of any of the styles represented, including Corporate Modern, Mid-Century
Modern, and/or Tudor Revival, nor do these properties appear to be unique examples of a style or property type,
period, or method of construction within Arcadia or to the surrounding communities. No information about the
named architects of 150 North Santa Anita Avenue, Fleming & Fryer of Newport Beach or William J. Fleming, was
revealed to indicate the buildings are the work of master architects. Similar conclusions were reached about
architects Jack Hale (3133 Wheeler Avenue) and Willis K. Hutchison & Associates (100 North Satna Anita
Avenue). No information about the architects or builders of 25 Wheeler Avenue were available from historical
permits, newspapers or other methods of archival research. The buildings also do not possess high artistic value.
In consideration of the final component of Criterion C/3, the properties do not appear to contribute to a potential
historic district. There is no visual cohesion or shared development history due to varying construction dates,
more recent development, or nearby development of a different character. Therefore, the properties under
evaluation on and adjacent to the Project site do not appear eligible under NRHP Criterion C, CRHR Criterion 3,
or City of Arcadia Historic Landmark Criterion 3.
Criterion D/4: That have yielded, or may be likely to yield, information important in prehistory or history.
The properties under evaluation on and adjacent to the Project site are not significant under Criterion D of the NRHP
or Criterion 4 of the CRHR as a source, or likely source, of important historical information nor do they appear likely
to yield important information about historic construction methods, materials, or technologies.
Integrity Discussion
To be eligible for listing in the National Register, properties must retain their physical integrity from the period in
which they gained significance. In the case of architecturally significant properties, the period of significance is
normally the date of construction. For historically significant properties, the length of the historic associations
usually measures the period of significance. As none of the evaluated properties are significant under any National
Register criterion, they do not have a period of significance and the integrity of the buildings does not require
examination. It is worth noting, however, that the properties do retain certain aspects of integrity, including location,
design and feeling. The buildings have never moved from their original locations and have had very few alterations,
notable changes or modifications to their original overall form, plan, space, structure, and style. They also appear
to have retained much of their original materials, and for several buildings, the workmanship of the original builders
is visible. To a certain extent, the buildings are still able to convey a sense of the time periods in which they were
built. However, the buildings lack important historical associations and have experienced substantial changes to
their setting over time as the area along Santa Anita Avenue underwent a modest infill and revitalization in the late
1990s through the 2000s, leading to the demolition of several surrounding commercial and industrial properties
and replacing them with modern commercial retail stores or parking structures. In summary, the properties do not
retain the requisite integrity for designation, and do not rise to the level of significance required for designation at
the national, state, or local levels.
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Summary of Findings
No cultural resources were identified within or adjacent to the Project site as a result of the CHRIS records search,
NAHC SLF search, extensive archival research, field survey, and property significance evaluation. Neither the 150
N Santa Anita Avenue (APN 5773-006-036), 31-33 Wheeler Avenue (APN 5773-006-005), or 25 Wheeler Avenue
(APN 5773-006-004) Project site properties, nor the adjacent 100 North Santa Anita Avenue (APN 5773-006-029)
property appear eligible for NRHP, CRHR, or City designation due to a lack of significant historical associations,
architectural merit, and physical integrity. Therefore, the properties are not considered historical resources for the
purposes of CEQA. Further, no potential indirect impacts to historical resources were identified. The Project would
not cause a substantial adverse change in the significance of a historical resource, or otherwise result in a direct
impact to a historical resource. No other adjacent resources were identified as a result of the records search or
survey that could be indirectly impacted by the proposed Project. Therefore, the Project would have a less-than-
significant impact on historical resources. No mitigation is required.
Disturbance of Human Remains
No prehistoric or historic burials were identified within the Project site as a result of the CHRIS records search.
However, in the unexpected event that human remains are found, those remains would require proper treatment,
in accordance with applicable laws. Procedures of conduct following the discovery of human remains on non-federal
lands are mandated by California Health and Safety Code §7050.5, PRC §5097.98 and the California Code of
Regulations (CCR) §15064.5(e). According to the provisions in CEQA, should human remains be encountered, all
work in the immediate vicinity of the burial must cease, and any necessary steps to ensure the integrity of the
immediate area must be taken. The Los Angeles County Coroner must then be immediately notified. The Coroner
determines whether the remains are Native American. If the Coroner determines the remains are Native American,
the Coroner has 24 hours to notify the NAHC, who will, in turn, notify the person they identify as the most likely
descendent (MLD) of any human remains. Further actions are determined, in part, by the desires of the MLD. The
MLD has 48 hours to make recommendations regarding the disposition of the remains following notification from
the NAHC of the discovery. If the MLD does not make recommendations within 48 hours, the owner shall, with
appropriate dignity, reinter the remains in an area of the property secure from further disturbance. Alternatively, if
the owner does not accept the MLDs recommendations, the owner or the descendent may request mediation by
the NAHC. Compliance with these existing regulations would ensure that impacts to human remains resulting from
the proposed Project would be less than significant. No mitigation is required.
Cumulative Effects
The CHRIS records search was completed by staff at the SCCIC on May 4, 2021. The records search identified seventeen
(17) previously conducted cultural resources technical investigations within the records search area. Four of these
previous investigations overlap the entirety of the proposed Project site and no cultural resources were identified within
the proposed Project site as a result of the overlapping studies. Additionally, the SCCIC records indicate that sixty-three
(63) previously recorded cultural resources were identified within the proposed Projects 0.5-mile buffer. These resources
include one historic-era archaeological site and sixty-two (62) historic built environment resources. None of these
resources are within or adjacent to the proposed Project site. As there are no known historical or archaeological
resources on the Project site, the Project site is not part of an existing or known grouping or district of historical or
archaeological resources that would be impacted as part of the cumulative impacts of other projects.
The proposed Project was determined to have less-than-significant direct impacts on human remains. Existing
regulations are adequate to address the potential for impacts due to the inadvertent discovery of human remains
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on the Project site. Other individual projects occurring in the vicinity of the Project site would also be subject to the
same state requirements to contact appropriate agencies and coordinate with the County Coroner. Therefore, the
proposed Project would not result in any cumulatively considerable impacts related to human remains.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on cultural resources as it relates to historical resources and disturbance of human remains, therefore, no
mitigation is required and no significant, unavoidable adverse impacts would occur.
2.3.6 Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy
Electricity
Construction
Temporary electric power for lighting, heating/cooling, and electronic equipment, such as computers inside
temporary construction trailers, as well as lighting for construction activities, would be required during short-term
construction activities. The electricity demand at any given time would vary throughout the construction period
based on the construction activities being performed and would cease upon completion of construction. When not
in use, electric equipment would be powered off so as to avoid unnecessary energy consumption. All sources of
electricity would be from existing power lines that serve the site and no new infrastructure would be required. There
is nothing unusual about construction of the proposed Project that would result in a wasteful, inefficient, and
unnecessary use of electrical energy. The electricity used for construction activities would be temporary and would
have a negligible contribution to the proposed Projects overall energy consumption. Impacts to electricity during
construction would be less than significant, and no mitigation is required.
Operations
The operational phase would require electricity for multiple purposes including building heating and cooling,
lighting, appliances, electronics, and water and wastewater conveyance. As discussed in Section 4.2 under
Approach and Methodology (Operational Emissions), CalEEMod default values for electricity consumption for the
proposed Projects land uses were utilized which account for compliance with the 2019 Title 24 standards. The
project includes 100-kW on-site solar system included in the CalEEMod analysis.
Buildout of the proposed Project is estimated to have a total electrical demand of 3,225,503kWh per year (or 3.32 million
kWh per year) for proposed Project usage without netting out the existing land use electrical use. This estimate, therefore,
is a conservative estimate of additional operational electricity demand because it does not reduce electricity estimates
for buildings that will be demolished. The Countys annual electricity use was approximately 20 billion kWh in 2019.
Therefore, the proposed Projects electrical consumption would be a small percentage (0.016%) of the Countys current
annual use. Southern California Edison (SCE) forecasts that its total energy consumption in 2026 (the Project buildout
year) will be approximately 120,000 gigawatt hours of electricity (CEC 2018). Based on the Projects estimated electrical
consumption of 3,225,503 kWh/year, the Projects increase in electricity would account for approximately 0.0027% of
SCEs total projected consumption during 2026 for the Projects buildout year.2
2 Projects consumption (3.226 gigawatt hours) divided by SCEs projected consumption (120,000 gigawatt hours).
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In addition, the proposed Project would be built in accordance with the current Building Energy Efficiency Standards
(Title 24) at the time of construction, which include robust requirements for energy efficiency. Also, the provisions
of the CALGreen code apply to the planning, design, operation, construction, use and occupancy of every newly
constructed building or structure. In mixed occupancy buildings, such as the proposed Project, each portion of a
building must comply with the specific green building measures applicable to each specific occupancy. The
project would also include a 100-kW onsite solar system. Therefore, due to the inherent increase in efficiency of
building code regulations, the proposed Project would not result in a wasteful, inefficient, or unnecessary use of
energy. Impacts related to operational electricity use would be less than significant.
Natural Gas
Construction
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 petroleum subsection. Any
minor amounts of natural gas that may be consumed as a result of proposed Project construction would be
substantially less than that required for proposed Projects operation and would have a negligible contribution to
the proposed Projects overall energy consumption.
Operations
Natural gas consumption during proposed Project operation would be required for various purposes, including building
heating and cooling. Default natural gas generation rates in CalEEMod for the proposed Project were utilized which
account for compliance with the 2019 Title 24 standards. The proposed Project would consume approximately
4,614,782 kBTU per year without netting out the existing land use natural gas consumption. Therefore, the
consumption estimate is conservative because it does not account for buildings that would be demolished. As
previously discussed, the County annual natural gas consumption is estimated to be 3 billion therms per year.
Therefore, the proposed Projects estimated increase in natural gas consumption of 4,614,782 kBTU (or 46,148
therms) per year would be a small percentage (0.0015%) of SoCalGas annual supply to County customers. In
addition, the proposed Project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6,
of the California Code of Regulations. Title 24, Part 11, contains energy measures that are applicable to the
proposed Project. The proposed Project would be required to meet Title 24 requirements applicable at that time,
as required by state regulations through the plan review process. Therefore, due to the inherent increase in
efficiency of building code regulations, the proposed Project would not result in a wasteful, inefficient, or
unnecessary use of natural gas. Impacts related to operational natural gas use would be less than significant.
Petroleum
Construction
Petroleum would be consumed throughout construction of the proposed Project. Fuel consumed by construction
equipment would be the primary energy resource expended over the course of construction, and VMT associated
with the transportation of construction materials and construction worker commutes would also result in petroleum
consumption. Heavy-duty construction equipment associated with construction activities, vendor trucks, and haul
trucks would rely on diesel fuel. Construction workers would travel to and from the Project site throughout the
duration of construction. It was assumed that construction workers would travel in gasoline-powered vehicles.
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Heavy-duty construction equipment of various types would be used during construction. CalEEMod was used to
estimate construction equipment usage. Based on that analysis, diesel-fueled construction equipment would
operate for an estimated 32,759 hours. Fuel consumption from construction equipment was estimated by
converting the total CO2 emissions from each construction phase to gallons using conversion factors for CO 2 to
gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and
the conversion factor for diesel is 10.21 kilograms per metric ton CO 2 per gallon (The Climate Registry 2020).
The proposed Project is estimated to consume approximately 187,433 gallons of petroleum during the construction
phase. For disclosure, by comparison, approximately 60 billion gallons of petroleum would be consumed in
California over the course of the proposed Projects construction phase (26 months), based on the California daily
petroleum consumption estimate of approximately 75.6 million gallons per day (EIA 2021c). Thus, the total
expected petroleum use from the proposed Projects construction represents approximately 0.0003% of Californias
consumption of petroleum over the construction duration. In accordance CARBs Airborne Toxics Control Measure,
the proposed Project would be required to restrict heavy-duty diesel vehicle idling time to 5 minutes, which would
reduce petroleum usage. Overall, because petroleum use during construction would be temporary, and would not
be wasteful or inefficient, impacts would be less than significant.
Operations
Mobile sources from buildout of the proposed Project would result in approximately 210,119 gallons of petroleum
fuel usage per year. For disclosure, by comparison, California as a whole consumes approximately 27.6 billion
gallons of petroleum per year (EIA 2021c).
Over the lifetime of the proposed Project, the fuel efficiency of vehicles 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, CARB has adopted an approach to passenger vehicles that combines the control of smog-causing
pollutants and 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 2011). As
such, operation of the proposed Project is expected to use decreasing amounts of petroleum over time due to
advances in vehicle fuel economy standards.
In summary, the proposed Project would increase petroleum use during operation, but due to efficiency increases
the amount of petroleum consumed would diminish over time. Petroleum consumption associated with the
proposed Project would not be considered inefficient or wasteful and would result in a less than significant impact.
Conflict or Obstruct Plan for Renewable Energy
The proposed Project would comply with all applicable regulatory requirements including Title 24 of the California
Code of Regulations contains energy efficiency standards for residential and nonresidential buildings based on a
state mandate to reduce Californias energy demand. Specifically, Title 24 addresses a number of energy efficiency
measures that impact energy used for lighting, water heating, heating, and air conditioning, including the energy
impact of the building envelope such as windows, doors, wall/floor/ceiling assemblies, and roofs. Part 6 of Title 24
specifically establishes energy efficiency standards for residential and nonresidential buildings constructed in the
State of California in order to reduce energy demand and consumption. Part 11 of Title 24 also includes the
CALGreen standards, which established mandatory minimum environmental performance standards for new
construction projects. The proposed Project would comply with Title 24, Part 6 and Part 11, per state regulations.
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Additionally, the proposed Project would receive electricity from SCE, which has the mandate to comply with SB
100. This policy requires that eligible renewable energy resources and zero-carbon resources supply 100% of the
retail sales of electricity to California by 2045, and that the zero-carbon electricity resources do not increase the
carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource
shuffling. Thus, the proposed Project would not conflict with or obstruct a state or local plan for renewable energy
or energy efficiency; therefore, impacts during construction and operation of the proposed Project would be less
than significant.
Cumulative Effects
The proposed Project and additional forecasted growth in SCEs service area and SoCalGas service area would
cumulatively increase the demand for electricity and natural gas supplies and infrastructure capacity. Although the
proposed Project would result in the use of renewable and non-renewable resources during construction and
operation, which could limit future availability of non-renewable energy sources, the use of such resources would
be on a relatively small scale, would be reduced by measures making the Project more energy-efficient, and would
be consistent with growth expectations for the service areas. Furthermore, as with the Project, during construction
and operation, other future development projects would be expected to incorporate energy conservation features,
comply with applicable regulations including CALGreen and state energy standards under Title 24, and incorporate
mitigation measures, as necessary.
Furthermore, as described above, the proposed Project would be consistent with the energy efficiency policies
emphasized by the 2020 RTP/SCS. Since the Project is consistent with the Connect SoCal (2020 RTP/SCS), its
contribution to cumulative impacts related to wasteful, inefficient, and unnecessary use of transportation fuel would
not be cumulatively considerable and, thus, would be less than significant.
As such, the Projects contribution to cumulative impacts related to wasteful, inefficient and unnecessary use of
electricity would not be cumulatively considerable and, thus, would be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on energy as it relates to consumption of energy, conflict or obstruction of a plan for renewable energy, and
cumulative impacts to energy, therefore, no mitigation is required and no significant, unavoidable adverse impacts
would occur.
2.3.7 Geology and Soils
Expose People or Structures to Fault Rupture
The Project site is not located within an Alquist-Priolo Earthquake Fault Zone and no known faults traverse the
Project site (CGS 2021). According to the Geotechnical Investigation, the closest such zone is located along the
Raymond Fault, located approximately 0.6 miles to the northwest of the Project site (Figure 4.5-2). Therefore, the
Project site would not be subject to rupture of a known earthquake fault because no faults traverse the site.
Furthermore, the Project site would not directly or indirectly cause or exacerbate existing fault rupture risks from
the construction of new buildings and associated infrastructure on the Project site because no Project-related
activities would occur within the Raymond Fault zone. Therefore, no impact related to surface rupture of a known
earthquake fault would occur.
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Expose People or Structures to Strong Seismic Ground Shaking
The Project site is located in the seismically active region of Southern California. The Raymond Fault and the Sierra
Madre Fault have been mapped in the vicinity of the Project site. These faults, as well as numerous other regional
faults (e.g., Puente Hills Thrust Fault, Santa Monica Fault, Verdugo Fault, Whittier Fault, San Fernando, and San
Andreas Fault), are capable of producing moderate to large earthquakes that could cause substantial ground
shaking at the Project site. The severity of ground shaking would depend on the magnitude of the earthquake, the
distance to the Project site, duration of shaking and on-site geologic conditions. Ground shaking could lead to
substantive damage to structures and infrastructure, personal injury and death, utility service disruption, fire,
explosion, and hazardous material spills, if not engineered appropriately.
The soils underlying the Project site fall within the characteristics of Class D (i.e., Stiff Soil profile), as defined in
Chapter 20 of the American Society of Civil Engineers (ASCE) 7-10. This information was used to calculate the
anticipated ground motions on the Project site, using the U.S. Geological Survey U.S. Seismic Design Maps tool
(Appendix D-1). According to the Geotechnical Investigation, the site has the potential to experience ground
accelerations of 0.939g, which is substantive and capable of causing significant damage if not designed
appropriately. The Geotechnical Investigation prepared for the Project provides the seismic parameters to be used
in the structural design of the Project, based on the materials encountered subsurface exploration at the site and
provides for preliminary design measures that are consistent with CBC building code requirements. The CBC
provides procedures for earthquake-resistant structural design that includes considerations for on-site soil
conditions, occupancy, and the configuration of the structure, including the structural system and height. Although
substantial damage to structures may be unavoidable during large earthquakes, the proposed structures would be
designed to resist structural collapse and thereby provide reasonable protection from serious injury, catastrophic
property damage, and loss of life.
The 2019 edition of the CBC is based on the 2018 International Building Code, and all construction must be
conducted in compliance with the latest version of the CBC. Chapters 16 and 16A of the 2019 CBC include
structural design requirements governing seismically resistant construction, including factors and coefficients used
to establish seismic site class and seismic occupancy category for the soil/rock at the building location and the
proposed building design.
Project construction would be completed in accordance with the CBC. As with all development within the City,
development within the Project site would be required to comply with the seismic safety requirements of the CBC.
The CBC provides procedures for earthquake resistant structural design that includes considerations for onsite soil
conditions, occupancy, and the configuration of the structure, including the structural system and height. Standards
provided in CBC Section 1803 also require preparation of a geotechnical evaluation and that all recommendations
set forth in a final site-specific design-level geotechnical report which would be based on the preliminary
Geotechnical Investigation that was prepared for the Project be incorporated into all applicable phases of Project
excavation, grading and construction. Therefore, upon compliance with the CBC and City policies aimed at
minimizing geologic hazards, including CBC Section 1803, requiring the incorporation of recommendations set forth
in the final design-level site-specific geotechnical investigation, the Project site would not directly or indirectly cause
substantial adverse effects involving strong seismic ground shaking, and impacts would be less than significant.
Expose People or Structures to Liquefaction
According to the Geotechnical Investigation, the historical high groundwater levels for the general area have
been interpreted at 100150 feet below the ground surface in the vicinity of the Project site, and the potential
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for liquefaction to occur beneath the Project site is considered to be very low. The site is not located within a
mapped California Geologic Survey liquefaction hazard zone (Appendix D-1, CGS 2021). As such, seismic-
related ground failure due to liquefaction would not be expected to occur on the Project site and impacts would
be less than significant.
Expose People or Structures to Landslides
The Project site is not located within an earthquake-induced landslide zone. Because the Project site is not located
within an area identified by the California Geological Survey (CGS) as having potential for seismic slope instability,
geologic hazards associated with landsliding are not anticipated at the site (Appendix D-1). Additionally, the Project
would not exacerbate the potential for on- or off-site landslides. As such, implementation of the Project would not
directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving
landslides. Impacts would be less than significant.
Soil Erosion or Loss of Topsoil
Construction
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 currently fully developed and paved, with
negligible amounts of soil exposed in areas of ornamental landscaping.
Project construction would entail demolition and grading of portions of the Project site as well as excavations for
the subterranean parking structure, followed by construction of the foundation and proposed structures. The Project
site has the potential for collapsible soils and would require removal and recompaction of any previously disturbed
and/or artificial fill soils. As recommended in the Geotechnical Investigation, the fills underlying the Project site
would be removed and replaced with compacted fill (Appendix D-1). These construction activities could result in
temporary, short-term impacts related to a potential for erosion and loss of topsoil during the development of the
Project site.
As previously discussed, Chapter 8 of the AMC requires that all grading plans and permits must comply with the
provisions of the NPDES General Construction Permit and implement erosion control BMPs before grading begins
to prevent erosion and loss of topsoil from the site. 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 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). No grading permit would be issued unless the plans for such work include a SWPPP with
details of BMPs which include erosion control measures to minimize the transport of sediment and protect public
and private property from the effects of erosion. The required SWPPP would establish site-specific erosion and
sediment control BMPs for all construction activities. Typical examples of erosion-related construction BMPs include
the following:
Silt fences and/or fiber rolls installed along with the limits of work and/or the Project construction site
Stockpile containment and exposed soil stabilization structures (e.g., Visqueen plastic sheeting, fiber rolls,
gravel bags and/or hydroseed)
Runoff control devices (e.g., fiber rolls, gravel bag barriers/chevrons, etc.) used during construction phases
conducted during the rainy season
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Wind erosion (dust) controls
Tracking controls at the site entrance, including regular street sweeping and tire washes for equipment
Regular inspections and maintenance of BMPs
These BMPs would be refined and/or added to as necessary by a qualified SWPPP professional to meet the
performance standards in the Construction General Permit. Compliance with the Construction General Permit would
ensure that soil erosion would be minimized.
Although the Project would require excavation of soils related to construction of the subterranean parking
structure and related to removal and recompaction of collapsible soils, this would not result in a substantial loss
of topsoil. The Project site is currently developed and paved and does not contain native topsoil, with the
exception of minimal landscaped areas adjacent to surface parking lots and buildings. The Project site is not
used, and is not zoned for, agricultural uses or other activities that require the use of topsoil. Therefore, with
compliance of the NPDES General Construction Permit, potential impacts associated with soil erosion and/or
loss of topsoil would be less than significant.
Operations
Long-term operation of the Project would not result in substantial soil erosion or loss of topsoil as the majority of
the Project site would be covered by the structures and paving, while the remaining portions of the site would be
covered with irrigated landscaping. No exposed areas subject to erosion would be created or affected by the
Project. In addition, the majority of the area surrounding the Project site is completely developed and would not
be susceptible to indirect erosional processes (e.g., uncontrolled runoff) caused by the Project. With the
implementation of applicable construction BMPs that also include post-construction requirements, impacts
related to erosion or loss of topsoil would be less than significant.
Located on or Would Cause Unstable Soil
Landslides
As previously discussed, the Project site is relatively level and the topography in the site vicinity slopes slightly
downward toward the south (Appendix D-1). The State of California (CGS 2018) and the City of Arcadia (2010)
indicate that the site is not located within a zone of required investigation for earthquake-induced landslides. There
are no known landslides near the site, nor is the site in the path of any known or potential landslides. Therefore,
the potential for slope stability hazards to adversely impact the site is considered low. Because the Project site is
not located within an area identified by the CGS as having potential for seismic slope instability, geologic hazards
associated with landsliding are not anticipated at the site (Appendix D-1). No impacts would occur.
Liquefaction/Lateral Spreading
According to the State of California (CGS 2017) and the City of Arcadia (2010) the site is not located in an area
potentially susceptible to liquefaction or lateral spreading. Potential impacts concerning liquefaction are evaluated
above. Lateral spreading is the finite, lateral movement of gently sloping, saturated soil deposits caused by
earthquake-induced liquefaction. Impacts associated with lateral spreading would be similar to those associated
with liquefaction and would therefore be less than significant.
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Subsidence
According to the Geotechnical Investigation, the existing artificial fill and any unsuitable, soft alluvial soils onsite are
considered suitable for reuse provided they are compacted to meet current building code requirements (Appendix D-1).
Volumetric changes in earth quantities would occur if excavated onsite soil materials were to be replaced with properly
compacted fill. In accordance with the CBC Section 1804A, the compacted fill shall comply with the provisions of an
approved final design level geotechnical report, which is also in accordance with CBC Section 1803, as discussed
above. The proposed Project would be required to meet the most recent building safety criteria and construction
design recommendations of the site-specific final design level geotechnical report that would be prepared for the
proposed Project. As such, impacts related to subsidence would be less than significant.
Collapsible Soils
As previously stated, the preliminary geotechnical investigation indicated that artificial fill soils in the upper 4 feet
exhibit collapsible potential upon wetting. If such materials are left in the current condition, excessive settlement
of structures and site improvements could result due to the weight of new foundations and the introduction of water
from rain or irrigation. Excessive settlement from such materials could be prevented through excavation and
recompacted, as recommended by the preliminary geotechnical investigation. Materials anticipated to exhibit this
condition consist of the artificial fill soils and any encountered soft alluvial soils. Soils below the collapsible soil
zone are anticipated to exhibit low compressibility characteristics in their current state (Appendix D-1).
The preliminary geotechnical investigation concluded that after appropriate site preparations (e.g., removal and
recompaction of artificial fills) total settlement of foundations would be less than about 1.25 inch and bearing
pressure is limited to about 4,000 pounds per square foot. Associated differential settlement should be less than
0.75 inches over 20 feet. Such settlement is anticipated to be tolerable for the proposed development.
A final design-level geotechnical investigation report is required in accordance with the CBC. As previously
discussed, the CBC, 2019 edition, including Appendix J, issuing grading requirements, is adopted by reference
pursuant to Section 8110 of the AMC (City of Arcadia 2021a). In accordance with Section 1803 of the CBC, a
geotechnical investigation is required to include soil testing, laboratory testing or engineering calculations to
evaluate soil types, soil expansion, depth of groundwater, deep foundations, rock strata, excavation, compacted fill,
soil strength, seismic design criteria and other soil characteristics that need to be considered in the structural
design and construction of buildings and infrastructure. Geotechnical investigations must be prepared by registered
professionals (i.e., California Registered Civil Engineer or Certified Engineering Geologist). Recommendations from
geotechnical investigations must be incorporated into the design and construction of the Project, as reviewed and
approved by the Citys Development Services Department. As such, impacts related to collapsible soils would be
less than significant.
In summary, upon Project compliance with the CBC and City policies aimed at minimizing geologic hazards, and the
recommendations set forth in the final design level geotechnical report, the proposed Project would not directly or
indirectly exacerbate existing conditions related to on-site or off-site landslide, lateral spreading, subsidence,
liquefaction or collapse, and impacts would be less than significant.
Located on Expansive Soil
Expansive soils are clay-rich soils that shrink when dry and swell when wet. This change in volume can exert
substantial pressure on foundations over time, resulting in structural distress and/or damage. According to the
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preliminary geotechnical investigation, the site is underlain by artificial fill and Holocene age alluvium comprised
of alluvial channel and outwash deposits consisting of varying amounts of silt, sand, and gravel (Appendix D-1).
As previously discussed, based on depth of the proposed subterranean levels, the near surface soils have a low
expansion potential. Given the low expansion potential anticipated at the site, only nominal steps will be needed to
mitigate adverse effects. Typical mitigation measures described in Chapter 18 of the CBC to alleviate expansive
soils include the following:
Excavation of expansive soils until such a depth that competent material is encountered
Installation of foundations designed to resist forces exerted on the foundation due by expansive soils
Stabilization of the soils by chemical, dewatering, pre-saturation, or equivalent techniques
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 CBC, Chapter 16, Section 1601 et seq. As such,
impacts would be less than significant.
Soils Incapable of Supporting Septic Tanks
The Project site is currently served by existing sewer infrastructure, and any new development would require connecting
to the existing system. There is adequate capacity in the sewer system for the Project. There are no septic tanks or
alternative wastewater disposal proposed; therefore, implementation of the Project would result in no impact.
Cumulative Effects
Potential cumulative impacts on geology and soils would result from Projects that combine to create geologic
hazards, including unstable geologic conditions, or contribute substantially to erosion. The majority of impacts from
geologic hazards, such as rupture of a fault line, liquefaction, landslides, expansive soils, and unstable soils, are
site-specific and are therefore generally mitigated on a project-by-project basis. Each cumulative Project would be
required to adhere to required building engineering design per the most recent version of the CBC in order to ensure
the safety of building occupants and avoid a cumulative geologic hazard. Additionally, as needed, Projects would
incorporate individual mitigation or geotechnical requirements for site-specific geologic hazards present on each
individual cumulative Project site, similar to that described above for the proposed Project.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on fault rupture, strong seismic ground shaking, liquefaction, landslides, erosion, unstable soil, expansive soil,
and septic tanks; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.
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2.3.8 Greenhouse Gas Emissions
Greenhouse Gas Emissions
Construction Emissions
On-site sources of GHG emissions include off-road equipment and off-site sources including haul trucks, vendor
trucks, and worker vehicles. The estimated total GHG emissions during construction of would be approximately
2,135 MT CO2e over the construction period, which is less than the GHG significance threshold of 3,000 MT CO2e
per year. Therefore, the proposed Project would not generate GHG emissions, either directly or indirectly, that may
have a significant impact on the environment, and this would represent a cumulatively less than significant impact.
Operational Emissions
The estimated operational GHG emissions from Project area sources, energy consumption, mobile sources, solid
waste, and water consumption and wastewater treatment associated with the proposed Project would be equal to
2,400 MT CO2e, below the SCAQMD GHG threshold of 3,000 MT CO2e per year. Even without taking into account
the removal of the existing land uses, the proposed Projects estimated emissions would be below the SCAQMD
GHG threshold of 3,000 MT CO 2e per year. Therefore, the proposed Project would not generate GHG emissions,
either directly or indirectly, that may have a significant impact on the environment, and this would represent a
cumulatively less than significant impact.
Conflict with an Applicable Plan, Policy, or Regulation
Consistency with the Connect SoCal (20202045 RTP/SCS)
SCAGs Connect SoCal is a regional growth-management strategy that targets per capita GHG reduction from
passenger vehicles and light-duty trucks in the Southern California region. The Connect SoCal incorporates local
land use projections and circulation networks in city and county general plans. Typically, a project would be
consistent with the RTP/SCS if the project does not exceed the underlying growth assumptions within the RTP/SCS.
The proposed Project would accommodate an expected 909 residents which would be counted within the overall
population growth projections included in the Connect SoCal of 5,519 residents between 2020 and 2045.
As stated in the Connect SoCal 20202045 RTP/SCS, there is no obligation by a jurisdiction to change its land use
policies, General Plan, or regulations to be consistent with the RTP/SCS, and lead agencies have the sole discretion
in determining a local projects consistency with the RTP/SCS (SCAG 2020a). Because there is no wholly reliable
population, housing, or employment data after 2010, as the U.S. Census is conducted every ten years, all data for
years prior to the 2020 Census should be viewed as projections or estimates. The proposed Project would
implement the guiding principles, goals and policies of SCAGs 20202045 RTP/SCS as they relate to livability,
economic prosperity, and sustainability through the development of walkable, mixed use communities along major
transportation corridors. The development of housing within 350 feet of transit (Metros L Line Arcadia Station),
thereby alleviating pressure on suburban and open space areas to develop, is fully supportive of SCAGs strategies.
Because the proposed Project would support SCAGs goals and strategies for growth in the region and because the
proposed Project would assist the development of new housing and improves the Citys job/housing balance,
impacts related to population growth assumed in Connect SoCal would be less than significant.
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Consistency with the CALGreen
The 2019 CALGreen requirements are comprehensive and applicable to the proposed Project. The provisions of
the CALGreen code apply to the planning, design, operation, construction, use and occupancy of every newly
constructed building or structure. In mixed occupancy buildings, such as the proposed Project, each portion of a
building must comply with the specific green building measures applicable to each specific occupancy (CEC 2019).
The proposed Project must comply with all relevant measures applicable to the types of structures to be built,
including live-work units and residential. Therefore, the proposed Project would be implemented consistent with the
requirements of CALGreen and impacts would be less than significant.
Consistency with CARBs Scoping Plan
The Scoping Plan provides a framework for actions to reduce Californias GHG emissions and requires CARB and
other state agencies to adopt regulations and other initiatives to reduce GHGs. The Scoping Plan recommends
strategies for implementation at the statewide level to meet the goals of AB 32 and establishes an overall
framework for the measures that will be adopted to reduce Californias GHG emissions. The proposed Project would
comply with all regulations adopted in furtherance of the Scoping Plan to the extent required by law and to the
extent that they are applicable to the proposed Project.
Consistency with EO S-3-05 and SB 32
EO S-3-05 establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990
levels by 2020, and to 80% below 1990 levels by 2050. SB 32 establishes for a statewide GHG emissions reduction
target whereby CARB, in adopting rules and regulations to achieve the maximum technologically feasible and cost-
effective GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40% below
1990 levels by December 31, 2030. CARB believes that the state is on a trajectory to meet the 2030 and 2050
GHG reduction targets set forth in AB 32, EO B-30-15, and EO S-3-05.
Consistency with General Plans Air Quality Element
The City Arcadias General Plan (City of Arcadia 2010) includes various policies related to reducing GHGs (both directly
and indirectly) because strategies that reduce criteria air pollutant emissions may also reduce GHG emissions. Total
proposed Project emissions, including operation and amortized construction, would be below the SCAQMD significant
threshold of 3,000 MT CO2e per year. Furthermore, based on the considerations previously outlined, the proposed
Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the
emissions of GHGs, and no mitigation is required. Therefore, this impact would be less than significant.
Cumulative Effect
GHG emissions inherently contribute to cumulative impacts. The proposed Project would not result in GHG
emissions in exceedance of the SCAQMD significance threshold. Therefore, cumulatively, Project GHG emissions
would be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on emissions generated, consistency with applicable regulations, and cumulative GHG effects; therefore, no
mitigation is required and no significant, unavoidable adverse impacts would occur.
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2.3.9 Hazards and Hazardous Materials
Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the Potential for
Upset Conditions
Long-Term Operational Impacts
The operational phase of the proposed Project would not be expected to create a significant hazard to the public or
the environment through the routine transport, use, or disposal of hazardous materials. Hazardous materials would
be limited to use of commercially available cleaning products, landscaping chemicals and fertilizers, and various other
commercially available substances. Such chemicals are typically used in an urban environment, and when used in
accordance with manufacturers recommendations and applicable regulations, do not result in a risk to human health
or the environment. The routine transport, use, and/or disposal of these substances would be subject to applicable
federal, state, and local health and safety laws and regulations, which would minimize health risk to the public
associated with hazardous materials. Therefore, impacts would be less than significant and no mitigation is required.
Hazardous Materials within One-Quarter mile of an Existing or Proposed School
There are no public or private K12 schools located within 0.25 miles of the Project site, therefore, impacts would
be less than significant and no mitigation is required.
Cortese List
The Project site is not listed on or adjacent to a Cortese List site, nor has the Project site been impacted by a Cortese
List site. Therefore, the Project would not create a significant hazard to the public or the environment due to its
location of a hazardous materials site included on the list compiled under Government Code Section 65762.5, and
no impact would occur.
Near an Airport or within an Airport Land Use Plan
The Project site is not located within 2 miles of a public use airport, nor is it located within an airport land use plan.
Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the
Project area, and no impact would occur.
Impair or Interfere with an Adopted Emergency Response Plan or Emergency Evacuation Plan
Short-Term Construction Impacts
Construction of the proposed Project would occur completely within the Project site and would not require road
closures. Additionally, the Project site is not located on a designated disaster evacuation route. The City of Arcadia
Safety Element Policies S-5.1, S-5.2, and S-5.11 require police and fire department personnel to be involved in the
development review process, integration of new technologies for crime and fire prevention in new development and
require new developments to pay for costs associated with increased public safety needs. As such, review of the
proposed Project as it relates to emergency response and emergency evacuation would be an integral part of the
review process within the City of Arcadia, and deficiencies would be remedied, and costs accounted for. As such,
impacts would be less than significant.
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Long-Term Operational Impacts
The proposed Project would increase residential density at the Project site. As noted above, review of the proposed
Project as it relates to emergency response and emergency evacuation would be an integral part of the review
process within the City of Arcadia in accordance with policies set forth in the General Plan, Safety Element, and
deficiencies would be remedied, and costs accounted for. As such, impacts would be less than significant.
Wildland Fires
The proposed Project site is located in a highly urbanized area and is not located within an area of high wildfire
hazard. Therefore, people and structures would not be subject to significant risks related to wildland fires, and
impacts would be less than significant.
Cumulative Effect
There are a variety of hazardous material and public health and safety issues that are relevant and applicable to
the Project. Many potential impacts related to hazardous materials and public health and safety risks would be
minimized due to compliance with federal, state, and local regulatory requirements.
Because cumulative Projects would be fully regulated, thus reducing potential for public safety risks, cumulative
impacts associated with exposure to hazards and hazardous materials would be less than significant. Through
mitigation and compliance with regulatory requirements, the construction or operation of the proposed Project itself
would not create significant human or environmental health or safety risks that could combine with other Project
impacts to create a significant and cumulatively considerable impact. For these reasons, the proposed Project
would not result in cumulatively considerable impacts related to hazards and hazardous materials.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on hazards and hazardous materials as it relates to the long-term use, storage and transport of hazardous
materials; proximity of an existing or proposed school; the proximity of the project to an airport or an airport land
use plan; emergency response plan; Cortese list; wildland fires; and cumulative impacts to hazards and hazardous
materials; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.
2.3.10 Hydrology and Water Quality
Violate Water Quality Standards or Waste Discharge Requirements
Short-Term Construction Impacts
Site grading would require a combination of cut and fill earthwork to create a building/parking structure pad and
to accommodate two levels of subterranean parking. Grading is estimated to result in approximately 57,200 cubic
yards of excavation/export (or cut) and 200 cubic yards of import fill for site rebalancing. Final grading plans
would be approved by the City Engineer before the City issues grading permits.
Grading and construction would potentially result in short-term erosion and associated siltation that could lead to
adjacent storm drain infrastructure. Erosion-induced sedimentation affects water quality and interferes with
photosynthesis; oxygen exchange; and the respiration, growth, and reproduction of aquatic species. Additionally,
other pollutants, such as nutrients, trace metals, and hydrocarbons, can attach to sediment and be transported to
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downstream drainages which could contribute to the degradation of water quality. Other pollutants that could affect
surface-water quality during the construction phase include petroleum products (gasoline, diesel, oil, and grease),
hydrocarbons from asphalt paving, construction equipment leaks, paints and solvents, detergents, fertilizers, and
pesticides (including insecticides, fungicides, herbicides, and rodenticides).
In accordance with the State NPDES Construction General Permit and WDR Permit, as established by the Porter-
Cologne Water Quality Act, the development of an acre or more of land must file a notice of intent with the SWRCB,
followed by development of a site-specific SWPPP for construction activities (Section 7827, General Control of
Runoff Required, Construction Activity, City of Arcadia Municipal Code). The property owner/developer must comply
with the Construction General Permit applicable at the time a grading permit is issued. The SWPPP must include
erosion- and sediment-control BMPs that will meet or exceed measures required by the determined risk level of the
Construction General Permit, as well as BMPs that control the other potential construction-related pollutants. A
Construction Site Monitoring Program that identifies monitoring and sampling requirements during construction is
a required component of the SWPPP. The SWPPP is required to identify BMPs that protect stormwater runoff and
ensure avoidance of substantial degradation of water quality.
Incorporation of required BMPs for temporary materials and waste storage and handling during construction, and
equipment and vehicle maintenance and fueling would reduce the potential discharge of polluted runoff from
construction sites, consistent with the State NPDES Construction General Permit and the Citys Municipal Code
requirements for construction activities.
As set forth in Section 7800 of the Citys Municipal Code, the Project must 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-stormwater into the Citys storm drain system, unless a
discharge permit, which meets the Citys requirements, is obtained. Section 7827 of the Municipal Code specifically
requires that all proposed development and/or redevelopment Project protect water quality by either (a)
implementing an erosion and sediment control plan and all applicable BMPs to ensure discharge of pollutants are
effectively prohibited or (b) preparing a SWPPP in accordance with the Construction General Permit. The proposed
Project would adhere to all applicable stormwater management and discharge control regulations, and, as such, is
not anticipated to violate any water quality standard or waste discharge requirement during operation.
The historical high groundwater levels in the Project vicinity have been interpreted at 100150 feet below the
ground surface, and as such, excavation activities associated with the subterranean parking garage are not
expected to encounter groundwater. However, perched groundwater conditions are dependent on seasonal
precipitation, land use, among other factors, and may vary as a result. Additionally, the Project proposes to install
drywells to satisfy low impact development requirements (as further discussed below), which are anticipated to
reach depths of 42 feet; therefore, it is possible that the construction of the drywells could encounter perched
groundwater (Appendix H-1).
In the event that groundwater is encountered during excavations, the Project applicant/developer would be required
by existing regulatory requirements to procure a dewatering permit from the Los Angeles RWQCB for pumping and
disposal of groundwater. Groundwater dewatering would be controlled in compliance with the Waste Discharge
Requirements for the Discharge of Groundwater from Construction and Project Dewatering to Surface Waters in
Coastal Watersheds of Los Angeles and Ventura Counties (Order No. R4-2018-0125, NPDES No. CAG994004). This
permit requires permittees to conduct monitoring of dewatering discharges and adhere to effluent and receiving
water limitations contained within the permit so that the water quality of surface waters is protected.
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Application for the permit would involve collecting and analyzing groundwater samples to determine its constituents.
In the event that contamination is identified, the permit would include specific types of treatment requirements to
ensure compliance with the discharge standards. The permit also establishes requirements for initial and
continuous groundwater testing throughout the dewatering process to ensure that the water remains suitable for
discharge and that the impacts of dewatering discharges do not constitute a significant and adverse impact to
downstream waters.
Compliance with existing regulations would prevent violation of water quality standards and minimize the potential
for contributing sources of polluted runoff. Therefore, compliance with existing regulations would ensure that the
Project would not violate any water quality standards or waste discharge requirements or otherwise substantially
degrade surface quality from demolition and construction activities. Impacts would be less than significant, and no
mitigation is required.
Long-Term Operational Impacts
The primary source of surface water pollution from long-term operations on the Project site would be incidental
spills of vehicle oils in parking garages. Certain metals, along with nutrients and pesticides from landscape areas,
could also be present in stormwater runoff, although on-site landscaping would be minimal. During storm events,
pollutants from paved areas lacking proper stormwater controls and BMPs could enter the municipal storm drain
system. Between periods of rainfall, surface pollutants tend to accumulate, and runoff from the first significant
storm of the year (first flush) would likely have the largest concentration of pollutants. Such discharges would
potentially violate state/federal antidegradation policies, the California Toxics Rule, and water quality objectives as
established in the Los Angeles RWQCB Basin Plan.
However, Project design, construction, and operation would be required to be completed consistent with the
RH/SGRWQG EWMP, and in accordance with the City Stormwater Management and Discharge Control Ordinance,
Municipal NPDES Permit, and the County of Los Angeles Low Impact Development Best Management Practices
Handbook (LID Manual), with the goal of reducing the amount of pollutants in stormwater and urban runoff (City of
Arcadia 2021b). The LID Manual requires that that post-construction stormwater runoff from new developments be
infiltrated, evapotranspired, captured and reused, and/or treated through a high efficiency BMP onsite for the 85th
percentile storm event, or 0.75 inches of precipitation, whichever is greater.
The LID Manual requires that BMPs be designed and implemented to manage and capture stormwater runoff.
Infiltration systems are the first priority type of BMP improvements, as such systems provide percolation and infiltration
of stormwater into the ground, which not only reduces the volume of stormwater runoff entering the MS4, but also
contributes to groundwater recharge in some areas. The second priority BMP is capturing and reusing stormwater
onsite for either landscape irrigation or toilet flushing. Proposed drainage for the proposed Project would include
stormwater treatment features, in accordance with the City and County LID requirements. According to a review of the
20112012 Municipal Separate Storm Sewer System (MS4) Annual Report for the Rio Hondo/San Gabriel River Water
Quality Group Enhanced Watershed Management Program (RH/SGRWQG EWMP) area, at least 150 BMPs were
reported within the City of Arcadia, including green infrastructure, source control, and institutional BMPS.
Based on the Geotechnical Investigation, prepared by Geocon West, Inc (see Appendix E-2), the Conceptual
Hydrology and LID Report (Appendix H-1) determined that infiltration is feasible for stormwater treatment. Two
drywells and one four-foot diameter primary settling chamber are proposed to be constructed on the Project site,
located in the south side of the basement parking lot, which would be able to capture the required runoff volume
and treat that volume as quickly as it enters the drywell system.
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The existing infiltration rate for the site is 13.83 inches/hour with a design infiltration of 6.92 inches/hour. 3 Based
on this data, the Project requires a mitigation volume of 7,592 cubic feet. A drywell with a diameter of 6 feet and
an infiltration depth of 42 feet would provide a disposal rate of 0.07091 cubic feet per second (cfs) and would
result in a disposal volume of 24,505 cubic feet over a 96-hour period. As a result, the 96-hour infiltration volume
for the combined wells would be 49,010 cubic feet. Based on the total mitigated volume of 7,592 cubic feet, after
subtracting the volume infiltrated as quickly as it enters the drywell of 6,577 cubic feet, the remaining volume is
1,015 cubic feet. The storage provided in the drywell system would be 1,062 cubic feet, which is adequate to
accommodate the mitigated volume.
In addition to the drywells and settling chamber, the Project includes street-level overflow curb drain outlets that
would discharge into the Wheeler Street curb gutter and run west to the catch basin on the northeast corner of
Wheeler Avenue and North Santa Anita Avenue. The existing peak flow rate value of 8.81 cubic feet per second
(cfs) would decrease by 0.73 cfs under proposed conditions, resulting in a proposed or post-Project peak flow rate
value of 8.08 cfs. The post-Project condition shows the conceptual location of the drywells, settling chamber, and
overflow pipes to the existing storm drain system, which would contribute to the peak flow rate reduction under
proposed conditions. Because the peak flow rate would be reduced in the proposed condition, it is understood that
the existing City storm drains would not be negatively affected by implementation of the proposed Project.
Once the water quality volume is met through the drywells, the higher flows would enter overflow pipes, which
would discharge stormwater to the local storm drain system. The proposed peak flow rate that would be used to
design the overflow piping is the reduced peak flow rate of 8.08 cfs generated after infiltration. As presented in
Appendix H-1, under the proposed infiltration system, the volume infiltrated in 96 hours is approximately six times
the required mitigated volume and the volume infiltrated as it enters the drywells are nearly equal to the mitigated
volume. Therefore, the drywells and settling chamber to be constructed as part of the Project would result in the
treatment of the entire required volume for the Project site and the elimination of pollutant runoff up to the 50-year
storm event.
The implementation of LID features would, to the maximum extent practicable, reduce the discharge of pollutants
into receiving waters, including inadvertent release of pollutants (e.g., hydraulic fluids and petroleum); improper
management of hazardous materials; and trash and debris during Project operations. In accordance with all
applicable state and local regulations, including General Plan Policy RS-9, Project source controls to improve water
quality would be provided for outdoor trash storage/waste areas and outdoor loading/unloading areas. As a result
of compliance with existing regulations, the Project would not violate any water quality standards or waste discharge
requirements or otherwise substantially degrade surface or groundwater quality during the long-term Project
operations. Impacts would be less than significant, and no mitigation is required.
Deplete Groundwater Supplies or Interfere with Groundwater Recharge
The amount of impervious area under proposed Project conditions would remain at 95%, which is the same as
under existing conditions. The soil zones encountered on site are suitable for infiltration of stormwater, the
proposed Project would incorporate drywells to facilitate infiltration in compliance with applicable LID requirements.
The Project site is not currently used for groundwater infiltration, either by spreading or by groundwater injection.
3 The design infiltration rate is the corrected in-situ infiltration rate and has been calculated in accordance with the Boring
Percolation Test Procedure in the County of Los Angeles Department of Public Works Geotechnical and Materials Engineering
Division (GMED) Guidelines for Geotechnical Investigation and Reporting, Low Impact Development Stormwater Infiltration .
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The 96-hour infiltration volume for the combined wells would be 49,010 cubic feet. As such, upon construction and
operation of the drywells, groundwater recharge at the site would increase in comparison to existing conditions.
The proposed Project is not anticipated to encounter groundwater during excavation for the subterranean parking
garage. However, perched groundwater conditions may vary over time, and in the unlikely event that groundwater
is encountered during excavations, the Project applicant/developer would be required by existing regulatory
requirements to procure a dewatering permit from the Los Angeles RWQCB for pumping and disposal of
groundwater. Groundwater dewatering would be controlled in compliance with the Waste Discharge Requirements
for the Discharge of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal
Watersheds of Los Angeles and Ventura Counties (Order No. R4-2018-0125, NPDES No. CAG994004). Temporary
dewatering, if required, would be short-term and would not substantially interfere with groundwater supplies.
Additionally, the Project site is above the Main San Gabriel Basin (Groundwater Basin 4-013), which has been
designated as Very Low Priority with respect to establishment of a GSA and completion of a Groundwater
Sustainability Plan (SGMA 2021). Therefore, the proposed Project would not substantially decrease groundwater
supplies. Impacts would be less than significant, and no mitigation is required.
Alter Existing Drainage Pattern (Erosion, Surface Runoff, Exceed Capacity Drainage System, Impede or Redirect
Flood Flows)
The proposed Project site is fully developed in the existing condition and is located in a highly urbanized portion of
Arcadia, surrounded by developed properties. Implementation of the proposed Project would not alter the existing
drainage patterns on the site such that downstream streams or rivers would be affected. The Project would infiltrate
stormwater in accordance with all applicable LID regulations and would continue to outflow into the existing storm
drain system. No naturalized drainages or creeks would be affected. According to the Conceptual Hydrology and LID
Report, total impervious surface area and post-project runoff are anticipated to be the same as under existing
conditions. Therefore, the Project would not substantially alter the existing drainage pattern of the site, including
through the alteration of the course of a stream or river or through the addition of impervious surfaces. Impacts would
be less than significant, and no mitigation is required.
Flood Hazard, Tsunami, or Seiche Zones
No areas within the City of Arcadia are designated 100-year flood zones (City of Arcadia 2010). According to the
Federal Emergency Management Agency (FEMA), the Project site is located within Zone X, which is an area of
Minimal Flood Hazard (FEMA 2021). Therefore, the Project site is not located within an area that would be subject
to flooding.
The Project is, however, located in the Santa Anita Dam flood inundation zone. Approximately half of the City 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 2010). According to the General Plan Safety
Element, flood hazards in the City are well addressed by existing storm control infrastructure. Seismic retrofit of the
Santa Anita Dam, which was built in 1927, was scheduled to begin in Spring of 2021 to improve public safety and
prevent flood damage to downstream communities (LACDPW 2019a). Dam failure potential is low and the extent
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of inundation would depend on the amount of water stored at the time of failure. Seismic upgrades will further
reduce already low potential for flooding due to dam failure at the Project site, and the proposed Project would not
exacerbate potential risks associated with dam failure.
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 (DOC 2021). 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 of the Project site is low, as the proposed sites primary uses (i.e.,
residential) would not include storage of hazardous materials or hazardous waste. Existing state, regional and local
regulations related to emergency preparedness would be sufficient to address potential hazards associated with
floods, tsunamis, or seiches, which have not been identified as hazards for the Project site. Therefore, Project
impacts would be less than significant, and no mitigation is required.
Conflict with Water Quality Control Plan or Sustainable Groundwater Management Plan
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. Compliance with the Citys
Stormwater Management requirements would protect 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 downstream waters. The Projects potential to 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.
The proposed Project would comply with applicable water quality regulatory requirements, including implementation
of a SWPPP, stormwater BMPs, and LID design, which would minimize potential off-site surface water quality
impacts and contribute to a reduction in water quality impacts within the Rio Hodo Watershed subarea and the
overall Los Angeles River Watershed. In addition, with compliance with these regulatory requirements, the Project
would reduce potential water quality impairment of surface waters such that existing and potential beneficial uses
of key surface water drainages throughout the jurisdiction of the Los Angeles RWQCB Basin Plan would not be
adversely impacted. As a result, the Project would not conflict with or obstruct the Los Angeles RWQCB Basin Plan.
With respect to groundwater management, SGMA empowers local agencies to form GSAs to manage basins
sustainably and requires those GSAs to adopt Groundwater Sustainability Plans for crucial groundwater basins in
California. A GSA has not been established for the Main San Gabriel Basin, as it is not considered a high priority
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basin. Further, the Project would not substantially deplete groundwater supplies or interfere substantially with
groundwater recharge. As a result, the Project would not conflict with or obstruct this sustainable groundwater
management plan. Impacts would be less than significant, and no mitigation is required.
Cumulative Effect
Water Quality
The geographic context for the analysis of cumulative impacts associated with water quality is the Los Angeles River
Watershed and the Rio Hondo Watershed subarea, which is already largely urbanized with impervious surfaces.
Although the land surrounding the Project site is largely developed with impervious surfaces, continued
redevelopment within the Project area could slightly increase the amount of impervious surfaces that could increase
stormwater runoff rates and amounts, as well as changes in land use that may increase the amount of pollutants
in stormwater runoff. Typical pollutants of concern would be associated with the construction phase (e.g., sediment,
fuels, litter), private vehicle use (e.g., any leakage of grease/oils), landscaping/grounds work (e.g., improper/
excessive use of pesticides, herbicides, and/or fertilizers), and/or trash (e.g., due to improper waste disposal). The
release of such pollutants, however, would be minimized through compliance with terms and conditions of the
NPDES permit, CALGreen Code, California Building Code, AMC, and the ordinance codes of other authorities in the
regionwhich all require implementation of a SWPPP for development and redevelopment projects. In summary,
all cumulative development would be subject to existing regulatory requirements to protect water quality and
minimize increases in stormwater runoff. For example, the NPDES permit requires the City to effectively prohibit
non-stormwater discharges from within its boundaries and to comply with the NPDES permit and to specifically
prohibit certain discharges.
Every two years, the Los Angeles RWQCB must reevaluate water quality within its geographic region and identify
those water bodies not meeting water quality standards. For those impaired water bodies, a TMDL must be prepared
and implemented to reduce pollutant loads to levels that would not contribute to a violation of water quality
standards. All development within the Los Angeles River Watershed would be subject to the water quality standards
outlined in the Basin Plan and would comply with any established TMDLs. The continuing review process would
ensure that cumulative development within the watershed would not substantially degrade water quality.
In addition, the Project would comply with existing and future regulations to protect water quality, including the
Construction General Permit. Compliance with existing regulations would prevent violation of water quality
standards and minimize the potential for contributing additional sources of polluted runoff. Therefore, Project
impacts associated with water quality standards and polluted runoff would be less than significant, and the Project
would not contribute considerably to cumulative impacts.
Drainage
The Los Angeles River Watershed is already largely urbanized with impervious surfaces. Cumulative development
within the City could potentially increase the amount of impervious surfaces that could cause or contribute to storm
drain system capacity exceedance, alter the existing storm drain system, and/or require construction of new or
expanded facilities. However, new development within the watershed would be subject to the same requirements
for LID infrastructure and BMPs to address the potential for increased runoff from development sites. All projects
must comply with current state and local environmental regulations, such as the AMC mandates. Potential impacts
to drainage associated with the Project would be less than significant, and the Project would not contribute
considerably to cumulative impacts.
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Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on hydrology and water quality. Therefore, no mitigation is required, and no significant, unavoidable adverse
impacts would occur.
2.3.11 Land Use
Physically Divide an Established Community
The physical division of an established community typically refers to the construction of a linear feature (e.g., a
major highway or railroad tracks) or removal of a means of access (e.g., a local road or bridge) that would impair
mobility within an existing community or between a community and outlying area.
The Project site currently consists of a 2-story office building, two 1-story commercial buildings, an 8-story office
building, a 1-story bank drive-through and surface parking. Access to the Project site is provided on Santa Clara
Street to the north, Wheeler Avenue to the south, an alleyway to the east, and Santa Anita Avenue to the west.
The proposed Project involves construction of a multi-family residential development and the demolition of some
of the existing structures on the site, including the 2-story office building, the two 1-story commercial buildings, and
surface parking. The Project includes a Tentative Parcel Map which would merge lots on site as well as a portion of
the alley would be vacated to accommodate the Project.
Under the existing condition, the Project site is developed land and is not used as a connection or thoroughfare
between established communities. Instead, connectivity within the area surrounding the Project site is facilitated via
local roadways. The proposed Project would not result in the construction of new driveways; rather, the Project would
allow for access via existing driveways on Santa Anita Avenue, Santa Clara Street, Wheeler Avenue, and an alleyway.
Further, the alleyway adjacent to the eastern boundary of the Project site would be partially converted into a
pedestrian paseo through the installation of removeable bollards, which would facilitate the Projects objectives of
connectivity to the Citys Downtown. Therefore, the Project does not include the construction of a new roadway that
would impair mobility within the existing Project site or the surrounding area. Rather, the Project would increase access
at existing driveways and pedestrian/transit connectivity. As such, the Project would not impede movement within the
Project site, within an established community, or from one established community to another.
Therefore, impacts associated with the division of an established community would be less than significant. No
mitigation is required.
Conflict with an Applicable Land Use Plan, Policy, or Regulation
Consistency with the Connect SoCal (SCAG 20202045 RTP/SCS)
SCAGs Connect SoCal is a regional growth-management strategy that targets per capita GHG reduction from
passenger vehicles and light-duty trucks in the Southern California region. The Connect SoCal incorporates local
land use projections and circulation networks in city and county general plans. Typically, a project would be
consistent with the RTP/SCS if the project does not exceed the underlying growth assumptions within the RTP/SCS.
The proposed Project would result in approximately 909 residents, which would estimate approximately 1.5% of the
2045 SCAG estimate for the Citys projected total population. Additionally, it is likely that the proposed residential
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units would accommodate a combination of existing residents and new residents that either currently work within
the City and/or new residents that would be hired as a result of projected employment generation within the City.
Furthermore, the proposed Project is estimated to generate a net loss of 20 employees as compared to existing
conditions. This indicates that the proposed Project would not outpace regional infrastructure, since the SCAG
RTP/SCS is used for local and regional planning purposes. Furthermore, the proposed Project would implement the
guiding principles, goals, and policies of SCAGs 20202045 RTP/SCS as they relate to livability, economic
prosperity, and sustainability through the development of a mixed-use residential development. The development
of the proposed Project within proximity to transit would thereby alleviating pressure on suburban and open space
areas to develop, is fully supportive of SCAGs strategies. the proposed Project would not conflict with any of the
goals within SCAGs Connect SoCal. The Project would develop the Project site, producing an estimated 909
residents and a net loss of 20 employees as compared to existing conditions. The Project sites vicinity is served by
existing public transit such as the Metro L Line and various bus routes provided by Metro and Foothill Transit. For
these reasons, the Project would not conflict with the applicable goals in the RTP/SCS adopted for the purpose of
avoiding or mitigating an environmental effect.
City of Arcadia General Plan Consistency
The proposed Project would result in the construction of a new multi-family residential building on a total lot area
of 128,517 square feet (sf), or 2.95 acres. As described in the General Plan, the DMU land use only accounts for
commercial square footage in calculation of FAR. The total non-residential area of the proposed Project consists of
83,253 square feet (consisting of a Bank of America building, an 8-story office building, and a 1-story office
building). Additionally, the Project includes 8 live/work units with a total of 15,145 square feet in size. Of the total
live/work areas proposed, 9,281 square feet would be designated for work or commercial uses. Therefore, the
total non-residential area, including the existing office and work areas is 92,534 square feet. In summary, the
proposed Projects FAR would result in 0.72, which is consistent with the General Plans maximum of 1.0. Applicable
policies identified in each element of the General Plan (Land Use and Community Design Element, Economic
Development Element, Circulation and Infrastructure Element, Housing Element, Resource Sustainability Element,
Parks, Recreation, and Community Resources Element, Safety Element, and Noise Element) were reviewed and it
was determined the Project would be consistent with applicable goals and policies of the General Plan. The
proposed Project does not require a General Plan Amendment for implementation to occur and would be consistent
with the General Plan for the purposes of avoiding or mitigating environmental effect.
City of Arcadia Municipal Code
The City of Arcadia Development Code, in conformance with the General Plan, regulates land use development in
the City. In each zone, the zoning regulations specify the permitted and prohibited uses, and the development
standards, including setbacks, height, parking, and design standards, among others. The proposed Project would
not require a Zone Change for implementation. The Project requests the following discretionary approvals for Project
implementation: Certification of Demolition; Minor Use Permit with Density Bonus; Site Plan and Design Review;
Street Vacation for the Alley; and a Tentative Parcel Map.
Compliance with applicable zoning regulations would reduce potential impacts associated with the avoidance or
mitigation of an environmental effect. With the Citys approval, demolition activities would be permitted and review of
the proposed site plan for design consistency would occur. The Project proposes a unit mix consisting of 64 studios,
168 one-bedroom units, 79 two-bedroom units, and 8 live-work units. The need for the issuance of a Minor Use Permit
is required for the development of multifamily dwellings and live-work units. Additionally, consistent with the General
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Plan, the Project site has a base density of 80 du/ac, allowing for a total of 236 dwelling units on the 2.95-acre site.
The Project applicant proposes to utilize a 35% density bonus under SB 1818, which would increase the allowable
dwelling unit count to 319 total units. In order to comply with SB 1818, the Project would include 26 affordable
dwelling units. Thus, the final unit mix would consist of 293 market rate units, and 26 affordable units, totaling 319
dwelling units. Utilization of the State Density Bonus is further codified in Section 9103.15 of the Citys Development
Code. Finally, the approval of a Street Vacation for the Alley on the Project sites eastern edge and approval of a
Tentative Parcel Map is required for Project implementation. The Tentative Parcel Map would merge four of the lots
into two legal lots and a portion of the alley would be vacated to accommodate the Projects design objectives for
pedestrian connectivity. Therefore, with the approval of these items, less than significant impacts would occur related
to land use regulations adopted for the purposes of avoiding or mitigating an environmental effect.
Cumulative Effects
Cumulative land use impacts could occur if any of the related projects would result in incompatible land uses, or
result in land uses that are inconsistent with adopted land use plans when combined with the impacts of the Project.
Given the built-out conditions of the greater Los Angeles Metropolitan region, including the Project site, cumulative
development would likely convert existing underutilized properties in the Project sites area to revitalized higher-
density developments to respond to the need for housing, sources of employment, and associated retail land uses.
The Project would benefit the surrounding community by replacing underutilized properties; add residential uses to
a job-rich community; and improve local and regional access to the regional transportation network. Furthermore,
by providing additional housing and employment in close proximity to transit, the Project would assist the City and
region in achieving short- and long-term planning goals and objectives related to reducing urban sprawl, efficiently
using existing infrastructure, reducing regional congestion, and improving air quality through the reduction of
vehicle miles traveled. This is consistent with SCAG and other regional policies for promoting more intense land
uses adjacent to transit stations and job centers.
Generally, land use conflicts would be related to noise, traffic, air quality, and hazards/human health and safety
issues. Land use conflicts are also typically site-specific and not cumulative in nature; in other words, despite the
number of cumulative projects in a given area, they would not necessarily compound to create cumulative land use
conflicts. Cumulative incompatibility issues associated with surrounding developments or projects are anticipated
to be addressed and mitigated for on a project-by-project basis. Further, all related projects in the City would be
subject to the same local development standards, such as those identified in the Citys Development Code, as the
proposed Project. Therefore, cumulative impacts related to land use and planning would be less than significant.
No mitigation is required.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on land use and planning; therefore, no mitigation is required, and no significant, unavoidable adverse
impacts would occur.
2.3.12 Mineral Resources
There are no oil wells or oil/mineral extraction activities on the Project site (CalGEM 2020). Current on-site land
uses do not allow for oil/mineral extraction. According to the Citys General Plan, Resource Sustainability Element,
Figure RS-1 (Mineral Resource Zones), the Project site is within the Mineral Resources Zone-4 (MRZ-4), which is
characterized as areas where there are insufficient data to assign any other Mineral Resource Zone designation.7
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The MRZ-4 classification does not imply that there is little likelihood for the presence of mineral resources, but
rather there is a lack of knowledge regarding mineral occurrence. However, given that the Project site is located
within an urban setting, does not currently allow for oil/mineral extraction, and is not designated for mineral
extraction, the Project would not result in the loss of availability of a locally-important mineral resource recovery
site delineated on the local general plan or other land use plan. Thus, impacts associated with mineral resources
would not occur and will not require further evaluation in the Draft EIR.
Finding
Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to mineral
resources; therefore, mineral resources were not addressed in the Draft EIR. No mitigation would be required and
no significant, unavoidable adverse impacts would occur.
2.3.13 Noise
Generation of a Substantial Temporary or Permanent Increase in Ambient Noise Levels
Construction Noise (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 performed, and the distance between
the source and receptor.
Construction of the proposed Project would include demolition, site preparation, grading, building construction,
paving, and application of architectural coatings and landscaping. No rock blasting, on-site rock crushing or pile
driving is anticipated to be necessary as part of this Project.
Equipment that would be in use during construction would include, in part, graders, backhoes, excavators,
loaders, cranes, dozers, cement pump trucks, pavers, rollers, welders, concrete saws, and air compressors.
Usually, construction equipment operates in alternating cycles of full power and low power, producing average
noise levels over time that are less than the listed 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.
The Federal Highway Administrations (FHWA) Roadway Construction Noise Model (RCNM) (FHWA 2008) 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. Although some noise reduction from intervening
structures is likely for most of the modeled locations because of the relatively large distances, barrier shielding was
conservatively neglected for this 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.
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The highest noise levels are predicted to occur during demolition, site preparation, and grading activities. At the
nearest noise-sensitive land use (a private school located to the northwest of the Project site), construction noise
levels would be as high as 64 dBA Leq at the school when Project construction occurs near the Project boundary,
approximately 630 feet away. At the typical construction activity/receiver distance from the school of approximately
765 feet, construction noise would range from approximately 50 to 63 dBA L eq. At the nearest existing residences
and at Arcadia County Park, each located approximately 650 feet from the nearest construction work, noise from
construction activities is estimated to range from approximately 51 to 63 dBA L eq.
At the adjacent medical office building, noise levels from construction activities would be as high as 88 dBA L eq
when Project construction occurs at the nearest Project boundary, approximately 30 feet away. At the typical
construction activity/receiver distance from the medical office building of approximately 165 feet, construction
noise would range from approximately 63 to 76 dBA Leq. According to the FHWA (FHWA 2011), the typical noise
reduction provided by buildings varies from 20 to 25 dBA for buildings of light frame construction with the windows
closed. Buildings constructed using masonry provide approximately 25 to 30 dB noise reduction with windows
closed. Conservatively assuming a noise reduction factor of 20 dB, the interior noise level at the medical office
building would be as high as 68 dBA Leq when Project construction occurs at the nearest Project boundary,
approximately 30 feet away. At the typical construction activity/receiver distance from the medical office building
of approximately 165 feet, the interior noise levels would range from approximately 43 to 56 dBA L eq.
According to the Citys Municipal Code, construction work is prohibited between the hours of 6:00 p.m. and 7:00
a.m. Monday Friday, 5:00 p.m. and 8:00 a.m. on Saturday, and any time on Sunday and holidays. Although nearby
off-site receivers would be exposed to elevated construction noise levels, the noise levels would not be high enough
to pose a hazard to human health based on the Division of Occupational Safety and Health (DOSH) standards.
Within the State of California, the DOSH, better known as Cal/OSHA, aims to protect and improve occupational
health and safety.
As noted above, at noise sensitive receptor locations, construction noise will reach up to 64 dBA L eq, which is below
Cal/OSHAs AL and PEL. Therefore, construction would not pose human health risks and would not generate a
substantial temporary increase in ambient noise levels in excess of standards.
Furthermore, the exposure would be short-term and would cease upon completion of construction. In compliance
with the Citys Municipal Code, construction activities associated with the proposed Project would not take place
between 6:00 a.m. and 7:00 a.m. on weekdays, 5:00 p.m. and 8:00 a.m. on Saturday, or at any time on Sunday or
holidays. Therefore, the proposed Project construction would be in compliance with applicable noise regulations,
and therefore construction noise would be less than significant, and no mitigation is required.
Operational Noise (Long-Term Impacts)
Off-Site Traffic Noise
The proposed Project would generate traffic along adjacent arterial roadways (primarily Santa Anita Avenue, Santa
Clara Street, Wheeler Avenue, and Huntington Drive). 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, Project-generated traffic noise level increases are considered significant if they cause an
increase of 3 dBA CNEL (a barely perceptible difference) compared to existing traffic noise levels, or cause noise
levels to exceed 65 dBA CNEL at residential land uses or other applicable thresholds based upon the Citys General
Plan. If existing traffic noise levels exceed 65 dBA CNEL under existing conditions, impacts are considered
significant if the Project increases traffic noise above existing traffic noise levels.
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The noise levels associated with roadway traffic were determined based on the Projects Transportation Technical
Memorandum (Appendix K-2) 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 receivers show 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. The proposed Project would not result in an exceedance of the Citys 65 dBA CNEL noise threshold
for residences or other applicable thresholds, 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.
Stationary Operations Noise
The incorporation of new multi-family homes and a mix of commercial uses attributed to development of the
proposed Project would add a variety of noise-producing mechanical equipment.
Residential Unit Heating, Ventilation, and Air Conditioning Noise: HVAC equipment would be located on the rooftop
of the proposed building and would be screened from direct view by nearby receivers by parapet walls and/or
mechanical equipment screen walls. Based upon information provided by the applicant, a total of 327 roof-mounted
Carrier air conditioner units would be used for heating, ventilation and air conditioning (HVAC), each with a cooling
capacity of 2 tons. From the HVAC manufacturers equipment specifications for representative models (details of
which are provided in Appendix I-3), the dimensionless sound power levels were found to range from approximately
55 dBA to 73 dBA. Conservatively assuming a sound power level of 73 dBA per HVAC unit, a Microsoft Excelbased
outdoor sound propagation prediction model was used to calculate the combined noise level from all 319 units at
nearby sensitive receptors
Using the aforementioned noise prediction model, and without consideration of noise reduction due to acoustical
shielding from structures other than the proposed Project, the noise levels from the combination of all operating
condenser units at the nearby receivers was estimated and noise levels at the nearest receivers would range from
approximately 24 to 40 dBA Leq, which would be well below the applicable noise standards and would also be well
below measured ambient noise levels. Therefore, on-site stationary noise would be less than significant. No
mitigation is required.
Excessive Groundborne Vibration or Groundborne Noise Levels
Construction activities can expose persons to excessive groundborne vibration or groundborne noise under certain
circumstances. Caltrans has collected groundborne vibration information related to construction activities (Caltrans
2020). Information from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips is
considered annoying. For context, heavier pieces of construction equipment, such as a large bulldozer or similar
equipment that may be expected on the Project site, have peak particle velocities of approximately 0.089 ips or
less at a reference distance of 25 feet (FTA 2018).
Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as
it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions
found in FTA and Caltrans guidance. A large bulldozer or similar type of heavy equipment operating on site would
generate an estimated vibration level of approximately 0.001 ips at the nearest residences located approximately
650 feet from the Project site. Therefore, because these predicted vibration levels are less than the Caltrans
guidance-based annoyance threshold of 0.2 ips PPV, the impact of vibration-induced annoyance to occupants of
nearby existing homes would be less than significant. No mitigation is required.
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Construction vibration, at sufficiently high levels, can also present a building damage risk. At the nearest office
building approximately 30 feet from the Project site, vibration is predicted at approximately 0.067 ips PPV, which is
be well below the guidance limit of 0.3 ips PPV for preventing structural damage (Caltrans 2020). Because the
predicted vibration levels are less than both the annoyance and building damage risk thresholds, vibration from
construction activities would be less than significant. No mitigation is required.
Once operational, the Project would not be expected to feature major onsite producers of groundborne vibration.
Anticipated onsite mechanical systems like pumps, compressors, and fans are designed and manufactured to
feature rotating or reciprocating components (e.g., impellers, rotors, and pistons) that are well-balanced with
isolated vibration within or external to the equipment casings. On this basis, potential vibration impacts due to
Project operation would be less than significant. No mitigation is required.
Expose People Residing or Working in Airport Land Use Plan to Excessive Noise Levels
The Project is not located within the vicinity of a private airstrip, and the nearest airport (San Gabriel Valley Airport,
formerly known as El Monte Airport) is located approximately 3.5 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 2021; County of Los Angeles 2014). 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.
Cumulative Effects
Temporary/Periodic Increases in Ambient Noise Levels
The Project would result in temporary noise increases during construction activities, as discussed under 4.10.4(a)
above. The construction period of the Project has the potential to overlap with the construction of other
development projects in the City. Due to the decrease in noise levels with distance and the presence of physical
barriers (i.e., intervening buildings and topography), noise due to construction of other projects would not
meaningfully combine with future development under the Proposed Project to produce a cumulative noise effect
during construction. By way of illustration, if there are two concurrent construction projects of comparable sound
emission intensity, and the activity nearest to the studied noise-sensitive receptor is compliant with the Citys
applicable noise threshold, the other activity could be no closer than three times the distance of the receptor to
the nearest activity and not make a cumulatively measurable contribution to the total and still City-compliant
noise exposure level. Cumulative construction noise is likely to be dominated by the closest or loudest activity to
the receptor, and the combination will be no more than a barely perceptible difference (i.e., up to a 3 dB change).
Based on the cumulative project list provided by the City for the Project, there are no construction projects that
would potentially contribute construction noise that would, in combination with the Project, result in cumulative
impacts. Thus, cumulative impacts associated with temporary increases in ambient noise levels would be less
than significant.
Vibration
Construction-related vibration from future development under the Project was addressed under Threshold 4.10.4(b)
above. Other foreseeable projects within the vicinity of the Project site would not be close enough to create a
combined excessive generation of groundborne vibration; therefore, cumulative impacts associated with excessive
groundborne vibration would be less than significant.
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Permanent Increase in Ambient Noise Levels
Off-Site Traffic
Future development from implementation of the Project along with other unrelated projects would generate off-
site traffic noise. When calculating future traffic impacts, the traffic study included traffic attributed to both the
Project and unrelated projects. Thus, future traffic noise prediction results with and without the Project already
account for the cumulative impacts from unrelated projects contributing to traffic increases. Since the noise
impacts are generated directly from the traffic analysis results, the Existing and Year 2024 traffic with and without
Project predicted increases in traffic noise levels described herein already reflect cumulative impacts. As
described herein, the noise level increases associated with both of these scenarios would not exceed applicable
standards. As such, anticipated increases would be below the significance thresholds; hence, the incremental
effect of the Project on off-site traffic noise is not cumulatively considerable. Cumulative off-site traffic noise
impacts would be less than significant.
Stationary Sources
Noise from operation of stationary mechanical equipment added to the outdoor ambient sound environment as a
result of Project implementation would include permanent on-site noise sources (e.g., rooftop HVAC equipment) as
addressed under Section 4.10.4, Impacts Analysis, under Threshold 4.10a. A cumulative impact could occur if noise
produced from such sources due to implementation of the Project were to combine with noise produced from the
operation of other unrelated projects in the vicinity to create a cumulatively significant permanent increase in
ambient noise levels. However, noise emission from HVAC equipment attenuates with distance and can be occluded
by structures and terrain. Additionally, the operation of the Project, along with the operation of other unrelated
projects, would be subject to applicable requirements from the Citys noise ordinance, which limits the exterior
noise levels at residences. Hence, for these two reasons, cumulative impacts to outdoor ambient noise levels
resulting from Project stationary sources would be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on noise as it relates to groundborne vibration, exposing people residing or working within an airport land
use plan to excessive noise levels, and cumulative noise impacts; therefore, no mitigation is required and no
significant, unavoidable adverse impacts would occur.
2.3.14 Population and Housing
Induce Substantial Population Growth
Short-Term Construction Impacts
Construction activities at the Project site would lead to the temporary need for construction workers, which may
come from the City, other areas of Los Angeles County, or elsewhere within the SCAG region. The proposed Project
involves fairly common construction requirements that would not require a highly specialized labor force to
permanently relocate from other regions. Construction of the Project is anticipated to start in June 2023, in which
construction would last approximately 26 months, ending in August 2025. The different construction activities
require specific skill sets for a much shorter duration than the overall construction schedule. Because
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construction workers would not be needed continuously and only for varying portions of the Project phases, it is
reasonable to assume that workers/crews would work at the Project site on a temporary basis only, and thus,
are not likely to relocate their households as a consequence of the construction job opportunities presented by
the Project. Because the demand for construction workers would be short-term, and because the Project site
within an urban metropolitan region with a high diversity of skilled labor, a permanent need for new workers to
relocate in order to accommodate the proposed Projects temporary construction workforce is not anticipated.
Any changes in the City or regional population, housing, or employment due to short-term construction activities
would be less than significant.
Long-Term Operational Impacts
The proposed Project would demolish some of the existing structures on the Project site, including a 2-story office
building, two 1-story commercial buildings, and surface parking. The Project site also contains an existing 8-story
office building and 1-story bank drive-through, which would remain in place. The Project would redevelop the site
with the construction of a 7-story multi-family residential building, consisting of 319 dwelling units with various
residential amenities throughout the building and Project site. An outdoor plaza would be constructed between the
8-story office tower and the proposed residential building. In addition, approximately 750 square feet of lobby space
within the existing 8-story building would be converted into a café, while the alleyway adjacent to the eastern
boundary of the site would be converted into a pedestrian paseo. The Project would also include a total of 576
parking spaces, contained within two above-ground parking areas, within Levels 1 and 2 of the proposed building,
and two subterranean parking levels. Implementation of the proposed Project would not require a General Plan
Amendment or Zone Change. Therefore, the proposed Project would directly result in building new housing where
housing currently does not exist.
Population Projections
SCAG estimated that Los Angeles County had 10,407,000 residents in 2020 and estimates the county would have
11,647,000 residents by 2045. The U.S. Census Bureau determined the City had a total of 56,681 residents in
2020 and SCAG estimates 62,200 residents by 2045. As such, the forecasted population growth for the City of
Arcadia is 5,519 persons between 2020 and 2045.
Using population and housing estimates from the California Department of Finance, the City has an occupancy rate
of 2.85 persons per household (DOF 2021). Assuming 2.85 persons per household, the proposed Projects
residential units would accommodate 909 individuals. Additionally, it is likely that the proposed residential units
would accommodate a combination of existing residents and new residents that either currently work within the
City and/or new residents that would be hired as a result of projected employment generation within the City.
Additionally, the Citys 2021 housing vacancy rate of 6.3% is slightly less than Los Angeles Countys housing vacancy
rate 6.4% (DOF 2021).
The U.S. Census Bureau determined, based on the 2020 Census results, there were 56,364 residents in the City
in 2010 (U.S. Census 2021). The Citys General Plan estimated a buildout population of 61,994 residents by 2035
(see Table 4.11-5). SCAGs Connect SoCal projections of 62,200 persons by 2045 represents an expectation that
the City will meet the population growth set forth in the General Plan. When considering the 2035 buildout of the
General Plan, it can be interpreted that the proposed Projects anticipated population of 909 residents would be
fulfilling a 2035 population projection that was anticipated at the time of the preparation of the Citys General Plan.
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The proposed Project would accommodate an expected 909 residents which would be counted within the overall
population growth projections included in the Connect SoCal of 5,519 residents between 2020 and 2045.
The proposed Project would be considered growth-accommodating rather than growth-inducing in that the proposed
Projects 319 new residential units would accommodate 909 residents, which are anticipated to be a mix of current
and future residents to the City. If all 909 residents would be new to the City, the Project would be within the overall
population growth projections included in the Connect SoCal.
Because the proposed Project would support SCAGs goals and strategies for growth in the region and because the
proposed Project would assist the development of new housing and improves the Citys job/housing balance,
impacts related to population growth would be less than significant.
Employment Projections
The Project would develop a new residential building, which would require staffing to support on-site services. In
addition, the proposed Project would include 8 live/work units. As further detailed in Appendix K-2 of this Draft EIR,
approximately 9,281 square feet of the live/work units would be considered a commercial/retail land use. The Project
also includes the interior renovation of the existing 8-story office tower in order to convert the space into a new 750
square foot café. Given that the existing office and commercial land uses on site would be demolished, the Project
would result in a loss of approximately 50 potential jobs and the proposed Project is anticipated to generate
approximately 30 jobs. Therefore, the proposed Project is estimated to generate a net loss of approximately 20 jobs
as compared to existing conditions.
Although the proposed Project would result in a loss of 20 employment opportunities at the Project site, the
proposed Project would not result in a significant effect to the City or region. According to the California
Employment Development Department, preliminary results find approximately 10.4% (529,700 persons) of
the Los Angeles Countys 5,108,400 person-labor force were unemployed as of July 2021, and approximately
7.8% (2,300 persons) of the Citys 29,300 person-labor force were unemployed in July 2021 (EDD 2021).
Given the fact that unemployment rates during COVID-19 may be skewed when compared to previous years,
the 2019 rates were also evaluated. According to the California Employment Development Department,
approximately 4.6% (234,400 persons) of the Los Angeles Countys 5,090,800 person-labor force were
unemployed as of July 2019, and approximately 3.7% (1 ,100 persons) of the Citys 29,800 person-labor force
were unemployed in July 2019 (EDD 2021). As such, it can be assumed that many of the 30 new jobs would
be filled by individuals that live within the City.
As previously discussed above, the number of jobs in the City would decrease by approximately 20 positions as a
result of the Project. Therefore, the proposed Project would not contribute to SCAGs employment growth projections
in Los Angeles County, nor would the Project contribute to SCAGs employment growth projections for the City.
Instead, the estimated loss of 20 jobs at the Project site resulting from the proposed Project would represent a
nominal change to the Citys jobs-rich community, as further described below.
Housing Projections Analysis
SCAG projects that Los Angeles County will have an increase of 647,000 housing units between 2020 and 2045,
and that the City will have an increase of 1,111 units during this same period. The proposed Projects 319
residential units would represent 0.05% of SCAGs projected housing for Los Angeles County and 28.7% of the
projected housing for the City. Therefore, the proposed Projects housing units would not exceed the projections for
housing within the City, as set forth in the 20202045 RTP/SCS.
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Californias housing element law requires that each city and county develop local housing programs designed to
meet its fair share of existing and future housing needs for all income groups. This effort is coordinated when
preparing the state-mandated Housing Element of the Citys General Plan. This fair share allocation concept seeks
to ensure that each jurisdiction accepts responsibility for the housing needs of, not only its resident population, but
for all households that might reasonably be expected to reside within the jurisdiction, particularly lower income
households. This assumes the availability of a variety and choice of housing accommodations appropriate to their
needs, as well as certain mobility among households within the regional market.
Because the proposed Project will be occupied within the timeframe of the 6th Cycle, it is most relevant to the analysis.
The Citys fair share allocation for the planning period is 3,214 units. This indicates that between the years 2021 to
2029, the City needs to accommodate at least 3,214 housing units, consisting of a variety of housing types to
accommodate extremely low, very low, low, moderate, and above moderate-income households to keep pace with
housing demand. The proposed Project would create new housing and would include affordable housing in
accordance with SB 1818. The specific allocation between the types of low-income housing has yet to be determined;
however, the proposed low-income units would satisfy a portion of the Citys mandated 6th Cycle RHNA allocation.
As such, the proposed Projects 319 new residential units would assist the City in meeting the mandated RHNA
allocation and would be consistent with and supportive of the Citys Housing Element projections for new residential
units within the City.
Jobs/Housing Balance
The City is considered to be a jobs-rich community. The proposed Project would generate additional housing available for
the community, as the jobs-housing balance of the proposed Project would be 0.09:14, which is a housing-rich project.
As such, the proposed Project would be contributing additional housing to the Citys jobs-rich community and would assist
in meeting the mandated RHNA allocation of housing units. In conclusion, the proposed Project would facilitate a more
balanced jobs-housing profile for the City by adding more housing to a city with an approximately 1.6:1 jobs to housing
ratio (SCAG 2020b).
Displace Substantial Numbers of Existing Housing or People
The Project site, under existing conditions, consists of surface parking as well as the commercial and office space.
No housing units are located on the Project site. Thus, Project implementation would not require demolition of
existing housing or displace people or housing. The proposed Project would include the construction of a mixed-use
development that would add approximately 319 housing units to the City. Impacts would be less than significant.
Cumulative Effect
Assuming 2.85 persons per household, the proposed Projects residential units would accommodate 909 residents.
Additionally, the Project is estimated to result in a net loss of 20 employees as compared to the existing conditions.
The remaining cumulative projects would primarily be increasing employment in the City and potentially further
exacerbating the jobs-rich profile of the City, which could increase the vehicle miles traveled between employment
centers and residential land uses. While the proposed Project would provide employment opportunities to the local
and regional area, the net loss of employment opportunities on site would not contribute to current projections for
employment growth in the City or Los Angeles County. The planned growth of cumulative projects within the City
includes over 73,795 square feet of additional commercial development. With the addition of the 319 housing
units, the proposed Project is anticipated to facilitate a more balanced jobs-housing profile for the City of Arcadia.
4 30 jobs and 319 housing units = 30/319 = 0.09
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A total of 486 units are proposed within one mile of the Project site, all of which are within the City limits. In addition
to the proposed 319 units of housing growth by the Project, the cumulative total would be estimated at 805 new
units. Given that the Citys Housing Element is currently undergoing an update in accordance with State law and at
the time of this Draft EIRs production, state and regional projections are used for analysis comparison. The
California Department of Finance estimates 21,289 units exist within the City. Moreover, SCAG estimates a total of
22,400 units would be built by 2045. As such, the addition of 805 units would result in 22,094 new units in the
City once the proposed Project is operational in 2024. Therefore, the estimated household growth is within the state
and regional growth projections. Furthermore, the proposed housing growth generated by the Project would further
the goals and strategies of SCAG and the Citys General Plan by providing housing in an urban setting in close
proximity to transit, while contributing to a more balanced jobs-housing community. Although, the proposed
Projects residential population would not exceed SCAGs population projections, it can also be assumed that many
of the residential units would accommodate workers within the City and could reduce vehicle miles traveled by
providing housing in proximity to employment centers.
Cumulative population growth could be assumed using the previously identified 2.85 persons per household. Thus,
the related projects could result in approximately 1,385 persons. In addition to proposed population growth
generated by the Project (909 residents), a total of 2,294 persons is anticipated. As such, 58,975 persons are
estimated at build out of both the related projects and the proposed Project, which is within SCAGs projected
population growth of 62,200 persons for the City by 2045. Thus, it is not anticipated that the proposed Project, in
combination with other future foreseeable projects, would create a cumulatively considerable impact to population,
housing or employment.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on population and housing related to inducing growth during construction and displacing a substantial
number of people or housing; therefore, no mitigation is required, and no significant, unavoidable adverse impacts
would occur.
2.3.15 Public Services and Recreation
Fire Protection
Construction
Construction activities associated with the proposed Project may temporarily result in a slight increase demand for fire
protection and emergency medical services. Construction activities may involve the operation of construction equipment
and machinery, storage, handling, and disposal of combustible materials, and the use of flammable or toxic materials.
To comply with California Department of Industrial Relations, Division of Occupational Safety and Health and Fire
and Building Code requirements, construction managers and personnel would be trained in fire prevention and
emergency response, and fire suppression equipment specific to construction would be maintained on site. Project
construction would comply with all applicable codes and ordinances related to the maintenance of mechanical
equipment, handling and storage of flammable materials, and cleanup of spills of flammable materials. City and
state regulations and code requirements would, in part, require personnel to be trained in fire prevention and
emergency response, maintenance for fire suppression equipment, and implementation of proper procedures for
storage and handling of flammable materials. Thus, compliance with regulatory requirements would reduce the
potential for construction activities to expose people to the risk of fire explosion related to hazardous materials.
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Section 21806 of the California Vehicle Code allows drivers of emergency vehicles to have a variety of options for
avoiding traffic, such as using sirens to clear a path of travel and driving in the lanes of opposing traffic. Based on
these considerations, construction of the proposed Project would not be considered a high-risk activity, and the AFD
is equipped and prepared to deal with construction-related traffic and fires, should they occur. Due to compliance
with applicable codes and fire safety standards, Project construction would not adversely impact firefighting and
emergency services in their ability to maintain acceptable service ratios, response times or other performance
objectives for fire protection. Therefore, impacts are less than significant, and no mitigation is required.
Operation
The Arcadia Fire Department (AFD) currently serves the Project site and the surrounding area. Each additional
development that provides net new square footage creates a greater demand on existing resources. The increased
use of the Project site resulting from the Project would be expected to increase the frequency of emergency
response calls relative to existing conditions. However, for the reasons enumerated below, the proposed increase
in development intensity at the Project site would not result in substantial adverse physical impacts associated with
the need for new or expanded fire protection facilities.
The need for new or expanded public services (such as fire protection facilities/structures/buildings) is associated
with a substantial population increase, a substantial increase in developed structures, and/or a substantial
increase in fire activity, such as wildfire hazards. Project employment and new residential uses would result in a net
loss of approximately 20 employees (as compared to existing conditions) and 909 new residents on the Project
site. The proposed Project would support SCAGs goals and strategies for growth in the region.
The Project site is currently served by three existing fire stations (Stations 105, 106, and 107). The AFD stated that
as the City continues to develop high density projects, call volume for fire services will continue to increase, which
will result in longer response times. With the addition of the proposed Project, services would be incrementally
impacted. However, the AFD has indicated that the proposed Project would not directly result in the need for new
facilities and/or physically altered facilities in order to maintain acceptable service ratios, response times, or other
performance objectives of the AFD. No expansion of fire department facilities is currently contemplated or required
to serve the proposed Project, and no new fire stations are required to serve the proposed Project (Appendix J-1).
Therefore, impacts would be less than significant and no mitigation is required.
Furthermore, the proposed Project would be designed and constructed in accordance with all applicable provisions
of the fire code, which includes requirements for adequate fire flows, width of emergency access routes, turning
radii, automatic sprinkler systems, fire alarms, and floor to sky height limits along emergency access routes.
Compliance with the fire code standards would be ensured through the plan check process and fire review prior to
the issuance of building permits for the Project. More specifically, the proposed Project would be designed to include
the following fire protection features, which would help prevent fire hazards: appropriate roadway access for fire
lines, AFD connections and fire sprinkler system control valves, and a fire alarm system. The building would also be
equipped with fire pumps and alarms consisting of smoke detection, voice alarm capability, and visual alarms.
These fire safety features and compliance with fire code standards would reduce the potential demand for fire
services by decreasing the likelihood and/or severity of a fire emergency at the site.
The operational phase of 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. Hazardous materials would be limited to use
of commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially
available substances typically used at office and residential establishments. Although the Project would introduce
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commercially available potentially hazardous materials, such as cleaning supplies and landscaping products, to
future residents, employees, and visitors of the Project site, the use of these substances would be subject to
applicable federal, state, and local health and safety laws and regulations that are intended to minimize health risk
to the public associated with hazardous materials. The use of commercially available hazardous materials would
not significantly impact AFD services.
According to the Engineering Due Diligence Report (Appendix G of this Draft EIR) there are three mains located on
the Project site available for domestic water and/or fire services connections. The specific location of new
connections required for Project implementation and pipe sizing would be based upon the Citys requirements and
subject to City approval. The system must provide adequate water supply for operation of the buildings domestic
requirements, automatic sprinkler systems and fire hydrants. Fire flows for the proposed development must be
based on the requirements listed in the California Fire Code that is in effect at the time of plan submission, as
amended by the City.
The Project site is located within an urbanized area and is not located within a Very High Fire Hazard Severity Zone
(CAL FIRE 2021). The Project is surrounded by roadways and developed properties on all sides and is entirely
developed, so it is not susceptible to exacerbating wildfire risks. Further, the Project site does not contain extensive
amounts of vegetation or wildland fuel. Therefore, the Project would not result in increased potential for wildland
fire hazards that could affect AFD services.
Given the reasons described above, the proposed Project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered fire protection facilities. Impacts would be less than
significant and no mitigation is required.
Police Protection
Construction
There is the potential for Project construction activities to create an increase in demand for police protection
services, as construction sites can be sources of attractive nuisances, can provide hazards, and can invite theft
and vandalism when not properly secured. This could result in an increase in the demand for police protection
services. During construction, the Project Applicant/developer or its construction contractor would implement
temporary security features including security fencing, lighting, and locked entry. These features would reduce the
need for police protection services during the Projects construction phase. Potential short-term construction
impacts to police services would not result in substantial adverse physical impacts associated with the provision of
new or physically altered police protection facilities, and impacts would be less than significant and no mitigation
is required.
Operation
As with fire protection services, the increased use of the Project site attributable to the proposed Project would be
expected to increase the frequency of emergency and non-emergency calls to the Arcadia Police Department (APD).
While the Project site currently places some demand on the APD due to the occupied commercial and office
buildings, the proposed Project would increase demands relative to existing conditions. The APD has stated that
the existing police station facilities are sufficient to provide service to the proposed Project and that the
development of the proposed Project would not result in the need for new facilities and/or physically altered
facilities to maintain acceptable service ratios, response times, or other performance objectives (Appendix J-2).
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The Project site is currently served by the APD at 250 West Huntington Drive. No expansion of this facility is currently
contemplated or required for the proposed Project (Appendix J-2). Payment of development fees by the Project
Applicant/developer would be used to offset the costs of increased personnel or equipment that could be required
to maintain acceptable service ratios, response times, and other performance objectives. The proposed Project
would incorporate operational practices and design elements to increase safety and to reduce the potential for
crime to occur, including constructing buildings equipped with alarm systems and access controls, and clear
visibility of public spaces and pedestrian corridors. Signage and lighting would be used to facilitate wayfinding and
safe pedestrian movement throughout the site and within the proposed buildings.
The APD has reported the current APD established performance standards are being achieved and the existing police
station is sufficient to provide service to the proposed Project (Appendix J-2). For these reasons, the proposed Project
would not result in substantial adverse physical impacts associated with the provision of new or physically altered
police protection facilities and potential impacts would be less than significant and not mitigation is required.
Schools
The proposed Projects approximately 909 residents would generate students that would attend AUSD schools.
Using the student generation rates from AUSD, at 319 dwelling units, the Project could generate approximately 137
new students (Appendix J-3). Communication with Arcadia Unified School District (AUSD) indicates the existing
schools are sufficient to support the proposed Project, and that all schools are below their capacity, even when
including the projected increases due to the Project (Appendix J-3). Education Code Section 17620 allows school
districts to assess fees on new residential and commercial construction within their respective boundaries.
Pursuant to California Government Code Section 65995, the payment of these fees by a developer serves to fully
mitigate all potential project impacts on school facilities from implementation of a project to less-than-significant
levels. Sections 65996(a) and (b) state that such fees collected by school districts provide full and complete school
facilities mitigation under CEQA. These fees can be collected without special city or county approval, to fund the
construction of school facilities necessitated by the impact of residential and commercial development activity.
The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required
to pay to mitigate a projects impacts on school facilities. The maximum fees authorized under SB 50 apply to zone
changes, general plan amendments, zoning permits and subdivisions. Pursuant to SB 50, the applicant would be
required to pay development fees for schools to AUSD prior to the issuance of the Projects building permit. The
provisions of SB 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding
any contrary provisions in CEQA or other state or local law. Therefore, with the payment of the applicable school
fees, the operation of the Project would not result in substantial adverse physical impacts associated with the
provision of new or physically altered schools, or the need for new or physically altered schools, the construction of
which could cause significant environmental impacts to maintain acceptable service ratios, or other performance
objectives for schools. As such, impacts on schools would be less than significant and no mitigation is required.
Parks
The Project would include 909 new residents. At least a portion of these residents are anticipated to patronize the
various public parks and recreation facilities located in proximity to the Project site. The Project would redevelop
the space between the existing office building and the proposed residential building with a new paseo and outdoor
plaza. This community open space area would include on-site wayfinding features, minimized vehicular access,
flexible pedestrian space, seating, trees and enhanced plantings, lighting, bicycle parking. The proposed Project
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would provide approximately 23,957 square feet of private open space and 17,398 square feet of public open
space, which exceeds the Citys requirement for 31,900 square feet of open space.
The CDPR minimum standard of park space is approximately 3 acres per 1,000 residents. The Los Angeles County
average is 3.3 acres per 1,000 residents, and the Citys strives to provide a minimum of 2.43 acres per 1,000
residents. The City and the County currently differ on where the City stands regarding the acreage per 1,000 resident
ratio because they each use different methodologies for determining the available park acreage. According to the
LACDPR, under existing conditions the City currently provides 1.32 acres of parkland per 1,000 residents
(Appendix J-4), and according to the ARCSD, the City provides 2.38 acres per 1,000 residents (Appendix J-4).
According to both agencies, the City is not currently meeting the acre per resident goal of 3.3 acres (County) and
2.43 acres (City) per 1,000 residents, respectively. When the projected population increase related to the Project
is incorporated, the City would continue to underperform when compared to the standards provided by both the
City and the County.
The state utilizes a slightly different model for calculating park service ratios. As previously discussed, the CDPR
FactFinder tool calculates parks acreage per 1,000 residents within a half-mile radius of a given center point (i.e.
150 North Santa Anita Avenue). According the CDPR, under existing conditions, the Project site is in a location with
an abundance of park space (19.68 acres per 1,000 residents), which significantly exceeds the minimum standards
provided by the CDPR, LACDPR and ARCSD. Under projected Project conditions, the City would continue to exceed
the minimum acreage standards by at least a factor of five (CDPR 2021). The City does not consider the Special
Parks, Joint-Use Parks and Facilities, County Parks and Facilities as municipal assets for recreation and does not
take credit for these facilities in the calculation of acres of parkland per residents. However, these additional 545
acres of parks and recreation facilities within the City do provide an important asset for the City residents and
towards the overall available open space and recreation amenities within the City.
Nevertheless, the City does not currently provide the 2.43 acres per 1,000 residents, as required by the Citys
General Plan. In order to address the additional demand on recreational facilities within the City, the proposed
Project would be subject to the Citys Council Resolution 6602, Park Facilities Impact Fee (Section 9105.15.040 of
the Citys Development Code), which requires new development projects to pay impact fees, which would support
park improvements as well as fund capital costs for new and existing recreational infrastructure. Pursuant to the
Park Facilities Impact Fee resolution, the Project Applicant/developer would pay its fair share of impact fees based
on the fee category and adopted impact fee rates. While the ARCSD indicates that new park facilities would be
required under both existing and Project conditions to meet the Citys performance standards, the mitigation fees
paid to the City as part of the proposed Project would fairly compensate for the Project associated increase in
demand or use of park facilities. Fees for the proposed Project are currently set at $3.73 per square foot, which
applies to all multifamily housing developments (City of Arcadia 2021a). Further, the Project would include common
open space areas, including an outdoor pool area, fire pit, barbeque dining area, game lounge, and a lawn/grassy
area, as well as an outdoor passive court. These on-site amenities would provide an alternative to off-site public
parks and recreational facilities, allowing the Projects residents to recreate on the Project site while incrementally
reducing impacts to off-site public parks and recreational facilities. Therefore, with required payment of fees as
mandated by the Citys Development Code, impacts associated with the need for new or expanded park facilities
would be less than significant and no mitigation is required.
Other Public Facilities
Other public facilities and services provided within the City include library services. Library services are provided at
the APL located at 20 West Duarte Road, approximately 0.9-mile south of the Project site. The APL indicated that
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although library staffing is currently not meeting their goal of a 0.9-ratio of staff per 1,000 residents, this existing
staffing deficit would not result in the need to provide any new library facilities and/or physically altered facilities to
maintain performance objectives of the Arcadia Public Library (Appendix J-5).
Another library located within the City boundaries is the Live Oak Library, which is managed by the County and
located 2.8 miles south of the Project site at the far southern end of Arcadia. The County levies a developer fee for
new residential projects within the unincorporated County and levies a special tax on parcels within 10 incorporated
cities, excluding Arcadia. As such, the proposed Project is outside of the Live Oak Library service area and is not
subject to any fees. The Countys library is 2.8 miles away from the Project site and is not anticipated to be utilized
frequently by proposed Project residents, as the APL is located almost two miles closer to the site.
The proposed Project is a mixed-use development project that would contribute to the tax revenues for the City,
thereby contributing to potential funding sources for library services. As stated above, the APL has indicated that
no new library facilities are required to serve the proposed Project. Therefore, impacts to other public facilities in
the area resulting from the proposed Project would be less than significant and no mitigation is required.
Increase in the Use of an Existing Neighborhood, Regional Park, or Recreational Facility
The Project would include 909 new residents. As previously discussed, the ARCSD is responsible for developed park
land that provides a wide variety of attractions and amenities. The City also offers a wide variety of recreational
programs and activities for residents, which have transitioned to become entirely virtual, for the time being. Virtual
offerings include soccer drills and yoga classes for kids and seminars for adults and seniors. At least a portion of
the potential future residents are anticipated to patronize the various public parks and recreation facilities located
in proximity to the Project site. Pursuant to the Section 9105.15.040 of the Development Code, the Project
Applicant/developer would pay its fair share of impact fees based on the fee category and adopted fee rates,
currently set at $3.73 per square foot for multifamily developments. While the ARCSD indicates that new park
facilities would be required under both existing and Project conditions to meet the Citys performance standards,
the mitigation fees paid to the City as part of the proposed Project would fairly compensate for the Project
associated increase in demand or use of park facilities. Fees for the proposed Project are currently set at $3.73
per square foot, which applies to all multifamily housing developments (Appendix J-4). Further, the Project would
include common open space areas, including an outdoor pool area, fire pit, barbeque dining area, game lounge,
and a lawn/grassy area, as well as an outdoor passive court. These on-site amenities would provide an alternative
to off-site public parks and recreational facilities, allowing the Projects residents to recreate on the Project site
while incrementally reducing impacts to off-site public parks and recreational facilities.
As such, with payment of the required development impact fees related to parks and recreation in combination with
provision of on-site recreational facilities, the Project would meet the anticipated demand for neighborhood and regional
parks or other recreational facilities. Project residents and, to a certain extent, the public utilizing the improved pedestrian
corridor and/or café, would have access to adequate on-site recreational facilities, which would offset increased use of
existing parks and recreational facilities in the City. Therefore, implementation of the Project would not result in a
substantial increase in the use of existing neighborhood and regional parks or other recreational facilities such that
substantial physical deterioration of the facility would occur. Impacts to neighborhood and regional parks would be less
than significant and no mitigation is required.
Inclusion of or Requirement for Construction/Expansion of Recreational Facilities
The performance standard for different responsible park agencies ranges between 2.43 to 3.30 acres per 1,000
residents and the City is currently underperforming on a City-wide basis. However, within the immediate Project
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area, there is an abundance of park space under both existing and projected Project conditions. The Project would
also include common open space areas, as well as landscaped areas around the Project site, including an outdoor
pool area, fire pit, barbeque dining area, game lounge, and a lawn/grassy area, as well as an outdoor passive court.
The construction of these common open space areas and associated recreational amenities is analyzed under this
EIR. As demonstrated throughout this Draft EIR, any environmental impacts as a result of Project implementation
would be reduced to a less-than-significant level through the incorporation of the mitigation measures described
throughout. Additionally, the Project would be subject to the Park Facilities Impact Fee resolution, which requires
new development projects to pay impact fees, which would support park improvements as well as fund capital costs
for other new and existing infrastructures. Pursuant to the Impact Fee, the Applicant/developer would pay its fair
share of impact fees based on the fee category and adopted fee rates, currently set at $3.73 per square foot. As
such, Project implementation would not require the construction or expansion of recreational facilities, and impacts
would be less than significant.
Cumulative Effects
The cumulative study area used to assess potential cumulative population and housing impacts includes the City
of Arcadia, AFD and APD service areas, and the AUSD. Cumulative impacts on public services including fire and
police protection, parks, and schools would result when projects collectively increase demand on services such that
additional facilities or services must be constructed or provided.
Fire Protection
A cumulatively significant impact related to fire protection and emergency services could occur as a result of
population growth and development within the AFD service area due to the Project and cumulative projects. The
Project, along with cumulative projects, could result in increased calls and demands for fire protection and
emergency services. The AFD stated that as the City continues to see higher density projects, call volume will
continue to see an increase, which will result in longer response times. Additionally, response times would inevitably
increase due to the increased burden of access associated with responding to incidents in multi-story
developmentssuch as the proposed Projectincluding the need to traverse up and/or across through stairwells,
elevators, and/or use of the aerial ladder. In addition, in downtown Arcadia there are a number of new mixed-use
buildings of similar density to the proposed Project being contemplated.
As such, the AFD is currently conducting analysis of the call response times and staffing resources that may be necessary
to keep response times within the City's guidelines. This analysis may result in a AFD Program or Impact Fee and may
result in a fair share contribution from this Project, as described under Conditions of Approval above, as well as
subsequent projects in the downtown area. This AFD Program or Impact Fee would fund solutions to address the
densification and multi-story development within the City and the downtown area specifically. An anticipated solution to
be funded by the AFD Program or Impact Fee to help decrease response times and increase emergency response safety
would be the implementation of an alerting or pre-emption system that is integrated with the City's traffic light system.
An example of such a system is HAAS ALERT. Such a system would not result in physical impacts to the environment, as
such technologies generally consist of a software program that would be mounted to the existing traffic lighting system
on existing streets. The AFD is currently working on a study that will apply to the downtown area.
The AFD has not identified the need for any new or altered fire stations or governmental facilities that would have
the potential to result in substantial adverse physical impacts, 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. Therefore, potential cumulative impacts would be less than significant, and
no mitigation is required.
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Additionally, both the Project and cumulative projects would be subject to the requirements of the fire code
standards. This would be ensured through the plan check process and fire review prior to the issuance of building
permits for the Project and cumulative projects. Furthermore, the Project and cumulative projects would
coordinate with the Arcadia Fire Department Fire Prevention Division to ensure fire flow requirements are met
and any required upgrades to the existing water distribution system are addressed for each individual project. As
determined by AFD, existing fire protection facilities are sufficient to meet the proposed Project (Appendix J-1).
Based on the above considerations, the Projects contribution to cumulative impacts to fire protection services
would be less than significant.
Police Protection
A cumulatively significant impact related to police protection services could occur as a result of population growth within
the APD service area due to the Project and cumulative projects. The APD has stated that the existing police station
facilities are sufficient to provide service to the proposed Project and that the development of the proposed Project would
not result in the need for new facilities and/or physically altered facilities to maintain acceptable service ratios, response
times, or other performance objectives (Appendix J-2). As with the proposed Project, the applicants of the cumulative
projects would be required to incorporate appropriate safety features into the design and construction of their respective
projects to minimize the potential for crime and to maximize safety, ultimately minimizing the need for police protection
services. In addition, the cumulative projects would contribute to funding police protection services or new facilities
through development impact fees. Based on the above considerations, the Projects contribution to cumulative impacts
to police protection services would be less than significant.
Schools
The increase in student population as a result of the proposed Project and cumulative residential projects could
require the construction or expansion of school facilities. The proposed Project itself, as determined by AUSD would
not result in significant impacts on service demand (Appendix J-3). While most cumulative projects require
discretionary actions, they would incrementally increase the need for school facilities. However, Education Code
Section 17620 allows school districts to assess fees on new residential and commercial construction within their
respective boundaries. Pursuant to California Government Code Section 65995, the payment of these fees by a
developer serves to fully mitigate all potential project impacts on school facilities from implementation of a project
to less-than-significant levels. Sections 65996(a) and (b) state that such fees collected by school districts provide
full and complete school facilities mitigation under CEQA. Therefore, the increase in the demand for school facilities
and services due to cumulative development would be less than significant level by the payment of development
impact fees.
Parks and Recreational Facilities
Buildout of the Project along with cumulative projects would increase use of existing local and regional parks and
could result in the accelerated deterioration of park and recreation facilities. As discussed, the Project itself would
result in less than significant impacts to park and recreation facilities. The deterioration that would occur to local
parks and recreational facilities from regional population growth may be offset with funding from new development
through Park Facilities Impact Fees. Cumulative projects would be required to demonstrate compliance with CEQA
prior to Project approval, and existing federal, state, and local regulations related to parks and recreational facilities
would mitigate potential adverse impacts to the environment that may result from the expansion of such facilities.
Therefore, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact
to park facilities.
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Other Public Facilities (Libraries)
Future cumulative development would generate new tax revenues and would be subject to the Citys development
impact fees, which act as funding sources for City libraries. The proposed Project itself, as determined by the APL,
would not result in new physical facilities (Appendix J-6). The Project and cumulative projects would be required to
fund their fair share of an established fee program designed to alleviate the cumulative impact. These revenues
would help offset the increase in demand for library services as a result of the Project. Therefore, cumulative
impacts to library services would be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on police and fire protection services, parks, schools, and other public facilities as well as impacts related
to recreation; therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.
2.3.16 Transportation
Conflict with Circulation System Plan, Ordinance, or Policy
RTP/SCS Consistency Analysis
The Project would facilitate a more balanced jobs-housing profile and once constructed, would continue to support
regional economic development. In addition, the Project sites vicinity is served by existing public transit including
Metro Routes 79, 187, and 287 and the Metro L Line; Foothill Transit Line 187; and Arcadia Transits Green and
Red Lines. Project development would increase transit accessibility of jobs and services within the Project sites
vicinity and would bring residential development the Citys Downtown, which contains a mix of office and
commercial development uses, thereby reducing travel demands for people. Further, the Project includes objectives
to support walkability and increased pedestrian access to support connectivity with the nearby Arcadia Metro L Line
Station. For these reasons, the proposed Project would not conflict with the applicable goals in the RTP/SCS.
City of Arcadia General Plan Consistency
The Project would be consistent with the applicable goals and policies of the Citys General Plan. The project would
not hinder the Citys ability to provide an efficient roadway system that serves all transportation modes and balances
the roadway system with planned land uses. The project would support the Citys goals to provide a connected,
balanced, and integrated bicycle and pedestrian network by developing a mixed-use project that promotes
pedestrian connectivity with the Citys Downtown and includes on-site improvements to facilitate circulation and
community cohesion within the existing environment.
Transit, Bicycle, and Pedestrian Facilities
The proposed Project would support transit, bicycle, and pedestrian circulation throughout the Project site and the
surrounding environment and would not conflict with any plans or policies regarding existing or proposed transit,
bicycle, and pedestrian facilities in the study area.
The Project would include bicycle parking as well as on-site improvements to support pedestrian connectivity with
the Citys Downtown and nearby Arcadia Metro L Line Station. Site improvements include redeveloping the space
between the existing office building and the proposed residential building with a new paseo and outdoor plaza. This
community open space area would include on-site wayfinding features, minimized vehicular access, flexible
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pedestrian space, trees and enhanced plantings, lighting, and bicycle parking. Additionally, the alleyway adjacent
to the eastern boundary of the Project site would be partially converted into a pedestrian and bicycle paseo and
would facilitate connectivity between the Arcadia Metro L Line Station and the Citys downtown amenities. Stairs
and a ramp would be installed on the Project sites southwest side between the residential building and existing
office tower, which would create an entrance to the paseo to the north from Wheeler Avenue. Pedestrian access is
also proposed to provide access to the paseo from the garage. The northern lobby would be accessible via the alley
and Santa Clara Street, and the southern lobby would be accessible via the alley and Wheeler Avenue. Sidewalks
and other designated pathways would follow direct and safe routes from the external pedestrian circulation system
to each building on the Project site. All pedestrian areas within the Project site would meet American Disability Act
(ADA) requirements and adhere to City design guidelines. Bicyclist and pedestrian safety would be maintained at
existing levels in the area. Additionally, the Project would not conflict with or result in the change of bus routes in
the study area; therefore, the Project would not severely delay, impact, or reduce the service level of transit in the
area. Therefore, the Project would not adversely affect, in a manner that conflicts with, an applicable program, plan,
ordinance, or policy, addressing the performance of the circulation system, including public transit, roadway, bicycle
or pedestrian facilities. Impacts would be less than significant.
Conflict with CEQA Guidelines Section 15064.3 (b)
State CEQA Guidelines Section 15064.3(b) focuses on newly adopted criteria (VMT) adopted pursuant to SB 743
for determining the significance of transportation impacts. The following VMT analysis is based on the City of Arcadia
Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (City of Arcadia 2020)
and OPRs Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018). As shown in the analysis
below, the Project would be screened from a project-level analysis and no impacts due to conflicts or inconsistencies
with Section 15064.3(b) are presumed, and impacts would be less than significant.
Screening Criteria
The Citys Guidelines provide three types of VMT screening that can be applied to the proposed Project to screen
from a project-level VMT assessment. The screening criteria are consistent with the recommendations provided in
OPRs Technical Advisory.
Transit Priority Area (TPA) Screening
Projects located within a TPA may be presumed to have a less than significant impact absent substantial evidence
to the contrary. This presumption may not be appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
2. Includes more parking for use by residents, customers, or employees of the project than
required by the jurisdiction (if the jurisdiction requires the project to supply parking);
3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization)
4. Replaces affordable residential units with a smaller number of moderate- or high-income
residential units
As shown in Appendix K-1, the proposed Project is located within a TPA. The Arcadia Metro L Line Station (East Los
Angeles to Azusa) is located approximately 400 feet north of the Project site, with a weekday peak service frequency
of five minutes. Additionally, the nearest bus service is provided by LA Metro Routes 79 and 287, along with Foothill
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Transit Route 187, with stops along 1st Avenue, Huntington Drive, and Santa Anita Avenue surrounding the Project
site. Peak frequencies range between 10 minutes (78/79 within the downtown Los Angeles area) and 40 minutes
(LA Metro Routes 79 and 287 within Arcadia). As previously noted, Route 79 operates in conjunction with Route 78
within the downtown Los Angeles area, upon which the route splits into two separate lines in the City of Alhambra,
with Route 79 traveling along Huntington Drive. Foothill Transit Route 187 operates with peak service frequencies
of 20 minutes. Although the nearby bus transit services do not operate with peak service frequencies of 15 minutes
or less, the Project site is located within one-half mile of a TPA as the Arcadia Metro L Line Station serves a Major
Transit Stop, operating with a weekday peak service frequency of 5 minutes. Therefore, the Project can be screened
out using this criterium.
Low VMT Area Screening
Residential and office projects located within a low VMT- generating area may be presumed to have a less than
significant impact absent substantial evidence to the contrary. In addition, other employment-related and mixed-
use land use projects may qualify for the use of screening if the project can reasonably be expected to generate
VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area.
This presumption may not be appropriate if the Project land uses would alter the existing built environment in such
a way as to increase the rate or length of vehicle trips.
For this screening, the SCAG travel forecasting model was used to measure VMT performance for individual traffic
analysis zones (TAZs). TAZs are geographic polygons similar to Census block groups used to represent areas of
homogenous travel behavior. Total daily VMT per service population (population plus employment) was estimated
for each TAZ.
The SGVCOG screening tool (available at https://www.sgvcog.org/vmt-analysis-tool) was used to determine whether
or not the proposed Project would be located in a low VMT-generating area. Per the Citys guidelines, a low VMT-
generating area is determined as 15% below the subarea baseline home-based VMT per capita and VMT per
employee. The VMT per Capita for the project TAZ is 11.78, and the subarea jurisdictions average is 15.61. Further,
the VMT per Worker for the project TAZ is 15.45, and the subarea jurisdictions average is 19.17. Therefore, the
TAZ would be 27.97% and 21.49% below the subarea threshold for VMT per Capita and per Worker, respectively,
which would meet the required baseline screening criteria established in the Citys guidelines. As such, the
proposed Project can be screened out using this criterium.
Project Type Screening
The Citys guidelines list local serving land uses that have been identified as having the presumption of a less than
significant impact. The land uses include land uses such as local serving schools, parks, day care centers, and local
serving retail of less than 50,000 square feet. The uses are those which should be able to demonstrate that its
users (employees, customers, visitors) would be existing within the community. The screening criterion also
identifies projects that would generate less than 110 daily vehicle trips and having a presumption of less than
significant. The proposed residential component of the Project would not fall under a local serving land use and
would also generate greater than 110 daily vehicle trips; therefore, this component of the Project cannot be
screened out from further VMT analysis using this criterium. However, the 750 square-foot proposed café would
serve as a local serving land use and can be screened out using this criterium.
In conclusion, while the residential component of the Project would not be screened out from VMT analysis using
the Project Type Screening, based on SB 743 and the revised CEQA guidelines, the Citys Transportation Study
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Guidelines for Vehicle Miles Traveled and Level of Service Assessment, and the San Gabriel Valley Council of
Governments (SGVCOG) VMT Assessment tool, the entire Project would be screened from a project-level VMT
analysis because the Project is in a Low VMT generating area within a TPA. Therefore, a VMT analysis is not required
and impacts to VMT would be less than significant.
Hazards Due to Geometric Design Feature
Project Access
The existing Project site is currently configured with seven access points. Proposed vehicular circulation to the
Project site and parking structure would remove or reconfigure four access points to provide full access drive aisles
as well as entrance-only and exit-only locations to and from the proposed parking garage, as follows:
Project Driveway (Northwest)/Santa Clara Street: ATM driveway; exit only
Alley Project Driveway (Northeast)/Santa Clara Street: Full access
Santa Anita Avenue/Project Driveway (West): Right-out; exit only (currently right-in; inbound only)
Project Driveway (Southwest)/Wheeler Avenue: Full access
Existing Driveway (North)/Santa Clara Street: To be removed
Existing Driveway (South)/Wheeler Avenue: To be removed
Alley Project Driveway (Southeast)/Wheeler Avenue: To be closed to non-emergency vehicular traffic
As noted above, vehicular access to the Project site would be available from the alley on the eastern edge
of the Project site from Santa Clara Street. An entrance and exit point to the parking structure is proposed
along the alleyway on the east side of the Project site from Santa Clara Street. Two sets of approximately
10 removable bollards are proposed within the eastern alleys right-of-way, closing off the alleyway south
of the parking garage entrance to Wheeler Drive from vehicular traffic to facilitate pedestrian and bicycle
movement between the L Line Station and Downtown Arcadia. The other parking garage access point is
located at the southwest corner of the garage, and can be accessed from Wheeler Avenue, which provides
full access to the site. Additionally, an exit-only drive aisle would also provide direct egress to Santa Anita
Avenue, south of the existing office building. It must be noted that this drive aisle currently exists and is
proposed to remain; however, it is currently designated as an ingress only drive aisle and would be
converted to an egress only drive aisle with the development of the proposed Project. Finally, an egress
point is provided through the existing ATM exit-only drive-thru at the northwestern corner of the site.
All reconfigured driveways and internal access points would be designed and constructed to ensure
appropriate line of sight and appropriate turning radii. The reconfigured driveways are also proposed to
better facilitate the internal site circulation pattern to meet the needs of both the existing and proposed
uses. No impacts are anticipated with the reconfigured driveways. The following design features would
facilitate access to the drive-thru and maintain flow through the parking garage:
Wayfinding signage would be provided at all parking garage ingress points for customers prior to entering
the garage
Wayfinding signage would be provided within the parking garage such that customers are directed to the
ATM drive-thru, and other users of the site are channeled to parking spaces and garage exits.
Northbound left-turning movements onto Santa Clara Street would be restricted.
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On and Off-site Queuing Analysis
To ensure the Project would not result in driveway queueing onto Santa Clara street, Santa Anita Street, or
Wheeler Avenue, which could create hazards to oncoming traffic, a queuing analysis was conducted at the
project driveways and for specific turning movements at adjacent intersections (see Appendix K-2). The
queuing analysis was prepared for all project driveways to assess the adequacy of any off-site storage lanes
into the Project site, as well as the adequacy of driveway throat lengths and space on-site for vehicles to
queue without impacting the internal circulation on the Project site. Queuing was analyzed utilizing the
SimTraffic software, which calculates the 95th percentile (design) queue. All queuing analysis data and
SimTraffic queuing worksheets are provided in Appendix K2.
None of the calculated 95th percentile (design) queues exceed storage capacities within the existing left-
turn pockets on Santa Clara Street, Santa Anita Avenue, or the two-way-left-turn-lane along Santa Clara
Street. None of the queues would conflict with turning movements into or out of the Project site, within the
internal access drive aisles, or along eastbound Wheeler Avenue with the addition of Project traffic during
the Existing and Opening Year (2024) conditions.
The longest 95th percentile queue is shown for the westbound, stop-controlled turning movement at the
Santa Anita Avenue/Wheeler Avenue intersection, reaching 94 feet in the PM peak hour under Existing plus
Project conditions and 96 feet in the PM peak hour under the Opening Year (2024) plus Project conditions.
Twenty-five (25) feet is equivalent to approximately one (1) car waiting to exit from the Project driveway
onto the adjacent street during the peak hour. Based on this assumption, approximately four (4) vehicles
would queue up to the intersection and would not overlap into the Project driveway.
Additionally, the 95th percentile queue for the westbound left-turn lane extends approximately 10 to 15 feet past
the striped left-turn pocket, but does not extend past the available stacking distance (as measured from the
intersection stop bar to the ATM driveway exit). This is an acceptable queue and would not impede operations at
the ATM driveway. In addition, the Project would restrict northbound left-turning movements onto Santa Clara Street
given the proximity of the intersection as noted above. As queueing would not exceed available stacking distances,
the addition of Project traffic would not create increased hazards due to a geometric design feature or incompatible
uses. Impacts would be less than significant and no mitigation is required.
Inadequate Emergency Access
Operation
All areas of the Project site would be accessible to emergency responders for the long-term operation of
the proposed Project. Local access to the Project site would be provided via Santa Anita Avenue, Santa
Clara Street, Wheeler Avenue, and 1st Avenue. All the Project access points would be designed according
to the Citys applicable design standards. The proposed Project would provide adequate access to the
Project site, including access for emergency vehicles. The internal drive aisles and loading and parking
areas would be designed to comply with Citys width, clearance, and turning radius requirements of the Fire
Department, which were established to ensure safe and efficient vehicular circulation. Because the project
would comply with all applicable local requirements related to emergency vehicle access and circulation,
the project would not result in inadequate emergency access. Therefore, operational impacts associated
with inadequate emergency access would be less than significant.
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Cumulative Effects
Plan, Program, Ordinance, or Policy Addressing Circulation
The proposed Project is consistent with the following plans addressing the circulation system SCAG 202020405
RTP/SCS; City of Arcadia General Plan; and the Metro Long Range Transportation Plan. The Project and would not
conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities under
cumulative conditions. Therefore, cumulative impacts related to a program, plan, ordinance, or policy related to
addressing the circulation system would be less than significant.
CEQA Guidelines Section 15064.3(b)
The Project is located within a low VMT generating area and within a TPA. The Project would be screened from a
project-level VMT analysis. Cumulative impacts can be presumed to be less than significant.
Hazardous Design Features
As discussed above, the Projects reconfiguration of the existing site access would not result in hazardous
conditions into or out of the Project site. The proposed Project has a completed circulation analysis using LOS
methodology provided in Appendix K-2, along with a 95th percentile queueing analysis provided in Appendix K-2 and
detailed in the section above, that indicates that the trips generated by the proposed Project would not result in
adverse circulation conditions. Because the impacts related to Project access points and circulation are site
specific, and would be less than significant, the Project would not contribute to cumulative impacts with respect to
hazardous design features.
Emergency Access
The Project would not result in inadequate emergency access and Project impacts to emergency access would be
less than significant. As with the proposed Project, driveways and/or circulation modifications proposed in the
surrounding area would comply with applicable local, regional, state, and/or federal requirements related to
emergency access and evacuation plans. Further, since modification to access are largely confined to the Project
site and the immediately surrounding area, Project-specific emergency access impacts would likely not impact other
cumulative projects. Therefore, the Projects contributions to cumulative impacts would be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on transportation as it relates to conflict with circulation system plan, ordinance, or policy; conflict with CEQA
Guidelines Section 15064.3 (b); inadequate emergency access; and cumulative impacts. Therefore, no mitigation
is required, and no significant, unavoidable adverse impacts would occur.
2.3.17 Tribal Cultural Resources
Change in a State listed or Eligible Tribal Cultural Resource
A CHRIS records search and pedestrian survey were conducted for the Project site. The CHRIS records search,
archival research, and the pedestrian survey did not identify any previously recorded archaeological resources of
Native American origin within or surrounding the Project site that are listed or eligible to be listed in the CRHR or in
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a local register. Further, no specific TCRs have been identified by California Native American tribes as part of the
Citys AB 52 notification and consultation process (Appendix L) that could be eligible for listing in the CRHR or in a
local register as a historical resource as defined in Public Resources Code section 5020.1(k). Therefore, the Project
would not adversely affect TCRs that are listed or eligible for listing in the state or local register. Impacts would
therefore be less than significant.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on tribal cultural resources as it relates to impacts to any listed resource or a resource eligible for listing.
Therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.
2.3.18 Utilities and Service Systems
Require or Result in the Relocation or Construction of New or Expanded Water, Wastewater Treatment, Stormwater
Drainage, Electric Power, Natural Gas, or Telecommunications Facilities
Water Conveyance
The City of Arcadia is its own water supplier, approximately 96% of the population living within the Citys sphere of
influence is served by the Arcadia water system, which supports approximately 13,400 service connections (City of
Arcadia 2013). The City primarily sources its water from the San Gabriel Valley and Raymond Groundwater Basins,
as well as from water imported from the Upper District.
The Citys water distribution infrastructure comprises 164.6 miles of water lines (City of Arcadia 2013). According
to the Report of Existing Infrastructure contained in Appendix G, the water lines closest to the Project site include
an 8-inch cast iron water main with 50 psi static pressure on Santa Clara Street, an 8-inch cast iron water main
with 54 psi static pressure on Wheeler Street and a 30-inch welded steel water main with 55 psi static pressure on
Santa Anita Avenue. These three mains are available for domestic water and/or fire services. The water service
connection for domestic water and fire protection within the proposed Project site would be made to one or more
of the existing City water lines the development area. The specific location of these connections and pipe sizing
would be based upon the Citys approval.
The proposed Project would increase water demand on the Project site relative to existing conditions, due to the
proposed increase in land use intensity. As such, the Project would place additional demands on the existing water
infrastructure that serves the area. To determine the potential constraints on the existing water infrastructure that
could be caused by the proposed Project, water flow requirements were measured against the available water flow
from the existing infrastructure.
Through flow assessment, it was determined that the existing system would provide adequate water supply for
operation of the Projects domestic requirements, automatic sprinkler systems and off-site fire hydrants, if required
by the state or City Fire Marshal. Fire flows for the proposed Project would be based on the requirements listed in
the version of the California Fire Code that is in effect at the time of plan submission, as amended by the City.
While it was determined that adequate water supply exists to serve the proposed Project, results of the flow test
demonstrated that the static and dynamic pressure on the public water system around the Project area is relatively
low. As demonstrated in the fire flow test provided by the City (Appendix G) fire and domestic water booster pumps
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would be required to ensure adequate pressure. The required booster pumps are included as a design feature of
the Project. The booster pumps would be located on-site in a dedicated room within the ground level parking garage.
Access would be provided via the alleyway along the southwest corner of the proposed residential development.
The Projects anticipated water demand falls within the future supply projections for the City of Arcadia. (These
projections take into account treatment of the water supply in accordance with regulatory standards.) As such, the
proposed Project would not require or result in the need for new or expanded water treatment facilities.
Water infrastructure required for the proposed Project would thus be limited to on-site infrastructure, consisting of
a booster pump, new water meters and connections to the existing water system to provide domestic water, fire
water, and irrigation water to the proposed Project. Connections may also be required to provide water conveyance
to additional fire hydrants. The minimum number of fire hydrants required would be calculated using Table C102.1
from the California Fire Code and the minimum number of fire hydrants would be installed pursuant to the California
Fire Code. Installation of new water connections would consist of either trenching to the depth of pipe placement
or using trenchless technology, which causes less ground disturbance. Trenching would result in temporary
stockpiling of soil along the length of the trench, pending backfilling, which could result in potential short-term
erosion and siltation. Trenchless technology requires temporary stockpiling of soil adjacent to excavations on both
ends of a pipe section. Environmental effects associated with soil disturbance and the potential for erosion and
siltation during this process would be addressed through construction best management practices for water quality
protection, including sandbag barriers, dust controls, perimeter controls, drain inlet protection, and proper
construction site housekeeping practices. Construction of water infrastructure for the Project would be limited to
the Project site boundaries and its immediate street frontages and would occur during the Projects construction
phase. As such, impacts associated with installation of water infrastructure necessary for the Project have been
analyzed in the EIR. No additional impacts outside of those analyzed and disclosed throughout this EIR would occur
as a result of construction of water infrastructure. For all of the foregoing reasons, the Projects water conveyance
and treatment impacts would be less than significant.
Sanitary Sewer Conveyance and Treatment
The existing buildings on the Project site proposed for demolition are currently served by an existing City owned and
maintained 8 diameter vitrified clay pipe (VCP) sewer line that runs laterally through the Project sites centerline,
south along the off-site alley way, and then east along Wheeler Avenue, where it intersects with the LACSDs Arcadia-
Sierra Madre Sections 2 and 5 Trunk Sewers. The 15-inch diameter trunk sewer line runs north-south along North
First Avenue and has a capacity of 4.5 million gallons per day (mgd) and conveyed a peak flow of 2.3 mgd when
last measured in 2013 (LACSD 2021). A sewer analysis was performed by Psomas (Appendix M) to determine
whether existing sewers have sufficient capacity to accommodate anticipated wastewater flows associated with the
project. The existing sewer pipes were analyzed using the County of Los Angeles Department of Public Works
(LACDPW) Sewer Manual S-C4 chart which requires a maximum design capacity at half full for pipes less than 15-
inches and at three quarters full for pipes 15-inches and greater. Based on the analysis, the sewer system serving
the Project site would remain under 50% capacity with the addition of the projects anticipated average and peak
flows (Appendix M). As such, the existing sewer system would have adequate capacity to serve the proposed Project,
and no new or upgraded sewer lines would be necessary as a result of the project.
According to the General Plan EIR, 1% of the Citys existing sewer infrastructure needs to be upgraded to
accommodate anticipated growth through 2026 (City of Arcadia 2010), however, the sections identified as requiring
improvements are not located on or adjacent to the Project site and the Project itself would not necessitate the
upgrades. As such, any sewer infrastructure improvements or expansions would be carried out by the City; however,
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the Projects development fees contribute towards any needed future capital improvements, as required through
the Citys regulatory requirements: Article VII, Chapter 4 of the Arcadia Municipal Code regulates sewer line design,
connection to the Citys sewer system, fees, and permits. Article VII, Chapter 5 of the Arcadia Municipal Code
regulates water system connection and fees, with Part 5 addressing water use and the Citys Water Conservation
Ordinance and Water Efficient Landscaping Ordinance.
Wastewater generated by the proposed Project would be treated at the San Jose Creek Water Reclamation Plant
(SJCWRP) located adjacent to the City of Industry, which has a capacity of 100 mgd and currently processes an
average flow of 61.2 mg (LACSD 2021). The remaining capacity at SJCWRP is approximately 38.8 mgd, or
approximately 39% of its total capacity. The existing uses on the project site generate an average flow of 0.03 CFS
(Appendix M). Implementation of the project would increase the average and peak daily wastewater flows from the
project site by 0.01 CFS, which is equivalent to an average flow of 0.0065 mgd (Appendix M). This increase in
wastewater generation represents approximately 0.02% of the remaining capacity of the SJCWRP. As such, the
project would not exceed the available treatment capacity of SJCWRP and would not, therefore, require the
construction of additional wastewater treatment infrastructure.
As with water infrastructure, the on-site sewer infrastructure necessary to serve the Project would consist of meters
and lateral connections to existing sewer lines. The construction processes required to install such infrastructure
would be similar to those described above for the on-site water infrastructure. Similarly, construction of sewer
infrastructure for the Project would be limited to the Project site boundaries and its immediate street frontages and
would occur during the Projects construction phase. As such, impacts associated with installation of sewer
infrastructure have been analyzed in the EIR as part of the project. No additional impacts outside of those analyzed
and disclosed throughout this EIR would occur as a result of construction of wastewater infrastructure. For all of
the foregoing reasons, the Projects wastewater conveyance impacts would be less than significant.
Stormwater Drainage
The proposed Project would not generate increased stormwater runoff. As described under Section 4,8, Hydrology
and Water Quality of this Draft EIR, the drainage patterns of the Project site would not substantially change relative
to existing conditions. .Project design, construction, and operation would be completed consistent with the Rio
Hondo/San Gabriel River Water Quality Group Enhanced Watershed Management Program, and in accordance with
the City Stormwater Management and Discharge Control Ordinance, and the County of Los Angeles Low Impact
Development Best Management Practices Handbook (LID Manual), with the goal of capturing stormwater runoff for
infiltration and reducing the amount of pollutants in stormwater and urban runoff (City of Arcadia 2021c). The
proposed Project would incorporate two drywells and one four-foot diameter primary settling chamber are proposed
to be constructed on the Project site, located in the south side of the basement parking lot, which would be able to
capture the required runoff volume and treat that volume as quickly as it enters the drywell system.
After installation of the infiltration drywells, the peak flow rate on the Project site would decrease by 0.73 cubic
feet per second, resulting in a proposed or post-Project peak flow rate value of 8.08 cubic feet per second.
Because the peak flow rate would be reduced in the proposed condition, it is understood that the existing City
storm drains would not be negatively affected by implementation of the proposed Project. 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. Impacts would
be less than significant.
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Dry Utilities
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 2010). These gas lines would not be
affected by the Projects construction-related activities. There is an existing 2-inch Gas Company gas line in Wheeler
Avenue and Santa Clara Street as well as an 8 gas main along Santa Anita Avenue. It is considered that these lines
will be adequate to provide gas service to the proposed development (Appendix G). No off-site improvements for
natural gas infrastructure are anticipated with the implementation of the proposed Project.
SCE provides electricity to the City and operates four substations within the Citys SOI. Both underground and
overhead electrical distribution lines are present within the City streets and yard easements, and high-voltage
transmission lines exist along the I-605 freeway (City of Arcadia 2010). Pole mounted transformer units currently
service the existing buildings on the east side of the Project site. The portion of overhead power along the alley
that is to be vacated would be demolished and a new power service feed would be established to accommodate
the Project. As part of the Project, a new transfer location would be provided onsite to service the new building
(Appendix G). In compliance with the Citys General Plan, all utilities in the Downtown area must be placed
underground. No off-site improvements for electric power infrastructure are anticipated with the implementation
of the proposed Project.
If unanticipated upgrades were to be required, they would be limited the lateral connections to the Project site and
not any centralized facilities. Any unforeseen upgrades would be coordinated with appropriate service providers to
minimize disruptions on service and would be completed by either trenchless technology or open trenching to the
depth of the underground utilities. Additionally, the Project would be required to comply with all regulatory
requirements and mitigation measures outlined within this Draft EIR for the purposes of mitigating impacts
associated with construction activities. No adverse physical effects beyond those already disclosed in this Draft EIR
would occur as a result of implementation of the Projects proposed utility system connections. Therefore, impacts
to dry utilities would be less than significant.
Sufficient Water Supplies
According to the General Plan EIR, the City of Arcadia is its own water supplier, and provides water to approximately
96% of the population living within the Citys SOI. 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.
The Citys water distribution infrastructure comprises 164.6 miles of water lines (City of Arcadia 2010).
The proposed Project does not involve enough new development to require evaluation pursuant to SB 221 or SB
610 (i.e., does not generate a water demand equal to or greater than that required by a 500-dwelling unit project),
thus, no Water Supply Assessment is required. The proposed Project is consistent with the General Plan and does
not require a General Plan Amendment; therefore, the Project would be consistent with the Citys growth projections
anticipated in local and regional planning documents, including the Citys 2020 Urban Water Management Plan
(UWMP). As stated in the UWMP, the projected populations used in the UWMP for the Citys service area were based
on projections 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.
The proposed Project is anticipated to generate an average demand of approximately 43,620 gallons per day (gpd)
of potable water (Appendix M). The Citys UWMP determines the Citys water demand based on projected
populations in the Citys service area using data provided by SCAG 2020-2045 RTP/SCS (Connect SoCal), and
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incorporates demographic trends, existing land use, general plan land use policies, and input and projections
through the year 2045 from the Department of Finance (DOF) and the US Census Bureau for counties, cities and
unincorporated areas within Southern California (City of Arcadia 2021a). The proposed Project falls within the
growth projections of all applicable planning documents, including SCAGs Connect SoCal.
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 2021a). Additionally, imported water from MWD can be utilized as a
supplemental source of supplies.
The Main Basin Judgment does not restrict the quantity of water, which parties may extract from the Main Basin.
Rather, it provides a means for replacing all annual extractions in excess of a Party's annual right to extract water
with Supplemental Water. The Main Basin Watermaster annually establishes an Operating Safe Yield for the Main
Basin which is then used to allocate to each Party its portion of the Operating Safe Yield which can be produced
free of a Replacement Water Assessment. If a producer extracts water in excess of its right under the annual
Operating Safe Yield, it must pay an assessment for Replacement Water, which is sufficient to purchase one acre-
foot of Supplemental Water to be spread in the Main Basin for each acre-foot of excess production. All water
production is metered and is reported quarterly to the Main Basin Watermaster (City of Arcadia 2021b).
Historical prolonged droughts have caused groundwater levels to decrease resulting in the Raymond Basin
Management Board to temporarily reduce the amount of groundwater which may be produced. The decreased
production is designed to promote recovery of groundwater levels. At such time the groundwater levels have
recovered the program may be suspended but can be reinstated as needed in the event groundwater levels
decrease in the future. Recognizing allowed pumping is limited, the City along with other Raymond Basin producers
have taken steps to reduce water demands to address the potential gap between supply and demand in the event
demands cannot be entirely reduced. The City has production facilities in the Main Basin and has the ability to shift
production, if needed. In addition, the City has a treated water connection and has access to MWD water as an
additional source of supply (City of Arcadia 2021b).
The Project would be required to include all drought-tolerant landscaping requirements included in local regulations.
AMC Section 7554.4, Plan Check Requirements, requires that, as part of the broader general permitting process,
a Landscape Design Plan, and a Landscape Documentation Package be prepared by a licensed landscape architect
that incorporates efficient use of water and BMPs into landscape project design. The proposed Project would not
include any wells that would directly deplete groundwater supplies, and the Citys UWMP anticipates adequate
supply through 2045. 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.
Additionally, Arcadia operates in accordance with Phase I Mandatory Water Conservation Prohibitions, which are
codified by the Citys Water Conservation Plan. Section 7553, Water Conservation Plan, of the Citys Municipal 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.
The proposed Project would adhere to the water conservation methods established in Title 24 of the California
Building Code. The Project would also adhere to the Citys Water Conservation Plan and Water Efficient Landscaping
Ordinance, per Article VII, Chapter 5, Part 5, Division 3 and 4 of the Citys Municipal Code. Additionally, the proposed
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Project would be subject to a development impact/connection fee, which would serve as the Projects fair share
contribution to water infrastructure improvements in the City. As 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.
Adequate Capacity for Wastewater Treatment
The proposed Project would be connected to the existing 8 vitrified clay pipe (VCP) sewer line that runs laterally
through the Project sites centerline, south along the off-site alley way, and then east along Wheeler Avenue, where
it intersects with LACSDs 15-inch Trunk Sewer line running north-south along North First Avenue. Wastewater
generated by the proposed Project would be treated at the San Jose Creek Water Reclamation Plant (SJCWRP)
located adjacent to the City of Industry, which has a capacity of 100 mgd and currently processes an average flow
of 61.2 mg (LACSD 2021). The remaining capacity at SJCWRP is approximately 38.8 mgd, or approximately 39% of
its total capacity. The existing uses on the project site generate an average flow of 0.03 CFS (Appendix M).
Implementation of the Project would increase the average and peak daily wastewater flows from the project site by
0.01 CFS, which is equivalent to an average flow of 0.0065 mgd (Appendix M). This increase in wastewater
generation represents approximately 0.02% of the remaining capacity of the SJCWRP.
Based on the capacity of the SJWRP, the wastewater generated by the proposed Project would be nominal 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. Finally, water conservation measures as established at the local and state level would be implemented and
would help reduce the amount of wastewater generated by the Project. Therefore, impacts would be less than significant.
Generation of Solid Waste
Construction
The Citys non-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. 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.
The proposed Project would involve redevelopment of the existing surface parking lot and three existing commercial
buildings. Demolition and construction activities associated with the proposed Project would result in the generation of
solid waste such as scrap lumber, concrete, residual wastes, packing materials, plastics, and soils. Per CALGreen
standards, 65% of construction and demolition waste must be diverted from landfills (CalRecycle 2020). As such, at least
65% of all construction and demolition debris from the site would be diverted. Additionally, any hazardous wastes that
are generated during demolition and construction activities would be managed and disposed of in compliance with all
applicable federal, state, and local laws. The remaining 35% of construction and demolition material that is not required
to be recycled would either be disposed of in a regional landfill or voluntarily recycled at a solid waste facility with available
capacity. As described in Section 4.15.1, Existing Conditions, the inert landfill in the County (Azusa Land Reclamation
landfill) has a remaining capacity of 51,512,201 tons and is expected to remain open for approximately 25 years, as of
2021. Due to the temporary nature of construction and required compliance with the Citys Municipal Code regulations
applicable to garbage, refuse and recycling (Article V, Chapter 1), construction would not generate waste in excess of
standards or in excess of the capacity of local infrastructure and would not otherwise impair the attainment of solid waste
reduction goals. Impacts would be less than significant.
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Operation
Once operational, the proposed Project would produce solid waste on a regular basis, in association with operation
and maintenance activities. Based on the CalEEMod solid waste generation rates, the proposed Project would
generate approximately 248 tons of solid waste per year (Appendix C-1, CalEEMod Outputs). This amount assumes
compliance with AB 939 requirements for 50% waste diversion from landfills. Solid waste generated by the proposed
Project would be collected and transported to a local or regional landfill. There is only one landfill within approximately
25 miles of the Project site: the Azusa Land Reclamation landfill (Azusa landfill), located approximately 6-miles east.
The Azusa landfill has a remaining capacity of 51,512,201 tons and is expected to remain open for approximately 25
years, as of 2021. As such, the annual solid waste that is anticipated to be produced by the proposed Project would
equate to approximately .00048% of the available capacity of the landfill through the estimated closure date. This
number would be further reduced in order to comply with CALGreen requirements for 65% waste diversion, which
would require the Project Applicant/Developer to either submit a construction waste management plan to the City that
identifies the C&D waste materials to be diverted from the landfills or use a waste management company that can
provide verifiable documentation that the percentage of C&D waste material diverted from the landfill meets
CALGreens 65% requirement.
Furthermore, according to the latest annual report for the Countywide Integrated Waste Management Plan, there
are landfills used by the County with up to 100 years of remaining life (LACDPW 2019b). For example, the Prima
Deshecha Sanitary Landfill in Orange County is expected to remain open for another 85 years, the Mesquite
Regional Landfill in Imperial County is expected to remain open for another 100 years, and the Simi Valley Landfill
in Ventura County is expected to remain open for another 67 years (CalRecycle 2021). As such, other landfills in
the region would also be able to accommodate solid waste from the proposed Project, and regional planning efforts
would ensure continued landfill capacity into the foreseeable future.
For the reasons described above, Project operations would not 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. Impacts would be less than significant. No mitigation is required.
Solid Waste Statutes and Regulations
The proposed Project would be required to comply with all applicable local and state regulations related to solid
waste. The solid waste facility in proximity to the Azusa landfill is regulated under federal, state, and local laws.
Additionally, the City is required to comply with the solid waste reduction and diversion requirements set for in
AB 939, AB 341, AB 1327, and AB 1826. Per AB 1826, businesses that generate 2 cubic yards or more of
commercial solid waste per week are required to arrange for organic waste recycling services. Any hazardous wastes
that are generated during construction activities would be managed and disposed of in compliance with all
applicable federal, state, and local laws.
In addition to the Citys requirements for recycling construction and demolition waste, the state has set a goal of
75% recycling, composting, and source reduction of solid waste by 2020. To help reach this goal, the state has
adopted AB 341 and AB 1826. AB 341 is a mandatory commercial recycling bill, and AB 1826 is mandatory organics
recycling. Waste generated by the proposed Project would enter the Citys waste stream but would not adversely
affect the Citys ability to meet AB 341 or AB 1826, because the proposed Projects waste generation would
represent a nominal percentage of the waste created within the City and because the businesses and residents at
the Project site would be subject to recycling and diversion requirements. In addition, waste diversion and reduction
during Project construction and operations would be completed in accordance with CALGreen standards,
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CalRecycle standards, City requirements, and the County Integrated Waste Management Plan. Republic Services,
Waste Management Inc., and Valley Vista Services all adhere to AB 341. As a result, the Project would comply with
federal, state, and local management and reduction statues and regulations related to solid waste. Impacts would
be less than significant.
Cumulative Effects
Water
Implementation of the Project, in conjunction with cumulative projects would increase demand for water services
provided in the Citys water supply system. The Project area and each cumulative project would incrementally
increase the amount of water that is required in the area. However, as previously described, the existing water lines
that serve the Project site have the capacity to convey the estimated peak flow generated from the Project. Similar
to the Project, the capacity of water lines associated with cumulative project development would be determined on
a project-specific basis. In the event that water line upgrades are required due to cumulative projects, all
construction work within the City public rights-of-way would be subject to local municipal code and applicable agency
requirements and would be subject to CEQA review accordingly. Based on the analysis presented in the Report of
Existing Infrastructure, (Appendix G), the proposed Project is not anticipated to contribute to a cumulative impact
related to water infrastructure.
The City (through its UWMP) anticipates its projected water supplies will meet demand through the year 2045. In
terms of the Citys overall water supply condition, any cumulative project that is consistent with the Citys General
Plan has been taken into account in the planned growth of the water system.
For projects that meet the requirements established pursuant to SB 610, SB 221, and Sections 1091010915 of
the State Water Code, a Water Supply Assessment demonstrating sufficient water availability is required on a
project-by-project basis. Similar to the Project, each cumulative project would be required to comply with City and
State Water Code and conservation programs for both water supply and infrastructure to partially offset the
cumulative demand for water. As a result, no significant cumulative water supply impacts are anticipated from
development of the Project and cumulative projects, and the Projects incremental effect would not be cumulatively
considerable. No mitigation is required.
Wastewater
The Project area and each cumulative project would incrementally increase the amount of wastewater that is being
generated in the area. Based on the analysis provided in Appendix M of this Draft EIR, the existing sewer lines that
serve the Project site have the capacity to convey the estimated peak flow generated from the Project. All
construction work within the City public rights-of-way would be subject to local municipal code and applicable agency
requirements and would be subject to CEQA review accordingly.
Similarly, the proposed Project is estimated to generate an average 52,272 gpd of wastewater, with a peak
generation of 156,816 gpd. For even the treatment site servicing the City with the smallest capacity (Whittier
Narrows), this would result in an average increase of less than 0.3%, and peak increase of approximately 1%. As
cumulative increases in wastewater treatment demand within the service area require facility upgrades, the City
would continue to regulate public sewer facilities in as outlined in the 2014 City of Arcadia Sewer System
Management Plan, and any affected treatment plants would continue to assess potential expansions to their
treatment facilities in accordance with regulatory permit requirements. As such, impacts to wastewater services
would not be cumulatively considerable. No mitigation is required.
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Dry Utilities - Electric Power, Natural Gas, and Telecommunication
The City of Arcadia is built-out and upgrades in electrical power, natural gas, and telecommunication capabilities are
anticipated primarily due to development in the form of the revitalization of outdated or underserved areas, and
redevelopment of specific properties that will increase density and require more sophisticated technology, such as the
proposed Project. However, such upgrades would generally be confined to the lateral connections to the individual project
sites and not any centralized facilities. Upgrades to centralized power, natural gas, and telecommunication facilities
would be determined by each of the power, gas, and telecommunications providers, as build-out continues within the
region. Individual projects would be required to provide for specific project needs. As a result, cumulative impacts
associated with upgrades of electric, natural gas, and telecommunication facilities would not be significant. As such,
impacts to electric power, natural gas, and telecommunication services would not be cumulatively considerable.
Solid Waste
Development of the Project in combination with cumulative projects would increase land-use intensities in the area,
resulting in increased solid waste generation in the service area for Azusa landfill. However, due to the built-out
nature of the City, the Project and cumulative projects are considered urban infill and/or redevelopment projects.
As such, solid waste is already being generated at the Project site and the majority, if not all, of the cumulative
project sites. Further, AB 939, or the Integrated Waste Management Act of 1989, mandates that cities divert from
landfills 50% of the total solid waste generated to recycling facilities. In order to satisfy CALGreen requirements of
diverting 65% of solid waste and to offset impacts associated with solid waste, the proposed Project and all
cumulative projects would be required to implement waste reduction, diversion, and recycling during both
demolition/construction and operation.
Through compliance with City and state solid waste diversion requirements, together with the Citys Source
Reduction and Recycling Element and applicable regulations outlined in Article V, Chapter 1, of the Citys Municipal
Code, impacts to solid waste services would not be cumulatively considerable. Impacts would be less than
significant, and no mitigation is required.
Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant
impact on utility and service systems; therefore, no mitigation is required.
2.3.19 Wildfire
The Project site is in a highly urbanized area and is not within a Very High Fire Hazard Severity Zone and would not
exacerbate or expose people or structures to wildfire risks or substantially impair an adopted emergency response
plan. The nearest wildland areas are located at the bottom of the San Gabriel Mountains, approximately 1 mile north
of the Project site. Based on the CAL FIREs Fire Hazard Severity Zones maps, the Project site is not located in or near
state responsibility areas or lands classified as Very High Fire Hazard Severity Zones. The closest designated Very High
Fire Hazard Severity Zone is located approximately 0.75-mile north of the Project site. Therefore, impacts associated
with wildland fire would not occur and will not require further evaluation in the EIR.
Finding
Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to wildfire;
therefore, wildfire was not addressed in the Draft EIR. No mitigation would be required and no significant,
unavoidable adverse impacts would occur.
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3 Findings on Project Alternatives
CEQA requires that an EIR describe a range of reasonable alternatives to the project, or to the location of the project,
that could feasibly attain the basic objectives of the project, and to evaluate the comparative merits of the
alternatives (14 CCR 15126.6[a]). The CEQA Guidelines direct that the selection of alternatives be governed by a
rule of reason (14 CCR 15126.6[a], [f]). As defined by the CEQA Guidelines, The range of alternatives required in
an EIR is governed by a rule of reason that requires the EIR to set forth only those alternatives necessary to permit
a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the
significant effects of the project. Of those alternatives, the EIR needs to examine in detail only the ones that the
Lead Agency determines could feasibly attain most of the basic objectives of the project (14 CCR 15126.6[f]).
Additionally, CEQA Guidelines section 15091(a)(3) requires findings to be made as to why project alternatives were
rejected. While an alternative may be potentially feasible under Guidelines section 15126.6 for inclusion in an EIR,
the ultimate determination of feasibility is to be made by the decision-making body under section 15091(a)(3). As
stated above, alternatives may be rejected when specific economic, legal, social, technological or other
considerations make the Project infeasible. In making these findings, the City Council finds that there are six
objectives for the Project, which are primarily dependent upon developing an under-utilized site consistent with the
underlying land use designation and zoning. However, the primary objectives of the Project are (1) addressing the
regional housing shortage by providing additional housing opportunities, including affordable housing, that support
the goals of the Housing Element of the General Plana and the Citys Regional Housing Needs Allocation (RHNA)
requirements; and (2) developing an under-utilized property within a Transit Priority Area consistent with the Citys
land use designation and zoning.
3.1 Alternatives Carried Forward for Consideration
This section discusses a reasonable range of alternatives to the Project, including a no project alternative, in
compliance with CEQA Guidelines Section 15126.6(e). These alternatives include the following:
Alternative A: No Project/Existing Development
Alternative B: Increased Commercial-Use Alternative: Conversion of Live/Work Units to Commercial
These alternatives are evaluated for their ability to avoid or substantially lessen the impacts of the Project identified
in the EIR, as well as consideration of their ability to meet the basic objectives of the proposed Project as described
in the Final EIR.
3.1.1 Alternative A - No Project/Existing Development
Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate and analyze the impacts of a no project
alternative. The purpose of describing and analyzing a no project alternative is to allow decision makers to
compare the impacts of approving the proposed Project with the impacts of not approving the proposed Project
(14 CCR 15126.6[e][1]). When defining the no project alternative, the analysis shall be informed by what would
be reasonably expected to occur in the foreseeable future if the project were not approved, based on current
plans and consistent with available infrastructure and community services (14 CCR 15126.6[e][2]).
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Description
Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate the specific alternative of no project
along with its impact. As stated in this section of the CEQA Guidelines, the purpose of describing and analyzing a
no project alternative is to allow decision makers to compare the impacts of approving a proposed Project with the
impacts of not approving a proposed Project. As stated in Section 15126.6(e)(3)(A), when a project is the revision
of an existing land use or regulatory plan or policy or an ongoing operation, the no project alternative will be the
continuation of the plan, policy, or operation into the future. Section 15126.6(e)(3)(B) further states that in certain
instances, the no project alternative means no build wherein the existing environmental setting is maintained.
The proposed Project does not include a General Plan Amendment or a Zone Change. Accordingly, Alternative A
assumes the proposed Project would not proceed, no new permanent development or land uses would be
introduced within the Project site, and the existing environment would be maintained. The existing uses would
continue to operate as they do currently. The existing office and commercial uses would remain in place and
operational, the existing surface parking lots would be retained, no new buildings or subterranean parking would
be constructed, and no on-site landscaping improvements or pedestrian connections would occur. Additionally, all
36 onsite trees, including six (6) protected species under Section 9110.01 of the Citys Tree Preservation
Ordinance, would be preserved under this alternative, and none of the nine (9) Project adjacent street-trees would
be encroached upon.
Analysis
Under this alternative, impacts would be slightly greater than under the proposed Project. Specifically,
hydrology and water quality impacts would be greater because the continued operation of the site does not
currently contain any low-impact development features potentially creating impacts to water quality, Further,
the No Project Alternative would not provide additional housing units that could help meet the Citys RHNA
goals and growth projections. Also,due to the underutilization of the site, the No Project Alternative would not
contribute to a reduction in citywide VMT and associated GHG emissions attributed to increased development
in a Transit Priority Area.
Finding
For the reasons stated below, and each of them independently of the others, the City finds that the No Project
Alternative is not feasible, and rejects that alternative. The No Project/Existing Development fails to satisfy the
Projects underlying purpose and to meet any of the Project objectives, and because specific economic, legal, social,
technological or other considerations make the alternative infeasible.
Rationale
No Project/Existing Development would have fewer impacts compared to the Project in terms of aesthetics, air
quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and
hazardous materials, hydrology and water quality (short-term impacts), noise, public services, recreation,
transportation, tribal cultural resources, and utilities and service systems. The No Project/Existing Alternative would
not achieve the Project objectives, with the exception of Objective No. 4, To propose development that is consistent with
the existing Downtown Mixed-Use (DMU) zoning and land use designation, which assumes existing land uses and surface
parking would remain. Although no new development would be proposed, Alternative A would be consistent with the
existing zoning and General Plan designation.
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3.1.2 Alternative B - Increased Commercial-Use Alternative:
Conversion of Live/Work Units to Commercial
Description
Alternative B considers an alternative design that would not substantively alter the environmental impacts of the
proposed Project, but would potentially improve the Projects consistency with local policies related to increasing density
near transit, and provide more employment-generating uses.
The underlying Downtown Mixed Use (DMU) land use designation permits service and retail uses, commercial
businesses, professional offices, and residential uses within the Citys downtown, at a maximum floor area ratio
(FAR) of 1.0 (in which only commercial square footage is counted in calculation of FAR) and a maximum unit density
of up to 80 dwelling units per acre (City of Arcadia 2010). The proposed Project satisfies the allowable 80 dwelling
units per acre (i.e., 236 units on the 2.95-acre site), and with addition of the 35% density bonus under Density
Bonus Law, the Project proposes a dwelling unit count of 319 total units, which would include 293 market-rate and
26 affordable dwelling units. Alternative B proposes a slight adjustment to this unit count by converting the 8 live-
work units to all-commercial, without altering the 26 affordable units, resulting in a total of 311 units, a slight
reduction from the Project.
The purpose of converting these live-work units to all-commercial would be to increase the amount of employment-
generating commercial uses on the Project site. Under the proposed Project, with the existing 83,253 square feet
of commercial uses and the additional 9,281 square feet of work uses from the proposed live-work units, the
total non-residential square footage on site would be 92,534 square feet, resulting in a FAR of 0.72. Under
Alternative B, the conversion of 5,864 square feet from residential to commercial would increase the FAR to 0.77.
Alternative B would generate residents associated with the 311 units and employment associated with construction
of the 15,145 square feet of commercial use, which is 5,864 square feet more than the proposed Project and
would generate an additional approximately 14 employees. Under Alternative B, due to the increased commercial
square footage, the number of potential employees would increase from 30 under the proposed Project (a net
deficit of 20 employees when compared to the existing conditions) to 44 under Alternative B (a net deficit of 6
employees when compared to the existing conditions).
Analysis
All impacts under Alternative B would be the same as the Project and would require all of the mitigation measures
identified for the Project. The following impacts would be slightly greater under this alternative. Alternative B would
generate slightly more vehicle trips from commercial activities; therefore, operational impacts on regional air quality
and contribution to GHG emissions under Alternative B would be slightly greater than those anticipated from the
proposed Project but would not exceed the thresholds.
In only one instance would an impact be less than the Project. Because employment would increase under
Alternative B when compared to the proposed Project, impacts to population and housing under Alternative B would
be slightly less than those anticipated from the proposed Project.
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Finding
For the reasons stated below, and each of them independently of the others, the City finds that Alternative B is not
feasible, and rejects that alternative. While Alternative B satisfies all of the Project Objectives, it does so to a lesser
degree. Alternative B is rejected because specific economic, legal, social, technological or other considerations
make the alternative infeasible.
Rationale
While the Alternative B would still achieve all of the Project objectives, the objectives would not be achieved to the
same extent as the Project. Primarily, Alternative B would lose 8 residential units which would not help the City
provide new multifamily residential housing, which is required to meet the Citys Regional Housing Needs Allocation
(RHNA) requirements (Objective 2). Maximizing housing near established transit is a priority for the City and the
SCAG region as a whole, and new housing is necessary to address the unprecedented shortage of housing
opportunities in Los Angeles County. Further, Alternative B would not result in a reduction of a significant
environmental impact. Neither the Project nor Alternative B would result in a significant environmental impact.
3.2.2 Environmentally Superior Alternative
An EIR must identify an environmentally superior alternative; and, where the no project alternative is
environmentally superior, the EIR is then required to identify an alternative from among the others evaluated as
environmentally superior (14 CCR 15126.6[e][2]).
Alternative A would result in reduced impacts to all environmental topics in the short-term because construction
activity would not occur. Alternative A would therefore eliminate all mitigation requirements for short-term
construction activities. Similarly, Alternative A would result in reduced environmental impacts to most
environmental topics in the long-term because no operational changes would occur. However, increased
environmental impacts would occur for the following topics: (1) Hydrology/Water Quality, due to the continued
operation of the site that does not currently contain any low-impact development features; (2) Population and
Housing, due to the lack of additional housing units that could help meet the Citys RHNA goals and growth
projections; and (3) Transportation, due to the underutilization of the site that would not contribute to a reduction
in cityside VMT and associated GHG attributed to increased development in a TPA. The proposed Project would
redevelop existing surface parking lots and construct a mix of land uses including residential and commercial, within
a TPA and the established Downtown Arcadia focus area, which would help the City to achieve its goals and policies
related to land use, circulation, economic development, and housing, which would not occur under Alternative A.
Nevertheless, the elimination of all construction and operational impacts associated with the proposed Project
would result in an environmentally superior alternative when compared to the proposed Project or Alternative B.
As required under CEQA Guidelines Section 15126.6(e)(2), if the environmentally superior alternative is the no
project alternative, the EIR must also identify an environmentally superior alternative among the other alternatives.
The proposed Project has no significant unavoidable impacts that could be addressed by the adoption of any
alternative. Alternative B would have similar environmental impacts when compared to the proposed Project for
almost all environmental topics and would not eliminate the need for any proposed mitigation measures. Alternative
B would result in slightly increased impacts associated with Air Quality and Greenhouse Gas Emissions, and result
in a slight decrease in impacts associated with Population and Housing. Therefore, because Alternative B would not
reduce or eliminate any of the significant impacts of the proposed Project, the proposed Project would be the
environmentally superior alternative.
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4 General CEQA Findings
Based on the information contained in the administrative record and based on the facts stated below, the City
makes the Findings set forth in Sections 4.1 and 4.2.
1. The plans for the proposed Project have been prepared and analyzed so as to provide for public involvement
in the planning and the CEQA processes.
2. To the degree that any impacts described in the Draft EIR are perceived to have a significant effect on the
environment, or such impacts appear ambiguous as to their effect on the environment, any significant
effect of such impacts has been substantially lessened or avoided by the mitigation measures set forth in
the Draft and Final EIR.
3. Comments regarding the Draft EIR received during the public review period have been adequately
addressed in Chapter 2, Responses to Comments Received, in the Final EIR. Any significant effects
described in such comments were avoided or substantially lessened by the mitigation measures described
in the Draft and Final EIR.
4.1 Findings Regarding Recirculation
The City finds that the Draft EIR does not require recirculation under CEQA (CEQA Section 21092.1, CEQA Guidelines
Section 15088.5). CEQA Guidelines Section 15088.5 requires recirculation of an EIR prior to certification of the
Final EIR when significant new information is added to the EIR after public notice is given of the availability of the
draft EIR for public review. As described in CEQA Guidelines Section 15088.5:
New information added to an EIR is not significant unless the EIR is changed in a way that deprives
the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of
the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative)
that the projects proponents have declined to implement. Significant new information requiring
recirculation includes, for example, a disclosure showing that:
1. A new significant environmental impact would result from the project or from a new mitigation
measure proposed to be implemented;
2. A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance;
3. A feasible project alternative or mitigation measure considerably different from others
previously analyzed would clearly lessen the significant environmental impacts of the
project, but the projects proponents decline to adopt it;
4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature
that meaningful public review and comment were precluded.
In addition, CEQA Guidelines Section 15088.5(b) provides that recirculation is not required where the new
information added to the EIR merely clarifies and amplifies or makes insignificant modifications in an adequate
EIR. Recirculation also is not required simply because new information is added to the EIR indeed, new
information is oftentimes added given CEQAs public/agency comment and response process and CEQAs post-
Draft EIR circulation requirement of proposed responses to comments submitted by public agencies. In short,
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recirculation is intended to be an exception rather than the general rule. (Laurel Heights Improvement Assn. v.
Regents of University of California (1993) 6 Cal.4th 1112, 1132.)
As such, the City makes the following Findings:
1. None of the public comments submitted to the City regarding the Draft EIR present any significant
new information that would require the Draft EIR to be recirculated for public review.
2. No new or modified mitigation measures are proposed that would have the potential to create new
significant environmental impacts.
3. The Draft EIR adequately analyzed project alternatives and there are no feasible project alternatives or
mitigation measures considerably different from others previously analyzed that would clearly lessen the
significant environmental impacts of the project.
4. The Draft EIR was not fundamentally and basically inadequate and conclusory in nature and did not
preclude meaningful public review and comment.
In this legal context, the City finds that recirculation of the Draft EIR prior to certification is not required. In addition
to providing responses to comments, the Final EIR includes revisions to expand upon information presented in the
Draft EIR (Chapter 3, Changes to the EIR); explain or enhance the evidentiary basis for the Draft EIRs findings;
update information; and to make clarifications, amplifications, updates, or helpful revisions to the Draft EIR. These
revisions, clarifications and/or updates do not result in any new significant impacts or increase the severity of a
previously identified significant impact. These changes are not substantial, do not deprive the public of a meaningful
opportunity to comment on a substantial adverse environmental effect, a feasible way to mitigate or avoid such an
effect or a feasible project alternative.
In summary, the Final EIR demonstrates that the proposed Project would not result in any new significant impacts
or increase the severity of a significant impact, as compared to the analysis presented in the Draft EIR. The changes
reflected in the Final EIR also do not indicate that meaningful public review of the Draft EIR was precluded in the
first instance. Accordingly, recirculation of the EIR is not required as revisions to the EIR are not significant as
defined in Section 15088.5 of the CEQA Guidelines.
4.2 Legal Effects of Findings
To the extent that these Findings conclude that the proposed mitigation measures outlined herein are feasible and
have not been modified, superseded, or withdrawn, the City hereby commits to implementing these measures.
These Findings, in other words, are not merely informational, but rather constitute a binding set of obligations that
will come into effect when the City approves the proposed Project.
The mitigation measures that are referenced herein and adopted concurrently with these Findings will be effectuated
through the process of construction and implementation of the proposed Project.
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5 Conclusion
The mitigation measures listed in conjunction with each of the findings set forth above, as implemented through
the MMRP, will eliminate or reduce to a less-than-significant level most of the adverse environmental impacts of
the Project.
Taken together, the EIR which consists of the Draft EIR, Final EIR, and the MMRP provide an adequate basis for
approval of the Project.
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