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HomeMy WebLinkAboutItem 07a - The Ivy Arcadia DATE: September 17, 2024 TO: Honorable Mayor and City Council FROM: Jason Kruckeberg, Assistant City Manager/Development Services Director Lisa L. Flores, Deputy Development Services Director By: Edwin Arreola, Acting Senior Planner SUBJECT: RESOLUTION NO. 7572 APPROVING ARCHITECTURAL DESIGN REVIEW NO. ADR 23-13 WITH A DENSITY BONUS AND CONDITIONAL USE PERMIT NO. CUP 23-09 FOR A REVISED SENIOR ASSISTED LIVING CARE FACILITY (“THE IVY ARCADIA”) WITH AN ADDENDUM TO THE ADOPTED MITIGATED NEGATIVE DECLARATION UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) AT 1150 W. COLORADO BOULEVARD CEQA: Adopt Addendum to Previously Approved Mitigated Negative Declaration Recommendation: Adopt SUMMARY At the August 20, 2024, City Council Meeting, the City Council held a public hearing related to Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 to amend a project that was previously approved by the City Council in 2020. The revised project, known as “The Ivy Arcadia”, proposes a three-story senior assisted living care facility with 100 units and 114 beds at 1150 W. Colorado Boulevard. The revised project also includes a density bonus to allow a Floor Area Ratio (“FAR”) of 0.88, which exceeds the maximum permitted FAR of 0.50. After hearing testimony from the Applicant and the public, the City Council voted 4-0 to continue the item to the September 17, 2024, City Council Meeting to allow the Applicant time to schedule a meeting with the neighboring property owners and discuss the project. A community meeting was held on September 4, 2024, and as a result several modifications were made to the project. It is recommended that the City Council approve Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 along with the new modifications proposed. BACKGROUND The applicant is requesting to demolish the existing 13,088 square foot restaurant building on site and construct a new 107,706 square foot, three-story Traditional/Cape Cod 1150 W. Colorado Boulevard – The Ivy Arcadia September 17, 2024 Page 2 of 3 architectural style building that will provide assisted living and memory care services for seniors that have Alzheimer’s and other related memory loss. The facility will have 100 units of various sizes with a total of 114 beds and will provide 24-hour staff services. At the June 11, 2024, Planning Commission Meeting, the Planning Commission voted 3-0, with two Commissioners absent, to recommend denial of the proposed project to the City Council. The Planning Commission determined that the project was not compatible with the adjacent neighborhood in terms of scale and height. For more information on the project and this item, refer to Exhibit “C” for the complete August 20, 2024, City Council staff report, including all attachments. DISCUSSION On September 4, 2024, the Applicant held a community meeting with the neighboring property owners to discuss the project proposal and receive feedback on the issues that the residents had concerns with. A total of 18 people attended the meeting. The Applicant provided a summary of all the comments and questions they had received for the project to date and provided responses to each of those comments. A lighting plan was presented to indicate that the Applicant was in compliance with the City’s lighting requirements that prevent glare from going to adjacent properties. The residents were also provided with new diagrams and renderings prepared by the Applicant that illustrated the proposed setbacks to each of the levels of the building in relation to the adjacent property lines. Additionally, the block wall between the subject property and the neighboring residential properties was analyzed to determine improvements that needed to be made to the wall. The Applicant has proposed the following modifications to the project site as a result of their community meeting and since the last City Council Meeting: 1) The Applicant has indicated that they will be relocating the trash enclosure from the rear of the property after receiving concerns from the neighbors about its proximity to the residential properties. The Applicant is now proposing to locate the trash enclosure along the southwest portion of the site adjacent to Michillinda Avenue. 2) After neighbors asked for a potential increase in the rear yard setback, the Applicant removed some common area space within the building to increase the rear yard setback of the building at its closest point to the neighboring properties by 2’-4”, for a total rear yard setback of 37’-4”. 3) The Applicant has enhanced the landscaping by providing more trees and shrubs on site as screening vegetation. The number of new trees on site was increased from 83 new trees to 140 new trees. A total of 86 of the trees will be located in the areas between the proposed building and the property lines for added privacy and screening. The remaining trees will be dispersed throughout the rest of the site. Refer to Exhibit “B” for revised drawings and diagrams that show the proposed changes proposed by the Applicant. 1150 W. Colorado Boulevard – The Ivy Arcadia September 17, 2024 Page 3 of 3 These proposed modifications have been reviewed by the Staff and it has been determined that these are positive changes that will create a better site plan in relation to the neighboring properties and improve privacy. RECOMMENDATION It is recommended that the City Council make the required findings and adopt Resolution No. 7572 and approve Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 and adopt the Addendum to the adopted Mitigated Negative Declaration, subject to the conditions of approval as presented in the Resolution, or as modified by the City Council. Exhibit “A”: Revised Resolution No. 7572 Exhibit “B”: Revised Architectural Plans and Diagrams Exhibit “C”: August 20, 2024, City Council staff report with all original attachments Exhibit A Revised 5HVROXWLRQ 1R7572 Exhibit A 1 RESOLUTION NO. 7572 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ARCADIA, CALIFORNIA, APPROVING ARCHITECTURAL DESIGN REVIEW NO. ADR 23-13 WITH A DENSITY BONUS AND CONDITIONAL USE PERMIT NO. CUP 23-09 FOR A REVISED SENIOR ASSISTED LIVING CARE FACILITY (“THE IVY ARCADIA”) WITH AN ADDENDUM TO THE ADOPTED MITIGATED NEGATIVE DECLARATION UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) AT 1150 W. COLORADO BOULEVARD WHEREAS, on November 9, 2023, applications were filed with the City of Arcadia (“City”) for Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 were filed by O&I Development, LLC (“Applicant”) on behalf of Artis Senior Living, LLC (“Property Owner”) to revise the project that was approved by the City Council on August 18, 2020 (Resolution No. 2372) which was for an assisted living care facility (known as Artis Senior Living Project) or the “Approved Project.” The Revised Project, known as “The Ivy Arcadia” is for a two-story development that is approximately 107,706 square feet with 100 units and 114 beds at 1150 W. Colorado Boulevard. The Revised Project also includes a density bonus to allow a Floor Area Ratio (“FAR”) of 0.88, which exceeds the maximum permitted FAR of .50. The Revised Project is a senior housing development under the State’s Density Bonus Law and is entitled to exceed the otherwise maximum FAR since it would physically preclude construction of the Revised Project under the General Plan and Zoning. The Ivy Arcadia is referred to as the “Revised Project”; and WHEREAS, on August 18, 2020, the City Council adopted a Mitigated Negative Declaration (“MND”) for the Approved Project. An Addendum to the adopted MND for The Ivy Arcadia was prepared to consider the environmental impacts of the Revised Project compared to those of the approved project, and in accordance with the requirements of 2 California Environmental Quality Act (“CEQA”) and the CEQA Guidelines. As with the Approved Project, the Revised Project would be required to comply with all the mitigation measures identified in the adopted 2020 MND. There are no design features included within the Revised Project that would suggest that these mitigation measures would not be sufficient to address any potentially significant impact that would arise from the implementation of the Revised Project. As such, there are no changes to the circumstances, and implementation of the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact and less-than-significant impact with mitigation in the adopted 2020 MND; and WHEREAS, on May 14, 2024, a duly noticed public hearing was held before the Planning Commission on said Revised Project, at which time all interested persons were given full opportunity to be heard and to present evidence; and WHEREAS, following consideration of all testimony and evidence including staff reports and attachments, the Planning Commission voted unanimously to recommend denial of the Revised Project on the basis that the Project was not compatible with the adjacent neighborhood in terms of scale and height and that they could not make three of the nine required findings. The Planning Commission directed Staff to prepare a Resolution incorporating the Planning Commission’s findings for the Revised Project; and WHEREAS, on June 11, 2024, the Revised Project was pulled from the consent calendar to allow the Applicant to present changes to the design before the Planning Commission, at which time all interested persons were given full opportunity to be heard and to present evidence; and 3 WHEREAS, following consideration of all testimony, the Planning Commission voted 3-0, with two Commissioners absent, to approve Planning Commission Resolution No. 2146 recommending denial of the Revised Project, which incorporated the Planning Commission’s findings for the Revised Project; and WHEREAS, on August 20, 2024, a duly noticed public hearing was held before the City Council to consider the Revised Project, at which time all interested persons were given full opportunity to be heard and to present evidence; and WHEREAS, after taking all testimony and closing the public hearing, the City Council voted 4-0 to continue its review of the Project to the September 17, 2024, City Council Meeting to allow the Applicant time to schedule a meeting with the neighboring property owners and discuss the project; and WHEREAS, on September 17, 2024, the item was further considered by the City Council. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF ARCADIA, CALIFORNIA, HEREBY RESOLVES AS FOLLOWS: SECTION 1. The factual data submitted by the Development Services Department in the staff report dated September 17, 2024, are true and correct. SECTION 2. The City Council finds, based upon the entire record, pursuant to Sections 9107.09.050(B) and 9107.19.050(F) of the Development Code, all of the following findings can be made. Conditional Use Permit 1. The Revised Project is consistent with the General Plan and any applicable specific plan; and is allowed within the applicable zone, subject to the granting of a 4 Conditional Use Permit, and complies with all other applicable provisions of the Development Code and the Municipal Code. FACT: Approval of the Revised Project will be consistent with the Commercial General Plan Land Use Designation. The site is zoned General Commercial (C-G) and pursuant to the Arcadia Development Code Section 9102.03.020, Table 2-8, allows a Large-Residential Care Facility in the General Commercial C-G zone subject to the review and approval of a Conditional Use Permit. The underlying zone allows for a broad array of commercial uses that are both neighborhood and citywide serving. The Revised Project will allow a business that can serve the aging population of the City, specifically those with Alzheimer’s disease and related memory delays. Aside from the FAR, the Revised Project complies will all the development standards of the General Commercial C-G zone. The Revised Project will not adversely affect the comprehensive General Plan, and is consistent with the following General Plan goals and policies: • Goal LU-1: A balance of land uses that preserves Arcadia status as a Community of Homes and a community of opportunity. • Policy LU-1.1: Promote new infill and redevelopment projects that are consistent with the City’s land use and compatible with surrounding existing uses. • Policy LU-1.2: Promote new uses of land that provide diverse economic, social, and cultural opportunities, and that reinforce the characteristics that make Arcadia a desirable place to live. 5 • Policy LU-1.5: Require that effective buffer areas be created between land uses that are of significantly different character or that have operating characteristics which could create nuisances along common boundary. 2. The design, location, size, and operating characteristics of the proposed activity will be compatible with the existing and future land uses in the vicinity. FACT: The Revised Project provides a transition between the commercial businesses in the Los Angeles County area to the west of the site and the adjacent residential properties to the east and south as a senior assisted living use. The Revised Project will be setback more than the minimum required from the adjacent residential properties and will have a parking and landscape buffer between the facility and the residential uses. The Revised Project, being more of a residential use, is not expected to negatively affect the adjacent properties. Parking for the project is above the minimum required and is expected to be an adequate amount for the site due to the nature of the use which would not consist of many residents that drive. Additionally, transportation services will be provided to the residents. Additionally, the Revised Project will result in an overall reduction of vehicular traffic as compared to the existing use and most other commercial uses that could be considered for the property. The project site is adequate in size and location to accommodate the revised development. Thus, the Revised Project will be compatible with the existing and future uses in the vicinity. 3. The site is physically suitable in terms of: a. Its design, location, shape, size, and operating characteristics of the proposed use in order to accommodate the use, and all fences, landscaping, loading, parking, 6 spaces, walls, yards, and other features required to adjust the use with the land and uses in the neighborhood. FACT: The site measures approximately 2.82 acres and is large enough to physically support the Revised Project. The current utility infrastructure on site is more than capable of accommodating the proposed use. Landscaping is being maintained along the perimeter of the lot and various new pockets of landscaping will be introduced around the building site. The Revised Project will have two points of access on to the lot and will also provide more than the required amount of parking. The Revised Project will comply with all of the regulations within the Development Code except for the FAR which is allowed to exceed the maximum because of the density bonus for senior housing development. Therefore, the site is adequate in size to accommodate the Revised Project. b. Streets and highways adequate in width and pavement type to accommodate public and emergency vehicle (e.g., fire and medical) access; FACT: The Revised Project will be located at the southeast corner of W. Colorado Boulevard and Michillinda Avenue. The site will have two access points, with one driveway off of each street frontage. Both streets have been designated and designed with the capacity to accommodate both normal public vehicular travel and emergency vehicles. Additionally, the Revised Project is expected to generate less traffic than the previous use. Thus, the adjacent streets are adequate in width and pavement type to carry the traffic that would be generated by the Revised Project and to accommodate emergency vehicle access. c. Public protection services (e.g., fire protection, police protection, etc.); and 7 FACT: The construction of the senior assisted living care facility will comply with the Building and Fire Codes, and all other applicable regulations to ensure the safety of the residents and facilitate emergency services. As part of the environmental review process, the Addendum to the Initial Study/Mitigated Negative Declaration determined that Fire and Police protection services can handle the demand for the Revised Project. d. The provision of utilities (e.g., potable water, schools, solid waste collection and disposal, storm drainage, wastewater collection, treatment, and disposal, etc.). FACT: It has been determined that the existing infrastructure and public utilities can handle the demand for the Project, and no upgrades are required. The Project will also comply with the Low Impact Development (“LID”) requirements for stormwater discharge through the implementation of a modular wetland on site. 4. The measure of site suitability shall be required to ensure that the type, density, and intensity of use being proposed will not adversely affect the public convenience, health, interest, safety, or general welfare, constitute a nuisance, or be materially injurious to the improvements, persons, property, or uses in the vicinity and zone in which the property is located. FACT: The Revised Project is not expected to be detrimental to the public health or welfare, or the surrounding residential and commercial properties. The Revised Project has been designed to be functionally suitable for the site and be sensitive to the privacy and impact on the adjacent residential properties. The Revised Project includes setbacks that exceed the minimum requirement and a landscape and parking buffer. In support of maintaining privacy between the neighboring residential properties, the existing large trees along the perimeter of the site will be kept. Additionally, most of the units on the upper 8 floors of the south side of the facility do not face the adjacent residential properties. Therefore, the Revised Project has incorporated design elements to provide added privacy to the neighbors. The Revised Project is expected to generate less trips than the previous restaurant use on the site and will have more than the minimum required parking. Traffic in the surrounding area is not expected to be impacted by the use. The construction of the project will meet all Building and Fire Codes, and all other applicable regulations. Therefore, the Revised Project will not adversely affect the public in general nor will it impact the uses in the vicinity and zone in which the property is located. Architectural Design Review 5. The proposed development is in compliance with all applicable development standards and regulation in the Development Code. FACT: The Revised Project is in compliance with all of the applicable development standards for the C-G zone, such as the maximum height, setbacks, and parking. The Revised Project proposes a Floor Area Ratio (“FAR”) of 0.88. The Revised Project is a senior housing development under the State’s Density Bonus Law and is entitled to exceed the otherwise maximum FAR, which would physically preclude construction of the Revised Project to the maximum allow residential density under the General Plan and Zoning. Therefore, the Revised Project meets the intent of this finding. 6. The proposed development is consistent in the objectives and standards of the applicable Design Guidelines. FACT: The Project is designed in the Traditional/Cape Cod architectural style. The design contains architectural features and materials that are commonly found within the revised architectural styles. The revised design provides varied massing and materials 9 and articulation on each of the building façades to help break up the building size which is encouraged by the Design Guidelines. The Revised Project also takes into account the privacy and site layout guidelines to ensure that there are minimal impacts on the surrounding properties. Therefore, the Revised Project has been designed to be consistent with the Design Guidelines. 7. The proposed development is compatible in terms of scale and aesthetic design with surrounding properties and developments. FACT: The building was strategically placed away from residential properties to the east and south to minimize any potential impacts to the adjacent residential properties and was pushed back from the street to maintain a comparable streetscape with the residential properties. The overall design has a balanced and aesthetically pleasing design that will complement the surrounding residential properties in the general vicinity. The use, although commercial in nature, will provide more of a residential type of use and will be less commercially active than other potential developments that could be developed on this site. The revised design will enhance the overall streetscape, as it provides a transition from the commercial corridor to the west of the site to the residential neighborhoods to the east. The location of the Project on the southeastern corner of W. Colorado Boulevard and Michillinda Avenue also provides a suitable focal point as an entryway to the City. 8. The proposed development will have an adequate and efficient site layout in terms of access, vehicular circulation, parking, and landscaping. FACT: The site, being a corner lot, will have two points of access, with one driveway from W. Colorado Boulevard and another driveway from Michillinda Avenue. The two access points will assist in providing ease of circulation on the lot along with the drive 10 aisles on site which meet the minimum 25’-0” width required for two-way traffic. Parking will be provided along all four sides of the building and a total of 70 parking spaces are being provided despite the code only requiring 38 spaces. Additionally, the lot will retain much of the existing landscaping along the perimeters of the property in supplying screening to the adjacent residential neighbors, which consist of large trees and hedging, and new pockets of landscaping will be introduced around the building to enhance the architectural design of the building. 9. The proposed development will be in compliance with all of the applicable criteria identified in Section 9107.19.040(C.5). FACT: All City requirements regarding disabled access and facilities, occupancy limits, building safety, health code compliance, emergency equipment, environmental regulation compliance, and parking and site design shall be complied with by the property owner/applicant to the satisfaction of the Building Official, City Engineer, Deputy Development Services Director, Fire Marshal, and Public Works Services Director, or their respective designees. Additionally, the Revised Project will be in compliance with the General Plan, Development Code, Density Bonus law for senior housing developments, the City’s Design Guidelines, and all other applicable City regulations. SECTION 3. For the foregoing reasons, the City Council adopts the Addendum to the Mitigated Negative Declaration in accordance with CEQA and determines the findings can be made to approve, and does hereby approve, Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09, for a new senior assisted living care facility at 1150 W. Colorado Boulevard, subject to the conditions of approval attached hereto. 11 SECTION 4. The City Clerk shall certify to the adoption of this Resolution. Passed, approved and adopted this 17th day of September, 2024. ________________________ Mayor of the City of Arcadia ATTEST: __________________________ City Clerk APPROVED AS TO FORM: __________________________ Michael J. Maurer City Attorney 12 Page Internationally Left Blank 13 Conditions of Approval 1. The project shall be developed and maintained by the Property Owner/Applicant in a manner that is consistent with the plans submitted and conditionally approved for Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09, subject to the satisfaction of the Deputy Development Services Director or designee. 2. Any exterior signs or monument signs are not a part of this approval and shall be subject to a separate sign permit. 3. The Property Owner/Applicant shall submit an official ALTA survey of the property to the City prior to submitting plans into Building Services for plan-check. The City shall retain all access and other rights over the sanitary sewer easement and storm drain easement that are located on and under the subject property, and the Property Owner/Applicant shall make any adjustment, modifications, and/or abandon the sewer line in its development of the property, or amendments to current easement of record, deemed by the City to reasonably necessary for the City to maintain such infrastructure and access. All new or existing manholes to remain on the site as part of the new development shall be within a paved area. Final placement of the manholes shall be subject to review and approval of the Public Works Department. Any agreement that is required by the City to allow the development to occur over the easements shall be prepared by the Property Owner/Applicant and shall be subject to approval by the City Attorney prior to recordation in the Los Angeles County Recorder’s Office. For purposes of the City Attorney review of any such document, the Property Owner/Applicant shall submit to the City a deposit of $5,000, of which any funds remaining after review and approval by the City shall be returned to the Property Owner/Applicant. 4. Prior to the issuance of the Certificate of Occupancy, the Property Owner/ Applicant shall submit to Planning Services a copy of the form of lease or occupancy agreement that will be utilized for the assisted living care facility. The form of such agreement must require all future residents to acknowledge the potential health risk associated with living within 500 feet of a freeway. Such acknowledgment shall be placed in all such future agreements for the senior living facility. 5. The replacement of the eastern perimeter wall (a portion or the entire wall) and any tree removal or encroachment shall be subject to review and approval by the Planning Division prior to issuance of a building permit. 6. The Property Owner/Applicant shall submit a haul route map and construction staging plan to Planning Services prior to issuance of a demolition permit. 14 7. The Property Owner/Applicant shall be responsible for the repair of all damage to public improvements in the public right-of-way resulting from construction related activities, including, but not limited to, the movement and/or delivery of equipment, materials, and soils to and/or from the site. The need for such repair shall be determined by the Deputy Development Services Director, the Public Works Services Director, City Engineer, or designees, during construction and up until issuance of a Certificate of Occupancy. 8. Accessible routes shall be provided from the public sidewalk, any public transportation stops, and the trash enclosure to an accessible building entrance. 9. An international symbol of accessibility (ISA) shall be provided at the head end of the accessible electric vehicle (EV) charging spaces. A 30” by 48” clear floor space shall be provided at the EV charger to approach and operate the charger. 10. The plans that are submitted to Building Services for plan-check shall comply with the latest adopted edition of the following codes as applicable: a. California Building Code (CBC) b. California Electrical Code c. California Mechanical Code d. California Plumbing Code e. California Energy Code f. California Fire Code g. California Green Building Standards Code h. California Existing Building Code i. Arcadia Municipal Code 11. Prior to the issuance of a building permit from Building Services, the Property Owner/Applicant shall irrevocably dedicate to the City approximately 4’-0” along the frontage of Colorado Boulevard and Michillinda Avenue for a total parkway width of 12’-0”, as measured from curb to property line. A corner cutback at Michillinda Avenue/Colorado Boulevard is also required to accommodate an ADA curb per Caltrans standard A88A. Both dedications shall be subject to review and approval by the City Engineer. 12. The Property Owner/Applicant shall be required to remove and replace the existing sidewalk, curb, and gutter along the property frontage of Michillinda Avenue and Colorado Boulevard. Red curb locations shall be repainted after construction of the new curb. 13. Prior to the issuance of the Certificate of Occupancy by Building Services, the Property Owner/Applicant shall modify the median island left turn pocket to accommodate the driveway approach on W. Colorado Boulevard in accordance with plans which shall be subject to approval by the City Engineer, or designee. 15 14. The Property Owner/Applicant shall be required to remove the existing driveway approaches and construct new driveway approaches per City Standards with ADA access around each approach. 15. A Low Impact Development (LID) plan is required for this development. It shall comply with the Los Angeles County Department of Public Works 2014 LID standard manual, and the measurements must be shown on the grading plan. 16. Coordinate with the utility companies to underground all utilities, including but not limited to, cable television, telephone, and electrical systems. If above ground utilities are being proposed, the utilities must be placed outside of the public right- of-way, on private property, and reviewed by the City Engineer prior to installation. 17. The Property Owner/Applicant shall coordinate with the Public Works Services Department on the replacement and/or protection of street trees prior to issuance of a grading permit from Building Services. 18. The Property Owner/Applicant shall make its fair share payment into the cost of a Citywide Standard of Cover Risk Assessment Survey to evaluate Fire resources Citywide. The fee shall be determined by the Fire Chief and the fee shall be collected prior to issuance of a building permit from Building Services. 19. The building shall be fully fire sprinklered per the City of Arcadia Fire Department Commercial Sprinkler Standard. The fire sprinkler system shall be monitored by a UL listed central station. Notification appliances shall be provided in all common areas. The dwelling units shall be provided with the ability to install visual appliances. 20. Single station smoke alarms shall be provided in all the dwelling units. Carbon monoxide alarms shall also be provided if gas fueled appliances are being used. Any commercial cooking hoods shall be protected by an automatic extinguishing system and the system shall be monitored by a fire alarm system. 21. An on-site minimum 26-foot wide fire lane extending from Michillinda Avenue to Colorado Boulevard shall be provided. 22. The Property Owner/Applicant shall install three (3) new fire hydrants. The locations shall be depicted on the site plan and shall be subject to review and approval by the Fire Marshall prior to issuance of a building permit for the project. The fire hydrants shall be placed at the following locations: a. A public hydrant on Michillinda Avenue located adjacent to the driveway entry. b. A public hydrant on Colorado Boulevard located adjacent to the driveway entry. c. A private hydrant on the east side of the property. 23. A Two-Way Communication system shall be provided per the Fire Department. 16 24. All passenger elevators shall be EMS capable. 25. Any use of delayed egress systems shall be per CBC 1010. 26. Refuge areas shall be provided within each smoke compartment per CBC 420.6.2. 27. Low-level exit signage shall be provided in all fire rated exit corridors. 28. Knox boxes shall be provided at the front entry and exterior doors at the southeast and southwest stairwells. Stairwell doors shall be keyed to provide for exterior emergency access. 29. Minimum 2A:10BC fire extinguishers shall be provided in all common areas. The maximum travel distance to a fire extinguisher shall be 75 feet. 30. In order to verify the required water service size for the project, the Property Owner/Applicant shall submit to the Public Works Services Department calculations for the maximum commercial use demand and maximum fire demand prior to the issuance of a building permit. Fire protection requirements shall be as stipulated by the Arcadia Fire Department and shall be conformed to Arcadia Standard Plan. A separate fire service with Double Check Detector Assembly (DCDA) shall be installed for fire service required. 31. The Property Owner/Applicant shall provide separate water services and meters for the facility and outdoor irrigation system. A reduced pressure backflow device shall be installed for each water service. 32. Prior to the issuance of a building permit, the Property Owner/Applicant shall submit a Water Meter Permit Application to the Public Works Services Department. 33. The Property Owner/Applicant shall provide a new water service installation. Installation shall be according to the specifications of the Public Works Services Department, Engineering Division. Abandonment of existing water services, if necessary, shall be completed by the Property Owner/Applicant, according to Public Works Services Department, Engineering Section specifications. 34. The Property Owner/Applicant shall connect to the Los Angeles County sewer line on Michillinda Avenue. The Property Owner/Applicant shall coordinate with the Los Angeles County Sanitation Districts (LACSD) for connection. 35. The Property Owner/Applicant shall abandon the entire easement portion of the existing sewer line between the project site and Altura Road. 36. Prior to the issuance of a grading permit, the Property Owner/Applicant shall prepare a Storm Water Pollution Prevention Plan (SWPPP) and shall obtain a Waste Discharge Identification (WDID) number from the State. 17 37. The trash enclosure area shall be installed by the Property Owner/Applicant and shall comply with the following: a. A minimum interior width of 9’-7” in order to accommodate three (3) 3-yard bin. b. A minimum roof clearance of 10-0” to allow the bin lids to open completely. c. Shall include a trash, recycling and organics recycling bins. d. Provide a minimum of one (1) foot clearance around the trash bin/recycling bin. 38. The Property Owner/Applicant shall comply with all City requirements regarding building safety, fire prevention, detection, suppression, emergency access, public right-of-way improvements, parking, water supply and water facilities, sewer facilities, trash reduction and recycling requirements, and National Pollutant Discharge Elimination System (NPDES) measures, all to the satisfaction of the Building Official, Fire Marshal, Public Works Services Director, and Deputy Development Services Director. Compliance with these requirements is to be determined by having fully detailed construction plans submitted for plan check review and approval by the foregoing City officials and employees. 39. To the maximum extent permitted by law, Applicant must defend, indemnify, and hold the City, any departments, agencies, divisions, boards, and/or commissions of the City, and its elected officials, officers, contractors serving as City officials, agents, employees, and attorneys of the City (“Indemnitees”) harmless from liability for damages and/or claims, actions, or proceedings for damages for personal injuries, including death, and claims for property damage, and with respect to all other actions and liabilities for damages caused or alleged to have been caused by reason of the Applicant’s activities in connection with ADR 23-13 with a density bonus and CUP 23-09 (“Revised Project”) on the Project site, and which may arise from the direct or indirect operations of the Applicant or those of the Applicant’s contractors, agents, tenants, employees or any other persons acting on Applicant’s behalf, which relate to the development and/or construction of the Project. This indemnity provision applies to all damages and claims, actions, or proceedings for damages, as described above, regardless of whether the City prepared, supplied, or approved the plans, specifications, or other documents for the Project. In the event of any legal action challenging the validity, applicability, or interpretation of any provision of this approval, or any other supporting document relating to the Project, the City will notify the Applicant of the claim, action, or proceedings and will cooperate in the defense of the matter. The Applicant must indemnify, defend and hold harmless the Indemnitees, and each of them, with respect to all liability, costs and expenses incurred by, and/or awarded against, the City or any of the Indemnitees in relation to such action. Within 15 days’ notice from the City of any such action, the Applicant shall provide to the City a cash deposit to cover legal fees, costs, and expenses incurred by City in connection with defense of any legal action in an initial amount to be reasonably determined by the City Attorney. The City may draw funds from the deposit for such fees, costs, and expenses. Within 5 business 18 days of each and every notice from the City that the deposit has fallen below the initial amount, Applicant/Property Owner shall replenish the deposit each and every time in order for City’s legal team to continue working on the matter. The City shall only refund to the Applicant/Property Owner any unexpended funds from the deposit within 30 days of: (i) a final, non-appealable decision by a court of competent jurisdiction resolving the legal action; or (ii) full and complete settlement of legal action. The City shall have the right to select legal counsel of its choice. The parties hereby agree to cooperate in defending such action. The City will not voluntarily assist in any such third-party challenge(s). In consideration for approval of the Project, this condition shall remain in effect if the entitlement(s) related to this Project is rescinded or revoked, at the request of the Applicant or not. 40. Approval of Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 shall not be in effect unless the Property Owner and Applicant have executed and filed the Acceptance Form with the City on or before 30 calendar days after the Planning Commission has adopted the Resolution. The Acceptance Form to the Development Services Department is to indicate awareness and acceptance of the conditions of approval. Mitigation Measures as Conditions of Approval The following conditions are found in the Mitigation Monitoring and Reporting Program (MMRP). They are recorded here to facilitate review and implementation. More information on the timing and responsible parties for these mitigation measures are detailed in the MMRP. Biological Resources 41. BIO-1: Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the Deputy Development Services Director or Designee. 42. BIO-2: Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: 19 a. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. b. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. c. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. d. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. e. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. f. The arborist shall monitor a few critical phases of the Project, including pre- demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. g. Additional construction best practices described in the Protected Tree Report shall be implemented. Cultural Resources 43. CUL-1: Treatment of previously unidentified archaeological deposits: If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility. Geology and Soils 20 44. GEO-1: If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. Noise 45. NOI-1: Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Planning Division, that the Project complies with the following: a. Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. b. The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on- site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Deputy Development Services Director (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. c. During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. d. Prior to issuance of any Grading or Building Permit, the Project applicant shall demonstrate to the satisfaction of the Deputy Development Services Director (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. 21 e. Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. Tribal Cultural Resources 46. TCR-1: The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians-Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. 47. TCR-2: Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place or recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the 22 material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. 48. TCR-3: 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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. 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. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically 23 and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. 49. TCR-4: Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in Southern California. 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Ú # ! Ú       $XWKRU &KHFNHU 5')/225 $)!Ú 1" 3 ,  * 7  ( 3 0 6 1  - - $        $  0  0  *  % & 7 & - 0 1 . & / 5        1 " 3 ,  1 - " ; "  4 6* 5 &         * 3 7 * / &  $ "       8(&1*" ª 84:9-*1*;&9.43 8(&1* " ª *&89*1*;&9.43 8(&1*" ª 7)+1447 3/$11,1* &200(176  Exhibit C August 20, 2024, City Council staff report with all original attachments Exhibit C DATE: August 20, 2024 TO: Honorable Mayor and City Council FROM: Jason Kruckeberg, Assistant City Manager/Development Services Director Lisa L. Flores, Deputy Development Services Director By: Edwin Arreola, Acting Senior Planner SUBJECT: RESOLUTION NO. 7572 APPROVING ARCHITECTURAL DESIGN REVIEW NO. ADR 23-13 WITH A DENSITY BONUS AND CONDITIONAL USE PERMIT NO. CUP 23-09 FOR A REVISED SENIOR ASSISTED LIVING CARE FACILITY (“THE IVY ARCADIA”) WITH AN ADDENDUM TO THE ADOPTED MITIGATED NEGATIVE DECLARATION UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) AT 1150 W. COLORADO BOULEVARD CEQA: Adopt Addendum to Previously Approved Mitigated Negative Declaration Recommendation: Adopt SUMMARY The Applicant, O&I Development, LLC, on behalf of the property owner, Artis Senior Living, LLC, is requesting approval of Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09, to amend a project that was approved by the City Council in 2020 for a new two-story senior assisted living care facility project with 80 units (Artis Senior Living Project) at 1150 W. Colorado Boulevard. The revised project, known as “The Ivy Arcadia,” will be a three-story senior assisted living care facility with 100 units and 114 beds. The revised project includes a density bonus to allow the Floor Area Ratio (“FAR”) of 0.88, which exceeds the maximum permitted FAR of 0.50. The Planning Commission voted 3-0, with two Commissioners absent, to recommend denial of the proposed project to the City Council. The Planning Commission determined that the project was not compatible with the adjacent neighborhood in terms of scale and height. It is recommended that the City Council find that the proposal adheres to the required findings and regulations and adopt Resolution No. 7572 adopting the Addendum to the Adopted Mitigated Negative Declaration and approving Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 for the revised project known as the “The Ivy Arcadia.” 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 2 of 16 BACKGROUND The subject site is located at the southeast corner of W. Colorado Boulevard and Michillinda Avenue at 1150 W. Colorado Boulevard. It is zoned General Commercial (C- G) and has a General Plan Land Use Designation of Commercial (.50 FAR). The site is approximately 2.82 acres in size and is currently developed with a vacant 13,088 square foot building that was previously occupied by Coco’s Bakery and Restaurant, which closed in July 2021. The site is surrounded by the 210 Freeway to the north, commercial uses to the west in unincorporated Los Angeles County, and single-family residential properties to the east and south. The residential properties adjacent to this site along the west side of N. Altura Road and both the north and south side of Altura Terrance are not within the Lower Rancho Homeowners Association (“HOA”) but the homes beyond those are located within the Lower Rancho HOA - refer to Figure 1 for an aerial view of the area, and Attachment No. 2 for an Aerial Photo with Zoning Information. Figure 1 – Aerial View of the Site On August 18, 2020, the City Council adopted a Mitigated Negative Declaration and approved the Artis Senior Living Project. The Artis Senior Living Project involved the demolition of the former Coco’s building and the development of a new two-story 44,192 square foot senior living care facility with 80 senior housing units and on-site amenities, inclusive of a community center, a gallery, a café, a barber/beauty shop, a small health N 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 3 of 16 center for the residents, and 58 parking spaces and one loading space for deliveries. The approval also included a Zone Change for the removal of the Architectural Design Overlay Zone and the Automobile Parking Overlay Zone from the site, which restricted the height and buildable area on the lot. The City granted the Applicant two one-year extensions, primarily as a result of the COVID-19 pandemic and the impacts on the industry, but the entitlements expired on March 18, 2024. On November 9, 2023, the Applicant for The Ivy Arcadia filed a revised assisted living care facility project proposal with the City. DISCUSSION The revised project consists of demolishing the existing 13,088 square foot restaurant building and constructing a new 107,706 square foot, three-story Traditional/Cape Cod architectural style building that will provide assisted living and memory care services for seniors that have Alzheimer’s and other related memory loss – refer to Attachment No. 3 for the Architectural Plans and Renderings. The Development Code allows a Large- Residential Care Facility in the General Commercial (C-G) Zone subject to the approval of a Conditional Use Permit. The Applicant, O&I Development, LLC, together with Oakmont Management Group, based in Irvine, California, operate 90 facilities in California, Hawaii, and Nevada that serve over 8,000 seniors. This will be Oakmont’s first facility in Arcadia, known as “The Ivy Arcadia”. This facility will provide 24-hour staffing and will provide residents with services such as daily meals, housekeeping services, transportation services, social activities, and other support services. The facility will serve persons 60 years of age or older; however, the average resident age for assisted living is 86 years old. The facility will have up to 20 employees working between the hours of 10:00 p.m. to 2:00 p.m. and 25 employees between the hours of 2:00 p.m. to 10:00 p.m. The Planning Commission held a public hearing on May 14, 2024, to forward a recommendation to the City Council on the proposed project. During the public hearing, five residents from the adjacent properties spoke against the project citing concerns with privacy due to the height and scale of the project as well as noise impacts. After discussion, the Planning Commission voted unanimously to recommend denial to the City Council and have staff return with a revised Resolution at its June 11 meeting – refer to Attachment No. 5 for an Excerpt of the May 14, 2024, Planning Commission Minutes and the Planning Commission Staff Report. At the June 11, 2024, Planning Commission meeting, the item was pulled from the consent calendar for further discussion. The Applicant was given additional time to present changes to the original project that was brought forth to the Planning Commission after hearing the neighboring property owners’ concerns with privacy, noise, and project aesthetics at the May 14, 2024, Planning Commission hearing. The Applicant conducted outreach to the neighboring property owners and held a meeting with the neighbors on June 3, 2024, to provide redesign updates and address any additional concerns. While 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 4 of 16 the square footage, number of units, and number of beds will remain the same, the Applicant has made revisions that further address some of the neighbors’ concerns, as later discussed in this analysis. The Applicant also provided view simulations of the project from the neighboring residential properties. A total of four residents spoke in opposition to the revised changes. The residents still had concerns with privacy due to the height and scale of the project. After discussion, the Planning Commission voted to adopt Resolution No. 2146 recommending denial to the City Council. The facility will have 100 units with a total of 114 beds. The units will consist of varying room types, including studio, one-bedroom, and two-bedroom units for assisted living and private and shared studios for memory care. The units will range between 396 square foot studios to 1,146 square foot two-bedroom units – refer to Figure 2 below for a Unit Summary. Unit amenities will include kitchens in some of the units, bathrooms, and closet space. The first floor will be comprised of 14 units for assisted living, 30 units for memory care, lobbies, offices, a dining room and a café, a laundry room, a sensory wellness room, a reading room, and a sitting and music area, as well as separate open-air courtyards in the middle of the building. The second floor will be comprised of 36 units for assisted living, offices, a laundry room, and a staff lounge. The third floor will include 20 units for assisted living, a dining room with an exhibition kitchen, a bar/lounge, an activity room, a media room, a fitness center with a physical therapy area, a beauty salon, and storage areas. Additionally, the facility will have an exterior outdoor patio for memory care patients, a workout area, a trash enclosure, and an emergency generator room. A dog park and a bocce ball court will be located on the southeastern portion of the property. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 5 of 16 Figure 2 – Unit Summary After the neighbors adjacent to the easterly property line brought up concerns with the proximity of these amenities at the Planning Commission hearing, the Applicant reduced the size of the dog park area from 1,380 square feet to approximately 685 square feet and both the bocce ball court and dog park have been set back approximately 22’-5” instead of the originally proposed 10’-0” from the neighboring properties to the east to accommodate additional landscape screening. The project design is intended to accommodate the needs of assisted living residents in addition to memory care residents, which requires space for additional quality of life amenities and services for the two 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 6 of 16 resident populations. As with the previously approved project, this proposal will provide housing options to the aging population in the region, and assistance for those with memory care needs. The redevelopment of the site with a senior assisted living care facility was determined by the City Council and Planning Commission back in 2020 as an appropriate use and development for this property that will not negatively affect the adjacent residential properties. The proposed height and setbacks for the revised project have been summarized in Figure 3 below. As can be seen, the proposed setbacks significantly exceed the setbacks required in the zone. Proposed Required Height 40’-0” 40’-0” Maximum Front Setback 20’-0” None Street Side Setback 50’-0” 5’-0” Minimum Interior Side Setback 51’-9” 10’-0” Minimum Rear Setback 35’-0” 20’-0” Minimum Figure 3 – Proposed Height and Setbacks Most of the units on the second and third floors do not face the adjacent residential properties. On the south side of the building, a total of three (3) units on the second floor and three (3) units on the third floor face the adjacent residential properties. On the east side of the building, a total of nine (9) units on the second floor and four (4) units on the third floor face the adjacent residential properties to the east. Furthermore, the additional setback and landscape screening, which was added after hearing the neighbors’ concerns at the Planning Commission hearing, provide additional privacy to the neighboring property owners along the property line. Therefore, the project has incorporated design elements to provide added privacy to the neighbors. The senior assisted living care facility has been designed to be functionally suitable for the proposed site and greater setbacks were provided to be sensitive to the neighbors in terms of privacy. The underlying General Commercial (C-G) Zone allows a maximum FAR of 0.5. The proposed senior assisted living care facility has a FAR of 0.88, which exceeds the maximum permitted FAR. However, under the California Density Bonus Law, a project is entitled to receive a density bonus as a matter of right if it meets the requirements of California Government Code Section 65915. In addition, pursuant to Senate Bill (SB) 713 that was signed by the Governor in October 2023, a local government cannot apply any development standard that precludes the construction of a development seeking a density bonus. Since the project is a senior housing development, it is entitled to receive a density 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 7 of 16 bonus and deviate from the maximum permitted FAR, which would otherwise physically preclude the construction of the proposal based on the maximum allowable residential density under the C-G Zone. The density bonus law does not require affordability for senior housing projects. By virtue of it being a senior housing project, it is subject to the density bonus law requirements. Aside from the FAR, the project would comply with all applicable development standards of the General Commercial C-G Zone, including height and setbacks. Similar to the approved project, the proposed building is designed in a Traditional/Cape Cod architectural style with varied massing and materials and articulation on each of the building façades to help break up the building size – refer to Figure 4 below for renderings of the project. The location on the southeastern corner of W. Colorado Boulevard and Michillinda Avenue provides a suitable focal point as an entryway to the City. The proposed design is consistent with the community character, and will enhance the overall streetscape, as it provides a transition from the commercial corridor to the west of the site, to the residential neighborhoods to the east. The design contains architectural features commonly found within the Traditional and Cape Cod architectural styles, such as white and gray colored vertical and horizontal cement fiber board siding, gray colored shingle siding, gray asphalt shingle roofing, and stone veneer at the base of the building. The design also includes many decorative features, such as white colored Juliet balconies and navy colored wooden shutters on most of the windows, accent gray standing seam metal roofing, planter boxes along the sides of the building, and a porte cochere and front porch that act as focal points on the street side elevations of the building. The use of the various materials along with the articulation provided on each of the building façades helps prevent long or tall looking wall expanses that would otherwise make the building appear large. The overall design is well balanced and aesthetically pleasing with the use of neutral tone colors. Although commercial buildings are typically encouraged to be placed closer to the street, the large setback provided to this building helps it fit in more as a part of the residential neighborhood, in proximity. This revised design will elevate this corner as one of the gateways into the City. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 8 of 16 Figure 4 – Rendering View from W. Colorado Boulevard (top) and Michillinda Avenue (bottom) Vehicular access to the site will be provided off the two existing driveways, one along Colorado Boulevard near the northeastern corner of the property and another along Michillinda Avenue near the southwestern corner. These driveways are proposed to be reconstructed in the same general location in compliance with the Americans with Disabilities Act (“ADA”). A porte cochere will also be provided in front of the main entrance to the facility as a loading and unloading area for the residents. The Development Code requires one (1) parking space for every three (3) licensed beds within the residential care facility. With a total of 114 beds proposed, the project requires a total of 38 parking spaces for the residents, employees, and visitors. Although the Code does not require additional parking for the employees, the Applicant is proposing 22 more parking spaces than the minimum required to ensure there is more than sufficient parking at any given time. The Applicant has reduced the number of parking spaces from 70 spaces to 60 spaces to address the neighbors’ concerns with potential noise from the vehicles along the shared property lines. Four (4) spaces were removed from alongside the eastern property line and six (6) spaces were removed from alongside the southern property line. The site will provide 49 standard spaces, 3 handicap parking spaces, 7 electric vehicle (“EV”) spaces, and 1 EV space that complies with ADA requirements. Parking will be located along the perimeter of the site and EV spaces, after the neighboring residents expressed concerns about the location of spaces along the eastern property line, have been relocated away from the property line and along the eastern side of the proposed building - refer to Figure 5 for the Site Plan. The number of parking spaces proposed is expected to be more than adequate for the site due to the nature of the use, with most residents not having a vehicle. Additionally, according to the traffic analysis, this senior assisted living care facility is expected to generate less trips than the previous Coco’s restaurant operation. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 9 of 16 Figure 5 – Site Plan There are 72 existing trees on site. Of those trees, 22 unprotected ones will be removed. A total of 16 trees on site are protected trees and will be preserved. The Applicant has revised the proposed landscaping to provide denser screening of the proposed building from the residential properties to the east and south, as privacy was a major concern with the adjacent residents. Per the revised conceptual landscape plan, screening shrubs are proposed to be planted as an additional layer along portions of the trees that currently exist along the property line. Additional trees are proposed to be planted in areas where trees are not present adjacent to the property line. An approximately 20-foot-wide landscape screening area runs along most of the easterly property line consisting of three layers: the existing trees adjacent to the property line; a proposed row of screening shrubs; and a row of Brisbane box and crape myrtle trees. In total, 83 new trees are proposed to be planted on site and on the public parkway as part of the conceptual landscape plan. The Applicant will be required to comply with all the tree protection measures in the Arborist Report to ensure that the protected trees will not be harmed 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 10 of 16 during any construction activities – refer to condition of approval no. 4 and Attachment No. 4. The previously approved project required a Protected Tree Encroachment Permit for the encroachment into the driplines of four off-site protected trees. However, the Development Code was amended in 2021 to not require an encroachment permit for any trees off-site that are not protected Oak or Sycamore trees. Since these four protected trees are not oaks or sycamores, a Protected Tree Encroachment Permit is no longer required. Originally, a retaining wall was being proposed along portions of the eastern and southern property line. Residents expressed safety and aesthetic concerns with the location of that wall. Thus, the Applicant has reworked the grading on site and relocated the retaining wall further into the subject lot, eliminating the need for the retaining wall to be adjacent to the property line. As part of the new development, a 4-foot-wide dedication along W. Colorado Boulevard and Michillinda Avenue will be granted to the City to accommodate the widening of the public rights-of-way from approximately 8 feet to 12 feet in width. Construction of the project is expected to occur over a 20-month period. FINDINGS The following findings must be made to approve the proposed project. The sections below contemplate the required findings in totality of the proposal, including the modifications made in response to adjacent property owner concerns. Conditional Use Permit Section 9107.09.050(B) of the Development Code requires that for a Conditional Use Permit to be granted, it must be found that all of the following prerequisite findings can be satisfied: 1. The proposed use is consistent with the General Plan and any applicable specific plan; and is allowed within the applicable zone, subject to the granting of a Conditional Use Permit, and complies with all other applicable provisions of the Development Code and the Municipal Code. Facts to Support This Finding: Approval of the senior assisted living care facility will be consistent with the Commercial General Plan Land Use Designation. The site is zoned General Commercial (C-G) and, pursuant to the Arcadia Development Code Section 9102.03.020, Table 2-8 allows a Large-Residential Care Facility in the General Commercial C-G Zone subject to the review and approval of a Conditional Use Permit. The underlying zone allows for a broad array of commercial uses that are both neighborhood and Citywide serving. The senior assisted living care facility will allow a business that can serve the aging population of the City, specifically those with 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 11 of 16 Alzheimer’s disease and related memory delays. Aside from the FAR, which is a concession of the density bonus, the project complies will all the development standards of the General Commercial C-G Zone. The proposed project will not adversely affect the comprehensive General Plan, and is consistent with the following General Plan goals and policies: • Goal LU-1: A balance of land uses that preserves Arcadia status as a Community of Homes and a community of opportunity. • Policy LU-1.1: Promote new infill and redevelopment projects that are consistent with the City’s land use and compatible with surrounding existing uses. • Policy LU-1.2: Promote new uses of land that provide diverse economic, social, and cultural opportunities, and that reinforce the characteristics that make Arcadia a desirable place to live. • Policy LU-1.5: Require that effective buffer areas be created between land uses that are of significantly different character or that have operating characteristics which could create nuisances along common boundary. 2. The design, location, size, and operating characteristics of the proposed activity will be compatible with the existing and future land uses in the vicinity. Facts to Support This Finding: The project provides a transition between the commercial businesses in the Los Angeles County area to the west of the site and the adjacent residential properties to the east and south as a senior assisted living use. The proposed building will be set back more than the minimum required from the adjacent residential properties and will have a parking and landscape buffer between the facility and the residential uses. The proposed use, being more of a residential use, is not expected to negatively affect the adjacent properties. Parking for the project is above the minimum required and is expected to be an adequate amount for the site due to the nature of the use. Additionally, transportation services will be provided to the residents, and the project will result in an overall reduction of vehicular traffic as compared to the existing use and most other commercial uses that could be considered for the property. The project site is adequate in size and location to accommodate the revised development. Thus, the proposed senior assisted living care facility will be compatible with the existing and future uses in the vicinity. 3. The site is physically suitable in terms of: a. Its design, location, shape, size, and operating characteristics of the proposed use in order to accommodate the use, and all fences, landscaping, loading, parking, spaces, walls, yards, and other features required to adjust the use with the land and uses in the neighborhood. Facts to Support This Finding: The site measures approximately 2.82 acres and is large enough to physically support the new senior care facility. The current utility infrastructure on site is more than capable of accommodating the proposed use. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 12 of 16 Landscaping is being maintained along the perimeter of the lot and various new pockets of landscaping will be introduced around the building site. The project will have two points of access on to the lot and will also provide more than the required amount of parking. The proposed project will comply with all of the regulations within the Development Code except for the FAR, which is allowed to exceed the maximum because of the density bonus for senior housing development. Therefore, the site is adequate in size to accommodate the proposed senior assisted living care facility. b. Streets and highways adequate in width and pavement type to accommodate public and emergency vehicle (e.g., fire and medical) access. Facts to Support This Finding: The project will be located at the southeast corner of W. Colorado Boulevard and Michillinda Avenue. The site will have two access points, with one driveway off each street frontage. Both streets have been designated and designed with the capacity to accommodate both normal public vehicular travel and emergency vehicles. Additionally, the project is expected to generate less traffic than the previous use. Thus, the adjacent streets are adequate in width and pavement type to carry the traffic that would be generated by the proposed facility and to accommodate emergency vehicle access. c. Public protection services (e.g., fire protection, police protection, etc.). Facts to Support This Finding: The construction of the senior assisted living care facility will comply with the Building and Fire Codes, and all other applicable regulations to ensure the safety of the residents and facilitate emergency services. As part of the environmental review process, the Addendum to the Initial Study/Mitigated Negative Declaration determined that Fire and Police protection services can handle the demand for the proposed senior assisted living care facility. d. The provision of utilities (e.g., potable water, schools, solid waste collection and disposal, storm drainage, wastewater collection, treatment, and disposal, etc.). Facts to Support This Finding: It has been determined that the existing infrastructure and public utilities can handle the demand for the proposed senior assisted living care facility, and no upgrades are required. The proposed project will also comply with the Low Impact Development (“LID”) requirements for stormwater discharge through the implementation of a modular wetland on site. 4. The measure of site suitability shall be required to ensure that the type, density, and intensity of use being proposed will not adversely affect the public convenience, health, interest, safety, or general welfare, constitute a nuisance, or be materially injurious to the improvements, persons, property, or uses in the vicinity and zone in which the property is located. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 13 of 16 Facts to Support This Finding: The proposed senior facility is not expected to be detrimental to the public health or welfare, or the surrounding residential and commercial properties. The proposed senior assisted living care facility has been designed to be functionally suitable for the proposed site and be sensitive to the privacy and impact on the adjacent residential properties. The project includes setbacks that exceed the minimum requirement and a landscape and parking buffer. In support of maintaining privacy between the neighboring residential properties, the existing large trees along the perimeter of the site will be kept. Additionally, most of the units on the upper floors of the south side and some units on the upper floor of the east side of the facility do not face the adjacent residential properties. Therefore, the project has incorporated design elements to provide added privacy to the neighbors. The proposed senior assisted living care facility is expected to generate less trips than the previous restaurant use on the site and will have more than the minimum required parking. Traffic in the surrounding area is not expected to be impacted by the use. The construction of the project will meet all Building and Fire Codes and all other applicable regulations. Therefore, the proposed project will not adversely affect the public in general nor will it impact the uses in the vicinity and zone in which the property is located. Architectural Design Review Section 9107.19.050(F) of the Development Code requires that for an Architectural Design Review to be granted, it must be found that all the following prerequisite findings can be satisfied: 1. The proposed development is in compliance with all applicable development standards and regulation in the Development Code. Facts to Support This Finding: The proposed senior assisted living care facility is in compliance with all of the applicable development standards for the C-G Zone, such as the maximum height, setbacks, and parking. The revised project proposes a Floor Area Ratio (“FAR”) of 0.88. The revised project is a senior housing development under the State’s Density Bonus Law and is entitled to exceed the otherwise maximum FAR, which would physically preclude construction of the revised project to the maximum allowable residential density under the General Plan and Zoning. Therefore, the revised project meets the intent of this finding. 2. The proposed development is consistent in the objectives and standards of the applicable Design Guidelines. Facts to Support This Finding: The proposed senior assisted living care facility is designed in the Traditional/Cape Cod architectural style. The design contains architectural features and materials that are commonly found within the proposed architectural styles and which are present in the residential neighborhoods near the site. The proposed design provides varied massing and materials and articulation on each of the building façades to help break up the building size, which is encouraged 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 14 of 16 by the Design Guidelines. The development also considers the privacy and site layout guidelines to ensure that there are minimal impacts on the surrounding properties. Therefore, the project has been designed to be consistent with the Design Guidelines. 3. The proposed development is compatible in terms of scale and aesthetic design with surrounding properties and developments. Facts to Support This Finding: The building was strategically placed away from residential properties to the east and south to minimize any potential impacts to the adjacent residential properties and was pushed back from the streets to maintain a comparable streetscape with the residential properties. The overall design has a balanced and aesthetically pleasing design that will complement the surrounding residential properties in the general vicinity. The use, although commercial in nature, will provide more of a residential type of use and will be less commercially active than other potential developments that could be developed on this site. The proposed design will enhance the overall streetscape, as it provides a transition from the commercial corridor to the west of the site to the residential neighborhoods to the east. The location of the project on the southeastern corner of W. Colorado Boulevard and Michillinda Avenue also provides a suitable focal point as an entryway to the City. 4. The proposed development will have an adequate and efficient site layout in terms of access, vehicular circulation, parking, and landscaping. Facts to Support This Finding: The site, being a corner lot, will have two points of access, with one driveway from W. Colorado Boulevard and another driveway from Michillinda Avenue. The two access points will assist in providing ease of circulation on the lot along with the drive aisles on site, which meet the minimum 25’-0” width required for two-way traffic. Parking will be provided along all four sides of the building and a total of 60 parking spaces are being provided despite the Code only requiring 38 spaces. Additionally, the lot will retain much of the existing mature landscaping along the perimeters of the property in supplying screening to the adjacent residential neighbors, which consist of large trees and hedging, and new pockets of landscaping will be introduced around the building to enhance the architectural design of the building. 5. The proposed development will be in compliance with all of the applicable criteria identified in Section 9107.19.040(C.5). Facts to Support This Finding: All City requirements regarding disabled access and facilities, occupancy limits, building safety, health code compliance, emergency equipment, environmental regulation compliance, and parking and site design shall be complied with by the property owner/applicant to the satisfaction of the Building Official, City Engineer, Deputy Development Services Director, Fire Marshal, and Public Works Services Director, or their respective designees. Additionally, the proposed development will be in compliance with the General Plan, Development 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 15 of 16 Code, Density Bonus law for senior housing developments, the City’s Design Guidelines, and all other applicable City regulations. Based on the foregoing and the attached documentation, all required findings can be made. ENVIRONMENTAL ASSESSMENT On August 18, 2020, the City Council adopted a Mitigated Negative Declaration (“MND”) for the Approved Project – The Artis Senior Living Project. An Addendum to the adopted MND for The Ivy Arcadia was prepared to consider the environmental impacts of the revised project compared to those of the approved project, in accordance with the requirements of California Environmental Quality Act (“CEQA”) and the CEQA Guidelines. As with the originally Approved Project, the Revised Project would be required to comply with all the mitigation measures identified in the adopted 2020 MND. There are no design features included within the Revised Project that would suggest that these mitigation measures would not be sufficient to address any potentially significant impact that would arise from the implementation of the Revised Project. As such, it has been determined that the Revised Project would not result in any new significant environmental impacts from what was previously analyzed in the adopted 2020 MND – Refer to Attachment No. 6. As such, an Addendum to the MND can be adopted. PUBLIC NOTICE/COMMENTS A public hearing notice for this item was posted at the City Clerk’s Office, City Council Chambers, the Arcadia Library, the City’s website, in the Arcadia Weekly and mailed to the property owners located within 300 feet of the subject property on May 2, 2024, prior to the Planning Commission meeting. During the notification period, one concern from the property owner at 545 N. Altura Road was received regarding damage to their rear wall because of the mature trees that lie on the project site. Under the conditions of approval for the project, the Applicant will be required to replace the property line wall along the entire perimeter if they can obtain owner approval. After the May 14 Planning Commission Meeting, a total of four letters of opposition were received from the adjacent residents and two letters of support were received from housing organizations – refer to Attachment No. 7 for all the public comments. It should also be noted that the Applicant also presented the project to the Lower Rancho Homeowners Association Architectural Review Board (“ARB”) on March 21, 2024. The ARB was pleased with Oakmont’s team and their expertise in senior living management, and they were satisfied with the building’s design and its height. Subsequent to the Planning Commission hearing and the revisions to the project based on input received, a second notice was mailed and published in the same manner as the original notice on August 8, 2024, specifically for the City Council Meeting. As of August 16, 2024, staff has not received any additional concerns or comments from the public. 1150 W. Colorado Boulevard – The Ivy Arcadia August 20, 2024 Page 16 of 16 FISCAL IMPACT The project will have no significant impact on City revenues or expenditures. RECOMMENDATION It is recommended that the City Council make the required findings and adopt Resolution No. 7572 and approve Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09, and adopt the Addendum to the adopted Mitigated Negative Declaration, subject to the following conditions of approval. Attachment No. 1: Resolution No. 7572 Attachment No. 2: Aerial Photo and Zoning Information and Photos of the Subject Property Attachment No. 3: Architectural Plans and Renderings Attachment No. 4: Arborist Report, dated April 2024 Attachment No. 5: Resolution No. 2146, Excerpt of the Planning Commission Minutes, dated May 14, 2024, and Planning Commission Staff Report (Without Attachments) Attachment No. 6: Addendum to the Adopted Initial Study/Mitigated Negative Declaration (MND) and the Adopted MND. Technical studies to the Adopted MND are available at: www.arcadiaca.gov/significantprojects Attachment No. 7: Comment Letters Attachment No. 8: Letter to City Council from Cox Castle dated August 14, 2024 $WWDFKPHQW1R 5HVROXWLRQ1R7572 $WWDFKPHQW1R Attachment No. 2 Aerial Photo with Zoning Information and Photos of the Subject Property and the Surrounding Properties Attachment No. 2 Overlays Selected parcel highlighted Parcel location within City of Arcadia N/A Property Owner(s): Lot Area (sq ft): Year Built: Main Structure / Unit (sq. ft.): C-G Number of Units: C Property Characteristics 1976 13,088 0 Property Owner Site Address:1150 W COLORADO BLVD Parcel Number: 5776-001-012 N/A Zoning: General Plan: N/A Downtown Overlay: Downtown Parking Overlay: Architectural Design Overlay:N/A N/A N/A N/A Residential Flex Overlay: N/A N/A N/A N/A Special Height Overlay: N/A Parking Overlay: Racetrack Event Overlay: This map is a user generated static output from an Internet mapping site and is for reference only. Data layers that appear on this map may or may not be accurate, current, or otherwise reliable. Report generated 30-Apr-2024 Page 1 of 1 Subject site Subject site: West view Subject site: East view Subject site: East view Subject site: West view Subject site: East parking lot area Subject site: South parking lot area Subject site: South parking lot area I-210 Freeway located north of the site Commercial building located across the street Gas station located across the street Residential properties to the south west of the site Residential properties that abut to the east of the site along N. Altura Rd. Residential properties that abut to the east of the site along N. Altura Rd. Residential properties that abut to the south of the site along Altura Terrace . Residential properties that abut to the east of the site along N. Altura Rd. Residential properties that abut to the south of the site along Altura Terrace . Residential properties that abut to the south of the site along Altura Terrace . Residential properties that abut to the south of the site along Altura Terrace . 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Ú # ! Ú       &+ &+ %8,/',1* 6(&7,216 ! 1" 3 ,  * 7  ( 3 0 6 1  - - $        $ 0  0  *  % & 7 & - 0 1 . & / 5        1 " 3 ,  1 - " ; "  4 6* 5 &         * 3 7 * / &  $ "       8(&1*" ª *&89ª<*89':.1).3,8*(9.43<&79.8 (4(4 84;*71&> 8(&1*" ª 3479-ª84:9-':.1).3,8*(9.43<&79.8 (4(4 84;*71&> Attachment No. 5 Resolution No. 2146, Excerpt of the Planning Commission Minutes, dated May 14, 2024, and Planning Commission Staff Report (Without Attachments) Attachment No. 5 DATE: May 14, 2024 TO: Honorable Chairman and Planning Commission FROM: Lisa L. Flores, Deputy Development Services Director Edwin Arreola, Associate Planner SUBJECT: RESOLUTION NO. 2146 – ARCHITECTURAL DESIGN REVIEW NO. ADR 23-13 WITH A DENSITY BONUS AND CONDITIONAL USE PERMIT NO. CUP 23-09 TO CONSIDER A REVISED SENIOR ASSISTED LIVING CARE FACILITY (“THE IVY ARCADIA”) WITH AN ADDENDUM TO THE ADOPTED MITIGATED NEGATIVE DECLARATION UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) AT 1150 W. COLORADO BOULEVARD Recommendation: Adopt Resolution No. 2146 Recommending Approval to the City Council SUMMARY The Applicant, O&I Development, LLC, on behalf of the property owner, Artis Senior Living, LLC, is requesting approval of Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 to amend a project that was approved by the City Council in 2020 for a new two-story senior assisted living care facility project with 80 units (Artis Senior Living Project) at 1150 W. Colorado Boulevard. The revised project, known as “The Ivy Arcadia,” will be a three-story senior assisted living care facility with 100 units and 114 beds. The revised project includes a density bonus to allow the Floor Area Ratio (FAR) of 0.88, which exceeds the maximum permitted FAR of 0.50. It is recommended that the Planning Commission adopt Resolution No. 2146 (Attachment No. 1) recommending that the City Council adopt the Addendum to the Adopted Mitigated Negative Declaration (Attachment No. 5) and approve Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 for the revised project known as the “The Ivy Arcadia.” The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 2 of 24 BACKGROUND The subject site is located at the southeast corner of W. Colorado Boulevard and Michillinda Avenue at 1150 W. Colorado Boulevard. It is zoned General Commercial (C- G) and has a General Plan Land Use Designation of Commercial (.50 FAR). The site is approximately 2.82 acres and is currently developed with a vacant 13,088 square foot building that was previously occupied Coco’s Bakery and Restaurant that closed in July 2021. The site is surrounded by the 210 freeway to the north, commercial uses to the west in the Los Angeles County area, and single-family residential properties to the east and south. The residential properties adjacent to this site along the west side of N. Altura Road and both the north and south side of Altura Terrance are not within the Lower Rancho Homeowners Association (HOA) but the homes beyond those are located within the Lower Rancho HOA - refer to Figure No.1 for an aerial view of the area, and Attachment No. 2 for an Aerial Photo with Zoning Information. Figure 1 – Aerial View of the Site On August 18, 2020, the City Council adopted a Mitigated Negative Declaration and approved the Artis Senior Living Project. The Artis Senior Living Project involved the demolition of the building and the development of a new two-story 44,192 square foot senior living care facility with 80 senior housing units and on-site amenities, inclusive of a community center, a gallery, a café, a barber/beauty shop, a small health center for the residents, and 58 parking spaces and one loading space for deliveries. The approval also The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 3 of 24 included a Zone Change for the removal of the Architectural Design Overlay Zone and the Automobile Parking Overlay Zone from the site which restricted the height and buildable area on the lot. The City granted the Applicant two one-year extensions and the entitlements expired on March 18, 2024. On November 9, 2023, the Applicant for The Ivy Arcadia filed a revised project of the assisted living care facility with the City. PROPOSAL The revised project consists of demolishing the existing 13,088 square foot restaurant building and construct a new 107,706 square foot, three-story Traditional/Cape Cod architectural style building that will provide assisted living and memory care services for seniors that have Alzheimer’s and other related memory loss – refer to Attachment No. 3 for the Architectural Plans and Renderings, and Figure No. 2 below for a rendering of the project. The Applicant, O&I Development, LLC - Oakmont Senior Living operates 90 facilities in California, Hawaii, and Nevada. This will be Oakmont’s first facility in Arcadia, known as The Ivy Arcadia, and they will provide 24-hour staffing and services such as daily meals, housekeeping services, transportation services, social activities, and other support services. The facility will serve persons 60 years of age or older, however, their average residence age for assisted living is 86 years old. They will have approximately 10 employees between the hours of 10:00 p.m. to 2:00 p.m. and 15 employees between the hours of 2:00 p.m. to 10:00 p.m. The facility will have 100 units with 114 beds. The units would consist of varying types, including studio, one-bedroom, and two-bedroom units for assisted living and private and shared studios for memory care. The building is proposed to be built at the maximum height of 40’-0” and will have an interior side yard setback of 51’-9”, whereas 10’-0” is required, a street-side yard setback of 50’-0”, whereas 5’-0” is required, a minimum rear yard setback of 35’-0”, whereas 20’-0” is required, and a 29’-0” front yard setback, whereas no setback is required. Figure 2 – Rendering View from W. Colorado Boulevard The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 4 of 24 The units will range between 396 square foot studios to 1,146 square foot two-bedroom units (see Figure 3 below for a Unit Summary). Unit amenities will include kitchens in some of the units, bathrooms, and closet space. The first floor will comprise of 14 units for assisted living, 30 units for memory care, lobbies, offices, a dining room and a café, a laundry room, a sensory wellness room, a reading room, and a sitting and music area, as well as separate open-air courtyards in the middle of the building. The second floor will comprise of 36 units for assisted living, offices, a laundry room, and a staff lounge. The third floor will comprise of 20 units for assisted living, a dining room with an exhibition kitchen, a bar/lounge, an activity room, a media room, a fitness center with a physical therapy area, a beauty salon, and storage areas. Additionally, the facility will have an exterior outdoor patio for memory care patients, a workout area, a trash enclosure, and an emergency generator room. A dog park and a bocce ball court will be located in the southeastern portion of the property. Figure 3 – Unit Summary Vehicular access to the site will be provided off the two existing driveways, one along Colorado Boulevard near the northeastern corner of the property and another along Michillinda Avenue near the southwestern corner. These driveways are proposed to be reconstructed in the same general location for American with Disabilities Act (ADA) compliance. A porte cochere would also be provided in front of the main entrance to the facility as a loading and unloading area for the residents. In terms of parking, the site will provide 70 parking spaces: 61 standard spaces, 2 handicap parking spaces, 6 electric The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 5 of 24 vehicle (EV) spaces, and 1 EV space that complies with ADA requirements. Parking will be located along the perimeter of the site (refer to the Site Plan below under Figure 4). Figure 4 – Site Plan As part of the project, 22 unprotected trees will be removed. All 16 of the protected trees on site will be preserved, and additional trees will be planted alongside the remaining unprotected trees to provide screening of the proposed building from the residential properties to the east and south. The Applicant will be required to comply with all the tree protection measures in the Arborist Report to ensure that the protected trees will not be harm during any construction activities – refer to condition of approval no. 4 and Attachment No. 4. As part of the new development, a 4-foot-wide dedication along W. Colorado Boulevard and Michillinda Avenue will be granted to the City to accommodate the widening of the The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 6 of 24 public rights-of-way from approximately 8 feet to 12 feet in width. Construction of the project is expected to occur over a 20-month period. ANALYSIS The Development Code allows a Large-Residential Care Facility in the General Commercial (C-G) zone subject to the approval of a Conditional Use Permit. The senior assisted living care facility has been designed to be functionally suitable for the proposed site and be sensitive to the privacy and impact on the adjacent residential properties. As with the previously approved project, this proposal will provide housing options to the aging population of the region, and assistance for those with memory care needs. The redevelopment of the site with a senior assisted living care facility was determined by the City Council and Planning Commission back in 2020 as an appropriate use and development for this property. According to the traffic analysis, this senior assisted living care facility is expected to generate less trips than the previous Coco’s restaurant when it was in operation. The underlying General Commercial (C-G) zone allows a maximum FAR of 0.5. The proposed senior assisted living care facility has a FAR of 0.88, which exceeds the maximum permitted FAR. However, under the California Density Bonus Law, a project is entitled to receive a density bonus as a matter of right if it meets the requirements of California Government Code Section 65915. In addition, pursuant to Senate Bill (SB) 713, which was signed by Governor Newsom in October 2023, a local government cannot apply any development standard that precludes the construction of a development seeking a density bonus. Since the project is a senior housing development, it is entitled to receive a density bonus and deviate from the maximum permitted FAR, which would otherwise physically preclude the construction of the proposal based on the maximum allowable residential density under the C-G zone. The density bonus law does not require affordability for senior housing projects. By virtue of it being a senior housing project, it is a density bonus law project, and any requests for a density bonus has to be approved by City Council. The proposed building will be situated 35’-0” from the adjacent residential properties to the south, and 51’-9” from the residential properties to the east. To maintain the existing privacy between facility and the neighboring residential properties, the existing large trees along the perimeter of the site will be kept and new trees and/or hedges will be added where there is a gap. Additionally, most of the units on the upper floors of the south side of the facility do not face the adjacent residential properties. Therefore, the project has incorporated design elements to provide added privacy to the neighbors. In terms of parking, the Development Code requires one (1) parking space for every three (3) licensed beds within the residential care facility. With a total of 114 beds proposed, the project requires a total of 38 parking spaces for the residents, employees, and visitors. Although the Code does not require additional parking for the employees, the Applicant is proposing 32 more parking spaces to ensure there is more than sufficient parking at any given time. The project would comply with all other applicable development standards, including height, and setbacks. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 7 of 24 The previously approved project required a Protected Tree Encroachment Permit for the encroachment into the driplines of four, off-site, protected trees. However, the Development Code has since been amended to not require an encroachment permit for any trees off-site that are not a protected Oak or Sycamore trees. Since these four protected trees are not oaks or sycamores, a Protected Tree Encroachment Permit is no longer required. Architectural Style Similarly to the approved project, the proposed building is designed in a Traditional/Cape Cod architectural style with varied massing and materials and articulation on each of the building façades to help break up the building size. The proposed design complements the adjoining residential properties and will enhance the overall streetscape, as it provides a transition from the commercial corridor to the west of the site to the residential neighborhoods to the east – refer to Attachment No. 3 for the architectural plans and to the rendering above. The design contains architectural features that are commonly found within the Traditional and Cape Cod architectural styles, such as white and gray colored vertical and horizontal cement fiber board siding, gray colored shingle siding, gray asphalt shingle roofing, and stone veneer at the base of the building. The design also includes many decorative features, such as white colored Juliet balconies and navy colored wooden shutters on most of the windows, accent gray standing seam metal roofing, planter boxes along the sides of the building, and a porte cochere and front porch that act as focal points on the street side elevations of the building. The use of the various materials along with the articulation provided on each of the building façades helps prevent long or tall looking wall expanses that would otherwise make the building appear large. The overall design is well balanced and aesthetically pleasing with the use of neutral tone colors. The location on the southeastern corner of W. Colorado Boulevard and Michillinda Avenue provides a suitable focal point as an entryway to the City. Although commercial buildings are typically encouraged to be placed closer to the street, the large setback provided to this building helps make it fit in as more of a part of the residential neighborhood in proximity. Figure 5 – Rendering View from Michillinda Avenue The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 8 of 24 This revised design will elevate this corner as the City has also envisioned a high-end development at this location since this is one of the gateways into the City. FINDINGS Conditional Use Permit Section 9107.09.050(B) of the Development Code requires that for a Conditional Use Permit to be granted, it must be found that all of the following prerequisite findings can be satisfied: 1. The proposed use is consistent with the General Plan and any applicable specific plan; and is allowed within the applicable zone, subject to the granting of a Conditional Use Permit, and complies with all other applicable provisions of the Development Code and the Municipal Code. Facts to Support This Finding: Approval of the senior assisted living care facility will be consistent with the Commercial General Plan Land Use Designation. The site is zoned General Commercial (C-G) and pursuant to the Arcadia Development Code Section 9102.03.020, Table 2-8, allows a Large-Residential Care Facility in the General Commercial C-G zone subject to the review and approval of a Conditional Use Permit. The underlying zone allows for a broad array of commercial uses that are both neighborhood and citywide serving. The senior assisted living care facility will allow a business that can serve the aging population of the City, specifically those with Alzheimer’s disease and related memory delays. Aside from the FAR, which is a concession of the density bonus, the project complies will all the development standards of the General Commercial C-G zone. The proposed project will not adversely affect the comprehensive General Plan, and is consistent with the following General Plan goals and policies: • Goal LU-1: A balance of land uses that preserves Arcadia status as a Community of Homes and a community of opportunity. • Policy LU-1.1: Promote new infill and redevelopment projects that are consistent with the City’s land use and compatible with surrounding existing uses. • Policy LU-1.2: Promote new uses of land that provide diverse economic, social, and cultural opportunities, and that reinforce the characteristics that make Arcadia a desirable place to live. • Policy LU-1.5: Require that effective buffer areas be created between land uses that are of significantly different character or that have operating characteristics which could create nuisances along common boundary. 2. The design, location, size, and operating characteristics of the proposed activity will be compatible with the existing and future land uses in the vicinity. Facts to Support This Finding: The project provides a transition between the commercial businesses in the Los Angeles County area to the west of the site and the The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 9 of 24 adjacent residential properties to the east and south as a senior assisted living use. The proposed building will be setback more than the minimum required from the adjacent residential properties and will have a parking and landscape buffer between the facility and the residential uses. The proposed use, being more of a residential use, is not expected to negatively affect the adjacent properties. Parking for the project is above the minimum required and is expected to be an adequate amount for the site due to the nature of the use which wouldn’t consist of many residents that drive. Additionally, transportation services will be provided to the residents. Additionally, the project will result in an overall reduction of vehicular traffic as compared to the existing use and most other commercial uses that could be considered for the property. The project site is adequate in size and location to accommodate the revised development. Thus, the proposed senior assisted living care facility will be compatible with the existing and future uses in the vicinity. 3. The site is physically suitable in terms of: a. Its design, location, shape, size, and operating characteristics of the proposed use in order to accommodate the use, and all fences, landscaping, loading, parking, spaces, walls, yards, and other features required to adjust the use with the land and uses in the neighborhood. Facts to Support This Finding: The site measures approximately 2.82 acres and is large enough to physically support the new senior care facility. The current utility infrastructure on site is more than capable of accommodating the proposed use. Landscaping is being maintained along the perimeter of the lot and various new pockets of landscaping will be introduced around the building site. The project will have two points of access on to the lot and will also provide more than the required amount of parking. The proposed project will comply with all of the regulations within the Development Code except for the FAR which is allowed to exceed the maximum because of the density bonus for senior housing development. Therefore, the site is adequate in size to accommodate the proposed senior assisted living care facility. b. Streets and highways adequate in width and pavement type to accommodate public and emergency vehicle (e.g., fire and medical) access. Facts to Support This Finding: The project will be located at the southeast corner of W. Colorado Boulevard and Michillinda Avenue. The site will have two access points, with one driveway off of each street frontage. Both streets have been designated and designed with the capacity to accommodate both normal public vehicular travel and emergency vehicles. Additionally, the project is expected to generate less traffic than the previous use. Thus, the adjacent streets are adequate in width and pavement type to carry the traffic that would be generated by the proposed facility and to accommodate emergency vehicle access. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 10 of 24 c. Public protection services (e.g., fire protection, police protection, etc.). Facts to Support This Finding: The construction of the senior assisted living care facility will comply with the Building and Fire Codes, and all other applicable regulations to ensure the safety of the residents and facilitate emergency services. As part of the environmental review process, the Addendum to the Initial Study/Mitigated Negative Declaration determined that Fire and Police protection services can handle the demand for the proposed senior assisted living care facility. d. The provision of utilities (e.g., potable water, schools, solid waste collection and disposal, storm drainage, wastewater collection, treatment, and disposal, etc.). Facts to Support This Finding: It has been determined that the existing infrastructure and public utilities can handle the demand for the proposed senior assisted living care facility, and no upgrades are required. The proposed project will also comply with the Low Impact Development (LID) requirements for stormwater discharge through the implementation of a modular wetland on site. 4. The measure of site suitability shall be required to ensure that the type, density, and intensity of use being proposed will not adversely affect the public convenience, health, interest, safety, or general welfare, constitute a nuisance, or be materially injurious to the improvements, persons, property, or uses in the vicinity and zone in which the property is located. Facts to Support This Finding: The proposed senior facility is not expected to be detrimental to the public health or welfare, or the surrounding residential and commercial properties. The proposed senior assisted living care facility has been designed to be functionally suitable for the proposed site and be sensitive to the privacy and impact on the adjacent residential properties. The project includes setbacks that exceed the minimum requirement and a landscape and parking buffer. In support of maintaining privacy between the neighboring residential properties, the existing large trees along the perimeter of the site will be kept. Additionally, most of the units on the upper floors of the south side of the facility do not face the adjacent residential properties. Therefore, the project has incorporated design elements to provide added privacy to the neighbors. The proposed senior assisted living care facility is expected to generate less trips than the previous restaurant use on the site and will have more than the minimum required parking. Traffic in the surrounding area is not expected to be impacted by the use. The construction of the project will meet all Building and Fire Codes, and all other applicable regulations. Therefore, the proposed project will not adversely affect the public in general nor will it impact the uses in the vicinity and zone in which the property is located. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 11 of 24 Architectural Design Review Section 9107.19.050(F) of the Development Code requires that for an Architectural Design Review to be granted, it must be found that all of the following prerequisite findings can be satisfied: 1. The proposed development is in compliance with all applicable development standards and regulation in the Development Code. Facts to Support This Finding: The proposed senior assisted living care facility is in compliance with all of the applicable development standards for the C-G zone, such as the maximum height, setbacks, and parking. The revised project proposes a Floor Area Ratio (FAR) of 0.88. The revised project is a senior housing development under the State’s Density Bonus Law and is entitled to exceed the otherwise maximum FAR, which would physically preclude construction of the revised project to the maximum allow residential density under the General Plan and Zoning. Therefore, the revised project meets the intent of this finding. 2. The proposed development is consistent in the objectives and standards of the applicable Design Guidelines. Facts to Support This Finding: The proposed senior assisted living care facility is designed in the Traditional/Cape Cod architectural style. The design contains architectural features and materials that are commonly found within the proposed architectural styles. The proposed design provides varied massing and materials and articulation on each of the building façades to help break up the building size which is encouraged by the Design Guidelines. The development also considers the privacy and site layout guidelines to ensure that there are minimal impacts on the surrounding properties. Therefore, the project has been designed to be consistent with the Design Guidelines. 3. The proposed development is compatible in terms of scale and aesthetic design with surrounding properties and developments. Facts to Support This Finding: The building was strategically placed away from residential properties to the east and south to minimize any potential impacts to the adjacent residential properties and was pushed back from the streets to maintain a comparable streetscape with the residential properties. The overall design has a balanced and aesthetically pleasing design that will complement the surrounding residential properties in the general vicinity. The use, although commercial in nature, will provide more of a residential type of use and will be less commercially active than other potential developments that could be developed on this site. The proposed design will enhance the overall streetscape, as it provides a transition from the commercial corridor to the west of the site to the residential neighborhoods to the east. The location of the project on the southeastern corner of W. Colorado Boulevard and Michillinda Avenue also provides a suitable focal point as an entryway to the City. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 12 of 24 4. The proposed development will have an adequate and efficient site layout in terms of access, vehicular circulation, parking, and landscaping. Facts to Support This Finding: The site, being a corner lot, will have two points of access, with one driveway from W. Colorado Boulevard and another driveway from Michillinda Avenue. The two access points will assist in providing ease of circulation on the lot along with the drive aisles on site which meet the minimum 25’-0” width required for two-way traffic. Parking will be provided along all four sides of the building and a total of 70 parking spaces are being provided despite the code only requiring 38 spaces. Additionally, the lot will retain much of the existing landscaping along the perimeters of the property in supplying screening to the adjacent residential neighbors, which consist of large trees and hedging, and new pockets of landscaping will be introduced around the building to enhance the architectural design of the building. 5. The proposed development will be in compliance with all of the applicable criteria identified in Section 9107.19.040(C.5). Facts to Support This Finding: All City requirements regarding disabled access and facilities, occupancy limits, building safety, health code compliance, emergency equipment, environmental regulation compliance, and parking and site design shall be complied with by the property owner/applicant to the satisfaction of the Building Official, City Engineer, Deputy Development Services Director, Fire Marshal, and Public Works Services Director, or their respective designees. Additionally, the proposed development will be in compliance with the General Plan, Development Code, Density Bonus law for senior housing developments, the City’s Design Guidelines, and all other applicable City regulations. ENVIRONMENTAL ASSESSMENT On August 18, 2020, the City Council adopted a Mitigated Negative Declaration (MND) for the Approved Project – The Artis Senior Living Project. An Addendum to the adopted MND for The Ivy Arcadia was prepared to consider the environmental impacts of the revised project compared to those of the approved project, and in accordance with the requirements of California Environmental Quality Act (CEQA) and the CEQA Guidelines. As with the Approved Project, the Revised Project would be required to comply with all the mitigation measures identified in the adopted 2020 MND. There are no design features included within the Revised Project that would suggest that these mitigation measures would not be sufficient to address any potentially significant impact that would arise from the implementation of the Revised Project. As such, there are no changes to the circumstances, and implementation of the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact and less-than-significant impact with mitigation in the adopted 2020 MND – Refer to Attachment No. 5. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 13 of 24 PUBLIC NOTICE/COMMENTS A public hearing notice for this item was posted at the City Clerk’s Office, City Council Chambers, the Arcadia Library, the City’s website, and in the Arcadia Weekly on May 2, 2024. It was also mailed to the property owners located within 300 feet of the subject property. As of May 10, 2024, no comments were received regarding this project. The Applicant also presented the project to the Lower Rancho Homeowners Association Architectural Review Board (ARB) on March 21, 2024. The ARB was pleased with Oakmont’s team and their expertise in senior living management, and they were satisfied with the building’s design and its height. During the notification period, Staff did receive one concern from the property owner at 545 N. Altura Road regarding damage to their rear wall because of the mature trees that lies on the project site. Due to this concern, the Applicant intends to replace their wall, and possibly the entire eastern perimeter wall if they can obtain all the owner’s approval. As a result, a condition of approval has been added that the Applicant shall file a separate permit for the tree permit (removal or encroachment) with the Planning Division and it shall be processed administratively by the staff – refer to condition no. 5. RECOMMENDATION It is recommended that the Planning Commission adopt Resolution No. 2146 recommending approval of Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 for new 107,706 square foot, three- story building containing 100 units with 114 beds, and adopt the Addendum to the approved Mitigated Negative Declaration, subject to the following conditions of approval: 1. The project shall be developed and maintained by the Property Owner/Applicant in a manner that is consistent with the plans submitted and conditionally approved for Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09, subject to the satisfaction of the Deputy Development Services Director or designee. 2. The Property Owner/Applicant shall submit an official ALTA survey of the property to the City prior to submitting plans into Building Services for plan-check. The City shall retain all access and other rights over the sanitary sewer easement and storm drain easement that are located on and under the subject property, and the Property Owner/Applicant shall make any adjustment, modifications, and/or abandon the sewer line in its development of the property, or amendments to current easement of record, deemed by the City to reasonably necessary for the City to maintain such infrastructure and access. All new or existing manholes to remain on the site as part of the new development shall be within a paved area. Final placement of the manholes shall be subject to review and approval of the Public Works Department. Any agreement that is required by the City to allow the development to occur over the easements shall be prepared by the Property Owner/Applicant and shall be subject to approval by the City Attorney prior to recordation in the Los Angeles County Recorder’s Office. For purposes of the City Attorney review of any such The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 14 of 24 document, the Property Owner/Applicant shall submit to the City a deposit of $5,000, of which any funds remaining after review and approval by the City shall be returned to the Property Owner/Applicant. 3. Prior to the issuance of the Certificate of Occupancy, the Property Owner/ Applicant shall submit to Planning Services a copy of the form of lease or occupancy agreement that will be utilized for the proposed senior living facility. The form of such agreement must require all future residents to acknowledge the potential health risk associated with living within 500 feet of a freeway. Such acknowledgment shall be placed in all such future agreements for the senior living facility. 4. The Property Owner/Applicant shall comply with all the tree protection measures in the Arborist Report that was prepared by a Certified Arborist, dated April 2024 to ensure that all 16 protected trees will not be harm or impacted by any construction activities. If any of the protected trees do not survive prior to issuance of a Certificate of Occupancy from the Building Division, the tree shall be replaced and the Deputy Development Services Director or designee has the discretion to approve the tree size and its location. 5. The replacement of the eastern perimeter wall (a portion or the entire wall) and any tree removal or encroachment shall be subject to review and approval by the Planning Division prior to issuance of a building permit. 6. The Property Owner/Applicant shall submit a haul route map and construction staging plan to Planning Services prior to issuance of a Demolition permit. 7. The Property Owner/Applicant shall be responsible for the repair of all damage to public improvements in the public right-of-way resulting from construction related activities, including, but not limited to, the movement and/or delivery of equipment, materials, and soils to and/or from the site. The need for such repair shall be determined by the Deputy Development Services Director, the Public Works Services Director, City Engineer, or designees, during construction and up until issuance of a Certificate of Occupancy. 8. Accessible routes shall be provided from the public sidewalk, any public transportation stops, and the trash enclosure to an accessible building entrance. 9. An international symbol of accessibility (ISA) shall be provided at the head end of the accessible electric vehicle (EV) charging spaces. A 30” by 48” clear floor space shall be provided at the EV charger to approach and operate the charger. 10. The plans that are submitted to Building Services for plan-check shall comply with the latest adopted edition of the following codes as applicable: a. California Building Code (CBC) b. California Electrical Code c. California Mechanical Code The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 15 of 24 d. California Plumbing Code e. California Energy Code f. California Fire Code g. California Green Building Standards Code h. California Existing Building Code i. Arcadia Municipal Code 11. Prior to the issuance of a building permit from Building Services, the Property Owner/Applicant shall irrevocably dedicate to the City 4’-0” along the frontage of Colorado Boulevard and Michillinda Avenue for a total parkway width of 12’-0”, as measured from curb to property line. A corner cutback at Michillinda Avenue/Colorado Boulevard is also required to accommodate an ADA curb per Caltrans standard A88A. Both dedications shall be subject to review and approval by the City Engineer. 12. The Property Owner/Applicant shall be required to remove and replace the existing sidewalk, curb, and gutter along the property frontage of Michillinda Avenue and Colorado Boulevard. Red curb locations shall be repainted after construction of the new curb. 13. Prior to the issuance of the Certificate of Occupancy by Building Services, the Property Owner/Applicant shall modify the median island left turn pocket to accommodate the driveway approach on W. Colorado Boulevard in accordance with plans which shall be subject to approval by the City Engineer, or designee. 14. The Property Owner/Applicant shall be required to remove the existing driveway approaches and construct new driveway approaches per City Standards with ADA access around each approach. 15. A Low Impact Development (LID) plan is required for this development. It shall comply with the Los Angeles County Department of Public Works 2014 LID standard manual, and the measurements must be shown on the grading plan. 16. Coordinate with the utility companies to underground all utilities, including but not limited to, cable television, telephone, and electrical systems. If above ground utilities are being proposed, the utilities must be placed outside of the public right- of-way, on private property, and reviewed by the City Engineer prior to installation. 17. The Property Owner/Applicant shall coordinate with the Public Works Services Department on the replacement and/or protection of street trees prior to issuance of a grading permit from Building Services. 18. The Property Owner/Applicant shall make its fair share payment into the cost of a Citywide Standard of Cover Risk Assessment Survey to evaluate Fire resources Citywide. The fee shall be determined by the Fire Chief and the fee shall be collected prior to issuance of a building permit from Building Services. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 16 of 24 19. The building shall be fully fire sprinklered per the City of Arcadia Fire Department Commercial Sprinkler Standard. The fire sprinkler system shall be monitored by a UL listed central station. Notification appliances shall be provided in all common areas. The dwelling units shall be provided with the ability to install visual appliances. 20. Single station smoke alarms shall be provided in all the dwelling units. Carbon monoxide alarms shall also be provided if gas fueled appliances are being used. Any commercial cooking hoods shall be protected by an automatic extinguishing system and the system shall be monitored by a fire alarm system. 21. An on-site minimum 26-foot wide fire lane extending from Michillinda Avenue to Colorado Boulevard shall be provided. 22. The Property Owner/Applicant shall install three (3) new fire hydrants. The locations shall be depicted on the site plan and shall be subject to review and approval by the Fire Marshall prior to issuance of a building permit for the project. The fire hydrants shall be placed at the following locations: a. A public hydrant on Michillinda Avenue located adjacent to the driveway entry. b. A public hydrant on Colorado Boulevard located adjacent to the driveway entry. c. A private hydrant on the east side of the property. 23. A Two-Way Communication system shall be provided per the Fire Department. 24. All passenger elevators shall be EMS capable. 25. Any use of delayed egress systems shall be per CBC 1010. 26. Refuge areas shall be provided within each smoke compartment per CBC 420.6.2. 27. Low-level exit signage shall be provided in all fire rated exit corridors. 28. Knox boxes shall be provided at the front entry and exterior doors at the southeast and southwest stairwells. Stairwell doors shall be keyed to provide for exterior emergency access. 29. Minimum 2A:10BC fire extinguishers shall be provided in all common areas. The maximum travel distance to a fire extinguisher shall be 75 feet. 30. In order to verify the required water service size for the project, the Property Owner/Applicant shall submit to the Public Works Services Department calculations for the maximum commercial use demand and maximum fire demand prior to the issuance of a building permit. Fire protection requirements shall be as stipulated by the Arcadia Fire Department and shall be conformed to Arcadia Standard Plan. A separate fire service with Double Check Detector Assembly (DCDA) shall be installed for fire service required. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 17 of 24 31. The Property Owner/Applicant shall provide separate water services and meters for the facility and outdoor irrigation system. A reduced pressure backflow device shall be installed for each water service. 32. Prior to the issuance of a building permit, the Property Owner/Applicant shall submit a Water Meter Permit Application to the Public Works Services Department. 33. The Property Owner/Applicant shall provide a new water service installation. Installation shall be according to the specifications of the Public Works Services Department, Engineering Division. Abandonment of existing water services, if necessary, shall be completed by the Property Owner/Applicant, according to Public Works Services Department, Engineering Section specifications. 34. The Property Owner/Applicant shall connect to the Los Angeles County sewer line on Michillinda Avenue. The Property Owner/Applicant shall coordinate with the Los Angeles County Sanitation Districts (LACSD) for connection. 35. The Property Owner/Applicant shall abandon the entire easement portion of the existing sewer line between the project site and Altura Road. 36. Prior to the issuance of a grading permit, the Property Owner/Applicant shall prepare a Storm Water Pollution Prevention Plan (SWPPP) and shall obtain a Waste Discharge Identification (WDID) number from the State. 37. The trash enclosure area shall be installed by the Property Owner/Applicant and shall comply with the following: a. A minimum interior width of 9’-7” in order to accommodate three (3) 3-yard bin. b. A minimum roof clearance of 10-0” to allow the bin lids to open completely. c. Shall include a trash, recycling and organics recycling bins. d. Provide a minimum of one (1) foot clearance around the trash bin/recycling bin. 38. The Property Owner/Applicant shall comply with all City requirements regarding building safety, fire prevention, detection, suppression, emergency access, public right-of-way improvements, parking, water supply and water facilities, sewer facilities, trash reduction and recycling requirements, and National Pollutant Discharge Elimination System (NPDES) measures, all to the satisfaction of the Building Official, Fire Marshal, Public Works Services Director, and Deputy Development Services Director. Compliance with these requirements is to be determined by having fully detailed construction plans submitted for plan check review and approval by the foregoing City officials and employees. 39. To the maximum extent permitted by law, Applicant must defend, indemnify, and hold the City, any departments, agencies, divisions, boards, and/or commissions of the City, and its elected officials, officers, contractors serving as City officials, agents, The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 18 of 24 employees, and attorneys of the City (“Indemnitees”) harmless from liability for damages and/or claims, actions, or proceedings for damages for personal injuries, including death, and claims for property damage, and with respect to all other actions and liabilities for damages caused or alleged to have been caused by reason of the Applicant’s activities in connection with ADR 23-13 and CUP 23-09 (“Project”) on the Project site, and which may arise from the direct or indirect operations of the Applicant or those of the Applicant’s contractors, agents, tenants, employees or any other persons acting on Applicant’s behalf, which relate to the development and/or construction of the Project. This indemnity provision applies to all damages and claims, actions, or proceedings for damages, as described above, regardless of whether the City prepared, supplied, or approved the plans, specifications, or other documents for the Project. In the event of any legal action challenging the validity, applicability, or interpretation of any provision of this approval, or any other supporting document relating to the Project, the City will notify the Applicant of the claim, action, or proceedings and will cooperate in the defense of the matter. The Applicant must indemnify, defend and hold harmless the Indemnitees, and each of them, with respect to all liability, costs and expenses incurred by, and/or awarded against, the City or any of the Indemnitees in relation to such action. Within 15 days’ notice from the City of any such action, the Applicant shall provide to the City a cash deposit to cover legal fees, costs, and expenses incurred by City in connection with defense of any legal action in an initial amount to be reasonably determined by the City Attorney. The City may draw funds from the deposit for such fees, costs, and expenses. Within 5 business days of each and every notice from the City that the deposit has fallen below the initial amount, Applicant/Property Owner shall replenish the deposit each and every time in order for City’s legal team to continue working on the matter. The City shall only refund to the Applicant/Property Owner any unexpended funds from the deposit within 30 days of: (i) a final, non-appealable decision by a court of competent jurisdiction resolving the legal action; or (ii) full and complete settlement of legal action. The City shall have the right to select legal counsel of its choice. The parties hereby agree to cooperate in defending such action. The City will not voluntarily assist in any such third-party challenge(s). In consideration for approval of the Project, this condition shall remain in effect if the entitlement(s) related to this Project is rescinded or revoked, at the request of the Applicant or not. 40. Approval of Architectural Design Review No. ADR 23-13 and Conditional Use Permit No. CUP 23-09 shall not be in effect unless the Property Owner and Applicant have executed and filed the Acceptance Form with the City on or before 30 calendar days after the Planning Commission has adopted the Resolution. The Acceptance Form to the Development Services Department is to indicate awareness and acceptance of the conditions of approval. Mitigation Measures as Conditions of Approval The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 19 of 24 The following conditions are found in the Mitigation Monitoring and Reporting Program (MMRP). They are recorded here to facilitate review and implementation. More information on the timing and responsible parties for these mitigation measures are detailed in the MMRP. Biological Resources 41. BIO-1: Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the Deputy Development Services Director or Designee. 42. BIO-2: Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: a. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. b. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. c. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. d. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. e. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 20 of 24 f. The arborist shall monitor a few critical phases of the Project, including pre- demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. g. Additional construction best practices described in the Protected Tree Report shall be implemented. Cultural Resources 43. CUL-1: Treatment of previously unidentified archaeological deposits: If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility. Geology and Soils 44. GEO-1: If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. Noise 45. NOI-1: Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Planning Division, that the Project complies with the following: a. Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 21 of 24 b. The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on- site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Deputy Development Services Director (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. c. During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. d. Prior to issuance of any Grading or Building Permit, the Project applicant shall demonstrate to the satisfaction of the Deputy Development Services Director (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. e. Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. Tribal Cultural Resources 46. TCR-1: The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians-Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 22 of 24 47. TCR-2: Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place or recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. 48. TCR-3: 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 23 of 24 Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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. 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. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. 49. TCR-4: Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working The Ivy Arcadia 1150 W. Colorado Boulevard May 14, 2024 Page 24 of 24 with Native American archaeological sites in Southern California. The qualified archaeologist shall ensure that all other personnel are appropriately trained and qualified. PLANNING COMMISSION ACTION It is recommended that the Planning Commission adopt Resolution No. 2146 recommending that the City Council adopt the Addendum to the adopted Mitigated Negative Declaration and approve Architectural Design Review No. ADR 23-13 with a density bonus and Conditional Use Permit No. CUP 23-09 approving the revised project, “The Ivy Arcadia” for a new three-story senior assisted living care facility with 100 units and 114 beds at 1150 W. Colorado Boulevard. If any Planning Commissioner or other interested party has any questions or comments regarding this matter prior to the May 14, 2024 hearing, please contact Lisa Flores, Deputy Director at (626) 574-5445, or by email at lflores@ArcadiaCA.gov. Approved: Lisa L. Flores Deputy Development Services Director Attachment No. 1: Resolution No. 2146 Attachment No. 2: Aerial Photo and Zoning Information and Photos of the Subject Property Attachment No. 3: Architectural Plans and Renderings Attachment No. 4: Arborist Report Attachment No. 5: Addendum to the Adopted Initial Study/Mitigated Negative Declaration (MND) and the Adopted MND. Technical studies to the Adopted MND are available at www.arcadiaca.gov/significantprojects $WWDFKPHQW1R $GGHQGXPWRWKH$GRSWHG,QLWLDO6WXG\ 0LWLJDWHG1HJDWLYH'HFODUDWLRQ 01' DQG WKH$GRSWHG01'±7HFKQLFDO6WXGLHV $SSHQGL[$ ±( FDQEHIRXQGDW ZZZ$UFDGLD&$JRYVLJQLILFDQWSURMHFWV $WWDFKPHQW1R Addendum to the Artis Senior Living Project Initial Study/Mitigated Negative Declaration LEAD AGENCY: City of Arcadia 240 W. Huntington Drive Arcadia, CA 91007 Contact: Edwin Arreola, Associate Planner (626) 821-4334 PREPARED BY: Michael Baker International 3760 Kilroy Airport Way, Suite 270 Long Beach, California 90806 April 2024 Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 1 1.0 INTRODUCTION On August 18, 2020, the City of Arcadia City Council adopted a Mitigated Negative Declaration (2020 MND) for the Artis Senior Living Project, which was proposed at the southeastern corner of the intersection of Colorado Boulevard and Michillinda Avenue at 1150 West Colorado Boulevard in the City of Arcadia (see Figure 1). The Artis Senior Living Project involved the demolition of an approximately 13,000-square-foot building (previously occupied by a Coco’s Bakery and Restaurant) and the development of a new two-story, 44,192-square-foot senior/assisted living care facility with 80 senior housing units and on-site amenities, inclusive of a community center, a gallery, a café, a barber/beauty shop, and a small health center for the residents, and 58 parking spaces and one loading space (Approved Project). The Project Applicant, O&I Development, LLC, is now proposing to develop the Project Site with a new 107,706-square-foot, three-story building containing 100 units (with 114 beds), which constitutes the Revised Project, known as The Ivy Arcadia. In considering whether to approve the Revised Project, the City, as the lead agency pursuant to the California Environmental Quality Act (CEQA), is required to consider the environmental impacts of the Revised Project as compared to those of the Approved Project. Therefore, this addendum assesses the environmental impacts of the Revised Project as compared to those of the Approved Project in accordance with the requirements of CEQA and the CEQA Guidelines. 2.0 STATUTORY BACKGROUND Under CEQA Guidelines Section 15162(c), once a project has been approved, the lead agency’s role in project approval is completed unless further discretionary approval on that project is required. Information appearing after an approval does not require reopening of that approval. If, after the project is approved, any of the conditions described in CEQA Guidelines Section 15162(a) occurs, a subsequent MND shall only be prepared by the public agency which grants the next discretionary approval for the project. More specifically, CEQA Guidelines Section 15162 states the following: (a) When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following: (1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or PROJECT SITE MI C H I L L I N D A A V E MI C H I L L I N D A A V E N A L T U R A R D N A L T U R A R D VA L I D O R D VA L I D O R D COL O R A D O B L V D COL O R A D O B L V D MO N T E V I S T A R D MO N T E V I S T A R D V O L A N T E D R V O L A N T E D R M O N T E V E R D E D R M O N T E V E R D E D R E GREEN STE GREEN ST RO S E M E A D B L V D RO S E M E A D B L V D CORTA CALLECORTA CALLE FOOTHILL BLVDFOOTHILL BLVD MOHAWK STMOHAWK ST ELMA RDELMA RD PALOMA DRPALOMA DR Figure 1 Project Location MapNOT TO SCALE 02/2024 • JN 198590 Source: Google Earth Pro, December 2023 THE IVY ARCADIA ADDENDUM Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 3 (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following: (A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. In addition, CEQA Guidelines Section 15164 states the following: (a) The lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. (b) An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred. (c) An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration. (d) The decision making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project. (e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency’s findings on the project, or elsewhere in the record. The explanation must be supported by substantial evidence. 3.0 SUMMARY OF APPROVED PROJECT DESCRIPTION Under the Approved Project, the existing, vacant building on-site, which was previously occupied by Coco’s Bakery and Restaurant, would be demolished, and associated landscaping and surface parking lot would be removed. However, the majority of the trees along the perimeter of the Project Site were proposed to be retained and incorporated into the Approved Project’s landscaping plan to continue to form a vegetative screen between the Project Site and the residential uses to the east and south. The Approved Project proposed to develop a W-shaped senior living facility, which was planned to support memory care and assisted living services. This facility was proposed to be entirely Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 4 dedicated to people afflicted with Alzheimer’s disease and related memory disorders. The Approved Project proposed a new two-story (with a maximum height of 37.5 feet), 44,192-square-foot building with 80 senior housing units and on-site amenities, inclusive of a community center, a gallery, a café, a barber/beauty shop, and a small health center for the residents. The Approved Project also proposed to include decorative landscaping, private walking paths, and an outdoor plaza on the west and south sides of the Project Site, which were proposed to be enclosed with an 8-foot-high wooden fence that would connect to the northwestern and northeastern corners of the building and extend to the southern property line. The Approved Project required a Minor Administrative Modification to allow the fence to exceed the maximum permitted height of 6 feet. Under the Approved Project, vehicle parking was proposed to include 55 regular parking stalls and 4 parking stalls that comply with the requirements of the Americans with Disabilities Act (ADA). Vehicular access to the new building was proposed to be from a single ingress/egress point on Colorado Boulevard, located at an existing ingress/egress point for the Project Site. The Approved Project proposed to remove 18 of the 60 unprotected trees on-site, including 13 trees in the center of the Project Site around the existing building. Although no protected trees were proposed to be removed or irrevocably damaged during Project-related grading and construction, some minor damage to the protected tree root systems was anticipated. Accordingly, the Approved Project required a Tree Encroachment Permit and the implementation of Mitigation Measure BIO-2 to prevent substantial damage to on- and off-site protected trees. 4.0 PROJECT DESCRIPTION Existing Conditions The Project Site consists of 2.82 acres of developed land in the northwestern portion of the City of Arcadia. The Project Site is located on the southeastern corner of the Colorado Boulevard and Michillinda Avenue intersection, immediately south of Interstate 210 (I-210/Foothill Freeway), as shown in Figure 1. The Project Site contains a vacant commercial building, previously occupied by Coco’s Bakery and Restaurant. The existing building, which comprises 13,088 square feet in total floor area, is a rectangular, one-story building located in the center of the Project Site. The building is surrounded on all sides by a surface parking lot with two driveway locations, one at the northeastern corner of the Project Site along Colorado Boulevard and another at the southwestern corner of the Project Site along Michillinda Avenue. Mature eucalyptus trees flank the western and eastern sides of the existing building. Additionally, there are decorative shrubs and turf along the northern, eastern, and western façades of the building, with one mature fern pine near its northeastern corner. Currently, there is a mix of trees along the perimeter of the Project Site, serving as a landscape buffer between the Project Site and neighboring streets to the north and west and between the Project Site and the residential neighborhoods to the east and south. The Colorado Boulevard and Michillinda Avenue frontages are both improved with a sidewalk, curb and gutter, two streetlights along each street, two traffic signal poles with safety lights, and one curb ramp at the southeastern corner. Each frontage is characterized by decorative ground cover; mature trees; a short, white-painted cinderblock wall; and decorative shrubs located between the sidewalk and the property line. The Project Site is designated in the City’s General Plan as Commercial (0.5 FAR) with a corresponding zoning of General Commercial (C-G). Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 5 Revised Project Under the Revised Project, the Project Applicant is proposing a new 107,706-square-foot, three- story building (with a maximum height of 40 feet from the average grade of the building) containing 100 units of varying types, including studio, one-bedroom, and two-bedroom units for assisted living and private and shared studios for memory care, providing a total of 114 beds. As with the Approved Project, the Revised Project would support assisted living and memory care services, the latter of which would entirely be dedicated to people afflicted with Alzheimer’s disease and related memory disorders. The first floor of the proposed building would comprise 14 units for assisted living and 30 units for memory care, front and rear lobbies, offices, a dining room and a café, a laundry room, a sensory wellness room, a reading room, and a sitting and music area, as well as separate open air courtyards for assisted living and memory care patients in the middle of the building, within 39,472 square feet of floor area. The second floor would comprise 36 units for assisted living, offices, a laundry room, and a staff lounge within 37,169 square feet of floor area. The third floor would comprise 20 units for assisted living, a dining room with an exhibition kitchen, a bar/lounge, an activity room, a media room, a fitness center with a physical therapy area, a beauty salon, and storage areas within 31,065 square feet of floor area. In addition, an exterior patio for memory care patients and a workout seating area with outdoor workout equipment would be located along the southern boundary of the Project Site. A dog park and a bocce ball court would be located in the southeastern portion of the Project Site, as shown in Figure 2. The proposed new building would feature a Cape Cod design with varied massing and materials with articulation on each of the building façades, similar in design to that of the Approved Project. Conceptual renderings are shown in Figure 3. The Revised Project would include multiple new sources of light, including pole-mounted LED security lighting in parking areas and the passenger drop-off area; path lighting on internal walkways; and accent lighting over building doorways. Vehicle parking would include 61 parking spaces, comprising 3 parking spaces that comply with the requirements of the Americans with Disabilities Act (ADA), 6 electric vehicle (EV) parking spaces, and 1 EV parking space that complies with ADA requirements. Parking would be located along the perimeter of the Project Site with one ADA-compliant and one ADA-compliant/EV parking spaces located near the northeastern corner of the proposed building, two ADA-compliant parking spaces near the northwestern corner by the main entrance, and six EV parking spaces in the parking lot along the eastern boundary. Vehicular access to the proposed building would be from the two existing driveways, one along Colorado Boulevard near the northeastern corner of the Project Site and another along Michillinda Avenue near the southwestern corner of the Project; these driveways would be reconstructed in the same general location to current City standards for ADA compliance. A porte cochere would be provided in front of the main entrance to the proposed building. A covered trash enclosure would be located along the southern boundary of the Project Site immediately adjacent to the Alzheimer exterior patio. An emergency generator would be located in the generator room on the first floor near the southwestern corner of the proposed building. Figure 2 Revised Project Site Plan Source: B. Hills Architecture, March 2024 NOT TO SCALE 03/2024 • JN 198590 THE IVY ARCADIA ADDENDUM Figure 3 Conceptual Renderings Source: B. Hills Architecture, January 2024 NOT TO SCALE 02/2024 • JN 198590 THE IVY ARCADIA ADDENDUM                               Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 8 In addition, a modular wetland, which is proposed in the southeastern corner of the Project Site, would be used to collect and treat surface water runoff from the Project Site prior to draining to the existing curb inlet and then to the existing storm drainage system to the east. With regard to wastewater, the Revised Project would connect to an existing 21-inch County of Los Angeles sewer main to the west along Michillinda Avenue via a new sewer lateral. Regarding on-site trees, although the Revised Project would require the removal of 22 unprotected trees, the Revised Project would not only preserve the majority of trees along the perimeter of the Project Site, as proposed under the Approved Project, but would plant additional trees to completely screen the views of the proposed building from the residential uses to the east and south, as shown in Figure 4. The existing curb, gutter, and sidewalks along the Project Site’s Colorado Boulevard and Michillinda Avenue frontages would be replaced. In addition, the Revised Project would be required to dedicate 4 feet of the Project Site along both Colorado Boulevard and Michillinda Avenue to accommodate the widening of these two public rights-of-way along the Project Site’s frontages to 12 feet in width; however, the physical improvement would be implemented by the City and is not part of the Revised Project. The Project Site’s General Plan land use designation and zoning allow for the development of the Revised Project through a Conditional Use Permit (CUP) as the Revised Project proposes a floor area ratio (FAR) of 0.88, which exceeds the maximum permitted FAR of 0.5. Under the California Density Bonus Law, a project is entitled to receive a density bonus as a matter of right if it meets the requirements of California Government Code Section 65915. In addition, pursuant to Senate Bill (SB) 713, which was signed by Governor Newsom in October 2023, a local government cannot apply any development standard that precludes the construction of a development seeking a density bonus. Accordingly, pursuant to Government Code Section 65915(b)(1)(C) and SB 713, as the Revised Project is a senior citizen housing development, the Revised Project is entitled to receive a density bonus and deviate from the maximum permitted FAR, which would otherwise physically preclude the construction of the Revised Project based on the maximum allowable residential density under the General Plan land use and zoning designations. The Revised Project would comply with all other applicable development standards. Construction of the Revised Project would occur over a 20-month period, commencing in the fall of 2024 and concluding in the summer of 2026. The Revised Project would require the following City approvals: x Adoption of the Addendum to the IS/MND x Conditional Use Permit No. CUP 23-09 x Architectural Design Review No. ADR 23-13 with a Density Bonus x Other discretionary and ministerial permits and approvals that may be deemed necessary, including, but not limited to grading permit, excavation permit, dedications, and building permits Figure 4 Conceptual Landscape Plan Source: O & I Development, January 2024 02/2024 • JN 198590 THE IVY ARCADIA ADDENDUM NOT TO SCALE Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 10 5.0 ENVIRONMENTAL ANALYSIS This section assesses the environmental effects of the Revised Project and compares them to the environmental effects of the previously Approved Project as disclosed in the adopted 2020 MND to determine if any of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent MND have occurred. This section includes the environmental topics that were included in the 2020 MND. 5.1 AESTHETICS Scenic Vistas and Scenic Resources According to the 2020 MND, there are no scenic vistas or scenic highways in the Project vicinity. Views of the San Gabriel Mountains are only available from main arterial roadways in the City that are oriented north and south. As such, motorists traveling northbound on Michillinda Avenue (along the western boundary of the Project Site) and North Altura Road (one block east of the Project Site) have distant views of the San Gabriel Mountains, which are partially obstructed by existing mature trees and existing development along both of these streets, I-210, and the overpass over Michillinda Avenue, as well as utility poles, traffic signals, and business signs on either side of Michillinda Avenue. As a result of these existing impediments, views of the San Gabriel Mountains are only available straight north and are obstructed to the northeast and northwest and would not be significantly affected by the Approved Project. As related to scenic resources, the existing mature trees along the perimeter of the Project Site, the majority of which are considered protected by the City, could be considered scenic resources. These protected trees would be preserved by the Approved Project to continue to provide a visual barrier between the Project Site and surrounding uses and contribute to maintaining the existing visual character of the Project area. Accordingly, the 2020 MND determined that the Approved Project would have a less-than-significant impact on scenic vistas and scenic resources. The Revised Project proposes the same land use type as the Approved Project within the boundaries of the Project Site. However, the Revised Project would involve a larger development and a slightly taller building than analyzed in the 2020 MND. Nonetheless, as with the Approved Project, views of the San Gabriel Mountains would not be significantly affected by the Revised Project given the existing intervening features that already obstruct such views and the remaining north-facing view corridors that would not be affected by the Revised Project. In addition, because the Revised Project would install additional trees along the eastern and southern boundaries of the Project Site to completely screen the views between the Project Site and the immediately adjacent residences, the increase in building height proposed under the Revised Project would not create an impact beyond those identified in the 2020 MND. Accordingly, as with the Approved Project, the Revised Project would have a less-than-significant impact on scenic vistas and scenic resources. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Conflict with Zoning Governing Scenic Quality According to the 2020 MND, the Approved Project would be consistent with underlying City zoning upon approval of a CUP. Additionally, because the Arcadia Development Code does not contain any specific zoning regulations that govern scenic quality other than the City’s Tree Preservation Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 11 Ordinance, the impacts discussed focused on the protected trees on the Project Site, which would be preserved in place to provide visual barriers between the Project Site and surrounding uses and would maintain the existing visual character of the Project vicinity. Therefore, the Approved Project would be consistent with applicable zoning and other regulations governing scenic quality, and impacts were determined to be less than significant. As with the Approved Project, the Revised Project would preserve the protected trees on the Project Site and would install additional trees along the eastern and southern boundaries of the Project Site to completely screen the views between the Project Site and the immediately adjacent residences and maintain the existing visual character of the Project vicinity. Given the approval of the Zone Change that eliminated the Architectural Design Overlay Zone and the Automobile Parking Overlay Zone from the Project Site under the Approved Project, the Revised Project would not require any additional zone change and, therefore, would be consistent with applicable zoning regulations, including the height limit of 40 feet for the C-G zoning designation, other regulations governing scenic quality, and the density bonus law. Thus, impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Light and Glare According to the 2020 MND, the Approved Project would contain multiple new sources of nighttime lighting, such as security lighting on internal walkways, lights in the parking areas and at building entrances, and accent lights along walking paths adjacent to landscaped areas. However, the Approved Project would be required to demonstrate compliance with Section 9103.01.120(D) of the Arcadia Development Code as part of the City’s design review process, which limits potential light and glare impacts by requiring that lights be directed downward and shielded/recessed to avoid spillage to adjacent properties and prohibits flashing or roof-mounted lights that are directed outward. This Arcadia Development Code section also prohibits light fixtures that are inappropriate for the scale, intensity, and height of the use they are serving. Additionally, the Approved Project would not utilize glossy or reflective construction materials that would generate significant amounts of glare off-site. Accordingly, the 2020 MND determined that the Approved Project would not generate excessive light or glare and, by complying with lighting regulations in the Arcadia Development Code, would result in a less-than-significant impact on day or nighttime views in the Project area. The Revised Project proposes the same land use type as the Approved Project and would not include land uses that would require more intense sources of light or building materials that would create glare beyond those identified for the Approved Project. As with the Approved Project, the Revised Project would be required to comply with the same regulations that would minimize impacts related to light and glare. Accordingly, as with the Approved Project, the Revised Project would not generate excessive light or glare and, by complying with lighting regulations in the Arcadia Development Code, would result in a less-than-significant impact on day or nighttime views in the Project area. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 12 5.2 AGRICULTURE AND FORESTRY RESOURCES According to the 2020 MND, the Project Site and the surrounding area are not mapped as Prime Farmland, Unique Farmland, and Farmland of Statewide Importance or subject to the Williamson Act contract. The Project Site is currently developed with an existing vacant building; thus, no agricultural uses, forestland, or timberland occur on the Project Site or the surrounding areas, and, as such, none of these uses would be converted to non-agricultural or non-forest uses as a result of the Approved Project. In addition, the Project Site is zoned as C-G and designated as Commercial in the City’s General Plan. Accordingly, the Approved Project would not conflict with existing zoning for, or cause the rezoning of, farmland, forestland, or timberland. Therefore, the 2020 MND determined that development of the Approved Project would have no impact on agriculture or forestry resources. As with the Approved Project, the Revised Project would have no impact on agriculture and forestry resources. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.3 AIR QUALITY Consistency with Plans According to the 2020 MND, the Approved Project would result in emissions below the regional and localized emissions thresholds established by the South Coast Air Quality Management District (SCAQMD) and, as such, would not have the potential to cause or affect a violation of the ambient air quality standards or delay the timely attainment of air quality standards or 2016 Air Quality Management Plan (AQMP) emissions reductions goals. In addition, because the Approved Project is consistent with the underlying zoning and General Plan land use designation for the Project Site, the population and employment growth associated with the Approved Project would have been anticipated and planned for in the City’s General Plan, on which the Southern California Association of Governments (SCAG) bases its growth projections for the City. As the SCAQMD has incorporated these same projections into the 2016 AQMP, the 2020 MND concluded that the Approved Project would be consistent with the 2016 AQMP and have a less-than-significant impact related to consistency with the 2016 AQMP. Since the adoption of the 2020 MND, the SCAQMD has adopted the 2022 AQMP, the air quality plan applicable to the Revised Project. The Revised Project would involve a slightly larger development than analyzed in the 2020 MND. In addition, because the restaurant occupying the existing building closed after the adoption of the 2020 MND, the trip credit from the restaurant use is no longer applied. Accordingly, the Revised Project would generate more trips and emissions compared to the Approved Project. However, as with the Approved Project, construction and operation of the Revised Project would result in emissions below the regional and localized emissions thresholds established by the SCAQMD, as shown in Tables 1, 2, and 3, in the discussion of Criteria Pollutants Emissions, below. As such, the Revised Project would not have the potential to cause or affect a violation of the ambient air quality standards or delay the timely attainment of air quality standards or 2022 AQMP emissions reductions goals. In addition, because the Revised Project is also consistent with the underlying zoning and General Plan land use designation for the Project Site, the Revised Project would also be consistent with the 2022 AQMP and have a less-than-significant impact related to consistency with the 2022 AQMP. Therefore, there are no material changes in circumstances, and the Revised Project Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 13 would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Criteria Pollutant Emissions According to the 2020 MND, construction of the Approved Project, which would take approximately 20 months to complete, would result in the generation of fugitive dust and pollutant emissions, resulting in substantial short-term increases in air pollutants. Similarly, operation of the Approved Project would result in long-term air quality impacts associated with mobile source emissions from traffic generated by the Approved Project and emissions from stationary area and energy sources. As mentioned previously, a trip credit was applied from the restaurant use for operational emissions. However, the 2020 MND determined that that construction and operation of the Approved Project would not exceed daily regional SCAQMD thresholds for any of the criteria pollutants analyzed and that impacts would be less than significant. As with the Approved Project, construction and operation of the Revised Project would result in the short-term and long-term generation of criteria pollutants, respectively. As described in Section 4.0, Project Description, of this addendum, construction for the Revised Project would occur approximately over 20 months. Since the Revised Project would involve a larger development than analyzed in the 2020 MND and the trip credit from the restaurant use is no longer applied, the Revised Project would generate more trips and emissions compared to the Approved Project. However, as with the Approved Project, construction and operation of the Revised Project would result in emissions below the regional and localized emissions thresholds established by the SCAQMD, as shown in Tables 1 and 2. As such, the Revised Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the region is non- attainment under California Ambient Air Quality Standards (i.e., ozone [O3], respirable particulate matter [PM10], and fine particulate matter [PM2.5]) and the National Ambient Air Quality Standards (i.e., O3 and PM2.5). Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Table 1 Revised Project Short-Term Construction Emissions Emissions Source Pollutant (pounds/day)a,b ROG NOX CO SO2 PM10 PM2.5 Year 1 Construction Emissionsb 5.65 53.3 54.2 0.08 6.08 3.71 Year 2 Construction Emissionsb 3.27 29.5 37 0.06 5.59 2.83 Year 3 Construction Emissionsb 35.4 11.4 19.9 0.03 1.63 0.66 Maximum Daily Emissions 35.4 53.3 54.2 0.08 6.08 3.71 SCAQMD Thresholds 75 100 550 150 150 55 Threshold Exceeded? No No No No No No Notes: ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = respirable particulate matter; PM2.5 = fine particulate matter a Emissions were calculated using CalEEMod version 2022.1. Higher emissions between summer and winter are presented as a conservative analysis. b Modeling assumptions include compliance with SCAQMD Rule 403, which requires properly maintaining mobile and other construction equipment, replacing ground cover in disturbed areas quickly, watering exposed surfaces twice daily, covering stockpiles with tarps, watering all haul roads twice daily, and limiting speeds on unpaved roads to 15 miles per hour. Source: Refer to Appendix A for assumptions used in this analysis. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 14 Table 2 Revised Project Long-Term Operational Emissions Exposure of Sensitive Receptors to Pollutants According to the 2020 MND, sensitive receptors in the vicinity of the Project Site include residential uses adjacent to the east and south, which could be potentially affected by air pollutant emissions generated during on-site construction activities. However, the 2020 MND determined that construction emissions resulting from the Approved Project would not exceed the localized significance thresholds (LSTs) established by the SCAQMD for these existing residences. According to the SCAQMD LST methodology, LSTs would apply to the operational phase of a project if the project included stationary sources or attracted mobile sources that may spend extended periods queuing and idling at the site (e.g., warehouse or transfer facilities). The Approved Project does not include such uses. Therefore, the 2020 MND determined that impacts associated with localized emissions from the construction and operation of the Approved Project would be less than significant. As with the Approved Project, sensitive receptors to the east and south of the Project Site may be potentially affected by air pollutant emissions generated during on-site construction activities of the Revised Project. Although the Revised Project would involve a slightly larger development than analyzed in the 2020 MND, construction of the Revised Project would not exceed the localized emissions thresholds for any criteria pollutants, as shown in Table 3. Additionally, the Revised Project proposes the same land use type as the Approved Project and would not include uses that may spend extended periods queuing and idling on the Project Site. Similar to the Approved Project, impacts associated with localized emissions from the construction and Emissions Source Pollutant (pounds/day)a ROG NOX CO SOX PM10 PM2.5 Project Summer Emissions Mobile 0.95 0.67 7.72 0.02 1.66 0.43 Area 3.08 1.55 6.31 0.01 0.12 0.12 Energy 0.02 0.28 0.12 <0.01 0.02 0.02 Total Summer Emissionsb 4.05 2.50 14.10 0.03 1.80 0.57 SCAQMD Threshold 55 55 550 150 150 55 Threshold Exceeded? No No No No No No Project Winter Emissions Mobile 0.94 0.74 7.15 0.02 1.66 0.43 Area 2.58 1.49 0.64 0.01 0.12 0.12 Energy 0.02 0.28 0.12 <0.01 0.02 0.02 Total Winter Emissionsb 3.53 2.51 7.90 0.03 1.80 0.57 SCAQMD Threshold 55 55 550 150 150 55 Threshold Exceeded? No No No No No No Notes: ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = respirable particulate matter; PM2.5 = fine particulate matter a Emissions were calculated using CalEEMod version 2022.1. b The numbers may be slightly off due to rounding. Source: Refer to Appendix A for assumptions used in this analysis. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 15 operation of the Revised Project would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Table 3 Revised Project Construction Localized Emissions Odor and Other Emissions According to the 2020 MND, the Approved Project would not include any uses identified by the SCAQMD as being associated with odors. However, construction activities associated with the Approved Project may generate other emissions and detectable odors from heavy-duty equipment exhaust and architectural coatings; these construction-related emissions and odors would be short term in nature and cease upon completion of construction. In addition, the Approved Project would be required to comply with existing regulations that reduce detectable odors from architectural coating application and heavy-duty equipment exhaust by limiting construction equipment idling time. Accordingly, the 2020 MND determined that the Approved Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people, and impacts would be less than significant. The Revised Project proposes the same land use type as the Approved Project and would not include land uses identified by the SCAQMD as being associated with odors. As with the Approved Project, construction activities associated with the Revised Project may generate other emissions and detectable odors from heavy-duty equipment exhaust and architectural coatings. However, as with the Approved Project, these construction-related emissions and odors would be Maximum Emissions Pollutant (pounds/day) NOX CO PM10 PM2.5 Year 1a 24.90 21.70 3.60 2.11 Year 2b 16.30 17.90 3.48 2.00 Year 3c 9.85 13.00 0.38 0.35 Maximum Daily Emissionsd 24.90 21.70 3.60 2.11 LST Screening Thresholde 89 623 5 3 Thresholds Exceeded? No No No No Note: NOx = nitrogen oxide; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter a Maximum on-site daily emissions occur during demolition phase for NOX, and CO, and during grading phase for PM10, and PM2.5 in Year 1. b Maximum on-site daily emissions occur during grading phase for NOX, CO, PM10, and PM2.5 in Year 2. c Maximum on-site daily emissions occur during building construction phase for NOX, CO, PM10, and PM2.5 in Year 3. d The maximum daily construction emissions includes fugitive dust control measures required by SCAQMD Rule 403, which includes the following: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces twice daily; cover stockpiles with tarps; water all haul roads twice daily; and limit speeds on unpaved roads to 15 miles per hour. e The LST Screening Threshold was determined using Appendix C of the SCAQMD Final Localized Significant Threshold Methodology guidance document for pollutants NOX, CO, PM10, and PM2.5. The Screening Threshold was based on the anticipated daily acreage disturbance for construction (one acre per day), the distance to sensitive receptors (adjacent to the Project Site, as such 25-meter threshold was used), and the source receptor area (SRA 9). Source: Refer to Appendix A for detailed model data. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 16 short term in nature and would cease upon completion of construction. In addition, the Revised Project would also be required to comply with existing regulations that reduce detectable odors from architectural coating application and heavy-duty equipment exhaust. As with the Approved Project, the Revised Project would not result in other emissions (such as those leading to odors) that would adversely affect a substantial number of people, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. 5.4 BIOLOGICAL RESOURCES Sensitive Species According to the 2020 MND, due to the disturbed nature of the Project Site and lack of native habitat to species known to occur in the City of Arcadia, it was determined that the Project Site would not support special-status species listed as threatened or endangered by the U.S. Fish and Wildlife Service (USFWS) or the California Department of Fish and Wildlife (CDFW). In addition, the Arcadia General Plan does not identify any sensitive or special-status species beyond the protected trees existing on-site as described below under Local Biological Resources Policies/Ordinances. Therefore, the 2020 MND determined that the Approved Project would not have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special-status species and that impacts would be less than significant. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, where no sensitive or special-status species are known to occur. Accordingly, the Revised Project would not have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special-status species, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Riparian Habitat, Wetlands, and Conservation Plans According to the 2020 MND, the Project Site does not support any riparian habitat, sensitive communities, or wetlands, and there are no adopted, approved, or proposed habitat conservation plans, natural community conservation plans, or other approved local, regional, or State conservation plans that cover habitats located in the City. Therefore, the 2020 MND determined that development of the Approved Project would have no impact on riparian habitat, sensitive communities, or wetlands or related to such conservation plans. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, where no riparian habitat, sensitive communities, or wetlands or applicable conservation plans have been identified. Accordingly, the Revised Project would have no impact on any riparian habitat, other sensitive natural communities, or wetlands or related to such conservation plans. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 17 Migratory Wildlife According to the 2020 MND, since the Project Site has been highly disturbed and is surrounded by developed, urban land uses, the Approved Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species. However, 72 trees, comprising 12 protected and 60 unprotected trees, were identified on-site, which could provide habitat to animals capable of flight. According to the 2020 MND, the existing building, on-site trees, and ornamental landscaping could provide suitable roosting and nesting habitat for bird species. Of the suitable habitat identified, the Approved Project would remove 18 unprotected trees, the existing building, and other existing landscaping. As such, the 2020 MND determined that, while migratory bird species are considered highly mobile, the possible removal of suitable roosting and nesting habitat would result in the potential for minor impacts to bird species. To reduce this impact to a less-than-significant level, the 2020 MND identified the following mitigation measure: BIO-1 Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City of the Planning & Community Development Administrator or Designee. Development of the Revised Project would require the removal of the existing building, 22 unprotected trees, and ornamental landscaping. Although the Revised Project would remove four additional trees when compared to the Approved Project, with implementation of Mitigation Measure BIO-1 required for the Approved Project, development of the Revised Project would not result in impacts to migratory bird species beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts to migratory wildlife that would affect the determination of less-than-significant impact with mitigation in the 2020 MND. Local Biological Resources Policies/Ordinances According to the 2020 MND, there were 72 trees located on the Project Site, 12 of which were considered protected under the City’s Tree Preservation Ordinance with all but two considered to be in good health. Four additional protected trees were identified off-site but with canopies that encroach onto the Project Site. The Approved Project would not remove any of these protected trees but would remove 18 unprotected trees to accommodate the proposed development. Of the 16 protected trees that are on or adjacent to the Project Site, the 12 on-site trees would experience some light grading within their immediate area. While the Protected Tree Report prepared for the Approved Project determined that the proposed development would not adversely affect the long- Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 18 term viability of the protected trees on or adjacent to the Project Site, some minor damage to the protected tree root systems was anticipated during construction. To prevent substantial damage to on- and off-site protected trees, meet the requirements of the Tree Preservation Ordinance, and ensure that impact to protected trees would be reduced to a less-than-significant level, the 2020 MND identified the following mitigation measure: BIO-2 Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: 1. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. 2. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. 3. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. 4. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. 5. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. 6. The arborist shall monitor a few critical phases of the Project, including pre- demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. 7. Additional construction best practices described in the Protected Tree Report shall be implemented. The tree report that was prepared for the 2020 MND was updated in April 2024 to reflect the Revised Project. As with the previous tree report, the April 2024 tree report also identified 72 trees on the Project Site, 12 of which are considered protected under the City’s Tree Preservation Ordinance with all but three (one more tree than previously identified) considered to be in good health. As with the previous tree report, four additional protected trees are identified off-site but with canopies that encroach onto the Project Site. Development of the Revised Project would require the removal of four additional trees, for a total of 22 unprotected trees, and light grading within the immediate area of the protected trees, which may result in minor damage to the root systems. However, as with the Approved Project, the Revised Project would comply with the Tree Preservation Ordinance and would implement the previously proposed mitigation measure to reduce impacts to Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 19 protected trees. With implementation of Mitigation Measure BIO-2 required for the Approved Project, development of the Revised Project would not result in impacts to protected trees beyond those identified for the Approved Project.1 Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact with mitigation in the 2020 MND. 5.5 CULTURAL RESOURCES Historical Resources According to the 2020 MND, no historical resources were identified on the Project Site as the existing building on-site does not meet the age requirement for eligibility listing in in the California Register of Historical Resources (CRHR). Similarly, there are no cultural resources listed or eligible for listing in the CRHR within the immediate vicinity of the Project Site. Therefore, the 2020 MND determined that, because physical alterations associated with development of the Approved Project would not extend beyond the Project Site, the Approved Project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5, and no impact to historical resources would occur. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, where no historical resources or immediately adjacent resources have been identified. Accordingly, the Revised Project would have no impact on historical resources. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Archaeological Resources According to the 2020 MND, no archaeological resources were identified on the Project Site or within a quarter mile of the Project Site; further, the site sensitivity for subsurface archaeological resources was considered low because the Project Site has been developed and redeveloped. However, the 2020 MND determined that the potential exists for unanticipated discovery of archaeological resources during ground-disturbing activities for the Approved Project. To reduce the impact of the Approved Project on archaeological resources to a less-than-significant level, the 2020 MND identified the following mitigation measure: CUL-1 Treatment of previously unidentified archaeological deposits. If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not 1 Arbor Care, Inc., Protected Tree Report: Tree Survey, Encroachment, Protection and Mitigation for 1150 W. Colorado Boulevard, Arcadia, CA 91006, April 2024. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 20 necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility. As with the Approved Project, development of the Revised Project would result in ground- disturbing activities during construction and, as such, would result in potential impacts related to unanticipated discovery of archaeological resources. With implementation of Mitigation Measure CUL-1 required for the Approved Project, development of the Revised Project would not result in impacts to archaeological resources beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact with mitigation in the 2020 MND. Human Remains According to the 2020 MND, the Approved Project would not likely disturb any human remains, including those interred outside of dedicated cemeteries given that the Cultural Resources Identification Memorandum prepared for the Approved Project found no indication of any past human burial activities on or near the Project Site. However, the 2020 MND determined that the potential exists to uncover buried human remains during construction-related earth-moving activities. Nonetheless, the Approved Project would be required to comply with the requirements of California Health and Safety Code Section 7050.5 related to the proper protocol to which the Approved Project must adhere in the event that buried human remains are discovered. Accordingly, the 2020 MND determined that, through compliance with California Health and Safety Code Section 7050.5, impacts of the Approved Project related to the disturbance of human remains would be less than significant. As with the Approved Project, development of the Revised Project would include construction- related earth-moving activities and, as such, would result in potential impacts related to unanticipated uncovering of buried human remains. Through compliance with California Health and Safety Code Section 7050.5, development of the Revised Project would not result in impacts to human remains beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than- significant impact determination in the 2020 MND. 5.6 ENERGY Consumption of Energy Resources According to the 2020 MND, the Approved Project’s net energy consumption (i.e., minus the energy consumption of the Coco’s Bakery and Restaurant that was in operation at the time) would constitute an approximate 0.0004-percent reduction from Los Angeles County’s typical annual electricity consumption and an approximate 0.0007-percent reduction from Los Angeles County’s typical annual natural gas consumption as a result of the Approved Project’s compliance with Title 24 standards, which provide efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting. Implementation of Title 24 standards significantly reduces energy usage. In addition, the Approved Project would generate a net decrease of approximately 374 daily trips when compared to the previous use on-site (i.e., Coco’s Restaurant). As a result, the Approved Project’s operational Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 21 vehicle consumption would constitute an approximately 0.0002-percent reduction from Los Angeles County’s fuel consumption. With regard to construction, the Approved Project’s construction fuel consumption would increase Los Angeles County’s consumption by 0.0069 percent. However, the 2020 MND determined that since the construction and operation of the Approved Project would not have any unusual characteristics that would result in excessive consumption of electricity, natural gas, and transportation fuel, the Approved Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources in comparison to other similar developments in the region, and impacts related to energy resources would be less than significant. Since the adoption of the 2020 MND, the restaurant occupying the existing building has closed, and the building has remained vacant. As such, the trip credit from the restaurant use is no longer applicable to the Revised Project. In addition, the Revised Project would also involve a slightly larger development than analyzed in the 2020 MND. Accordingly, the Revised Project would result in higher energy consumption than the Approved Project. As shown in Table 4, the Revised Project’s energy usage would constitute an approximate 0.0006-percent increase over Los Angeles County’s typical annual electricity consumption, an approximate 0.0004 percent increase over Los Angeles County’s typical annual natural gas consumption, and an approximate 0.4351-percent increase over Los Angeles County’s fuel consumption. The Revised Project’s construction off-road and construction on-road fuel consumption would increase the County’s consumption by 0.1307 percent and 0.2683 percent, respectively. These increases would be considered nominal compared to the County’s annual energy consumption. Table 4 Revised Project and Countywide Energy Consumption ENERGY TYPE PROJECT ANNUAL ENERGY CONSUMPTIONa LOS ANGELES COUNTY ANNUAL ENERGY CONSUMPTIONb PERCENTAGE INCREASE COUNTYWIDEb Electricity Consumption 386 MWh 68,484,956 MWh 0.0006 Natural Gas Consumption 11,107 Therms 2,820,285,935 Therms 0.0004 Fuel Consumption Construction Off-road Consumptionc 41,852 Gallons 32,013,160 Gallons 0.1307 Construction On-road Consumption 29,661 Gallons 11,054,467 Gallons 0.2683 Operational Automotive Fuel Consumption3 45,837 Gallons 10,533,272 Gallons 0.4351 Notes: MWh = mega-watt hours a As modeled in CalEEMod version 2022.1. b The Revised Project’s increases in electricity and natural gas consumption are compared to the total consumption in Los Angeles County in 2022. The Revised Project’s increase in construction and operational automotive fuel consumption is compared with the projected countywide heavy-duty vehicle/diesel fuel consumption and on-road automotive fuel consumption in 2024 (the year when construction starts). Los Angeles County electricity consumption data source: California Energy Commission, Electricity Consumption by County, http://www.ecdms.energy.ca.gov/elecbycounty.aspx, accessed December 27, 2023. Los Angeles County natural gas consumption data source: California Energy Commission, Gas Consumption by County, http://www.ecdms.energy. ca.gov/gasbycounty.aspx, accessed December 27, 2023. c Project fuel consumption calculated based on CalEEMod results. Countywide fuel consumption is from the California Air Resources Board EMFAC2021 model. Refer to Appendix A for assumptions used in this analysis. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 22 As with the Approved Project, because the Revised Project would not have any unusual characteristics that would result in excessive operational energy consumption associated with electricity and natural gas usage and vehicular travel, the Revised Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources in comparison to other similar developments in the region, and impacts related to energy resources would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Consistency with Plans According to the 2020 MND, the Approved Project’s overall energy efficiency measures, such as the use of energy-efficient appliances, heaters, and heating, ventilation, and air conditioning (HVAC) systems; use of water-efficient landscaping (which would reduce the electricity used for water transport and treatment); and incorporation of building code-mandated energy-efficient design features, would generally support the energy reduction goals established in the City’s 2019 Energy Action Plan. The Approved Project’s energy consumption would be typical of senior living development projects in Southern California and would not result in an increased energy demand beyond the capacity of Southern California Edison (SCE) or Southern California Gas Company (SoCalGas). Accordingly, the 2020 MND determined that the Approved Project would not conflict with or obstruct any plans for renewable energy or energy efficiency, and no impact would occur. The Revised Project would involve a slightly larger development than analyzed in the 2020 MND. However, as with the Approved Project, the Revised Project would use energy-efficient appliances, heaters, HVAC systems, and water-efficient landscaping (which would reduce the electricity used for water transport and treatment) and incorporate building code-mandated energy efficient design features that would generally support the energy reduction goals established in the City’s 2019 Energy Action Plan. As with the Approved Project, the Revised Project’s energy consumption would be typical of senior living development projects in Southern California and would not have any unusual characteristics that would result in excessive energy consumption beyond the capacity of SCE or SoCalGas. Similarly, the Revised Project would not conflict with or obstruct any plans for renewable energy or energy efficiency, and no impact would occur. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.7 GEOLOGY AND SOILS Fault Rupture, Seismic Ground Shaking, Liquefaction, Unstable Soils, and Expansive Soils According to the 2020 MND, the Project Site is near the Sierra Madre and Raymond Fault zones; thus, it is in an area subject to strong ground shaking due to these and other regional faults. The Project Site is also located within a liquefaction zone due to the relatively shallow groundwater depth at the Project Site. However, the Project Site is located outside Alquist-Priolo Earthquake Fault and Hazard Management Zones. The Project Site is also located in an area with potential to contain expansive soils. The Approved Project would be required to adhere to building regulations and seismic and building design standards that dictate seismic safety, earthquake- resistant structural design, and structural integrity of structures to minimize the impacts resulting from ground shaking, liquefaction, unstable soils (which may result in lateral spreading, Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 23 subsidence, or ground collapse), and expansive soils. Accordingly, with the Approved Project’s adherence to applicable building regulations and seismic and building design standards, the 2020 MND determined that the Approved Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, liquefaction, lateral spreading, subsidence, ground collapse, and expansive soils, and that impacts of the Approved Project related to these issues would be less than significant. As with the Approved Project, development of the Revised Project would be required to adhere to the same building regulations and seismic and building design standards that would minimize the impacts resulting from ground shaking, liquefaction, unstable soils, and expansive soils. With adherence to such regulations and standards, the Revised Project would not result in impacts related to these issues beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than- significant impact determination in the 2020 MND. Landslides According to the 2020 MND and the City’s General Plan Safety Element, the Project Site is not located within an earthquake-induced landslide hazard area. Therefore, the 2020 MND determined that the Approved Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides, and no impact related to landslides would occur. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, where no earthquake-induced landslide hazard area has been identified. Accordingly, development of the Revised Project would have no impact related to landslides. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Soil Erosion/Loss of Topsoil According to the 2020 MND, because of the extensive ground alterations that have occurred on- site from the development of the existing building (previously occupied by a Coco’s Bakery and Restaurant) and the prior uses consisting of the Eaton’s Santa Anita Hotel and Restaurant, it is unlikely that any native topsoil remains in the near surface, and, thus, no impact involving the loss of topsoil would occur. However, during construction of the Approved Project, the uncovered soils may become exposed to wind or rainstorms and thus be subject to erosion. Nonetheless, to prevent stormwater-related erosion, the Approved Project would be required to comply with existing regulations, including, but not limited to, SCAQMD Rule 403 to reduce wind erosion the County of Los Angeles’ National Pollutant Discharge Elimination System (NPDES) Construction General Permit requirements to reduce stormwater erosion. The Approved Project would also prepare a Stormwater Pollution Prevention Plan (SWPPP) to establish erosion and sedimentation controls as required by the City. Accordingly, with the Approved Project’s compliance with existing regulations, the 2020 MND determined that the potential for soil erosion during construction activity would be reduced to a less-than-significant level. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 24 As with the Approved Project, development of the Revised Project would be required to comply with the same regulations that would minimize the potential for soil erosion. Through compliance with existing regulations, development of the Revised Project would not result in substantial soil erosion beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Paleontological Resources According to the 2020 MND, no paleontological resources were identified on the Project Site. However, the 2020 MND determined that the potential exists for encountering vertebrate paleontological resources during grading activities for the Approved Project. To avoid the potential destruction of paleontological resources and ensure proper identification and treatment of such resources that may be discovered during grading, the 2020 MND identified the following mitigation measure to reduce the potential impact of the Approved Project to paleontological resources to a less-than-significant level: GEO-1 Paleontological Resource Monitor. If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. As with the Approved Project, development of the Revised Project would include ground- disturbing activities during construction and, as such, would result in potential impacts related to the unanticipated discovery of paleontological resources. With implementation of Mitigation Measure GEO-1 required for the Approved Project, development of the Revised Project would not result in impacts to paleontological resources beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact with mitigation in the 2020 MND. 5.8 GREENHOUSE GAS (GHG) EMISSIONS According to the 2020 MND, the Approved Project would result in a net decrease in daily trips, thereby causing a net decrease in GHG emissions over existing conditions. Accordingly, the 2020 MND determined that the Approved Project would generate levels of GHG emissions that would have a less-than-significant impact on the environment. In addition, according to the 2020 MND, the Approved Project would be consistent with the plans, policies, regulations, and GHG reduction actions/strategies outlined in the 2017 CARB Scoping Plan and SCAG 2016-2040 RTP/SCS. Therefore, the Approved Project would not conflict with any applicable plan, policy, or regulation Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 25 of an agency adopted for the purpose of reducing emissions of GHGs, and impacts would be less than significant. The Revised Project would involve a slightly larger development than analyzed in the 2020 MND. In addition, because the restaurant occupying the existing building closed and has remained vacant since the adoption of the 2020 MND, the trip credit from the restaurant use is no longer applied. As a result, the Revised Project would emit a total of 598.30 metric tons of carbon dioxide equivalent (MTCO2e) per year, which would be 801.95 MTCO2e per year higher than the Approved Project, as shown in Table 5. Table 5 Estimated Greenhouse Gas Emissions Since there is no applicable adopted numerical threshold of significance for GHG emissions, the methodology for evaluating the Revised Project’s impacts related to GHG emissions focuses on its consistency with Statewide, regional, and local plans adopted for the purpose of reducing and/or Source CO2 CH4 N2O Refrigerants CO2e Metric Tons/yeara,b Approved Project Emissions Total Approved Project-Related Emissions c -202.95 MTCO2e/year Revised Project Emissions Direct Emissions Construction (amortized over 30 years)d 27.27 <0.01 <0.01 0.01 27.27 Area Source 23.20 0.01 <0.01 0.00 23.20 Mobile Source 294.00 0.02 0.01 0.44 299.00 Refrigerants 0.00 0.00 0.00 0.22 0.22 Total Direct Emissions 344.47 0.03 0.01 0.67 349.70 Indirect Emissions Energy 152.00 0.01 <0.01 0.00 153.00 Solid Waste 24.10 2.41 0.00 0.00 84.40 Water Demand 7.31 0.12 <0.01 0.00 11.20 Total Indirect Emissions 183.41 2.54 <0.01 0.00 248.60 Total Revised Project-Related Emissions 598.30 MTCO2e/year Difference between Approved Project and Revised Project Emissionse 801.95 MTCO2e/year Notes: a Emissions calculated using California Emissions Estimator Model Version 2022.1 (CalEEMod) computer model. b Totals may be slightly off due to rounding. c Total Approved Project GHG emissions are from the 2020 MND. In the 2020 MND, the Project resulted in a GHG emissions reduction of approximately 202.95 MT CO2e per year when compared to the existing Coco’s Restaurant. This overall reduction in GHG emissions was attributed to the decrease in total daily vehicle trips associated with the development as compared with existing conditions at the time. d Total Revised Project construction GHG emissions equate to 818.00 MTCO2e. Value shown is amortized over the lifetime of the Revised Project (assumed to be 30 years). e Overall resultant emissions were derived by subtracting the Approved Project’s emissions from the Revised Project’s Emissions. Refer to Appendix A for detailed model input/output data. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 26 mitigating GHG emissions. Since the adoption of the 2020 MND, the California Air Resources Board (CARB) has adopted the 2022 Scoping Plan, and SCAG has adopted the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). Accordingly, the evaluation of consistency with such plans is the sole basis for determining the significance of the Revised Project’s GHG-related impacts on the environment. The 2022 Scoping Plan describes the approach the State will take to achieve carbon neutrality by 2045, and the 2020-2045 RTP/SCS includes strategies that will assist the region to reach the regional target of reducing GHG from transportation sector. The 2022 Scoping Plan identifies reduction measures necessary to achieve the goal of carbon neutrality by 2045 or earlier. Actions that reduce GHG emissions are identified for each Assembly Bill (AB) 32 inventory sector. An evaluation of applicable reduction actions/strategies by emissions source category to determine how the Revised Project would be consistent with or exceed reduction actions/strategies outlined in the 2022 Scoping Plan is provided in Table 6. Table 6 Consistency with the 2022 Scoping Plan Actions and Strategies Project Consistency Analysis Smart Growth/Vehicles Miles Traveled (VMT) Reduce VMT per capita to 25% below 2019 levels by 2030, and 30% below 2019 levels by 2045 Consistent. The Revised Project would provide a dining room, a café, a laundry room, a sensory wellness room, a reading room, a sitting and music area, a beauty salon, a fitness center with a physical therapy area, a bar/lounge, an activity room, a media room, and separate open-air courtyards and outdoor spaces. Providing these amenities on-site would reduce VMT as the residents do not need to drive off-site for services. In addition, the residents are anticipated to have limited mobility and, as such, are expected to generate a very small number of vehicle trips. Furthermore, the Revised Project would provide bicycle parking, which would promote an alternative mode of transportation for visitors and employees. As such, the Revised Project would be consistent with this action. New Residential and Commercial Buildings All electric appliances beginning 2026 (residential) and 2029 (commercial), contributing to 6 million heat pumps installed statewide by 2030 Consistent. The City of Arcadia has not adopted an ordinance or program limiting the use of natural gas for on-site cooking and/or heating. However, if such an ordinance is adopted, the Revised Project would be required to comply with the applicable goals or policies limiting the use of natural gas equipment in the future. Furthermore, the Revised Project would install high efficiency lighting and appliances. As such, the Revised Project would be consistent with this action. Construction Equipment 25% of energy demand electrified by 2030 and 75% electrified by 2045 Consistent. The City of Arcadia has not adopted an ordinance or program requiring electric-powered construction equipment. However, if such an ordinance is adopted, the Revised Project would be required to comply with the applicable goals or policies requiring the use of electric construction equipment in the future. As such, the Revised Project would be consistent with this action. Non-combustion Methane Emissions Divert 75% of organic waste from landfills by 2025 Consistent. SB 1383 establishes targets to achieve a 50 percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2020 and a 75 percent reduction by 2025. The Revised Project would comply with local and regional regulations and recycle or compost 75 percent of waste by 2025 pursuant to SB 1383. As such, the Revised Project would be consistent with this action. Source: California Air Resources Board, 2022 Scoping Plan, November 16, 2022. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 27 The 2020-2045 RTP/SCS includes performance goals that were adopted to help focus future investments on the best-performing projects, as well as different strategies to preserve, maintain, and optimize the performance of the existing transportation system. The SCAG 2020-2045 RTP/SCS is forecast to help California reach its GHG emissions reduction goals by reducing GHG emissions from passenger cars by 8 percent below 2005 levels by 2020 and 19 percent by 2035 in accordance with the California Air Resources Board targets adopted in March 2018. Five key SCS strategies are included in the 2020-2045 RTP/SCS to help the region meet its regional vehicle miles traveled (VMT) and GHG reduction goals, as required by the State. Table 7 presents the Revised Project’s consistency with these five strategies. As shown therein, the Revised Project would be consistent with the GHG emission reduction strategies contained in the 2020-2045 RTP/SCS. Table 7 Consistency with the 2020-2045 RTP/SCS Reduction Strategy Applicable Land Use Tools Project Consistency Analysis Focus Growth Near Destinations and Mobility Options x Emphasize land use patterns that facilitate multimodal access to work, educational and other destinations x Focus on a regional jobs/housing balance to reduce commute times and distances and expand job opportunities near transit and along center-focused main streets x Plan for growth near transit investments and support implementation of first/last mile strategies x Promote the redevelopment of underperforming retail developments and other outmoded nonresidential uses x Prioritize infill and redevelopment of underutilized land to accommodate new growth, increase amenities and connectivity in existing neighborhoods x Encourage design and transportation options that reduce the reliance on and number of solo car trips (this could include mixed uses or locating and orienting close to existing destinations) x Identify ways to “right size” parking requirements and promote alternative parking strategies (e.g. shared parking or smart parking) Center Focused Placemaking, Priority Growth Areas (PGA), Job Centers, High Quality Transit Areas (HQTAs), Transit Priority Areas (TPA), Neighborhood Mobility Areas (NMAs), Livable Corridors, Spheres of Influence (SOIs), Green Region, Urban Greening Consistent. The Project Site is located within an area that is near residential uses. The Revised Project would be required to incorporate pedestrian-oriented features, bicycle parking, EV charging stations, and vanpool/carpool parking spaces to promote other forms of transportation. Existing bus stops are located less than 1 mile south of the Project Site. Therefore, the Revised Project would focus growth near destinations and mobility options. Promote Diverse Housing Choices x Preserve and rehabilitate affordable housing and prevent displacement x Identify funding opportunities for new workforce and affordable housing development x Create incentives and reduce regulatory barriers for building context sensitive accessory dwelling units to increase housing supply PGA, Job Centers, HQTAs, NMA, TPAs, Livable Corridors, Green Region, Urban Greening Consistent. The Revised Project would involve development of an assisted living facility within a mile of a transit station, which increases housing supply and supports reduction of GHG emissions. Therefore, the Revised Project would be consistent with this reduction strategy. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 28 Table 7 Consistency with the 2020-2045 RTP/SCS Reduction Strategy Applicable Land Use Tools Project Consistency Analysis x Provide support to local jurisdictions to streamline and lessen barriers to housing development that supports reduction of greenhouse gas emissions Leverage Technology Innovations x Promote low emission technologies such as neighborhood electric vehicles, shared rides hailing, car sharing, bike sharing and scooters by providing supportive and safe infrastructure such as dedicated lanes, charging and parking/drop-off space x Improve access to services through technology— such as telework and telemedicine as well as other incentives such as a “mobility wallet,” an app-based system for storing transit and other multi-modal payments x Identify ways to incorporate “micro-power grids” in communities, for example solar energy, hydrogen fuel cell power storage and power generation HQTA, TPAs, NMA, Livable Corridors Consistent. The Revised Project would provide seven EV parking spaces, including one that is ADA- compliant. Therefore, the Revised Project would promote low emission technology innovations and help the City, County, and State meet their GHG reduction goals. The Revised Project would be consistent with this reduction strategy. Support Implementation of Sustainability Policies x Pursue funding opportunities to support local sustainable development implementation projects that reduce greenhouse gas emissions x Support statewide legislation that reduces barriers to new construction and that incentivizes development near transit corridors and stations x Support local jurisdictions in the establishment of Enhanced Infrastructure Financing Districts (EIFDs), Community Revitalization and Investment Authorities (CRIAs), or other tax increment or value capture tools to finance sustainable infrastructure and development projects, including parks and open space x Work with local jurisdictions/communities to identify opportunities and assess barriers to implement sustainability strategies x Enhance partnerships with other planning organizations to promote resources and best practices in the SCAG region x Continue to support long range planning efforts by local jurisdictions Provide educational opportunities to local decisions makers and staff on new tools, best practices and policies related to implementing the Sustainable Communities Strategy Center Focused Placemaking, PGA, Job Centers, HQTAs, TPA, NMAs, Livable Corridors, SOIs, Green Region, Urban Greening. Consistent. The Revised Project would be located close to bus stops and provide bicycle parking spaces, which would promote alternative modes of transportation. Furthermore, the Revised Project would be required to comply with 2022 Title 24 standards and install high efficiency features, such as energy-efficient appliances, low-flow fixtures, and water-efficiency irrigation. Thus, the Revised Project would be consistent with this reduction strategy. Promote a Green Region x Support development of local climate adaptation and hazard mitigation plans, as well as project Green Region, Urban Consistent. The Revised Project involves development of an assisted Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 29 In summary, the Revised Project’s characteristics render it consistent with statewide, regional, and local climate change mandates, plans, policies, and recommendations. More specifically, the GHG plan consistency analysis demonstrates that the Revised Project would comply with the regulations and GHG reduction goals, policies, actions, and strategies outlined in the 2022 Scoping Plan and 2020-2045 RTP/SCS. Consistency with these plans would reduce the impact of the Revised Project’s incremental contribution of GHG emissions. Accordingly, the Revised Project would not conflict with any applicable plan, policy, regulation, or recommendation adopted for the purpose of reducing GHG emissions. Impacts in this regard would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact in the 2020 MND. 5.9 HAZARDS AND HAZARDOUS MATERIALS Routine Transport, Use, Disposal, or Accidental Release of Hazardous Materials According to the 2020 MND, given the age of the existing restaurant building on-site (constructed in the 1970s), there is potential for the building to contain asbestos-containing materials (ACM) and/or lead-based paint (LBP). However, the Approved Project would be required to comply with existing regulations to properly identify, remove, handle, and dispose of ACMs and LBP. Compliance with these regulations would ensure that existing hazardous materials would be effectively disposed of during the demolition phase and would, therefore, have no effect on the health and safety of construction workers and area residents. In addition, the transport, use, and disposal of hazardous materials, as well as the potential release of these materials to the environment, are closely regulated through State and federal laws. Furthermore, the use of hazardous materials during operation of the Approved Project would likely involve minor quantities of typical household hazardous materials, such as cleaning products, solvents, adhesives, Table 7 Consistency with the 2020-2045 RTP/SCS Reduction Strategy Applicable Land Use Tools Project Consistency Analysis implementation that improves community resiliency to climate change and natural hazards x Support local policies for renewable energy production, reduction of urban heat islands and carbon sequestration x Integrate local food production into the regional landscape x Promote more resource efficient development focused on conservation, recycling and reclamation x Preserve, enhance and restore regional wildlife connectivity x Reduce consumption of resource areas, including agricultural land x Identify ways to improve access to public park space Greening, Greenbelts and Community Separators living facility on developed land and, therefore, would not interfere with regional wildlife connectivity or agricultural land. As discussed above, the Revised Project would be required to comply with the 2022 Title 24 standards, which would help reduce energy consumption and reduce GHG emissions. Thus, the Revised Project would support efficient development that reduces energy consumption and GHG emissions. The Revised Project would be consistent with this reduction strategy. Source: Southern California Association of Governments, 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy – Connect SoCal , September 3, 2020. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 30 refrigerants, paints, other chemical materials used in building maintenance, small amounts of oil and fuels from internal combustion engines, pesticides and herbicides, sharp or used needles, and electronic waste. This level of hazardous materials use would be typical for institutional uses and, thus, is not identified as a significant threat to the environment. Accordingly, the 2020 MND determined that based on the type of land use proposed, the relatively minor anticipated level of use, storage, and disposal of hazardous materials and compliance with various State and federal laws regulating hazardous materials, the Approved Project would result in a less-than-significant impact involving the routine transport, use, or disposal of hazardous materials or the accidental release of hazardous materials into the environment. The Revised Project proposes the same land use type as the Approved Project and would not include land uses that may generate hazardous materials or hazardous waste beyond those identified for the Approved Project. As with the Approved Project, the Revised Project would be required to comply with the same regulations that would minimize the impacts to the public and the environment as related to the routine transport, use, or disposal of hazardous materials or the accidental release of hazardous materials into the environment, including the removal of ACM and LBP if found on-site. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Impacts Related to Hazardous Emissions, Cortese List Site, Airports, and Wildland Fires According to the 2020 MND, there are no schools within a quarter mile of the Project Site, and, as such, the Approved Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within a quarter mile of an existing or proposed school. In addition, the Project Site is not included on the Cortese List, which is the list of hazardous waste sites or facilities compiled by the California Department of Toxic Substances Control under Government Code Section 65962.5. As such, the Approved Project would not create a significant hazard to the public or the environment. Furthermore, the nearest airport to the Project Site is the San Gabriel Airport, which is approximately 4.5 miles to the southeast, and, as such, the Approved Project would not result in a safety hazard or excessive noise for people residing or working in the Project area. Finally, the Project Site is not located within a Very High Fire Hazard Severity Zone, as identified by the California Department of Forestry and Fire Protection, or surrounded by wildland areas. As such, the Approved Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fire. Accordingly, the 2020 MND determined that the Approved Project would have no impact related to these issues. The Revised Project would be developed within the boundaries of the Project Site and proposes the same land use type as the Approved Project. Accordingly, as with the Approved Project, the Revised Project would have no impact related to hazardous emissions near schools, creating a hazard as a hazardous waste site, airport safety hazards, or wildland fires. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Emergency Evacuation Plan Access to the Project Site is currently available on Michillinda Avenue and Colorado Boulevard. According to the 2020 MND, the Approved Project would have access to major thoroughfares that Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 31 have been identified as a Principal Travel Corridor by the City’s General Plan, such as Michillinda Avenue, I-210, and Foothill Boulevard, during an emergency evacuation. In addition, the Approved Project would reduce the number of daily trips and peak hour trips generated by the Coco’s Bakery and Restaurant, which was in operation at the time, thereby reducing traffic on adjacent and nearby thoroughfares. Therefore, the 2020 MND determined that development of the Approved Project would not impair implementation of an adopted emergency response plan or evacuation plan. The Revised Project proposes the same land use type as the Approved Project and would not include land uses that may interfere with or obstruct emergency evacuation of the Project Site and the Project vicinity. As with the Approved Project, the Revised Project would have access to major thoroughfares during an emergency evacuation. The Revised Project would generate no more than 30 vehicle trips in the peak hours, as presented in Appendix B of this Initial Study. This minimal increase in peak hour trips would have a negligible impact on the area intersections. Accordingly, as with the Approved Project, development of the Revised Project would not impair implementation of an adopted emergency response plan or evacuation plan. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than- significant impact determination in the 2020 MND. 5.10 HYDROLOGY AND WATER QUALITY Water Quality According to the 2020 MND, the Approved Project could have both short- and long-term impacts on water quality. Short-term impacts would occur during the construction phase, when the pollutants of greatest concern are sediment and hydrocarbon or fossil fuel remnants, which could run off the Project Site without any best management practices (BMPs) in place. Long-term impacts would result from stormwater runoff from the Project Site during operation of the Approved Project. However, construction runoff is regulated by the NPDES Construction General Permit, which requires identification of a variety of water quality control BMPs to be specified on construction plans and implemented throughout construction. Similarly, the Approved Project would be required to comply with the City’s Low Impact Development (LID) Ordinance, which requires the preparation of a LID Plan that addresses on-site stormwater runoff retention and treatment and implementation of post-construction BMPs, such as cleaning the parking areas and the sidewalks along the Project Site’s frontages. Accordingly, the 2020 MND determined that through compliance with existing regulations and the preparation of a LID Plan, potential water quality impacts during construction and operation of the Approved Project would be avoided or reduced to less-than-significant levels, and the Approved Project would not result in violations of any water quality standards or waste discharge requirements. As with the Approved Project, the Revised Project would be required to comply with the same regulations that would minimize the impacts on water quality, including the preparation of a LID Plan, and, as such, would not substantially degrade surface or groundwater quality and result in impacts beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 32 Groundwater According to the 2020 MND, there are no groundwater wells on the Project Site, and none were proposed by the Approved Project. The Approved Project would reduce, but not substantially change, the amount of impervious surface area on-site and, as such, would not have an effect on groundwater levels beneath the Project Site; if any, the effect would be minimal and likely beneficial given the Approved Project’s reduction in overall impervious surfaces as compared to existing conditions. As such, operation of the Approved Project would not interfere with groundwater recharge. Accordingly, the Approved Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Approved Project may impede sustainable groundwater management of the basin. Therefore, impacts to groundwater would be less than significant. As with the Approved Project, development of the Revised Project would not substantially change the amount of impervious surface area on-site and would not have an effect on groundwater levels beneath the Project Site. Similar to the Approved Project, the Revised Project would likely have a beneficial effect given the reduction in overall impervious surfaces as compared to existing conditions. Accordingly, the Revised Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Revised Project may impede sustainable groundwater management of the basin, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Drainage According to the 2020 MND, there are no natural drainage courses on the Project Site, and, because the Project Site is currently fully developed with impervious surfaces, the Approved Project would not result in a substantial alteration of the existing drainage pattern of the Project Site. The Approved Project would be required to comply with existing regulations to (1) minimize erosion that may lead to siltation on- or off-site during construction; (2) ensure proper drainage to avoid or redirect flooding on- or off-site; and (3) prevent discharge of sediment and polluted stormwater runoff, and retain, control, and treat stormwater runoff on the Project Site. Accordingly, the 2020 MND determined that the Approved Project would not alter the existing drainage pattern of the Project Site in a manner that would result in substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site, create or contribute runoff water that would exceed the capacity of the existing stormwater drainage system or provide substantial additional sources of polluted runoff, or impede or redirect flood flows. Therefore, impacts related to drainage would be less than significant. As with the Approved Project, development of the Revised Project would not substantially change the amount of impervious surface area on-site as compared to existing conditions. In addition, the Revised Project would be required to comply with same existing regulations as the Approved Project. Furthermore, similar to the Approved Project, the Revised Project would likely have a beneficial effect given the reduction in overall impervious surfaces as compared to existing conditions. A modular wetland is proposed in the southeastern corner of the Project Site to collect and treat surface water runoff from the Project Site prior to draining to the existing curb inlet and then to the existing storm drainage system to the east. Accordingly, the Revised Project would Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 33 not alter the existing drainage pattern of the Project Site that would result in flooding on- or off- site, create or contribute runoff water that would exceed the capacity of the existing stormwater drainage system or provide substantial additional sources of polluted runoff, or impede or redirect flood flows; as such, impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Flooding According to the 2020 MND, the Project Site is not located near any reservoir, other bodies of water, or the Pacific Ocean to be potentially inundated by seiches or tsunamis. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map for the area, the Project Site is located within Zone X, which represents an area of minimal flood hazard. However, according to the City’s General Plan Safety Element, the Project Site is located within a designated inundation area for the Morris S. Jones Reservoir. Nonetheless, dams are regulated and monitored for structural safety by the California Department of Water Resources in accordance with the California Water Code to reduce the potential for catastrophic failure and inundation of downstream areas, such as the Project Site. In addition, the Approved Project would be required to implement a LID plan, which would incorporate water quality control features on- site, such as maintenance of landscape areas and proper storage of any hazardous materials, which would prevent the release of pollutants in the unlikely event that the Project Site is inundated by catastrophic dam failure. Therefore, the 2020 MND determined that the Approved Project would not risk release of pollutants due to inundation, and no impact would occur. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, which has been identified as not being subject to inundation by seiches or tsunamis. Given that the Revised Project is located within a designated inundation area for the Morris S. Jones Reservoir, the Revised Project would be required to implement water quality control features on-site to prevent the release of pollutants when inundated. Accordingly, the Revised Project would not risk release of pollutants due to inundation, and no impact would occur. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Consistency with Water Quality Control Plan or Sustainable Groundwater Management Plan According to the 2020 MND, because the Approved Project would not result in a substantial increase in potable water demand and because it would not involve the use, disposal, or storage of hazardous chemicals that could impact water quality, the Approved Project would not interfere with the Main Basin Watermaster’s 2019 Supply Plan, and impacts would be less than significant. Although the Revised Project would consume and generate more water and wastewater, respectively, than the Approved Project, the Revised Project would also not result in a substantial increase in potable water demand. As discussed in Section 5.19, Utilities/Service Systems, of this addendum, because the Revised Project is consistent with the underlying zoning and General Plan designation for the Project Site, the population and employment growth associated with the Revised Project would have been incorporated into the SCAG 2020-2045 RTP/SCS growth projections, on which the City’s 2020 Urban Water Management Plan (UWMP) was based. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 34 According to the 2020 UWMP, the City can meet water demands during normal years, single dry years, and five consecutive year drought periods through 2045.2 In addition, as with the Approved Project, because the Revised Project would not involve the use, disposal, or storage of hazardous chemicals that could impact water quality, the Revised Project would not interfere with the Main Basin Watermaster’s 2019 Supply Plan, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less- than-significant impact determination in the 2020 MND. 5.11 LAND USE AND PLANNING Physical Division of an Established Community According to the 2020 MND, the Approved Project would not result in physical alterations to any land use beyond the Project Site boundaries or significant changes to the public rights-of-way beyond the widening of Colorado Boulevard and Michillinda Avenue along the Project Site’s frontages to be implemented by the City following the Approved Project’s 4-foot dedication from the Project Site. Therefore, the 2020 MND determined that the Approved Project would not physically divide an established community, and no impact would occur. As with the Approved Project, development of the Revised Project would occur on the Project Site and, as such, would not result in physical alterations to any land use beyond the Project Site boundaries. Similar to the Approved Project, the Revised Project would dedicate 4 feet from the Project Site to allow the City to improve and widen Colorado Boulevard and Michillinda Avenue along the Project Sites frontages. In addition, the Revised Project would connect to an existing 21-inch sewer main to the west along Michillinda Avenue via a new sewer lateral. However, as with the Approved Project, the Revised Project would not physically divide an established community, and no impact would occur. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. Conflict with Plans, Policies, or Regulations According to the 2020 MND, the Approved Project would be consistent with the development standards and regulation of the underlying C-G zone upon approval of a CUP. In addition, the Arcadia General Plan Parks, Recreation, and Community Resources Element and the Safety Element do not identify any land use restrictions for the Project Site that, respectively, (1) would require conservation of the Project Site for purposes of protecting wildlife habitat or other natural resources or (2) pertain to avoidance of environmental hazards on or near the Project Site. The Project Site is not within an area where special land use policies or zoning standards have been created for the purpose of avoiding or mitigating environmental effects. Accordingly, the 2020 MND determined that the Approved Project would not conflict with an applicable land use plan, policy, or regulation established for the purpose of avoiding or mitigating an environmental effect, and impacts related to land use and planning would be less than significant. As with the Approved Project, development of the Revised Project would occur on the Project Site and not within an area where special land use policies or zoning standards have been created 2 City of Arcadia, Final 2020 Urban Water Management Plan , June 2021. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 35 for the purpose of avoiding or mitigating environmental effects. Additionally, the Revised Project would be consistent with the existing General Plan Land Use designation of Commercial and zone of G-C. As discussed in Section 4.0, Project Description, of this addendum, the Revised Project is entitled to receive a density bonus and deviate from the maximum permitted FAR for the Project Site through a CUP; the Revised Project would comply with all other applicable development standards. Accordingly, as with the Approved Project, the Revised Project would not conflict with an applicable land use plan, policy, or regulation established for the purpose of avoiding or mitigating an environmental effect, and impacts related to land use and planning would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. 5.12 MINERAL RESOURCES According to the 2020 MND, since the Project Site is currently developed with a building previously occupied by Coco’s Bakery and Restaurant and surface parking, development of the Approved Project on the Project Site would not result in the loss of availability of (1) a known mineral resource that would be of regional or Statewide value or (2) a locally-important mineral resource recovery site. Accordingly, the 2020 MND determined that the Approved Project would have no impact to mineral resources. As with the Approved Project, development of the Revised Project would occur within the Project Site boundaries and, as such, would not result in the loss of a known mineral resource or a locally- important mineral resource recovery site. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.13 NOISE Temporary or Permanent Increase in Ambient Noise Levels According to the 2020 MND, although construction noise is allowed during the City’s allowable construction hours and is not considered to be a significant impact during those hours, construction of the Approved Project could expose adjoining residential uses to temporary high noise levels. To reduce the short-term construction impacts on adjacent sensitive receptors to less-than-significant levels, the 2020 MND identified the following mitigation measure: NOI-1 Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Planning Division, that the Project complies with the following: x Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. x The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on-site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 36 complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Planning & Community Development Administrator (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. x During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. x Prior to issuance of any Grading or Building Permit, the Project applicant shall demonstrate to the satisfaction of the Community Development Director (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. x Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. In addition, according to the 2020 MND, the Approved Project would generate fewer trips when compared to the existing use on the Project Site at the time (i.e., Coco’s Bakery and Restaurant). As such, the 2020 MND determined that, because the Approved Project’s trip generation would reduce existing traffic volumes along local roadways, traffic noise levels also would be reduced and would be less than significant. Additionally, the 2020 MND determined that the Approved Project’s operational stationary noise associated with mechanical equipment, slow-moving trucks, and parking areas would not exceed the City’s noise standards or introduce new sources of noise in the Project vicinity compared to existing conditions. Therefore, operation of the Approved Project was determined to result in less-than-significant noise impacts in the 2020 MND. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, with sensitive receptors located immediately adjacent to the east and south. Although the Revised Project would involve a slightly larger development and, thus, longer construction duration than analyzed in the 2020 MND, there would be no change in the construction equipment anticipated to be used or the distance between the closest receptors and the proposed construction activities. As with the Approved Project, although construction noise is allowed during the City’s allowable construction hours and is not considered to be a significant impact during those hours, the Revised Project could expose adjoining residential uses to temporary high noise levels and would, therefore, be required to comply with Mitigation Measure NOI-1 to reduce short-term construction noise impacts to less-than-significant levels. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 37 new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact with mitigation in the 2020 MND. As discussed in Section 5.17, Transportation/Traffic, of this addendum, the Revised Project would generate more trips compared to the Approved Project. However, the Revised Project would only add 17 or fewer trips to the two driveways when compared to the Approved Project; this increase in traffic would be equivalent to an average of no more than 1 trip every 3.5 minutes and, as such, would have a negligible impact on the area intersections. In addition, according to the City of Arcadia Traffic Volume Map, existing daily traffic volumes along Colorado Street and Michillinda Avenue are 20,842 and 18,522 trips per day, respectively.3 As determined by the California Department of Transportation, a doubling in roadway traffic volumes is required to generate any noticeable increase in roadway noise levels.4 Accordingly, the Revised Project’s minimal trip generation of approximately 296 trips per day (compared to the 208 trips per day generated by the Approved Project) would not double existing traffic volumes along Colorado Boulevard and Michillinda Avenue or result in a perceptible increase in traffic noise. In addition, the Revised Project proposes the same land use type as the Approved Project and would not include stationary sources, such as mechanical equipment, slow-moving trucks, and parking areas, beyond those identified for the Approved Project. Therefore, the Revised Project’s operational stationary noise levels would not exceed the City’s noise standards or introduce new sources of noise in the Project vicinity compared to existing conditions and would be considered less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Groundborne Vibration According to the 2020 MND, construction of the Approved Project would not generate groundborne vibration exceeding the building damage or human annoyance thresholds established by the Federal Transit Administration. Similarly, operation of the Approved Project would not include uses that would generate excessive groundborne vibration. Accordingly, the 2020 MND determined that the Approved Project would not result in excessive groundborne vibration or groundborne noise levels, and impacts would be less than significant. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, with sensitive receptors located immediately adjacent to the east and south. Although the Revised Project would involve a larger development and longer construction duration than analyzed in the 2020 MND, there would be no change in the construction equipment anticipated to be used or the distance between the closest receptors and the proposed construction activities. Accordingly, construction and operation of the Revised Project would not generate groundborne vibration exceeding the building damage or human annoyance thresholds or include uses that would generate excessive groundborne vibration beyond those identified for the Approved Project. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. 3 City of Arcadia, Traffic Volume Map, February 2019. 4 California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 38 Airport-Related Noise As discussed in Section 5.9, Hazards and Hazardous Materials, of this addendum, the nearest airport to the Project Site is the San Gabriel Airport, which is approximately 4.5 miles to the southeast, and, as such, the Approved Project would not result in a safety hazard or excessive noise for people residing or working in the Project area. Accordingly, the 2020 MND determined that the Approved Project would have no impact related to excessive noise levels associated with aircraft operation. The Revised Project would be developed within the boundaries of the Project Site and proposes the same land use type as the Approved Project. Accordingly, as with the Approved Project, the Revised Project would have no impact related to excessive noise levels associated with aircraft operation. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.14 POPULATION AND HOUSING According to the 2020 MND, the Approved Project, which was estimated to generate 80 residents and 40 employees,5 would account for approximately 0.9 percent of the forecasted population growth and 0.7 percent of the forecasted employment growth between 2012 and 2040 as projected in the SCAG 2016-2020 RTP/SCS.6 The 2020 MND determined that the Approved Project would not result in substantial unplanned growth in the area, and impacts would be less than significant. The Revised Project would have 114 beds, resulting in the generation of 114 residents. Using the same assumption (based on SCAG’s Employment Density Report) as that for the Approved Project, the Revised Project is also estimated to generate 40 employees. The SCAG 2020-2045 RTP/SCS, the update to the 2016-2040 RTP/SCS, estimates that the City’s population would increase by 4,900 residents and 2,800 employees between 2016 and 2045. Accordingly, the Revised Project’s residents and employees would account for approximately 2.3 percent of the forecasted population growth and 1.4 percent of the forecasted employment growth between 2016 and 2045. Although the Revised Project would increase the number of residents and employees and the corresponding percentages in forecasted growth, the Revised Project would remain consistent with the zoning and General Plan land use designation for the Project Site pursuant to the California Density Bonus Law, as discussed in Section 4.0, Project Description, of this addendum. As with the Approved Project, the Revised Project would not result in substantial unplanned growth in the area, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. With regard to displacement of people or housing, the Project Site contains an existing building, which was previously occupied by Coco’s Bakery and Restaurant and is now vacant, and surface 5 According to the 2020 MND, the number of employees was calculated using SCAG’s Employment Density Report (Employment Density Study Summary Report, Table B-1, 2001), which provided an average employee density of 14.24 employees per acre for Special Care Facilities in Los Angeles County. As the Project Site is 2.79 acres in size, the estimated number of employees serving the Approved Project would be 40. 6 The 2016-2040 RTP/SCS estimated that the population in Arcadia would increase from 56,700 to 65,900 and employment from 28,900 to 34,400 between 2012 and 2040. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 39 parking. Accordingly, because there are no current residents or housing units on the Project Site, the Approved Project would not displace people or housing, necessitating the construction of replacement housing elsewhere. As such, no impact related to displacement would occur. As with the Approved Project, the Revised Project would occur within the Project Site boundaries and, thus, would not displace people or housing. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.15 PUBLIC SERVICES Fire and Police Protection According to the 2020 MND, the Approved Project would incrementally increase the demand for fire and police protection services. However, the Approved Project would be required to comply with the California Fire Code and Arcadia Fire Department regulations governing hydrant placement, fire flows, and building construction, and with the Arcadia Fire Department’s review and approval of the Project Site’s access and circulation plans. With regard to police protection, the Approved Project would include on-site security resources, such as security guards and orderlies, to patrol the grounds, monitor locked entry and exit points to the property, and protect residents. In addition, the Approved Project would be required to comply with Policy S-5.11 of the Arcadia General Plan and pay its fair share of costs associated with any necessary increases in public safety equipment, facilities, and staffing to provide life safety protection. Accordingly, through compliance with existing regulations and incorporation of safety and security features in the design of the proposed development, the Approved Project would have a less-than-significant impact on fire and police protection services. As with the Approved Project, the Revised Project would incrementally increase the demand for fire protection and emergency medical services. Although the Revised Project would generate 34 additional residents than the Approved Project, the Revised Project would not present unique or more difficult circumstances than the Approved Project that would warrant new or expanded fire or police protection services or facilities. As with the Approved Project, the Revised Project would be required to comply with existing regulations and incorporate safety and security features in the design of the proposed development resulting in a less-than-significant impact on fire and police protection services. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Schools, Parks, and Other Public Facilities According to the 2020 MND, because the Approved Project would be inhabited by seniors affected by memory loss, there would be no school-aged children living on the Project Site that would incrementally increase the demand for schools. In addition, the residents of the Approved Project were anticipated to have limited mobility and, thus, not expected to substantially increase the demand on parks, libraries, and other public facilities. Furthermore, the Approved Project would include activity rooms, enclosed landscaped outdoor area with gardens, walking paths, and a gazebo for use by the Project’s residents. Accordingly, the 2020 MND determined that the Approved Project would have no impact on schools, City park facilities, libraries, and other public facilities. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 40 As with the Approved Project, the Revised Project would be inhabited by seniors affected by memory loss, and, as such, no school-aged children would be living on the Project Site. Similarly, the residents of the Revised Project are anticipated to have limited mobility and are not expected to substantially increase the demand on parks, libraries, and other public facilities. As with the Approved Project, the Revised Project would provide indoor recreational amenities, such as a reading room, sitting and music areas, sensory wellness room, a bar/lounge, an activity room, a media room, and a fitness center with a physical therapy area, and outdoor recreational amenities, such as open air courtyards, a seating area with outdoor workout equipment, a dog park, and a bocce ball court, for use by the Project’s residents. Accordingly, as with the Approved Project, the Revised Project would have no impact on schools, City park facilities, libraries, and other public facilities. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.16 RECREATION As discussed in Section 5.16, Public Services (Parks), residents of the Approved Project were expected to have limited mobility and, thus, not expected to increase the demand on parks or other recreational facilities. In addition, the Approved Project would include activities rooms, enclosed landscaped outdoor area with gardens, walking paths, and a gazebo for use by the Project’s residents. Accordingly, the 2020 MND determined that the Approved Project would have no impact on parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. As with the Approved Project, the residents of the Revised Project are anticipated to have limited mobility and are not expected to substantially increase the demand on parks or other recreational facilities. As with the Approved Project, the Revised Project would provide indoor recreational amenities, such as a reading room, sitting and music areas, sensory wellness room, a bar/lounge, an activity room, a media room, and a fitness center with a physical therapy area, and outdoor recreational amenities, such as open air courtyards, a seating area with outdoor workout equipment, a dog park, and a bocce ball court, for use by the Project’s residents. Accordingly, as with the Approved Project, the Revised Project would have no impact on parks or other recreational facilities. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.17 TRANSPORTATION/TRAFFIC Conflict with Plans, Policies, or Regulations According to the 2020 MND, while the Approved Project’s construction traffic would temporarily affect traffic flow on the surrounding street network, particularly along the truck haul routes, the impacts would be temporary and would fluctuate in intensity throughout the construction day and vary throughout the overall construction program, with less traffic generated in phases following the demolition and grading phases. Accordingly, the 2020 MND determined that, because the construction traffic impacts associated with the Approved Project would be temporary, they would not significantly affect the performance of the circulation system with respect to level of service standards or other metrics related to congestion and travel delay. During operation, the Approved Project would generate fewer trips when compared to the existing use on the Project Site at the Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 41 time (i.e., Coco’s Bakery and Restaurant), resulting in a less-than-significant impact related to trip generation, trip distribution, and intersection performance. In addition, the residents of the Approved Project were anticipated to have limited mobility and, as such, would have little to no impact on surrounding bus, pedestrian, or bicycle facilities. Project employees were anticipated to have a small impact on bus, pedestrian, or bicycle systems as the number of employees and visitors that would utilize transit or bicycle infrastructure to access the senior living and memory care facility under the Approved Project as compared to those of the existing use of the Project Site at the time was deemed negligible. Accordingly, the 2020 MND determined that the Approved Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, taking into account all modes of transportation including transit, roadways, bicycle and pedestrian facilities; as such, impacts related to transportation would be less than significant. The Revised Project proposes the same land use type as the Approved Project and would temporarily affect traffic flow on the surrounding street network during construction. As with the Approved Project, the short-term nature of the construction traffic impacts would not significantly affect the performance of the circulation system with respect to level of service standards or other metrics related to congestion and travel delay. During operation, because the Revised Project would involve a larger development than analyzed in the 2020 MND and the trip credit from the restaurant use is no longer applied due to its closing, the Revised Project would generate more trips compared to the Approved Project (see Appendix B). However, the Revised Project would only add 17 or fewer trips to the two driveways when compared to the Approved Project; this increase in traffic would be equivalent to an average of no more than 1 trip every 3.5 minutes and, as such, would have a negligible impact on the area intersections. As with the Approved Project, the residents of the Revised Project are anticipated to have limited mobility and, as such, would have little to no impact on surrounding bus, pedestrian, or bicycle facilities. In addition, because the number of employees under the Revised Project would be the same as that under the Approved Project employees, as discussed in Section 5.14, Population and Housing, of this addendum, the Revised Project would not result in impacts on bus, pedestrian, or bicycle systems beyond those identified for the Approved Project. Accordingly, as with the Approved Project, the Revised Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, taking into account all modes of transportation including transit, roadways, bicycle and pedestrian facilities; as such, impacts related to transportation would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. VMT Analysis According to the 2020 MND, the Approved Project would result in a substantial reduction in daily trips compared to the existing use at the time. Accordingly, the 2020 MND determined that the Approved Project’s impact on citywide and regional VMT would be less than significant. With regard to the Revised Project, the City of Arcadia Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment identifies Assisted Living Facilities as one of the types of land uses under the VMT Project Type Screening criteria. Land uses of this type are presumed to result in a less-than-significant transportation impact under CEQA and do not require a detailed quantitative VMT assessment. Accordingly, the Revised Project would not conflict with CEQA Guidelines Section 15064.3(b), and impacts would be considered less than significant. Therefore, there are no material changes in circumstances, and the Revised Project Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 42 would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Hazards Due to a Geometric Design Feature According to the 2020 MND, the Approved Project would not create uses that could generate an incompatible use of area roadways, which could impair circulation or safety on area roads. In addition, no internal street network was proposed as part of the Approved Project, and, therefore, no potential hazards associated with a geometric design feature, such as a sharp curve, would occur within the Project Site. The Approved Project proposed a single entrance and exit driveway onto Colorado Boulevard, which would be designed to meet the mandatory design standards of the City of Arcadia as it relates to width, intersection control, and sight distance. Accordingly, the 2020 MND determined that through compliance with applicable City requirements related to roadway safety, the Approved Project would not increase hazards due to a geometric design feature or incompatible uses, and impacts would be less than significant. The Revised Project proposes the same land use type as the Approved Project and, as such, would not create any uses that could impair circulation or safety on area roads. As with the Approved Project, no internal street network is proposed as part of the Revised Project, and, therefore, no potential hazards associated with a geometric design feature, such as a sharp curve, would occur within the Project Site. The Revised Project would retain the two existing driveways, which would be reconstructed in the same general location, to provide site access along Colorado Boulevard and Michillinda Avenue; the design of these driveways would be reviewed to confirm that the reconstruction meets the mandatory design standards of the City of Arcadia as they relate to width, intersection control, and sight distance. Accordingly, as with the Approved Project, through compliance with applicable City requirements related to roadway safety, the Revised Project would not increase hazards due to a geometric design feature or incompatible uses, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Emergency Access According to the 2020 MND, the Approved Project’s building plans and structures would be reviewed by the Arcadia Fire Department for compliance with applicable safety and emergency access standards, including the adequacy of fire flow, access, and fire hydrant placement. In addition, because the Project Site is located in an urban setting, where the surrounding street network allows for access to the Project Site from multiple directions and because the Approved Project would be designed to accommodate emergency response vehicles, the 2020 MND determined that the Approved Project’s impacts related to emergency access would be less than significant. As with the Approved Project, the Revised Project’s building plans and structures would be reviewed by the Arcadia Fire Department for compliance with applicable safety and emergency access standards, including the adequacy of fire flow, access, and fire hydrant placement. Similarly, because it is confined to the same Project Site, the Revised Project’s impacts related to emergency access would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 43 more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. 5.18 TRIBAL CULTURAL RESOURCES According to the 2020 MND, no documented historic or prehistoric cultural resources were identified on the Project Site or within a quarter-mile radius of the Project Site. As such, the 2020 MND determined that the Approved Project would not cause an adverse change in the significance of a tribal cultural resource, defined in Public Resources Code (PRC) Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register or in a local register of historical resources, and no impact would occur. With regard to the impact related to the significance of a resource to a California Native American tribe, the City formally consulted with the Gabrieleño Band of Mission Indians–Kizh Nation. However, the information obtained during consultation did not demonstrate that existing tribal cultural resources are present within the Project Site. Accordingly, the 2020 MND determined that, due to the lack of substantial evidence as to why the Project area should be considered sensitive for tribal cultural resources, impacts related to tribal cultural resources would be less- than-significant. However, the 2020 MND included the following voluntary mitigation measures imposed by the City to address the inadvertent discovery of tribal cultural resources: TCR-1 Retail a Native American Monitor/Consultant. The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians-Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. TCR-2 Unanticipated Discovery of Tribal Cultural and Archaeological Resources. Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place or Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 44 recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary Objects. 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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. 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 Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 45 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. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. TCR-4 Professional Standards. Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in Southern California. The qualified archaeologist shall ensure that all other personnel are appropriately trained and qualified. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, where no tribal cultural resources have been identified. Thus, development of the Revised Project would result in a less-than-significant impact on tribal cultural resources. However, as with the Approved Project, the Revised Project would include Mitigation Measures TCR-1 through TCR-4, which are voluntary mitigation measures that the City would impose as an added protection to address the inadvertent discovery of tribal cultural resources. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 46 Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. 5.19 UTILITIES/SERVICE SYSTEMS Water Conveyance/Supply and Wastewater Treatment/Conveyance According to the 2020 MND, the Approved Project would result in the daily consumption of approximately 10,000 gallons of water and daily generation of the same amount of wastewater. These would represent a daily net reduction of 3,088 gallons in water consumption and wastewater generation due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the 2020 MND determined that the Approved Project would not require or result in the relocation or construction of new or expanded water or wastewater treatment facility, the construction or relocation of which could cause significant environmental effects, and impacts related to water consumption/water supply and wastewater generation would be less than significant. The Revised Project proposes the same land use type as the Approved Project. However, the Revised Project would involve a larger development than analyzed in the 2020 MND. In addition, because the restaurant occupying the existing building closed since the adoption of the 2020 MND, the amount of water consumed and wastewater generated by the restaurant use are no longer applied. As a result, the Revised Project would consume approximately 14,250 gallons per day of water and would generate the same amount of wastewater.7 Nonetheless, according to the City’s 2020 Urban Water Management Plan (UWMP), the City can meet water demands during normal years, single dry years, and five consecutive year drought periods through 2045.8 Because the Revised Project is consistent with the underlying zoning and General Plan land use designation for the Project Site, the population and employment growth associated with the Revised Project would have been incorporated into the SCAG 2020-2045 RTP/SCS growth projections, on which the City’s 2020 UWMP was based. Furthermore, as related to wastewater, the City’s 2020 UWMP identified the three water reclamation plants owned by the Los Angeles County Sanitation Districts of Los Angeles and serving the City as having a combined treatment capacity of 415 million gallons per day of wastewater. As such, the approximately 14,250 gallons per day of wastewater generated by the Revised Project would represent 0.003 percent of the treatment capacity, which is considered a negligible increase. The Revised Project would connect to an existing 21-inch sewer main to the west along Michillinda Avenue via a new sewer lateral. Accordingly, as with the Approved Project, the Revised Project would not require or result in the relocation or construction of new or expanded water or wastewater treatment facility, the construction or relocation of which could cause significant environmental effects, and impacts related to water consumption/water supply and wastewater generation would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project 7 Based on the water consumption and wastewater generation rate of 125 gallons per day per bed used in the 2020 MND. 8 City of Arcadia, Final 2020 Urban Water Management Plan , June 2021. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 47 would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Storm Drains As discussed in Section 5.10, Hydrology and Water Quality, of this addendum, the 2020 MND determined that the Approved Project would slightly reduce the amount of impervious surfaces on the Project Site due to the increase in the amount of pervious landscape areas proposed by the Approved Project as compared to existing conditions. In addition, only stormwater overflow from the Project Site would drain to the existing private storm drain at the southeastern corner of the Project Site. Therefore, the Approved Project would not contribute to additional runoff as compared to existing conditions and would not result in the relocation or construction of new or expanded storm drain facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to drainage were determined to be less than significant. As with the Approved Project, development of the Revised Project would not substantially change the amount of impervious surface area on-site as compared to existing conditions. In addition, the Revised Project would be required to comply with the same existing regulations as the Approved Project. Furthermore, similar to the Approved Project, the Revised Project would likely have a beneficial effect given the reduction in overall impervious surfaces as compared to existing conditions. As such, the Revised Project would not alter the existing drainage pattern of the Project Site that would create or contribute runoff water that would exceed the capacity of the existing stormwater drainage system. Accordingly, as with the Approved Project, the Revised Project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects, and impacts related to storm drains would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than- significant impact determination in the 2020 MND. Electricity, Natural Gas, and Telecommunications According to the 2020 MND, the Approved Project would result in a net reduction in electricity and natural gas consumption due to the change in land use from a high turnover restaurant to an assisted living facility; further, the Approved Project could be served by existing telecommunication facilities that are available in the Project area. Accordingly, the Approved Project would not require or result in the relocation or construction of new or expanded power lines, natural gas lines, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to electricity, natural gas, and telecommunication facilities would be less than significant. The Revised Project proposes the same land use type as the Approved Project. However, the Revised Project would involve a larger development than analyzed in the 2020 MND. In addition, because the restaurant occupying the existing building closed since the adoption of the 2020 MND, the amount of electricity and natural gas consumed by the restaurant use is no longer applied. As a result, the Revised Project would result in higher consumption of electricity and natural gas than the Approved Project. Nonetheless, as discussed in Section 5.6, Energy, of this addendum, the Revised Project’s electricity and natural gas usage would constitute a nominal increase compared to the County’s annual electricity and natural gas consumption. As with the Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 48 Approved Project, the Revised Project could be served by existing telecommunication facilities that are available in the Project area. Accordingly, as with the Project, the Revised Project would not require or result in the relocation or construction of new or expanded power lines, natural gas lines, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects. As such, impacts related to electricity, natural gas, and telecommunication facilities would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than-significant impact determination in the 2020 MND. Solid Waste According to the 2020 MND, the Approved Project would result in the daily generation of approximately 400 pounds of solid waste, a daily net reduction of 9 pounds due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the 2020 MND determined that the Approved Project 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 and that impacts would be less than significant. The Revised Project proposes the same land use type as the Approved Project. However, the Revised Project would involve a larger development than analyzed in the 2020 MND. In addition, because the restaurant occupying the existing building closed since the adoption of the 2020 MND, the amount of solid waste generated by the restaurant use is no longer applied. As a result, the Revised Project would generate approximately 570 pounds per day of solid waste.9 This would represent a daily net increase of 170 pounds of solid waste when compared to the Approved Project. However, according to the 2020 MND, the City’s General Plan Update Program Environmental Impact Report determined that there would be no significant adverse impact on landfill capacity and that continuation of existing City and County programs and implementation of pertinent goals, policies, and implementation actions in the General Plan Update would provide for future developments’ compliance with solid waste regulations.10 Accordingly, as with the Approved Project, the Revised Project 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, and impacts would be less than significant. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the less-than- significant impact determination in the 2020 MND. 5.20 WILDFIRE According to the 2020 MND, the Project Site is not located within or adjacent to a state responsibility area or a Very High Fire Hazard Severity Zone (VHFHSZ), as designated by the California Department of Forestry and Fire Protection. Accordingly, the 2020 MND determined that the Approved Project would not (1) substantially impair an adopted emergency response plan or emergency evacuation plan, (2) exacerbate wildfire risks and expose the residents of the Approved Project to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire, (3) require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk 9 Based on the solid waste generation rate of 5 pounds per day per person used in the 2020 MND. 10 City of Arcadia, General Plan Update Draft Program EIR, September 2010, p. 4.16-33. Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 49 or that may result in temporary or ongoing impacts to the environment, or (4) expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. No impact related to wildfire would occur. As with the Approved Project, development of the Revised Project would occur within the boundaries of the Project Site, which is not located within or adjacent to a state responsibility area or a VHFHSZ. Accordingly, as with the Approved Project, development of the Revised Project would have no impact related to wildfire. Therefore, there are no material changes in circumstances, and the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the no-impact determination in the 2020 MND. 5.21 MANDATORY FINDINGS OF SIGNIFICANCE The 2020 MND determined that, with implementation of the identified mitigation measures related to biological resources, archaeological resources, paleontological resources, noise, and tribal cultural resources, the Approved Project would not degrade the quality of the environment. Specifically, the Approved Project would not have substantial impacts to special-status species, stream habitat, and wildlife dispersal. Mitigation Measure BIO-1 would ensure that tree removal would not pose a significant impact to migratory wildlife species. Furthermore, the Approved Project would not affect the local, regional, or national populations or ranges of any plant or animal species and would not threaten any plant communities. Similarly, with implementation of Mitigation Measures CUL-1, GEO-1, and TCR-1 through TCR-4, the Approved Project would not have substantial impacts to historical, archaeological, paleontological, or tribal cultural resources and, thus, would not eliminate any important examples of California history or prehistory. Therefore, the Approved Project would not result in a Mandatory Finding of Significance due to impacts to biological, cultural, paleontological, or tribal cultural resources. In addition, the 2020 MND determined that the Approved Project would not have the potential to cause impacts that are cumulatively considerable as the Approved Project would not result in any significant and unavoidable impacts in any environmental categories. In all cases, the impacts associated with the Approved Project would be limited to the Project Site and were of such a negligible degree that they would not result in a significant contribution to any cumulative impacts. In some cases, the Approved Project would result in a net reduction when compared to existing conditions (i.e., related to emissions, transportation, water consumption, and wastewater and solid waste generation). Therefore, the Approved Project would not result in a Mandatory Finding of Significance due to cumulative impacts. Furthermore, the Approved Project would not have the potential to result in direct or indirect substantial adverse effects on human beings. Although construction noise is allowed during the City’s allowable construction hours and is not considered to be a significant impact during those hours, the Approved Project could expose adjoining residential uses to temporary high noise levels during construction activities. Accordingly, Mitigation Measure NOI-1 was recommended to reduce short-term construction noise impacts through noise reduction methods to a less-than- significant level. In all other environmental issue areas, the Approved Project would not approach or exceed any significance thresholds typically associated with direct or indirect effects on people, such as air, water, or land pollution, natural environmental hazards, transportation-related hazards, or adverse effects to emergency service response. Therefore, the Approved Project Addendum to the Artis Senior Living Project IS/MND April 2024 City of Arcadia Page 50 would not result in a Mandatory Finding of Significance due to direct or indirect effects on human beings. As with the Approved Project, the Revised Project would be required to comply with all mitigation measures identified in the 2020 MND. Furthermore, there are no design features included within the Revised Project that would suggest that these mitigation measures would not be sufficient to address any potentially significant impact that would arise from implementation of the Revised Project. As such, there are no material changes in circumstances, and implementation of the Revised Project would not result in any new significant or substantially more severe environmental impacts that would affect the determination of less-than-significant impact and less-than- significant impact with mitigation in the 2020 MND. 6.0 CONCLUSION CEQA Guidelines Section 15164(b) states that the Lead Agency shall prepare an addendum to a previously certified negative declaration if only minor technical changes or additions are necessary or none of the conditions described in CEQA Guidelines Section 15162 calling for the preparation of a subsequent negative declaration have occurred. The Revised Project described above does not result in significant modifications or have any occurrences within the conditions described in CEQA Guidelines Section 15162. In addition, the impact comparison provided above demonstrates that no new potentially significant impacts would occur and that no substantial increase in the severity of impacts would occur upon implementation of the Revised Project. On the basis of the evaluation contained in this document, there are no changes in the Approved Project or the circumstances under which the Revised Project is being undertaken or any new information of substantial importance that was not known to the Lead Agency at the time the 2020 MND was adopted that trigger any of the conditions identified in CEQA Guidelines Section 15162, which would require a subsequent CEQA document. Therefore, pursuant to CEQA Guidelines Sections 15162 and 15164, this addendum has been prepared to document the changes to the adopted 2020 MND for the Revised Project to explain the Lead Agency’s decision not to prepare a subsequent CEQA document or a new MND. Addendum to the Artis Senior Living Project IS/MND April 2024 City Arcadia Attachment A ATTACHMENT A Air Quality/GHG Assumptions and Model Outputs Artis Senior Living Project ISMND Detailed Report, 12/26/2023 1 / 49 Artis Senior Living Project ISMND Detailed Report Table of Contents 1. Basic Project Information 1.1. Basic Project Information 1.2. Land Use Types 1.3. User-Selected Emission Reduction Measures by Emissions Sector 2. Emissions Summary 2.1. Construction Emissions Compared Against Thresholds 2.2. Construction Emissions by Year, Unmitigated 2.4. Operations Emissions Compared Against Thresholds 2.5. Operations Emissions by Sector, Unmitigated 3. Construction Emissions Details 3.1. Demolition (2024) - Unmitigated 3.3. Grading (2024) - Unmitigated 3.5. Grading (2025) - Unmitigated 3.7. Building Construction (2025) - Unmitigated Artis Senior Living Project ISMND Detailed Report, 12/26/2023 2 / 49 3.9. Building Construction (2026) - Unmitigated 3.11. Paving (2024) - Unmitigated 3.13. Architectural Coating (2026) - Unmitigated 4. Operations Emissions Details 4.1. Mobile Emissions by Land Use 4.1.1. Unmitigated 4.2. Energy 4.2.1. Electricity Emissions By Land Use - Unmitigated 4.2.3. Natural Gas Emissions By Land Use - Unmitigated 4.3. Area Emissions by Source 4.3.1. Unmitigated 4.4. Water Emissions by Land Use 4.4.1. Unmitigated 4.5. Waste Emissions by Land Use 4.5.1. Unmitigated 4.6. Refrigerant Emissions by Land Use 4.6.1. Unmitigated Artis Senior Living Project ISMND Detailed Report, 12/26/2023 3 / 49 4.7. Offroad Emissions By Equipment Type 4.7.1. Unmitigated 4.8. Stationary Emissions By Equipment Type 4.8.1. Unmitigated 4.9. User Defined Emissions By Equipment Type 4.9.1. Unmitigated 4.10. Soil Carbon Accumulation By Vegetation Type 4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated 4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated 4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated 5. Activity Data 5.1. Construction Schedule 5.2. Off-Road Equipment 5.2.1. Unmitigated 5.3. Construction Vehicles 5.3.1. Unmitigated 5.4. Vehicles Artis Senior Living Project ISMND Detailed Report, 12/26/2023 4 / 49 5.4.1. Construction Vehicle Control Strategies 5.5. Architectural Coatings 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities 5.6.2. Construction Earthmoving Control Strategies 5.7. Construction Paving 5.8. Construction Electricity Consumption and Emissions Factors 5.9. Operational Mobile Sources 5.9.1. Unmitigated 5.10. Operational Area Sources 5.10.1. Hearths 5.10.1.1. Unmitigated 5.10.2. Architectural Coatings 5.10.3. Landscape Equipment 5.11. Operational Energy Consumption 5.11.1. Unmitigated 5.12. Operational Water and Wastewater Consumption Artis Senior Living Project ISMND Detailed Report, 12/26/2023 5 / 49 5.12.1. Unmitigated 5.13. Operational Waste Generation 5.13.1. Unmitigated 5.14. Operational Refrigeration and Air Conditioning Equipment 5.14.1. Unmitigated 5.15. Operational Off-Road Equipment 5.15.1. Unmitigated 5.16. Stationary Sources 5.16.1. Emergency Generators and Fire Pumps 5.16.2. Process Boilers 5.17. User Defined 5.18. Vegetation 5.18.1. Land Use Change 5.18.1.1. Unmitigated 5.18.1. Biomass Cover Type 5.18.1.1. Unmitigated 5.18.2. Sequestration Artis Senior Living Project ISMND Detailed Report, 12/26/2023 6 / 49 5.18.2.1. Unmitigated 6. Climate Risk Detailed Report 6.1. Climate Risk Summary 6.2. Initial Climate Risk Scores 6.3. Adjusted Climate Risk Scores 6.4. Climate Risk Reduction Measures 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores 7.2. Healthy Places Index Scores 7.3. Overall Health & Equity Scores 7.4. Health & Equity Measures 7.5. Evaluation Scorecard 7.6. Health & Equity Custom Measures 8. User Changes to Default Data Artis Senior Living Project ISMND Detailed Report, 12/26/2023 7 / 49 1. Basic Project Information 1.1. Basic Project Information Data Field Value Project Name Artis Senior Living Project ISMND Construction Start Date 10/1/2024 Operational Year 2026 Lead Agency — Land Use Scale Project/site Analysis Level for Defaults County Windspeed (m/s)0.50 Precipitation (days)24.4 Location 1150 Colorado St, Arcadia, CA 91007, USA County Los Angeles-South Coast City Arcadia Air District South Coast AQMD Air Basin South Coast TAZ 4971 EDFZ 7 Electric Utility Southern California Edison Gas Utility Southern California Gas App Version 2022.1.1.21 1.2. Land Use Types Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq ft) Special Landscape Area (sq ft) Population Description Artis Senior Living Project ISMND Detailed Report, 12/26/2023 8 / 49 Congregate Care (Assisted Living) 100 Dwelling Unit 6.25 107,706 0.00 — 296 — Parking Lot 56.0 Space 0.50 0.00 0.00 — — — 1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected 2. Emissions Summary 2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Unmit. 1.81 35.4 11.4 19.9 0.03 0.44 1.22 1.63 0.40 0.29 0.66 — 4,035 4,035 0.17 0.11 4.86 4,076 Daily, Winter (Max) —————————————————— Unmit. 6.73 5.65 53.3 54.2 0.08 2.31 4.41 6.08 2.13 1.74 3.71 — 10,100 10,100 0.43 0.38 0.23 10,214 Average Daily (Max) —————————————————— Unmit. 1.23 2.34 8.05 12.7 0.02 0.31 0.73 1.05 0.29 0.18 0.46 — 2,648 2,648 0.11 0.07 1.42 2,674 Annual (Max) —————————————————— Unmit. 0.22 0.43 1.47 2.31 < 0.005 0.06 0.13 0.19 0.05 0.03 0.08 — 438 438 0.02 0.01 0.23 443 2.2. Construction Emissions by Year, Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Artis Senior Living Project ISMND Detailed Report, 12/26/2023 9 / 49 Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily - Summer (Max) —————————————————— 2025 1.72 1.45 11.1 18.2 0.03 0.44 1.03 1.47 0.40 0.25 0.65 — 3,732 3,732 0.15 0.10 4.57 3,771 2026 1.81 35.4 11.4 19.9 0.03 0.41 1.22 1.63 0.37 0.29 0.66 — 4,035 4,035 0.17 0.11 4.86 4,076 Daily - Winter (Max) —————————————————— 2024 6.73 5.65 53.3 54.2 0.08 2.31 3.77 6.08 2.13 1.59 3.71 — 10,100 10,100 0.43 0.34 0.16 10,214 2025 3.98 3.27 29.5 37.0 0.06 1.18 4.41 5.59 1.08 1.74 2.83 — 8,412 8,412 0.37 0.38 0.23 8,535 2026 1.60 1.34 10.6 17.1 0.03 0.38 1.03 1.42 0.35 0.25 0.60 — 3,655 3,655 0.15 0.10 0.11 3,690 Average Daily —————————————————— 2024 0.57 0.48 4.60 4.68 0.01 0.20 0.43 0.63 0.18 0.18 0.37 — 920 920 0.04 0.04 0.28 933 2025 1.23 1.03 8.05 12.7 0.02 0.31 0.73 1.05 0.29 0.18 0.46 — 2,648 2,648 0.11 0.07 1.42 2,674 2026 0.58 2.34 3.82 6.27 0.01 0.14 0.37 0.51 0.13 0.09 0.21 — 1,324 1,324 0.06 0.04 0.66 1,337 Annual—————————————————— 2024 0.10 0.09 0.84 0.85 < 0.005 0.04 0.08 0.11 0.03 0.03 0.07 — 152 152 0.01 0.01 0.05 154 2025 0.22 0.19 1.47 2.31 < 0.005 0.06 0.13 0.19 0.05 0.03 0.08 — 438 438 0.02 0.01 0.23 443 2026 0.11 0.43 0.70 1.14 < 0.005 0.03 0.07 0.09 0.02 0.02 0.04 — 219 219 0.01 0.01 0.11 221 2.4. Operations Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Unmit. 1.78 4.05 2.50 14.1 0.03 0.16 1.65 1.80 0.16 0.42 0.57 153 4,700 4,852 15.5 0.10 7.54 5,277 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 10 / 49 ——————————————————Daily, Winter (Max) Unmit. 1.24 3.53 2.51 7.90 0.03 0.15 1.65 1.80 0.15 0.42 0.57 153 4,608 4,761 15.5 0.10 1.53 5,181 Average Daily (Max) —————————————————— Unmit. 1.43 3.79 1.17 11.4 0.02 0.04 1.62 1.67 0.04 0.41 0.46 153 2,874 3,027 15.5 0.10 4.03 3,447 Annual (Max) —————————————————— Unmit. 0.26 0.69 0.21 2.08 < 0.005 0.01 0.30 0.30 0.01 0.08 0.08 25.3 476 501 2.56 0.02 0.67 571 2.5. Operations Emissions by Sector, Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Mobile 1.04 0.95 0.67 7.72 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,834 1,834 0.09 0.07 6.17 1,865 Area 0.71 3.08 1.55 6.31 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,910 1,910 0.04 < 0.005 — 1,912 Energy 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 918 918 0.07 < 0.005 — 921 Water———————————7.1437.044.10.730.02—67.8 Waste———————————1460.0014614.60.00—510 Refrig.————————————————1.371.37 Total 1.78 4.05 2.50 14.1 0.03 0.16 1.65 1.80 0.16 0.42 0.57 153 4,700 4,852 15.5 0.10 7.54 5,277 Daily, Winter (Max) —————————————————— Mobile 1.03 0.94 0.74 7.15 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,758 1,758 0.10 0.08 0.16 1,784 Area 0.17 2.58 1.49 0.64 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,895 1,895 0.04 < 0.005 — 1,897 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 11 / 49 Energy 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 918 918 0.07 < 0.005 — 921 Water———————————7.1437.044.10.730.02—67.8 Waste———————————1460.0014614.60.00—510 Refrig.————————————————1.371.37 Total 1.24 3.53 2.51 7.90 0.03 0.15 1.65 1.80 0.15 0.42 0.57 153 4,608 4,761 15.5 0.10 1.53 5,181 Average Daily —————————————————— Mobile 1.02 0.93 0.74 7.33 0.02 0.01 1.62 1.63 0.01 0.41 0.42 — 1,778 1,778 0.09 0.08 2.66 1,807 Area 0.38 2.84 0.14 3.93 < 0.005 0.01 — 0.01 0.01 — 0.01 0.00 140 140 < 0.005 < 0.005 — 140 Energy 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 918 918 0.07 < 0.005 — 921 Water———————————7.1437.044.10.730.02—67.8 Waste———————————1460.0014614.60.00—510 Refrig.————————————————1.371.37 Total 1.43 3.79 1.17 11.4 0.02 0.04 1.62 1.67 0.04 0.41 0.46 153 2,874 3,027 15.5 0.10 4.03 3,447 Annual—————————————————— Mobile 0.19 0.17 0.14 1.34 < 0.005 < 0.005 0.30 0.30 < 0.005 0.08 0.08 — 294 294 0.02 0.01 0.44 299 Area 0.07 0.52 0.03 0.72 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 23.2 23.2 < 0.005 < 0.005 — 23.2 Energy 0.01 < 0.005 0.05 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 152 152 0.01 < 0.005 — 153 Water———————————1.186.127.310.12<0.005—11.2 Waste———————————24.10.0024.12.410.00—84.4 Refrig.————————————————0.230.23 Total 0.26 0.69 0.21 2.08 < 0.005 0.01 0.30 0.30 0.01 0.08 0.08 25.3 476 501 2.56 0.02 0.67 571 3. Construction Emissions Details 3.1. Demolition (2024) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Artis Senior Living Project ISMND Detailed Report, 12/26/2023 12 / 49 Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Off-Road Equipment 3.12 2.62 24.9 21.7 0.03 1.06 — 1.06 0.98 — 0.98 — 3,425 3,425 0.14 0.03 — 3,437 Demolitio n ——————0.000.00—0.000.00——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Off-Road Equipment 0.20 0.17 1.64 1.43 < 0.005 0.07 — 0.07 0.06 — 0.06 — 225 225 0.01 < 0.005 — 226 Demolitio n ——————0.000.00—0.000.00——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment 0.04 0.03 0.30 0.26 < 0.005 0.01 — 0.01 0.01 — 0.01 — 37.3 37.3 < 0.005 < 0.005 — 37.4 Demolitio n ——————0.000.00—0.000.00——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Daily, Summer (Max) —————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 13 / 49 Daily, Winter (Max) —————————————————— Worker 0.07 0.07 0.08 0.96 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 201 201 0.01 0.01 0.02 203 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Worker < 0.005 < 0.005 0.01 0.07 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 13.4 13.4 < 0.005 < 0.005 0.02 13.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.22 2.22 < 0.005 < 0.005 < 0.005 2.25 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 3.3. Grading (2024) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Off-Road Equipment 2.26 1.90 18.2 18.8 0.03 0.84 — 0.84 0.77 — 0.77 — 2,958 2,958 0.12 0.02 — 2,969 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 14 / 49 ———————1.341.34—2.762.76——————Dust From Material Movement Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Off-Road Equipment 0.27 0.23 2.18 2.25 < 0.005 0.10 — 0.10 0.09 — 0.09 — 353 353 0.01 < 0.005 — 354 Dust From Material Movement ——————0.330.33—0.160.16——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment 0.05 0.04 0.40 0.41 < 0.005 0.02 — 0.02 0.02 — 0.02 — 58.5 58.5 < 0.005 < 0.005 — 58.7 Dust From Material Movement ——————0.060.06—0.030.03——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Worker 0.07 0.07 0.08 0.96 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 201 201 0.01 0.01 0.02 203 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.12 0.03 2.08 0.77 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,603 1,603 0.09 0.26 0.10 1,682 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 15 / 49 Average Daily —————————————————— Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.02 0.02 0.00 0.01 0.01 — 24.3 24.3 < 0.005 < 0.005 0.04 24.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.25 0.09 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 191 191 0.01 0.03 0.19 201 Annual—————————————————— Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.03 4.03 < 0.005 < 0.005 0.01 4.08 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 31.7 31.7 < 0.005 0.01 0.03 33.3 3.5. Grading (2025) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Off-Road Equipment 2.07 1.74 16.3 17.9 0.03 0.72 — 0.72 0.66 — 0.66 — 2,959 2,959 0.12 0.02 — 2,970 Dust From Material Movement ——————2.762.76—1.341.34——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Off-Road Equipment < 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 5.79 5.79 < 0.005 < 0.005 — 5.81 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 16 / 49 Dust From Material Movement ——————0.010.01—<0.005<0.005——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.96 0.96 < 0.005 < 0.005 — 0.96 Dust From Material Movement ——————<0.005<0.005—<0.005<0.005——————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Worker 0.07 0.06 0.07 0.88 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 197 197 0.01 0.01 0.02 199 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.12 0.02 2.01 0.76 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,575 1,575 0.09 0.25 0.09 1,651 Average Daily —————————————————— Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.39 0.39 < 0.005 < 0.005 < 0.005 0.40 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.08 3.08 < 0.005 < 0.005 < 0.005 3.23 Annual—————————————————— Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.06 0.06 < 0.005 < 0.005 < 0.005 0.07 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 17 / 49 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.51 0.51 < 0.005 < 0.005 < 0.005 0.54 3.7. Building Construction (2025) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Off-Road Equipment 1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Off-Road Equipment 1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Off-Road Equipment 0.96 0.80 7.46 9.31 0.02 0.31 — 0.31 0.28 — 0.28 — 1,713 1,713 0.07 0.01 — 1,719 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment 0.18 0.15 1.36 1.70 < 0.005 0.06 — 0.06 0.05 — 0.05 — 284 284 0.01 < 0.005 — 285 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 18 / 49 Daily, Summer (Max) —————————————————— Worker 0.34 0.31 0.31 5.01 0.00 0.00 0.94 0.94 0.00 0.22 0.22 — 996 996 0.04 0.03 3.64 1,010 Vendor 0.02 0.01 0.39 0.19 < 0.005 < 0.005 0.09 0.10 < 0.005 0.03 0.03 — 339 339 0.01 0.05 0.93 355 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Worker 0.34 0.31 0.35 4.25 0.00 0.00 0.94 0.94 0.00 0.22 0.22 — 944 944 0.04 0.04 0.09 955 Vendor 0.02 0.01 0.40 0.19 < 0.005 < 0.005 0.09 0.10 < 0.005 0.03 0.03 — 339 339 0.01 0.05 0.02 354 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Worker 0.24 0.22 0.27 3.19 0.00 0.00 0.66 0.66 0.00 0.15 0.15 — 684 684 0.03 0.02 1.12 693 Vendor 0.02 0.01 0.29 0.13 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 — 242 242 0.01 0.03 0.29 253 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Worker 0.04 0.04 0.05 0.58 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 113 113 0.01 < 0.005 0.19 115 Vendor < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 40.1 40.1 < 0.005 0.01 0.05 41.9 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 3.9. Building Construction (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 19 / 49 2,405—0.020.102,3972,397—0.35—0.350.38—0.380.0213.09.851.071.28Off-Road Equipment Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Off-Road Equipment 1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Off-Road Equipment 0.46 0.38 3.51 4.62 0.01 0.13 — 0.13 0.12 — 0.12 — 854 854 0.03 0.01 — 857 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment 0.08 0.07 0.64 0.84 < 0.005 0.02 — 0.02 0.02 — 0.02 — 141 141 0.01 < 0.005 — 142 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Daily, Summer (Max) —————————————————— Worker 0.30 0.27 0.28 4.65 0.00 0.00 0.94 0.94 0.00 0.22 0.22 — 976 976 0.04 0.03 3.30 990 Vendor 0.02 0.01 0.37 0.18 < 0.005 < 0.005 0.09 0.10 < 0.005 0.03 0.03 — 333 333 0.01 0.05 0.90 349 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Worker 0.30 0.26 0.31 3.97 0.00 0.00 0.94 0.94 0.00 0.22 0.22 — 925 925 0.04 0.03 0.09 936 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 20 / 49 Vendor 0.02 0.01 0.38 0.18 < 0.005 < 0.005 0.09 0.10 < 0.005 0.03 0.03 — 333 333 0.01 0.05 0.02 348 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Worker 0.11 0.09 0.12 1.48 0.00 0.00 0.33 0.33 0.00 0.08 0.08 — 334 334 0.01 0.01 0.51 339 Vendor 0.01 < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.14 124 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Worker 0.02 0.02 0.02 0.27 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 55.3 55.3 < 0.005 < 0.005 0.08 56.1 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 19.7 19.7 < 0.005 < 0.005 0.02 20.5 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 3.11. Paving (2024) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Off-Road Equipment 1.01 0.85 7.81 10.0 0.01 0.39 — 0.39 0.36 — 0.36 — 1,512 1,512 0.06 0.01 — 1,517 Paving—0.06———————————————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 21 / 49 99.7—<0.005< 0.00599.499.4—0.02—0.020.03—0.03<0.0050.660.510.060.07Off-Road Equipment Paving—<0.005———————————————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment 0.01 0.01 0.09 0.12 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 16.5 16.5 < 0.005 < 0.005 — 16.5 Paving—<0.005———————————————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — ————————————————— Daily, Summer (Max) —————————————————— Daily, Winter (Max) —————————————————— Worker 0.07 0.07 0.08 0.96 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 201 201 0.01 0.01 0.02 203 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily —————————————————— Worker < 0.005 < 0.005 0.01 0.07 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 13.4 13.4 < 0.005 < 0.005 0.02 13.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.22 2.22 < 0.005 < 0.005 < 0.005 2.25 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 22 / 49 3.13. Architectural Coating (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite—————————————————— Daily, Summer (Max) —————————————————— Off-Road Equipment 0.15 0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architect ural Coatings —33.9———————————————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Average Daily —————————————————— Off-Road Equipment 0.01 0.01 0.05 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.32 7.32 < 0.005 < 0.005 — 7.34 Architect ural Coatings —1.86———————————————— Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Off-Road Equipment < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.21 1.21 < 0.005 < 0.005 — 1.22 Architect ural Coatings —0.34———————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 23 / 49 0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite truck Offsite — ————————————————— Daily, Summer (Max) —————————————————— Worker 0.06 0.05 0.06 0.93 0.00 0.00 0.19 0.19 0.00 0.04 0.04 — 195 195 0.01 0.01 0.66 198 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) —————————————————— Average Daily —————————————————— Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.3 10.3 < 0.005 < 0.005 0.02 10.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————— Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.70 1.70 < 0.005 < 0.005 < 0.005 1.73 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 4. Operations Emissions Details 4.1. Mobile Emissions by Land Use 4.1.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Artis Senior Living Project ISMND Detailed Report, 12/26/2023 24 / 49 Daily, Summer (Max) —————————————————— Congreg ate Care (Assisted Living) 1.04 0.95 0.67 7.72 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,834 1,834 0.09 0.07 6.17 1,865 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.04 0.95 0.67 7.72 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,834 1,834 0.09 0.07 6.17 1,865 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) 1.03 0.94 0.74 7.15 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,758 1,758 0.10 0.08 0.16 1,784 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.03 0.94 0.74 7.15 0.02 0.01 1.65 1.66 0.01 0.42 0.43 — 1,758 1,758 0.10 0.08 0.16 1,784 Annual—————————————————— Congreg ate Care (Assisted Living) 0.19 0.17 0.14 1.34 < 0.005 < 0.005 0.30 0.30 < 0.005 0.08 0.08 — 294 294 0.02 0.01 0.44 299 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.19 0.17 0.14 1.34 < 0.005 < 0.005 0.30 0.30 < 0.005 0.08 0.08 — 294 294 0.02 0.01 0.44 299 4.2. Energy Artis Senior Living Project ISMND Detailed Report, 12/26/2023 25 / 49 4.2.1. Electricity Emissions By Land Use - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Congreg ate Care (Assisted Living) ————————————5345340.03<0.005—536 Parking Lot ————————————28.028.0<0.005<0.005—28.1 Total————————————5625620.03<0.005—564 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) ————————————5345340.03<0.005—536 Parking Lot ————————————28.028.0<0.005<0.005—28.1 Total————————————5625620.03<0.005—564 Annual—————————————————— Congreg ate Care (Assisted Living) ————————————88.588.50.01<0.005—88.8 Parking Lot ————————————4.644.64<0.005<0.005—4.66 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 26 / 49 Total————————————93.193.10.01<0.005—93.5 4.2.3. Natural Gas Emissions By Land Use - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Congreg ate Care (Assisted Living) 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 356 356 0.03 < 0.005 — 357 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 356 356 0.03 < 0.005 — 357 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 356 356 0.03 < 0.005 — 357 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.03 0.02 0.28 0.12 < 0.005 0.02 — 0.02 0.02 — 0.02 — 356 356 0.03 < 0.005 — 357 Annual—————————————————— Congreg ate Care (Assisted Living) 0.01 < 0.005 0.05 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 58.9 58.9 0.01 < 0.005 — 59.1 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 27 / 49 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.01 < 0.005 0.05 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 58.9 58.9 0.01 < 0.005 — 59.1 4.3. Area Emissions by Source 4.3.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Hearths 0.17 0.09 1.49 0.64 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,895 1,895 0.04 < 0.005 — 1,897 Consum er Products —2.31———————————————— Architect ural Coatings —0.19———————————————— Landsca pe Equipme nt 0.53 0.50 0.05 5.67 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.2 15.2 < 0.005 < 0.005 — 15.2 Total 0.71 3.08 1.55 6.31 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,910 1,910 0.04 < 0.005 — 1,912 Daily, Winter (Max) —————————————————— Hearths 0.17 0.09 1.49 0.64 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,895 1,895 0.04 < 0.005 — 1,897 Consum er Products —2.31———————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 28 / 49 ————————————————0.19—Architect ural Coatings Total 0.17 2.58 1.49 0.64 0.01 0.12 — 0.12 0.12 — 0.12 0.00 1,895 1,895 0.04 < 0.005 — 1,897 Annual—————————————————— Hearths < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 21.5 21.5 < 0.005 < 0.005 — 21.5 Consum er Products —0.42———————————————— Architect ural Coatings —0.03———————————————— Landsca pe Equipme nt 0.07 0.06 0.01 0.71 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.72 1.72 < 0.005 < 0.005 — 1.73 Total 0.07 0.52 0.03 0.72 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 23.2 23.2 < 0.005 < 0.005 — 23.2 4.4. Water Emissions by Land Use 4.4.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Congreg ate Care (Assisted Living) ———————————7.1437.044.10.730.02—67.8 Parking Lot ———————————0.000.000.000.000.00—0.00 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 29 / 49 Total———————————7.1437.044.10.730.02—67.8 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) ———————————7.1437.044.10.730.02—67.8 Parking Lot ———————————0.000.000.000.000.00—0.00 Total———————————7.1437.044.10.730.02—67.8 Annual—————————————————— Congreg ate Care (Assisted Living) ———————————1.186.127.310.12<0.005—11.2 Parking Lot ———————————0.000.000.000.000.00—0.00 Total———————————1.186.127.310.12<0.005—11.2 4.5. Waste Emissions by Land Use 4.5.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 30 / 49 510—0.0014.61460.00146———————————Congreg ate Care (Assisted Living) Parking Lot ———————————0.000.000.000.000.00—0.00 Total———————————1460.0014614.60.00—510 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) ———————————1460.0014614.60.00—510 Parking Lot ———————————0.000.000.000.000.00—0.00 Total———————————1460.0014614.60.00—510 Annual—————————————————— Congreg ate Care (Assisted Living) ———————————24.10.0024.12.410.00—84.4 Parking Lot ———————————0.000.000.000.000.00—0.00 Total———————————24.10.0024.12.410.00—84.4 4.6. Refrigerant Emissions by Land Use 4.6.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Artis Senior Living Project ISMND Detailed Report, 12/26/2023 31 / 49 CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGTOGLand Use Daily, Summer (Max) —————————————————— Congreg ate Care (Assisted Living) ————————————————1.371.37 Total————————————————1.371.37 Daily, Winter (Max) —————————————————— Congreg ate Care (Assisted Living) ————————————————1.371.37 Total————————————————1.371.37 Annual—————————————————— Congreg ate Care (Assisted Living) ————————————————0.230.23 Total————————————————0.230.23 4.7. Offroad Emissions By Equipment Type 4.7.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Artis Senior Living Project ISMND Detailed Report, 12/26/2023 32 / 49 Daily, Summer (Max) —————————————————— Total—————————————————— Daily, Winter (Max) —————————————————— Total—————————————————— Annual—————————————————— Total—————————————————— 4.8. Stationary Emissions By Equipment Type 4.8.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Total—————————————————— Daily, Winter (Max) —————————————————— Total—————————————————— Annual—————————————————— Total—————————————————— 4.9. User Defined Emissions By Equipment Type Artis Senior Living Project ISMND Detailed Report, 12/26/2023 33 / 49 4.9.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Total—————————————————— Daily, Winter (Max) —————————————————— Total—————————————————— Annual—————————————————— Total—————————————————— 4.10. Soil Carbon Accumulation By Vegetation Type 4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio n TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Total—————————————————— Daily, Winter (Max) —————————————————— Total—————————————————— Annual—————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 34 / 49 Total—————————————————— 4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Total—————————————————— Daily, Winter (Max) —————————————————— Total—————————————————— Annual—————————————————— Total—————————————————— 4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) —————————————————— Avoided — ————————————————— Subtotal—————————————————— Sequest ered —————————————————— Subtotal—————————————————— Remove d —————————————————— Artis Senior Living Project ISMND Detailed Report, 12/26/2023 35 / 49 Subtotal—————————————————— ——————————————————— Daily, Winter (Max) —————————————————— Avoided — ————————————————— Subtotal—————————————————— Sequest ered —————————————————— Subtotal—————————————————— Remove d —————————————————— Subtotal—————————————————— ——————————————————— Annual—————————————————— Avoided — ————————————————— Subtotal—————————————————— Sequest ered —————————————————— Subtotal—————————————————— Remove d —————————————————— Subtotal—————————————————— ——————————————————— 5. Activity Data 5.1. Construction Schedule Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Artis Senior Living Project ISMND Detailed Report, 12/26/2023 36 / 49 Demolition Demolition 10/1/2024 11/1/2024 5.00 24.0 — Grading Grading 11/1/2024 1/1/2025 5.00 44.0 — Building Construction Building Construction 1/1/2025 7/1/2026 5.00 391 — Paving Paving 10/1/2024 11/1/2024 5.00 24.0 — Architectural Coating Architectural Coating 7/1/2026 7/28/2026 5.00 20.0 — 5.2. Off-Road Equipment 5.2.1. Unmitigated Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Concrete/Industrial Saws Diesel Average 1.00 8.00 33.0 0.73 Grading Graders Diesel Average 1.00 8.00 148 0.41 Grading Excavators Diesel Average 1.00 8.00 36.0 0.38 Grading Tractors/Loaders/Backh oes Diesel Average 3.00 8.00 84.0 0.37 Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Building Construction Tractors/Loaders/Backh oes Diesel Average 3.00 7.00 84.0 0.37 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42 Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 37 / 49 Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 5.3. Construction Vehicles 5.3.1. Unmitigated Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — — Demolition Worker 15.0 18.5 LDA,LDT1,LDT2 Demolition Vendor — 10.2 HHDT,MHDT Demolition Hauling 0.00 20.0 HHDT Demolition Onsite truck — — HHDT Grading — — — — Grading Worker 15.0 18.5 LDA,LDT1,LDT2 Grading Vendor — 10.2 HHDT,MHDT Grading Hauling 22.7 20.0 HHDT Grading Onsite truck — — HHDT Building Construction — — — — Building Construction Worker 72.0 18.5 LDA,LDT1,LDT2 Building Construction Vendor 10.7 10.2 HHDT,MHDT Building Construction Hauling 0.00 20.0 HHDT Building Construction Onsite truck — — HHDT Paving———— Paving Worker 15.0 18.5 LDA,LDT1,LDT2 Paving Vendor — 10.2 HHDT,MHDT Paving Hauling 0.00 20.0 HHDT Paving Onsite truck — — HHDT Architectural Coating — — — — Artis Senior Living Project ISMND Detailed Report, 12/26/2023 38 / 49 Architectural Coating Worker 14.4 18.5 LDA,LDT1,LDT2 Architectural Coating Vendor — 10.2 HHDT,MHDT Architectural Coating Hauling 0.00 20.0 HHDT Architectural Coating Onsite truck — — HHDT 5.4. Vehicles 5.4.1. Construction Vehicle Control Strategies Non-applicable. No control strategies activated by user. 5.5. Architectural Coatings Phase Name Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft) Non-Residential Exterior Area Coated (sq ft) Parking Area Coated (sq ft) Architectural Coating 218,105 72,702 0.00 0.00 1,317 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities Phase Name Material Imported (Cubic Yards)Material Exported (Cubic Yards)Acres Graded (acres)Material Demolished (sq. ft.)Acres Paved (acres) Demolition 0.00 0.00 0.00 — — Grading — 8,000 44.0 0.00 — Paving 0.00 0.00 0.00 0.00 0.50 5.6.2. Construction Earthmoving Control Strategies Control Strategies Applied Frequency (per day)PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61% Artis Senior Living Project ISMND Detailed Report, 12/26/2023 39 / 49 5.7. Construction Paving Land Use Area Paved (acres)% Asphalt Congregate Care (Assisted Living) — 0% Parking Lot 0.50 100% 5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh) Year kWh per Year CO2 CH4 N2O 2024 0.00 532 0.03 < 0.005 2025 0.00 532 0.03 < 0.005 2026 0.00 532 0.03 < 0.005 5.9. Operational Mobile Sources 5.9.1. Unmitigated Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Congregate Care (Assisted Living) 296 296 296 108,040 2,323 2,323 2,323 847,872 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.10. Operational Area Sources 5.10.1. Hearths 5.10.1.1. Unmitigated Hearth Type Unmitigated (number) Congregate Care (Assisted Living) — Artis Senior Living Project ISMND Detailed Report, 12/26/2023 40 / 49 Wood Fireplaces 0 Gas Fireplaces 90 Propane Fireplaces 0 Electric Fireplaces 0 No Fireplaces 10 5.10.2. Architectural Coatings Residential Interior Area Coated (sq ft)Residential Exterior Area Coated (sq ft)Non-Residential Interior Area Coated (sq ft) Non-Residential Exterior Area Coated (sq ft) Parking Area Coated (sq ft) 218104.65 72,702 0.00 0.00 1,317 5.10.3. Landscape Equipment Season Unit Value Snow Days day/yr 0.00 Summer Days day/yr 250 5.11. Operational Energy Consumption 5.11.1. Unmitigated Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr) Congregate Care (Assisted Living) 366,583 532 0.0330 0.0040 1,110,684 Parking Lot 19,232 532 0.0330 0.0040 0.00 5.12. Operational Water and Wastewater Consumption Artis Senior Living Project ISMND Detailed Report, 12/26/2023 41 / 49 5.12.1. Unmitigated Land Use Indoor Water (gal/year)Outdoor Water (gal/year) Congregate Care (Assisted Living) 3,727,380 0.00 Parking Lot 0.00 0.00 5.13. Operational Waste Generation 5.13.1. Unmitigated Land Use Waste (ton/year)Cogeneration (kWh/year) Congregate Care (Assisted Living) 270 — Parking Lot 0.00 — 5.14. Operational Refrigeration and Air Conditioning Equipment 5.14.1. Unmitigated Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced Congregate Care (Assisted Living) Average room A/C & Other residential A/C and heat pumps R-410A 2,088 < 0.005 2.50 2.50 10.0 Congregate Care (Assisted Living) Household refrigerators and/or freezers R-134a 1,430 0.22 0.60 0.00 1.00 5.15. Operational Off-Road Equipment 5.15.1. Unmitigated Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Artis Senior Living Project ISMND Detailed Report, 12/26/2023 42 / 49 5.16. Stationary Sources 5.16.1. Emergency Generators and Fire Pumps Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor 5.16.2. Process Boilers Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr) 5.17. User Defined Equipment Type Fuel Type 5.18. Vegetation 5.18.1. Land Use Change 5.18.1.1. Unmitigated Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres 5.18.1. Biomass Cover Type 5.18.1.1. Unmitigated Biomass Cover Type Initial Acres Final Acres 5.18.2. Sequestration 5.18.2.1. Unmitigated Artis Senior Living Project ISMND Detailed Report, 12/26/2023 43 / 49 Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) 6. Climate Risk Detailed Report 6.1. Climate Risk Summary Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100. Climate Hazard Result for Project Location Unit Temperature and Extreme Heat 20.8 annual days of extreme heat Extreme Precipitation 7.85 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth Wildfire 6.20 annual hectares burned Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. 6.2. Initial Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 2 0 0 N/A Extreme Precipitation N/A N/A N/A N/A Sea Level Rise 1 0 0 N/A Wildfire 1 0 0 N/A Flooding N/A N/A N/A N/A Artis Senior Living Project ISMND Detailed Report, 12/26/2023 44 / 49 Drought N/A N/A N/A N/A Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation 0 0 0 N/A The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures. 6.3. Adjusted Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 2 1 1 3 Extreme Precipitation N/A N/A N/A N/A Sea Level Rise 1 1 1 2 Wildfire 1 1 1 2 Flooding N/A N/A N/A N/A Drought N/A N/A N/A N/A Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation 1 1 1 2 The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures. 6.4. Climate Risk Reduction Measures 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. Artis Senior Living Project ISMND Detailed Report, 12/26/2023 45 / 49 Indicator Result for Project Census Tract Exposure Indicators — AQ-Ozone 84.6 AQ-PM 67.7 AQ-DPM 64.9 Drinking Water 73.7 Lead Risk Housing 82.5 Pesticides 0.00 Toxic Releases 69.0 Traffic 92.3 Effect Indicators — CleanUp Sites 27.8 Groundwater 30.9 Haz Waste Facilities/Generators 41.8 Impaired Water Bodies 0.00 Solid Waste 52.9 Sensitive Population — Asthma 7.85 Cardio-vascular 11.0 Low Birth Weights 23.9 Socioeconomic Factor Indicators — Education 13.7 Housing 39.2 Linguistic 71.7 Poverty 37.0 Unemployment 15.8 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 46 / 49 7.2. Healthy Places Index Scores The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. Indicator Result for Project Census Tract Economic — Above Poverty 81.39355832 Employed 67.22699859 Median HI 79.26344155 Education — Bachelor's or higher 85.4484794 High school enrollment 100 Preschool enrollment 95.7141024 Transportation — Auto Access 34.2871808 Active commuting 31.10483767 Social — 2-parent households 89.32375209 Voting 33.50442705 Neighborhood — Alcohol availability 52.31618119 Park access 81.35506224 Retail density 93.53265751 Supermarket access 46.91389709 Tree canopy 71.61555242 Housing — Homeownership 56.70473502 Housing habitability 58.14192224 Low-inc homeowner severe housing cost burden 83.07455409 Artis Senior Living Project ISMND Detailed Report, 12/26/2023 47 / 49 Low-inc renter severe housing cost burden 28.21763121 Uncrowded housing 92.9038881 Health Outcomes — Insured adults 94.73886822 Arthritis 0.0 Asthma ER Admissions 94.4 High Blood Pressure 0.0 Cancer (excluding skin)0.0 Asthma 0.0 Coronary Heart Disease 0.0 Chronic Obstructive Pulmonary Disease 0.0 Diagnosed Diabetes 0.0 Life Expectancy at Birth 95.9 Cognitively Disabled 43.0 Physically Disabled 65.4 Heart Attack ER Admissions 85.9 Mental Health Not Good 0.0 Chronic Kidney Disease 0.0 Obesity 0.0 Pedestrian Injuries 68.0 Physical Health Not Good 0.0 Stroke 0.0 Health Risk Behaviors — Binge Drinking 0.0 Current Smoker 0.0 No Leisure Time for Physical Activity 0.0 Climate Change Exposures — Artis Senior Living Project ISMND Detailed Report, 12/26/2023 48 / 49 Wildfire Risk 0.0 SLR Inundation Area 0.0 Children 77.6 Elderly 23.5 English Speaking 37.4 Foreign-born 74.6 Outdoor Workers 93.5 Climate Change Adaptive Capacity — Impervious Surface Cover 71.9 Traffic Density 89.7 Traffic Access 23.0 Other Indices — Hardship 15.3 Other Decision Support — 2016 Voting 40.7 7.3. Overall Health & Equity Scores Metric Result for Project Census Tract CalEnviroScreen 4.0 Score for Project Location (a) 31.0 Healthy Places Index Score for Project Location (b) 81.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. 7.4. Health & Equity Measures Artis Senior Living Project ISMND Detailed Report, 12/26/2023 49 / 49 No Health & Equity Measures selected. 7.5. Evaluation Scorecard Health & Equity Evaluation Scorecard not completed. 7.6. Health & Equity Custom Measures No Health & Equity Custom Measures created. 8. User Changes to Default Data Screen Justification Land Use Per Project Description Construction: Construction Phases Per AQ Questionnaire, Architectural Coating days keeps at default Construction: Architectural Coatings SCAQMD Rule 1113 Operations: Vehicle Data Pertrafficstudy Operations: Hearths No wood stove Operations: Architectural Coatings SCAQMD Rule 1113 Artis Senior Living Project Energy Calculations (kBTU/yr) (Therms) (kWh/yr) (MWh/yr) Congregate Care (Assisted Living) 1,110,684 11,107 366,583 367 Parking Lot 0 0 19,232 19 Totals 1,110,684 11,107 385,815 386 1 kBTU = 0.01 therms Electricity (MWh) 386 68,484,956 0.0006% Natural Gas (Therms)11,107 2,820,285,935 0.0004% Land Use Natural Gas Use Electricity Use Percentage Increase Countywide Energy Type Los Angeles County Annual Energy Consumption (2022) Project Annual Energy Consumption Artis Senior Living Project Energy Calculations Vehicle Type Percent of Vehicle Trips1 Daily Trips2 Annual Vehicle Miles Traveled Average Fuel Economy (miles per gallon)3 Total Annual Fuel Consumption (gallons)4 Passenger Cars 0.50 148 423,364 22 19,244 Light/Medium Trucks 0.48 141 403,630 17.3 23,331 County On-Road Heavy Trucks/Other 0.02 7 20,879 6.4 3,262 2026 TOTAL 6 1.00 296 847,872 -- 45,837 10,533,727 0.4351% 5. Values may be slightly off due to rounding. Source: Refer to CalEEMod outputs for assumptions used in this analysis. Notes: 1. Percent of Vehicle Trip distribution based on trip characteristics within the CalEEMod model. 2. Daily Trips taken from ITE manual. 3. Average fuel economy derived from the Department of Transportation. 4. Total Daily Fuel Consumption calculated by dividing the daily VMT by the average fuel economy (i.e., VMT/Average Fuel Economy). Artis Senior Living Project Energy Calculations Phase Phase Length (# days)# Worker Trips Worker Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day)Total Fuel Consumption Demolition 24 15 18.5 6,660 267.44 Grading 44 15 18.5 12,210 490.31 Building Construction 391 72 18.5 520,812 20,913.76 Paving 24 15 18.5 6,660 267.44 Architectural Coating 20 14 18.5 5,328 213.95 22,152.89 Phase Phase Length (# days)# Vendor Trips Vendor Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day)Total Fuel Consumption Demolition 24 0 10.2 0 0.00 Grading 44 0 10.2 0 0.00 Building Construction 391 11 10.2 42,674 5,114.37 Paving 24 0 10.2 0 0.00 Architectural Coating 20 0 10.2 0 0.00 5,114.37 Phase Phase Length (# days)# Hauling Trips Hauling Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day)1 Total Fuel Consumption Demolition 24 0 20 0 0.00 Grading 44 23 20 19,976 2,394.09 Building Construction 391 0 20 0 0.00 Paving 24 0 20 0 0.00 Architectural Coating 20 0 20 0 0.00 2,394.09 29,661.35 County On-road Gallons 11,054,467 2024 0.2683% TOTAL OFF-SITE MOBILE GALLONS CONSUMED DURING CONSTRUCTION WORKER TRIPS VENDOR TRIPS HAULING TRIPS 24.90284233 8.343886151 8.343886151 Artis Senior Living Project Energy Calculations Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Fuel Consumption Rate (gallons per hour) Duration (total hours/day)# days Total Fuel Consumption (gallons) Demolition Rubber Tired Dozers 2 8 367 0.40 5.872 16 24 2254.85 Demolition Excavators 3 8 36 0.38 0.5472 24 24 315.19 Demolition Concrete/Industrial Saws 1 8 33 0.73 0.9636 8 24 185.01 Grading Graders 1 8 148 0.41 2.4272 8 44 854.37 Grading Excavators 1 8 36 0.38 0.5472 8 44 192.61 Grading Tractors/Loaders/Backhoes 3 8 84 0.37 1.2432 24 44 1312.82 Grading Rubber Tired Dozers 1 8 367 0.40 5.872 8 44 2066.94 Building Construction Forklifts 3 8 82 0.20 0.656 24 391 6155.90 Building Construction Generator Sets 1 8 14 0.74 0.4144 8 391 1296.24 Building Construction Cranes 1 7 367 0.29 4.2572 7 391 11651.96 Building Construction Welders 1 8 46 0.45 0.828 8 391 2589.98 Building Construction Tractors/Loaders/Backhoes 3 8 84 0.37 1.2432 24 391 11666.19 Paving Pavers 2 8 81 0.42 1.3608 16 24 522.55 Paving Paving Equipment 28 89 0.36 1.2816 16 24 492.13 Paving Rollers 2 8 36 0.38 0.5472 16 24 210.12 Architectural Coating Air Compressors 1 6 37 0.48 0.7104 6 20 85.25 Total: 41,852.13 Notes: Fuel Consumption Rate = Horsepower x Load Factor x Fuel Consumption Factor Where: Fuel Consumption Factor for a diesel engine is 0.04 gallons per horsepower per hour (gal/hp/hr) and a gasoline engine is 0.06 gal/hp/hr. Source: Refer to CalEEMod outputs for assumptions used in this analysis. Addendum to the Artis Senior Living Project IS/MND April 2024 City Arcadia Attachment B ATTACHMENT B Trip Generation Analysis 1 | Page TECHNICAL MEMORANDUM To: Edwin Arreola, City of Arcadia From: Carla Dietrich, Michael Baker International CC: Madonna Marcelo, Michael Baker International Date: March 21, 2024 Subject: Addendum to the Artis Senior Assisted Living Project Trip Generation Analysis Project Background On August 18, 2020, the City of Arcadia City Council adopted a Mitigated Negative Declaration for the Artis Senior Living Project, which was proposed at the southeastern corner of the intersection of Colorado Boulevard and Michillinda Avenue at 1150 West Colorado Boulevard in the City of Arcadia. The Artis Senior Living Project involved the demolition of an approximately 13,000-square-foot building (previously occupied by a Coco’s Bakery and Restaurant) and the development of a new two-story, 44,192-square-foot senior/assisted living care facility with 80 rooms and on-site amenities (Approved Project). The Project Applicant, O&I Development, LLC, is now proposing to develop the Project site with a new 107,706-square-foot, three-story building which would have the same use as the Approved Project and constitute the Revised Project. In considering whether to approve the Revised Project, the City, as the lead agency pursuant to the California Environmental Quality Act (CEQA), is required to consider the environmental consequences of the Revised Project as compared to those of the Approved Project. Therefore, this addendum assesses the trip generation analysis of the Revised Project as compared to the Approved Project using the same analysis process of evaluating the Project trip generation using the Institute of Transportation Engineer’s (ITE) Trip Generation Manual, 10th Edition. Project Description The Revised Project proposes the construction of a 107,706 square-foot building with 100 units of varying size including studio, one-bedroom, and two-bedroom units for assisted living and private and shared studios for memory care. The 100 units are proposed to accommodate 114 beds. As with the Approved Project, the Revised Project would support assisted living and memory care services, the latter of which would entirely be dedicated to people afflicted with Alzheimer’s disease and related memory disorders. Exhibit A-1 (attached) shows the proposed site plan. Previous Approved Project Finding The Approved Project trip generation analysis determined a minimal change in the number of site trips entering and exiting the site at the W. Colorado Boulevard driveway. It was anticipated that these minimal changes in site trips would have had a negligible impact on site driveway and nearby intersection operations. It should be noted that the Coco’s Bakery and Restaurant was operational when the Approved Project trip generation analysis was initiated and thus an existing trip credit was applied as part of that analysis. 2 | Page Revised Project Trip Generation Applicable Trip Credits Trip credits may be applied to account for certain conditions including current operational uses located at the proposed site. Table 1 details the type of trip credits which were considered during this study. Table 1: Trip Credit Summary Item Project Condition Credit Applied? Existing Active Land Use While the site was occupied by an operational Coco’s Bakery and Restaurant during the Approved Project analysis, the restaurant is no longer operational. A conservative approach was taken and a trip credit was not applied for the Revised Project trip generation analysis. No Internal Trip Reduction Singular land use proposed which is not consistent with internal trip reductions. No Pass-by Trip Reduction Land use not consistent with pass-by trips. No Project Trips Trip generation analysis was conducted for the weekday daily, AM Peak Hour, and PM Peak Hour time periods. The ITE Trip Generation Manual, 10th Edition published in 2017, was the source of the project trip generation rates, as was the case for the Approved Project analysis. Table 2 summarizes the trip generation rates for the Assisted Living use (Land Use Code 254). It should be noted that the planned Project includes amenities for residents including a beauty salon, a fitness facility, and a restaurant. These uses are ancillary to the care facility and will be available for use by the residents rather than for commercial purposes or outside users. Ancillary uses are accounted for in the Land Use Code 254 trip generation rates. Table 2: Trip Generation Rates Land Use ITE Code Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Total In Out Assisted Living 254 2.6 / bed 50% 50% 0.19 / bed 63% 37% 0.26 / bed 38% 62% Source: Institute of Transportation Engineer’s Trip Generation Manual, 10th Edition. The project trips estimated for the proposed assisted living facility Revised Project are shown in Table 3. As shown, the estimated new trips for an assisted living facility with 114 beds is 296 daily trips, 22 AM peak hour trips and 30 PM peak hour trips. Table 3: Estimated Number of Project Trips (Revised Project) Land Use ITE Code Intensity Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Total In Out Assisted Living 254 114 beds 296 148 148 22 14 8 30 11 19 3| Page Trip Distribution/Assignment The Revised Project facility will have two access points (see Exhibit 1). One driveway will provide full access along W. Colorado Boulevard and the second driveway will provide right-in/right-out access along Michillinda Avenue. While the Approved Project only had one site driveway which was located on W. Colorado Boulevard, the driveway locations for the Revised Project are consistent with the two existing Coco’s Bakery and Restaurant driveways.Exhibit 2 graphically shows the anticipated distribution patterns for the proposed Assisted Living facility with two driveways and Exhibit 3 shows the anticipated site trips for the Revised Project at each of the site driveways. Exhibit 1: Revised Project Site Access Exhibit 2: Revised Project Trip Distribution Mi c h i l l i n d a A v e Driveway #2 – Right-In/Right-Out Driveway #1 – Full Access Legend X% (X%)AM Peak Hour (PM Peak Hour) Entering Distribution Percentages X% (X%) AM Peak Hour (PM Peak Hour) Exiting Distribution Percentages25% (25%) Mi c h i l l i n d a A v e 10 % ( 1 0 % ) 60% (60%) 4| Page Exhibit 3: Revised Project Site Trip Assignment Table 3 summarizes the total site trips at each of the site driveways. Here are the key findings: x Revised Project – It is anticipated that the Revised Project will add no more than 16 site trips to each of the two site driveways during each of the peak hours. x Comparison of the Revised Project to the Approved Project – A comparison of site trips between the Revised Project to the Approved Project indicates that the Revised Project will add 17 or fewer site trips to each of the site driveways during each of the peak hours. It should be noted that the Approved Project site trips were adjusted by applying a trip credit for the Coco’s Bakery and Restauranttrips. Since the restaurant closed between the time of the original evaluation of the Approved Project and this evaluation of the Revised Project, the Coco’s Bakery and Restaurant trip credit was no longer applied to provide a conservative estimate.If the trip credit had been accounted for in this analysis of the Revised Project, the additional site trips added under the Revised Project would be even fewer. Table 3: Estimated Number of Project Trips Site Driveway Intersection Total Site Trips Revised Project Approved Project1 Comparison AM Peak Hour PM Peak Hour AM Peak Hour PM Peak Hour AM Peak Hour PM Peak Hour Driveway #1 – W. Colorado Blvd 13 16 1 -1 +12 +17 Driveway #2 – Michillinda Ave 10 16 Did Not Exist +10 +16 Total 23 32 1 -1 +22 +33 Note:1) Approved Project site trips include trip credit from previous Coco’s Bakery and Restaurant use (Exhibit 4 from Artis Senior Assisted Living Facility Trip Generation Analysis technical memorandum dated December 17, 2019). 5 (11) 4 (3) Mi c h i l l i n d a A v e Legend X (X)AM Peak Hour (PM Peak Hour) Entering Site Trips X (X) AM Peak Hour (PM Peak Hour) Exiting Site Trips 1( 2 ) 5 | Page Additional Trip Generation Analysis As noted above, the analysis utilized trip rates from the ITE Trip Generation Manual, 10th Edition published in 2017. This was the source of the project trip generation rates for the Approved Project analysis. An updated Trip Generation Manual (11th Edition) was published after the Approved Project analysis was completed. While the use of the 10th Edition is appropriate for the comparison to the Approved Project since it was the previously approved method, an additional comparison was conducted using the 11th Edition. Table 4 provides the trip rates and Table 5 provides the estimated trips for both editions of the manual. As shown, the daily, AM Peak Hour, and PM Peak Hour rates included 11th Edition of the manual are the same or lower than the 10th Edition rates. Therefore, the difference in the estimated Project trips using both editions of the manual are negligible. Table 4: Comparison of Trip Generation Manual Rates Land Use ITE Code Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Total In Out 10th Edition Assisted Living 254 2.6 / bed 50% 50% 0.19 / bed 63% 37% 0.26 / bed 38% 62% 11th Edition Assisted Living 254 2.6 / bed 50% 50% 0.18 / bed 60% 40% 0.24 / bed 39% 61% Table 5: Comparison of Trip Generation Manual Estimated Trips Land Use ITE Code Intensity Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Total In Out 10th Edition Assisted Living 254 114 beds 296 148 148 22 14 8 30 11 19 11th Edition Assisted Living 254 114 beds 296 148 148 21 12 9 27 11 16 Difference 0 0 0 -1 -2 +1 -3 0 -3 Findings It is estimated that the Revised Project will add no more than 16 new peak hour site trips to each of the site driveways during each of the peak hours. A comparison between the Approved Project and the Revised Project again shows a minimal increase in traffic due to the Revised Project (no more than 17 peak hour trips at each of the site driveways). These additional trips are equivalent to an average of no more than 1 trip every 3½ minutes. It is anticipated that these minimal changes in site trips would have a negligible impact on the area intersections. Additionally, if the Coco’s Bakery and Restaurant trip credit had been taken in this analysis of the Revised Project, the additional site trips added under the Revised Project would be even fewer. The trip comparison utilized the 10th Edition of the ITE Trip Generation Manual to be consistent with the Approved Project. An additional comparison was conducted using the 11 th Edition of the Trip Generation Manual which was published after the Approved Project analysis was conducted. The daily, AM Peak Hour, and PM Peak Hour rates included 6 | Page 11th Edition of the manual for the Assisted Living use are the same or lower than the 10th Edition rates. Therefore, the difference in the estimated Project trips using both editions of the manual are negligible. Additionally, after the Approved Project trip generation technical memorandum, the City-adopted the City of Arcadia Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (August 2020). The guidance in that document states that a Traffic Study with Level of Service analysis shall be required for a proposed project when either the AM or PM peak hour trip generation for the proposed development is expected to exceed 100 vehicle trips and for projects that will add 51 or more trips during either the AM or PM peak hour to any intersection. While these guidelines were not adopted at the time of the original analysis, it is interesting to note that the Revised Project generates only a small fraction of the current trip thresholds requiring a Level of Service Traffic Study. Also, after the Project was analyzed, the CEQA transportation metric changed from Level of Service to Vehicle Miles Traveled (VMT). While VMT is not required in this analysis, it should be noted that the City of Arcadia Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (August 2020) identifies Assisted Living Facilities as one of the types of land uses under the VMT Project Type Screening criteria. Land uses of this type can be presumed to have a less-than-significant impact absent substantial evidence to the contrary based on those guidelines. 7 | Page Attachments Exhibit A-1: Revised Project Site Plan Source: b.hills architecture. California Environmental Quality Act INITIAL STUDY Artis Senior Living Project Lead Agency: City of Arcadia 240 W. Huntington Drive Arcadia, CA 91007 (626) 574-5422 Contact: Vanessa Quiroz, Associate Planner Prepared by: 3760 Kilroy Airport Way Suite 270 Long Beach, CA 90806 Office: (562) 200-7165 Fax: (562) 200-1766 Artis Senior Housing Project Draft Initial Study Page i April 2020 Table of Contents SECTION A. Environmental Checklist Form .......................................................................... 1 SECTION B. Environmental Factors Potentially Affected .................................................... 20 SECTION C. Determination................................................................................................... 21 SECTION D. Evaluation of Environmental Impacts ............................................................. 22 I. Aesthetics ....................................................................................................................................... 22 II. Agriculture and Forestry Resources ........................................................................................... 25 III. Air Quality ...................................................................................................................................... 28 IV. Biological Resources ..................................................................................................................... 34 V. Cultural Resources ........................................................................................................................ 40 VI. Energy ............................................................................................................................................. 42 VII. Geology and Soils.......................................................................................................................... 45 VIII. Greenhouse Gas Emissions ........................................................................................................ 51 IX. Hazards and Hazardous Materials .............................................................................................. 56 X. Hydrology and Water Quality ..................................................................................................... 61 XI. Land Use and Planning ................................................................................................................ 67 XII. Mineral Resources ......................................................................................................................... 69 XIII. Noise ............................................................................................................................................... 70 XIV. Population and Housing .............................................................................................................. 77 XV. Public Services ............................................................................................................................... 78 XVI. Recreation ....................................................................................................................................... 80 XVII. Transportation/Traffic ................................................................................................................. 81 XVIII. Tribal Cultural Resources ............................................................................................................. 85 XIX. Utilities and Service Systems ....................................................................................................... 89 XX. Wildfire ........................................................................................................................................... 94 XXI. Mandatory Findings of Significance ........................................................................................... 95 SECTION E. List of Mitigation Measures ............................................................................. 97 SECTION F. References ...................................................................................................... 103 Artis Senior Housing Project Draft Initial Study Page ii April 2020 List of Tables Table III-1 Short-Term Construction Emissions ................................................................................. 31 Table III-2 Long-Term Operational Air Emissions ............................................................................ 32 Table III-3 Localized Significance of Construction Emissions.......................................................... 33 Table VI-1 Project and Countywide Energy Consumption ............................................................... 43 Table VIII-1 Estimated Greenhouse Gas Emissions ............................................................................. 52 Table VIII-2 Project Consistency with the 2017 CARB Scoping Plan ................................................ 54 Table VIII-3 Project Consistency with the 2016-2040 RTP/SCS ........................................................ 55 Table XIII-1 Noise Measurements ............................................................................................................ 71 Table XIII-2 Maximum Noise Levels Generated by Construction Equipment ................................. 71 Table XIII-3 Maximum Noise Levels Generated by Parking Lots....................................................... 74 Table XIII-4 Typical Vibration Levels for Construction Equipment .................................................. 76 Table XVII-1 Estimated Number of Project Trips .................................................................................. 83 Table XIX-1 Water Consumption and Wastewater Generation Estimatesa ....................................... 91 Table XIX-2 Solid Waste Generation Estimates ..................................................................................... 93 List of Figures Figure A-1 Regional Location Map ............................................................................................................. 6 Figure A-2 Project Location Map ................................................................................................................ 7 Figure A-3 Project Site Overlay Zones ....................................................................................................... 8 Figure A-4 North Building Elevations ........................................................................................................ 9 Figure A-5 South Building Elevations ...................................................................................................... 10 Figure A-6 Eastern And Southern Parking And Landscaping Areas ................................................... 11 Figure A-7 Western Parking And Landscaping Areas ............................................................................ 12 Figure A-8 Existing Project Site Entry And Exit Points ........................................................................ 13 Figure A-9 Proposed Site Plan ................................................................................................................... 14 Figure A-10 Proposed Elevations North And South ............................................................................... 15 Figure A-11 Proposed Elevations East And West .................................................................................... 16 Figure A-12 Conceptual Project Rendering ............................................................................................... 17 Figure A-13 Proposed Landscape Plan ....................................................................................................... 18 Figure A-14 Aerial View Of The Project Site And Surroundings ........................................................... 19 Artis Senior Housing Project Draft Initial Study Page iii April 2020 Appendices Appendix A Protected Tree Report Appendix B Air Quality/Greenhouse Gas/Energy Worksheets Appendix C Cultural Resources Identification Memorandum Appendix D Noise Spreadsheets and Modeling Outputs Appendix E Project Trip Generation Analysis Artis Senior Housing Project Draft Initial Study Page iv April 2020 7KLVSDJHLQWHQWLRQDOO\OHIWEODQN    Artis Senior Housing Project Draft Initial Study Page 1 April 2020 SECTION A. ENVIRONMENTAL CHECKLIST FORM 1. Project Title: Artis Senior Living Project 2. Lead Agency Name and Address: City of Arcadia 240 W. Huntington Drive Arcadia, CA 91007 3. Contact Person and Phone Number: Vanessa Quiroz, Associate Planner/(626) 574-5422 4. Project Location: As shown in Figure A-1, Regional Location Map, the City of Arcadia is located in the central San Gabriel Valley area in the eastern portion of Los Angeles County. As shown in Figure A-2, Project Location Map, the Project Site is located at the southeastern corner of the intersection of Colorado Boulevard and Michillinda Avenue at 1150 West Colorado Boulevard, Arcadia, CA 91007. The Project Site comprises Los Angeles County Assessor’s Parcel Number 5776-001-012. 5. Project Sponsor’s Name and Address: Artis Senior Living of Arcadia, LLC 1651 Old Meadow Road, Suite 100 McLean, VA 22102 6. General Plan Designation: Commercial 7. Zoning: General Commercial (C-G) with an Architectural Design Overlay and an Automobile Parking Overlay 8. Description of Project: Existing Conditions The proposed Project Site is designated in the City’s General Plan as Commercial with a corresponding zoning of C-G, General Commercial. The C-G Zone is intended to provide areas for the development of retail, offices, restaurants, and service uses. The Project Site is included within two municipal overlay zones, the Architectural Design Overlay Zone and the Automobile Parking Overlay Zone. As shown in Figure A-3, Project Site Overlay Zones , these overlay zones are limited to the Project Site, with the Architectural Design Overlay Zone covering the central and northwestern portion of the Project Site and the Automobile Parking Overlay Zone covering the southern and eastern portions of the Project Site. The Architectural Design Overlay Zone states that various building design characteristics (such as building exterior materials, roof pitch, window size, landscaping, and automobile parking area) shall be subject to Planning Commission review and approval. Further, the Architectural Design Overlay Zone states that only one free-standing sign shall be permitted and located within 100 feet of the northern and western property lines, the maximum building height shall Artis Senior Housing Project Draft Initial Study Page 2 April 2020 not reach 30 feet above ground level, and no structure erected or permitted shall exceed 19,500 square feet of ground floor area.1,2 The Automobile Parking Overlay Zone restricts the overlay area to ground level parking uses The Project Site consists of 2.79 acres of developed land in the northwestern portion of the City of Arcadia. The Project Site is located on the southeastern corner of the Colorado Boulevard and Michillinda Avenue intersection, immediately south of Interstate 210 (I-210/ Foothill Freeway). The Project Site contains an existing Coco’s Bakery and Restaurant, which was constructed in 1976. The existing Coco’s, which comprises 13,088 square feet in total floor area, is a rectangular, one-story building located in the center of the Project Site. The building is surrounded on all sides by a surface parking lot, with two driveway locations, one at the northeastern corner of the Project Site along Colorado Boulevard and another at the southwestern corner of the Project Site along Michillinda Avenue. Mature eucalyptus trees flank the western and eastern sides of the Coco’s building. Additionally, there are decorative shrubs and turf along the northern, eastern, and western façades of the building, with one mature fern pine near the northeastern corner of the building. Currently, there is a mix of trees along the perimeter of the Project Site, serving as a landscape buffer between the Project Site and neighboring streets to the north and west and the residential neighborhoods to the east and south. The parking lot contains pole-mounted security lights, concrete bollards with chains that divide the parking lot on the south side of the lot, and landscape islands with decorative shrubs. Architectural lighting is also mounted along the edge of the roof of the northern façade and on the four corners of the roof of the Coco’s building and is directed inwardly. This roof-mounted lighting illuminates the Coco’s sign mounted above the building entrance on the north elevation and creates visual interest by illuminating the gently pitched roof line. Photos of the Project Site’s existing conditions are shown in Figures A-4 through A-8. The Colorado Boulevard and Michillinda Avenue frontages are both improved with a sidewalk, curb, gutter, and three streetlights each, with a sidewalk parkway comprising a strip of turf grass. Each frontage is characterized by decorative ground cover; mature trees; a short, white-painted cinderblock wall; and decorative shrubs located between the sidewalk and the property line. A block and wood sign for Coco’s (and The Oak Tree Room inside Coco’s) is located at the northwestern corner of the Project Site. Project Characteristics To accommodate the Proposed Project, the Coco’s building would be demolished, and associated landscaping and surface parking lot would be removed. However, the majority of the trees along the perimeter of the Project Site would be retained and incorporated into the Proposed Project’s landscaping plan. As shown in Figure A-9, Proposed Site Plan, the Proposed Project would develop a W-shaped senior living facility, which would support memory care and assisted living services that would entirely be dedicated to people afflicted with Alzheimer’s disease and related memory disorders. The facility would comprise a new two-story 44,192-square-foot building with 80 senior housing units; each unit, which would 1 City of Arcadia Resolution No. 4440, signed and approved July 2, 1974. 2 City of Arcadia Ordinance No. 1510, signed and approved July 16, 1974. Artis Senior Housing Project Draft Initial Study Page 3 April 2020 range in size generally between 216 square feet and 302 square feet, would primarily consist of a bed and a private bathroom with a shower. The first floor of the proposed building would contain 40 senior housing units, a lobby, offices, resident dining rooms, storage, and several large and small activities rooms and common spaces within 23,767 square feet of floor area, while the second floor of the proposed building would contain 40 units of senior housing, as well as dining rooms and activities room and common space, within 20,425 square feet of floor area. The Proposed Project would also include decorative landscaping, private walking paths, and an outdoor plaza on the west and south sides of the Project Site. The proposed building would extend to 37.5 feet in height. As shown in Figures A-10 and A-11, the proposed structure would feature a traditional/Craftsman-style design with varied massing and materials with articulation on each of the building façades to increase visual interest and avoid flat, street-facing surfaces. The moderately pitched roof would be made of black walnut-colored asphalt shingles and would contain recessed, flat centers, which would screen mechanical equipment, such as heating and air conditioning equipment and exhaust fans, from view from the street. The elevations would feature windows with exterior shutters alongside brick and alternating vertical and horizontal cement fiber board siding. The design would include decorative features, such as trellises on the north, east, and west elevations, as well as columns and decorative railing at the front and rear entrances. An 8-foot-high wooden fence, with a decorative wooden topper, would enclose the southern portion of the Project Site, which would include a gazebo, lawn, outdoor plaza, and walking paths described above. This fence would connect to the northwestern and northeastern corners of the building and extend to the southern property line. There is one gate with a Knox Box that connects the walkways within the fenced enclosure to the parking area on the east side of the Project Site. Two gated pathways with Knox Boxes would connect the enclosed walking paths to Michillinda Avenue on the west side of the Project Site. The majority of the building would extend to approximately 30 feet in height, with the front entrance, located in the center of the building, extending to 37.5 feet in height. The building would be topped with a small, decorative cupola, which would extend to approximately 40 feet, 10 inches in height. A conceptual rendering of the Proposed Project is displayed in Figure A-12. The Proposed Project would include multiple new sources of light, including pole-mounted LED security lighting in parking areas and the passenger drop-off area; path lighting on internal walkways; accent lighting over building doorways; and a lighted sign located on the northwest corner of the Project Site. Vehicle parking would include 55 regular parking stalls and 4 parking stalls that comply with the requirements of the Americans with Disabilities Act (ADA). Vehicular access to the proposed building would be from a single ingress/egress point on Colorado Boulevard, located at an existing ingress/egress point for the Project Site. A circular drive in front of the proposed building’s entrance would accommodate passenger loading and unloading. A separate loading dock for materials and food deliveries would be located near the Project Site’s driveway at the northeastern corner of the proposed building. Directly north of the loading space would be the trash enclosure and an emergency generator for the senior care facility. The exterior finishes and materials of the enclosures would match the senior care facility. The Artis Senior Housing Project Draft Initial Study Page 4 April 2020 enclosure to the trash area and emergency generator would stand between 8 and 12 feet in height. The majority of trees along the perimeter of the Project Site would be preserved in place to continue to form a vegetative screen between the Project Site and the residential uses to the east and south. The proposed building would be surrounded by landscaping, including drought-tolerant shrubs and ground cover, flower gardens, decorative trees, a lawn area/outdoor plaza with a gazebo, and a meandering concrete walkway with connections through locked gates to the existing sidewalks on Michillinda Avenue and Colorado Boulevard. The existing curb, gutter, and sidewalks along the Project Site’s Colorado Boulevard and Michillinda Avenue frontages would be replaced as part of the Proposed Project. The public right-of-way along the Project Site’s Colorado Boulevard frontage would be widened to 12 feet in width, which would require a four-foot dedication from the Project Site, as shown in Figure A-9. Additional decorative trees would be planted in the parking area to provide shade and additional screening from adjacent uses. A detailed landscape plan is available as Figure A-13, Proposed Landscape Plan. The Proposed Project would require the following City approvals: x Adoption of the IS/MND x Zone Change: To revoke the existing Architectural Design (D) Overlay Zone and Automobile Parking (P) Overlay Zone from the Project Site; x Architectural Design Review Approval; x Conditional Use Permit to allow for the development of the Proposed Project in a C- G Zone; x Tree Encroachment Permit; and x Minor Administrative Modification for the request to exceed the maximum permitted fence height of 6 feet. 9. Surrounding Land Uses and Setting: The Project Site is located in a fully urbanized part of the City of Arcadia, where the built environment consists of a mixture of single-family residential and commercial uses to the east in the City of Pasadena, and I-210 to the north, across the street from the Project Site. Colorado Avenue is a four-lane, east-west running roadway with a center turn lane, classified as a Secondary Travel Corridor by the Arcadia General Plan Circulation and Infrastructure Element. Michillinda Avenue is a four-lane, north-south running roadway that forms the western boundary of the City of Arcadia. Land uses west of Michillinda Avenue are located in East Pasadena, a neighborhood in unincorporated Los Angeles County. Figure A-14, Aerial View of the Project Site and Surroundings, provides a view of the local land use pattern in the vicinity of the Project Site. These surrounding land uses include one-level, detached, single-family homes to the east and south, which were generally constructed between the 1930s and 1970s; a gasoline station with a convenience store and a single-family home across Michillinda Avenue to the west; an approximately 40-foot-high Artis Senior Housing Project Draft Initial Study Page 5 April 2020 commercial building to the northwest; and mature trees and I-210 across Colorado Boulevard to the north. 10. Other Public Agencies Whose Approval is Required: x California Department of Social Services (DSS) x Division of the State Architect 11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?3 Yes. The City sent notification letters to the Gabrielino-Tongva Tribe and the Gabrieleño Band of Mission Indians—Kizh Nation on January 10, 2020. On January 23, 2020, Andrew Salas, of the Gabrieleño Band of Mission Indians – Kizh Nation submitted a formal request to consult with the City. The tribal consultation process commenced on April 1, 2020 via a conference call attended by Andrew Salas and Matt Teutimez of the Gabrileño Band of Mission Indians, Lisa Flores and Vanessa Quiroz of the City of Arcadia, and Madonna Marcelo and John Bellas of Michael Baker International (the City’s environmental consultant). Please refer to Section XVIII, Tribal Cultural Resources, of this Initial Study for a discussion of the results of the consultation. 3 NOTE: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See Public Resources Code section 21080.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality. FIGURE A-1 Regional Location Map G: \ P r o j e c t s \ M a r g o \ A r c i a d a \ F i g u r e 1 . m x d ( 1 0 / 2 2 / 2 0 1 9 ) Map Detail Los Angeles County Legend Project Site 03 MILES ^ Project Site ^ Source: ESRI streetmap FIGURE A-2 Project Location Map %&g( W Orange Grove Ave Mi c h i l l i n d a A v e Foothill Blvd G: \ P r o j e c t s \ M a r g o \ A r c i a d a \ F i g u r e 2 . m x d ( 1 0 / 2 3 / 2 0 1 9 ) 0800 Feet Project Site Source: ESRI World Imagery Service Ro s e m e a d B l v d Colorado Blvd FIGURE A-9 Proposed Site PlanNot to Scale Source: Gateway Engineering, Inc., March 2020 Artis Senior Housing Project Draft Initial Study Page 20 April 2020 SECTION B. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. ܆ Aesthetics ܆ Agriculture and Forestry Resources ܆ Air Quality ܆ Biological Resources ܆ Cultural Resources ܆ Energy ܆ Geology/Soils ܆ Greenhouse Gas Emissions ܆ Hazards & Hazardous Materials ܆ Hydrology/Water Quality ܆ Land Use/Planning ܆ Mineral Resources ܆ Noise ܆ Population/Housing ܆ Public Services ܆ Recreation ܆ Transportation/Traffic ܆ Tribal Cultural Resources ܆ Utilities/Service Systems ܆ Wildfire ܆ Mandatory Findings of Significance For the evaluation of potential impacts, the questions in the Initial Study Checklist are stated and an answer is provided according to the analysis undertaken as part of the Initial Study. The analysis considers the long-term, direct, indirect, and cumulative impacts of the project. To each question, there are four possible responses: ƒ No Impact. The project would not have any measurable environmental impact on the environment. ƒ Less Than Significant Impact. The project would have the potential for impacting the environment, although this impact would be below established thresholds that are considered to be significant. ƒ Less Than Significant Impact With Measures Incorporated . The project would have the potential to generate impacts which may be considered a significant effect on the environment, although measures or changes to the development’s physical or operational characteristics can reduce these impacts to levels that are less than significant. ƒ Potentially Significant Impact. The project would have impacts which are considered significant, and additional analysis is required to identify measures that could reduce these impacts to less than significant levels. Artis Senior Housing Project Draft Initial Study Page 22 April 2020 SECTION D. EVALUATION OF ENVIRONMENTAL IMPACTS I. Aesthetics Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact AESTHETICS: Except as provided in Public Resources Code Section 21099, would the project: a) Have a substantial adverse effect on a scenic vista? ܆ ܆ ܈ ܆ b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? ܆ ܆ ܈ ܆ c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? ܆ ܆ ܈ ܆ d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? ܆ ܆ ܈ ܆ Discussion The Proposed Project is not classified as a “transit-oriented infill project” as set forth in Section 21099 of the Public Resources Code (PRC), and, thus, the provisions of that section do not apply to this Project. a) Would the project have a substantial adverse effect on a scenic vista? Less Than Significant Impact. A scenic vista is defined as a publicly accessible, prominent vantage point that provides expansive views of highly valued landscapes or prominent visual elements composed of man-made or natural features. Michillinda Avenue and North Altura Road, which both provide views of the San Gabriel Mountains for northbound travelers, could be considered public vantage points that provide a view of a highly valued landscape (i.e., the San Gabriel Mountains); however, the mountain views are distant, not expansive, and are extensively obstructed by existing development, utilities, and landscaping. Further, because the majority of the City is relatively flat, including the area surrounding the Project Site, the City of Arcadia General Plan does not identify any prominent vantage points from which the public can view an expansive scenic vista within or beyond the City.4,5 As discussed in the Project Description of this Initial Study, the Project Site is located in a highly urbanized area, dominated by features of a built environment. The surrounding development includes a mixture of building sizes, styles, and forms, and includes single-family residential, low- and mid-rise commercial, and freeway infrastructure. Many of the main arterial roadways in the City of Arcadia that 4 City of Arcadia, Arcadia General Plan Land Use and Community Design Element, November 2010. 5 City of Arcadia, Arcadia General Plan Parks, Recreation, and Community Resources Element, November 2010. Artis Senior Housing Project Draft Initial Study Page 23 April 2020 are oriented north and south provide views of the San Gabriel Mountains in the distance. As such, motorists traveling northbound on Michillinda Avenue (along the western boundary of the Project Site) and North Altura Road (one block east of the Project Site) have distant views of the San Gabriel Mountains, which begin approximately 1.9 miles north of the Project Site. Views of the mountains are partially obstructed by mature trees and existing development along both of these streets, I-210, and the overpass over Michillinda Avenue, as well as utility poles, traffic signals, and business signs on either side of Michillinda Avenue. As a result of these existing impediments, views of the San Gabriel Mountains are only available straight north and are obstructed to the northeast and northwest. In addition, because the proposed senior housing building would be set back approximately 106 feet from the Project Site’s eastern boundary and set back approximately 52 feet from Michillinda Avenue, the proposed building would not substantially impact the existing, limited mountain views available to motorists. Further, the existing restaurant building is approximately 20 feet in height and is surrounded by mature eucalyptus trees that extend to approximately 60 feet high. The majority of the Proposed Project would extend to approximately 30 feet in height, with the front entrance, located in the center of the building, extending to 37.5 feet in height (see Figures A-10 and A-11, which illustrate the Proposed Project’s building elevations and indicate building heights). The building would be topped with a small, decorative cupola, which would extend to approximately 40 feet, 10 inches in height. The existing eucalyptus trees on the Project Site are visible from North Altura Road, looking west over the existing single-family homes. The Proposed Project may also be visible from North Altura Road looking west over the existing single-family homes; however, the Proposed Project would not obstruct any existing views of the San Gabriel Mountains to the north from North Altura Road. Therefore, effects of the Proposed Project on scenic vistas would be less than significant. b) Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Less Than Significant Impact. The closest officially designated State scenic highway to the Project Site is part of the Angeles Crest State Scenic Highway, State Route 2 (SR-2), from near La Cañada- Flintridge north to the San Bernardino County line. This State scenic highway is approximately 8.5 miles northwest of the Project Site. The Arroyo Seco Historic Parkway (SR-110), between mileposts 25.7 and 31.9 in Los Angeles, is approximately 5 miles west of the Project Site. The distance between the Project Site and these officially designated scenic highways indicates that the Proposed Project would not be visible from a State scenic highway. Finally, I-210 north of SR-134 is designated as an eligible scenic highway; however, since the Project Site is approximately 5 miles west of this eligible scenic highway, the Proposed Project would not be visible from this viewshed. As such, the Proposed Project would not adversely affect the viewshed from a State scenic highway. There are a number of scenic resources on the Project Site. Although there are no rock outcroppings or historic buildings on the Project Site, the Project Site’s mature trees could be considered scenic resources because the City’s General Plan states that “Arcadia’s trees are a significant aesthetic and ecological resource” and are “one of the City’s real treasures,” distinguishing Arcadia from other cities in the vicinity.6 Specifically, mature trees of various species are located around the perimeter of the Project Site, nearly all of which are protected by the City of Arcadia, as is described in further detail in Section IV, Biological Resources, of this Initial Study. As stated in the Project Description of this Initial Study, these protected trees provide a visual barrier between the Proposed Project and 6 City of Arcadia, Arcadia General Plan Land Use and Community Design Element, November 2010, page 2-21. Artis Senior Housing Project Draft Initial Study Page 24 April 2020 surrounding uses and maintaining the existing visual character of the Project area.7 Therefore, because of the Project Site’s distance from the nearest officially designated scenic highway and the lack of impacts to scenic resources on the Project Site, the Proposed Project would have a less-than- significant impact on scenic resources, such as trees, rock outcroppings, or historic buildings within a State scenic highway. c) Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Less Than Significant Impact. The Proposed Project would be located in a fully urbanized area, where there is a variety of nonresidential and residential land uses and extensive urban infrastructure improvements (see Figure A-14, Aerial View of Project Site and Surroundings). For purposes of determining impact significance for projects within urbanized areas, a project is evaluated for whether it would conflict with applicable zoning or other regulations governing “scenic quality.” The term “scenic quality” is not specifically defined in the threshold language of Appendix G of the CEQA Guidelines. No applicable federal or State regulations pertain to aesthetic impact; however, the Proposed Project would need to comply with Arcadia Municipal Code regulations governing scenic quality for areas zoned General Commercial. The Project is consistent with the underlying General Commercial (C-G) zone because the development of a residential care facility is allowed with an approved Conditional Use Permit (CUP) from the City.8 However, the Project would require a zone change to remove an existing Architectural Design (D) Overlay Zone and an Automobile Parking (P) Overlay Zone from the Project Site. While the Proposed Project would conflict with the existing overlay zones covering the Project Site, the Proposed Project would be consistent with underlying City zoning upon approval of a CUP. Further, the Arcadia Development Code does not contain any specific zoning regulations that govern scenic quality other than the protected tree ordinances described in Section IV, Biological Resources, of this Initial Study. As stated above, all protected trees on the Project Site would be preserved in place, providing visual barriers between the Proposed Project and surrounding uses and maintaining the existing visual character of the Project vicinity, as presented in Figure A-13, Proposed Landscape Plan. Per the Protected Tree Report, available as Appendix A and further discussed in Section IV, Biological Resources, of this Initial Study, no mitigation measures to offset tree removals would be required as part of the Proposed Project.9 Therefore, the Proposed Project would be consistent with applicable zoning and other regulations governing scenic quality, and impacts would be less than significant. 7 Arbor Care, Inc., Protected Tree Report: Tree Survey, Encroachment, Protection and Mitigation 1150 West Colorado Boulevard, Arcadia, CA 91106, revised December 2019. 8 City of Arcadia, Arcadia Municipal Code Section 9102.03.020. 9 Arbor Care, Inc., Protected Tree Report: Tree Survey, Encroachment, Protection and Mitigation 1150 West Colorado Boulevard, Arcadia, CA 91106, revised December 2019. Artis Senior Housing Project Draft Initial Study Page 25 April 2020 d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Less Than Significant Impact. The Project Site is currently developed with an existing Coco’s building, which is surrounded by a surface parking lot and scattered landscaped areas. Existing sources of light on the Project Site include building security lights on the restaurant building and pole-mounted parking lot lights. The area surrounding the Project Site is highly urbanized and, therefore, is already impacted by nighttime lighting from streetlights along Colorado Boulevard and Michillinda Avenue, as well as traffic signals at the intersection of Colorado Boulevard and Michillinda Avenue, vehicle headlights, and existing parking lot and building security lights at the commercial and gasoline station uses across Michillinda Avenue from the Project Site. The residential neighborhoods south and east of the Project Site do not contribute substantial nighttime lighting to the Project vicinity, apart from residential security and landscape lighting, and overhead streetlights located along North Altura Road and Altura Terrace. The Proposed Project would contain multiple new sources of nighttime lighting, such as security lighting on internal walkways, overhead LED lights in the parking areas, and lights at building entrances, as well as accent lights along walking paths adjacent to landscaped areas and vehicle headlights from those entering and exiting the Project Site. The Proposed Project would be required to demonstrate compliance with Section 9103.01.120(D) of the Arcadia Development Code as part of the City’s design review process, which limits potential light and glare impacts by requiring that lights be directed downward and shielded/recessed to avoid spillage to adjacent properties and prohibits flashing or roof-mounted lights that are directed outward. This Arcadia Development Code section also prohibits light fixtures that are inappropriate for the scale, intensity, and height of the use they are serving. Further, the Project would be allowed one sign, the lighting of which would have to comply with City of Arcadia sign regulations.10 Additionally, the Project would not utilize glossy or reflective construction materials that would generate significant amounts of glare off-site. Therefore, the Project would not generate excessive light or glare, and by complying with lighting regulations in the Arcadia Development Code, would result in a less-than-significant impact on day or nighttime views in the Project area. II. Agriculture and Forestry Resources Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact AGRICULTURE AND FORESTRY RESOURCES: In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project: 10 City of Arcadia, Arcadia Municipal Code Article IX, Division 3, Section 9103.11, Signs. Artis Senior Housing Project Draft Initial Study Page 26 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? ܆ ܆ ܆ ܈ b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? ܆ ܆ ܆ ܈ c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? ܆ ܆ ܆ ܈ d) Result in the loss of forest land or conversion of forest land to non-forest use? ܆ ܆ ܆ ܈ e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? ܆ ܆ ܆ ܈ Discussion a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. As stated in the Project Description of this Initial Study, the Project Site is located in a fully urbanized part of the City of Arcadia, where the built environment consists of a mixture of single- family residences, commercial buildings, and major highway infrastructure. The Project Site is currently developed with a Coco’s restaurant, which is surrounded by a surface parking lot and ornamental landscaping. No agricultural uses or operations occur on-site or in the vicinity of the Project Site. Additionally, neither the Project Site nor the area surrounding it are mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide or Local Importance pursuant to the Farmland Mapping and Monitoring Program of the California Department of Conservation.11 Therefore, the Project would not convert farmland to a non-agricultural use, and no impact would occur. b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The Project Site is zoned as C-G (General Commercial) by the City and designated for Commercial in the City’s General Plan. Agricultural uses are not permitted on properties zoned C-G. 11 California Department of Conservation, California Important Farmland Finder, accessed November 8, 2019, https://maps.conservation.ca.gov/DLRP/CIFF/. Artis Senior Housing Project Draft Initial Study Page 27 April 2020 Further, neither the Project Site nor the surrounding area is subject to a Williamson Act contract.12 Therefore, the Project would not conflict with existing zoning for agricultural uses or a Williamson Act contract, and no impact would occur. c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? No Impact. The Project Site is zoned as C-G (General Commercial) by the City and designated for Commercial in the City’s General Plan. Accordingly, the Project Site does not include any forestland or timberland and is almost entirely covered by man-made, impervious surfaces (i.e., building and surface parking lot). Therefore, the Project would not conflict with existing zoning for, or cause rezoning of, forestland, timberland, or timberland zoned Timberland Production, and no impact would occur. d) Would the project result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The Project Site is located in a fully urbanized area and does not include any forestland or timberland. Therefore, the Project would not result in the loss or conversion of forestland to non- forest use, and no impact would occur. e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? No Impact. As stated in the response to Checklist Question II.c, above, the Project Site is fully urbanized and almost entirely covered by impervious surfaces. While the Proposed Project would alter the Project Site, resulting in a greater amount of pervious areas due to the increase in landscaped areas, the Project would not result in conversion of farmland to non-agricultural use or forestland to non- forest use, and no impact would occur. 12 California Department of Conservation, The California Land Conservation Act of 1965 2016 Status Report, December 2016. Artis Senior Housing Project Draft Initial Study Page 28 April 2020 III. Air Quality Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact AIR QUALITY: Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? ܆ ܆ ܈ ܆ b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? ܆ ܆ ܈ ܆ c) Expose sensitive receptors to substantial pollutant concentrations? ܆ ܆ ܈ ܆ d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? ܆ ܆ ܈ ܆ Discussion a) Would the project conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The City of Arcadia is located within the South Coast Air Basin (Basin), which is bounded by the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east and by the Pacific Ocean to the south and west. The South Coast Air Quality Management District (SCAQMD) has jurisdiction in the Basin, which has a history of recorded air quality violations and is an area where both State and federal ambient air quality standards are exceeded.13 Areas that meet ambient air quality standards are classified as attainment areas, while areas that do not meet these standards are classified as nonattainment areas. The air quality in the Los Angeles County portion of the Basin does not meet the ambient air quality standards for ozone (O 3), coarse particulate matter (PM10), fine particulate matter (PM2.5), and lead and is therefore classified as a nonattainment area for these pollutants.14 The SCAQMD is required to reduce emissions of air pollutants for which the Basin is in federal nonattainment (i.e., O3 and PM2.5). In order to reduce emissions, the SCAQMD adopted the 2016 Air Quality Management Plan (AQMP), which establishes a program of rules and regulations directed at reducing air pollutant emissions and achieving State and federal air quality standards.15 The 2016 AQMP is a regional and multiagency effort including the SCAQMD, the California Air Resources Board (CARB), the Southern California Association of Governments (SCAG), and the U.S. Environmental Protection Agency (USEPA). In addition to the AQMP, the SCAQMD regulates construction activities through Rule 403, which requires that excessive fugitive dust emissions be controlled by regular watering or other dust prevention measures, thus greatly reducing PM10 and PM2.5 concentrations. 13 South Coast Air Quality Management District, Final 2016 Air Quality Management Plan, March 2017. 14 South Coast Air Quality Management District, Final 2016 Air Quality Management Plan, March 2017. 15 South Coast Air Quality Management District, Final 2016 Air Quality Management Plan, March 2017. Artis Senior Housing Project Draft Initial Study Page 29 April 2020 The 2016 AQMP pollutant control strategies are based on the latest scientific and technical information and planning assumptions, including the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), updated emission inventory methodologies for various source categories, and SCAG’s latest growth forecasts.16 SCAG’s latest growth forecasts were defined in consultation with local governments and with reference to local general plans. Therefore, the SCAQMD considers projects that are consistent with the 2016 AQMP to also have less-than- significant cumulative impacts.17 Criteria for determining consistency with the 2016 AQMP are defined by the following indicators: Criterion 1: x The Proposed 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 attainment of air quality standards or the interim emissions reductions specified in the AQMP. Since this criterion pertains to pollutant concentrations, rather than to total regional emissions, an analysis of the Project’s pollutant emissions relative to localized pollutant concentrations is used as the basis for evaluating project consistency. As discussed in the response to Checklist Question III.c, below, localized emissions of CO, NOX, PM10, and PM2.5 generated by the Project would be less than significant. Therefore, the Proposed Project would not result in an increase in the frequency or severity of existing air quality violations. Because reactive organic gases (ROGs) are not a criteria pollutant, there is no ambient standard or localized threshold for ROGs. Due to the role ROGs play in O3 formation, it is classified as a precursor pollutant and only a regional emissions threshold has been established. Further, as discussed in the response to Checklist Question III.b, below, the Proposed Project would result in emissions below the SCAQMD thresholds. Therefore, the Proposed Project would not have the potential to cause or affect a violation of the ambient air quality standards. Finally, the Proposed Project would result in less-than- significant impacts with regard to localized emissions during Project construction and operation. As such, the Proposed Project would not delay the timely attainment of air quality standards or 2016 AQMP emissions reductions and, therefore, meets the first criterion for consistency with the 2016 AQMP. Criterion 2: x The Proposed Project will be consistent with the population, housing, and employment growth projections utilized in the preparation of the AQMP and will implement all feasible air quality mitigation measures. A project is consistent with the 2016 AQMP in part if it is consistent with the population, housing, and employment assumptions that were used in the development of the 2016 AQMP. In the case of the 2016 AQMP, the basis for the projections of air pollutant emissions include the Arcadia General Plan and SCAG’s RTP/SCS. The RTP/SCS also provides socioeconomic forecast projections of regional population growth. The Project proposes to construct a senior living facility and associated surface parking lot. The existing General Plan land use designation for the Project Site is Commercial, with a corresponding zoning of C- G, General Commercial. Further, the Project Site is within two municipal overlay zones, the Architectural 16 Southern California Association of Governments, 2016–2040 Regional Transportation Plan/Sustainable Communities Strategy, April 2016. 17 South Coast Air Quality Management District, SCAQMD Air Quality Significance Thresholds, March 2015. Artis Senior Housing Project Draft Initial Study Page 30 April 2020 Design overlay zone and the Automobile Parking overlay zone. While the Proposed Project would conflict with the existing overlay zones covering the Project Site, the Proposed Project would be consistent with the underlying City zoning upon approval of a CUP, as further discussed in response to Checklist Question XI.b, below. Therefore, the Proposed Project is consistent with the General Plan. The population, housing, and employment forecasts, which are adopted by SCAG’s Regional Council, are based on the local plans and policies applicable to the City. As the SCAQMD has incorporated these same projections into the 2016 AQMP, it can be concluded that the Proposed Project would be consistent with the projections. The Proposed Project would not require mitigation and would result in less-than-significant air quality impacts, as described in responses to Checklist Questions III.b through III.d, below. Further, compliance with all emissions reduction regulations established by the SCAQMD, such as Rule 403 controlling fugitive dust, would be required. As such, the Proposed Project meets the second AQMP consistency criterion. In conclusion, the Proposed Project would not result in a long-term impact on the region’s ability to meet State and federal air quality standards. As discussed above, the Proposed Project’s long-term influence would also be consistent with the SCAQMD’s and SCAG’s goals and policies and is, therefore, considered consistent with the 2016 AQMP. As such, impacts would be less than significant. b) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Less Than Significant Impact. The Project Site is located in the Basin, which is considered a nonattainment area for certain criteria pollutants. The Project would involve demolition, grading, and other construction activities, and would result in long-term operations at the Project Site; therefore, it would contribute to regional and localized pollutant emissions during construction (short-term) and Project occupancy (long-term). Further discussion of construction-related and operation-related emissions are provided below. Construction The Project involves construction activities associated with demolition, grading, paving, building construction, and architectural coating phases. It is anticipated that the Project would be constructed over approximately 19 months. Variables factored into estimating the total construction emissions include the level of activity, length of construction period, number of pieces and types of equipment in use, site characteristics, weather conditions, number of construction personnel, and the amount of materials to be transported on- or offsite. The analysis of daily construction emissions has been prepared utilizing the California Emissions Estimator Model (CalEEMod) version 2016.3.2.18 Refer to Appendix B, Air Quality/Greenhouse Gas/Energy worksheets, for the CalEEMod outputs and results. Table III-1 presents the anticipated daily short-term construction emissions associated with the Project. 18 South Coast Air Quality Management District, California Emissions Estimator Model (CalEEMod), version 2016.3.2. Artis Senior Housing Project Draft Initial Study Page 31 April 2020 Table III-1 Short-Term Construction Emissions Emissions Source Pollutant (pounds/day)a,b ROG NOX CO SO2 PM10 PM2.5 Year 1 4.38 49.34 32.32 0.07 5.53 3.26 Year 2 3.50 17.82 20.01 0.04 1.72 1.02 Year 3 3.48 1.35 2.37 0.00 0.23 0.11 Maximum Daily Emissions 4.38 49.34 32.32 0.07 5.53 3.26 SCAQMD Thresholds 75 100 550 150 150 55 Is Threshold Exceeded? No No No No No No Notes: ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SO 2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter a Emissions were calculated using CalEEMod, version 2016.3.2. b Modeling assumptions include compliance with SCAQMD Rule 403 which requires properly maintaining mobile and other construction equipment; replacing ground cover in disturbed areas quickly; watering exposed surfaces three times daily; covering stockpiles with tarps; watering all haul roads twice daily; and limiting speeds on unpaved roads to 15 miles per hour. Source: Refer to Appendix B for detailed model input/output data. Construction activities, such as land clearing and ground disturbance, are a source of fugitive dust emissions that may have a substantial, temporary impact on local air quality. Fugitive dust emissions vary substantially from day to day, depending on the level of activity, specific operations, and weather conditions, and would be short term, ceasing upon Project completion. As stated above, SCAQMD Rule 403 requires that excessive fugitive dust emissions be controlled by regular watering or other dust prevention measures. Adherence to SCAQMD Rule 403 would greatly reduce PM10 and PM2.5 concentrations. As shown in Table III-1, total PM10 and PM2.5 emissions would not exceed the SCAQMD thresholds during construction. Other construction-related exhaust emissions would result from the transport of machinery and supplies to and from the Project Site and emissions produced by equipment used on-site. As presented in Table III-1, construction equipment and worker vehicle exhaust emissions (SO2, CO, and NOx) would be below the established SCAQMD significance thresholds.19 In addition to gaseous and particulate emissions, the application of asphalt and surface coatings creates ROG emissions, which are O3 precursors. As required, all architectural coatings for the proposed structure would comply with SCAQMD Rule 1113, Architectural Coating, which provides specifications on painting practices and regulates the ROG content of paint. As shown in Table III-1, Project-related total daily construction emissions of particulate matter, equipment and vehicle exhaust, and ROG emissions would not exceed the SCAQMD significance thresholds. As such, air quality impacts would be less than significant. Operation Emissions during Project operation would be predominantly associated with motor vehicle use (mobile source emissions). To a lesser extent, area sources, such as the use of landscape maintenance equipment, and architectural coatings, as well as energy sources, such as non-hearth natural gas and 19 South Coast Air Quality Management District, SCAQMD Air Quality Significance Thresholds, March 2015. Artis Senior Housing Project Draft Initial Study Page 32 April 2020 electricity, would also contribute to overall emissions. The total daily operational emissions in winter and summer are displayed in Table III-2. Table III-2 Long-Term Operational Air Emissions Emissions Source Pollutant (pounds/day)a,b ROG NOX CO SOX PM10 PM2.5 Existing Coco’s Restaurant Emissions Area Source Emissions 0.33 0.00 0.01 0.00 0.00 0.00 Energy Emissions 0.09 0.81 0.68 0.00 0.06 0.06 Mobile Emissions 0.87 3.68 8.35 0.02 1.79 0.50 Total Daily Emissions2 1.29 4.49 9.04 0.02 1.85 0.56 Proposed Artis Senior Living Facility Emissions Area Source Emissions 1.30 1.27 7.13 0.01 0.13 0.13 Energy Emissions 0.03 0.22 0.10 0.00 0.02 0.02 Mobile Emissions3 0.39 1.95 5.26 0.02 1.53 0.42 Total Daily Emissions2 1.72 3.44 12.49 0.03 1.68 0.57 Total Net Daily Emissions (Proposed – Existing) 0.43 -1.05 3.45 0.01 -0.17 0.01 SCAQMD Threshold 55 55 550 150 150 55 Is Threshold Exceeded? No No No No No No Notes: ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter a Emissions were calculated using CalEEMod, version 2016.3.2. b The numbers may be slightly off due to rounding. Source: Refer to Appendix B for detailed model input/output data. As shown in Table III-2, the Project would generate a substantial reduction in mobile source emissions. This is because the Project would result in a net reduction of approximately 374 daily vehicle trips as compared with existing conditions (Coco’s Restaurant).20 This net reduction in vehicle trips is discussed further in Section XVII, Transportation/Traffic, of this Initial Study. Additionally, area source emissions, such as emissions generated from consumer products, architectural coatings, and internal combustion landscaping equipment, would result in a modest increase over existing conditions. As shown in Table III-2, the total daily emissions from mobile, area source, and energy emissions would not exceed SCAQMD thresholds for ROG, NO X, CO, SOX, PM10, or PM2.5. Thus, operational air quality impacts would be less than significant. c) Would the project expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact. Sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants. Examples of these sensitive receptors are residences, schools, hospitals, and daycare centers. CARB has identified the following groups of individuals as the most likely to be affected by air pollution: the elderly over 65, children under 14, athletes, and persons with cardiovascular and chronic respiratory diseases, such as asthma, emphysema, and bronchitis.21 In order to identify impacts to sensitive receptors, the SCAQMD recommends addressing localized significance thresholds (LSTs) for construction and 20 Michael Baker International, Artis Senior Assisted Living Facility Trip Generation Analysis, December 17, 2019. 21 South Coast Air Quality Management District, CEQA Air Quality Handbook, November 1993. Artis Senior Housing Project Draft Initial Study Page 33 April 2020 operations impacts (area sources only).22 The closest sensitive receptors are residences adjoining the Project Site to the east and south. These sensitive receptors may be potentially affected by air pollutant emissions generated during on-site construction activities Table III-3 presents the localized construction-related emissions for NOX, CO, PM10, and PM2.5 in comparison to the appropriate LST designated by SCAQMD. The localized emissions presented in Table III-3 are less than the emissions displayed in Table III-2 because localized emissions include only on-site emissions (i.e., from construction equipment and fugitive dust) and do not include off- site emissions (i.e., from hauling activities). As shown in Table III-3, the Project’s localized construction emissions would not exceed the LST with adherence to SCAQMD rules and requirements. Therefore, localized significance impacts from construction would be less than significant. Table III-3 Localized Significance of Construction Emissions Sourcea Pollutant (pounds/day) NOX CO PM10 PM2.5 Year 1b 46.40 30.88 5.20 3.16 Year 2c 15.62 16.36 0.81 0.76 Year 3d 1.30 1.81 0.07 0.07 Maximum Daily Emissions 46.40 30.88 5.20 3.16 SCAQMD Localized Significance Thresholde 128 953 7 5 Thresholds Exceeded? No No No No Notes: NOx = nitrogen oxide; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter a Modeling assumptions include compliance with SCAQMD Rule 403 which requires properly maintaining mobile and other construction equipment; replacing ground cover in disturbed areas quickly; watering exposed surfaces three times daily; covering stockpiles with tarps; watering all haul roads twice daily; and limiting speeds on unpaved roads to 15 miles per hour. b Year 1 grading phase emissions present the worst-case scenario for NOX, CO, PM10, and PM2.5. c Year 2 building construction phase emissions present the worst-case scenario for NO X, CO, PM10, and PM2.5. d Year 3 architectural coating phase emissions present the worst-case scenario for NOX, CO, PM10, and PM2.5. e The LST was determined using Appendix C of the SCAQMD Final Localized Significant Threshold Methodology guidance document for pollutants NOX, CO, PM10, and PM2.5. The LST was based on the anticipated daily acreage disturbance for construction (the thresholds for 2 acres were used), the distance to sensitive receptors (25 meters), and the source receptor area (SRA 9). Source: Refer to Appendix B for detailed model input/output data. Regarding operational emissions, SCAQMD states that LSTs would apply to the operational phase of a Proposed Project if the Project includes stationary sources or attracts mobile sources that may spend extended periods queuing and idling at the site (e.g., warehouse or transfer facilities).23 Because the Proposed Project does not include such uses, no long-term LST analysis is needed and operational LST impacts would be less than significant. 22 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, July 2008. 23 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, July 2008. Artis Senior Housing Project Draft Initial Study Page 34 April 2020 Therefore, because the Project would not exceed short-term or long-term LSTs, the Project would not expose sensitive receptors to substantial pollutant concentrations, and air quality impacts would be less than significant. d) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? Less Than Significant Impact. According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding.24 The Proposed Project does not include any uses identified by the SCAQMD as being associated with odors. Construction activities associated with the Project may generate other emissions and detectable odors from heavy-duty equipment exhaust and architectural coatings. However, construction-related emissions and odors would be short term in nature and cease upon Project completion. In addition, the Project would be required to comply with the California Code of Regulations, Title 13, Sections 2449(d)(3) and 2485, which minimizes the idling time of construction equipment either by shutting it off when not in use or by reducing idling time to no more than five minutes. This would further reduce the detectable odors from heavy-duty equipment exhaust. The Project would also be required to comply with the SCAQMD Regulation XI, Rule 1113 – Architectural Coatings, which would minimize odor impacts from ROG emissions during architectural coating. Any odor impacts to existing adjacent land uses would be short term and minimal. As such, the Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people, and impacts would be less than significant. IV. Biological Resources Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact BIOLOGICAL RESOURCES: Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? ܆ ܆ ܈ ܆ b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? ܆ ܆ ܆ ܈ 24 South Coast Air Quality Management District, CEQA Air Quality Handbook, November 1993. Artis Senior Housing Project Draft Initial Study Page 35 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? ܆ ܆ ܆ ܈ d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? ܆ ܈ ܆ ܆ e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? ܆ ܈ ܆ ܆ f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? ܆ ܆ ܆ ܈ Discussion a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Less than Significant Impact. The Project Site is located in a fully urbanized area where the built environment consists of a mixture of single-family residential and commercial buildings and major highway infrastructure. The Project Site is currently developed with a restaurant building, which is surrounded by surface parking and landscaping. As stated in the Project Description of this Initial Study, mature eucalyptus trees flank the western and eastern sides of the restaurant building. Additionally, there are decorative shrubs and turf along the northern, eastern, and western façades of the building, with one mature fern pine near the northeastern corner of the building. There is a mix of existing trees along the perimeter of the Project Site, serving as landscape buffers between the Project Site and neighboring streets to the north and west and the residential neighborhoods to the east and south. In total, there are 72 trees located on the Project Site. According to the U.S. Fish and Wildlife Service (USFWS), the only threatened or endangered species that have potential of occurring in this part of Arcadia are the California condor, the coastal California gnatcatcher, and the Braunton’s milk-vetch flowering plant.25 While there are 72 trees on the Project Site, the Site does not contain any native habitat that would support the California condor or the coastal California gnatcatcher. The Project Site’s manicured landscaping does not support native plant species, such as the Braunton’s milk-vetch. Due to the disturbed nature of the Project Site, the Project Site would not support special- status species listed by the USFWS, or species listed on the California Department of Fish and 25 U.S. Fish and Wildlife Service (USFWS), Environmental Conservation Online System: Information for Planning and Consultation, resource list generated November 22, 2019. Artis Senior Housing Project Draft Initial Study Page 36 April 2020 Wildlife’s (CDFW) Special Plant and Animal Lists.26 Further, the Arcadia General Plan does not identify any sensitive or special-status species, apart from protected trees, which are discussed in the response to Checklist Question IV.e of this Initial Study. Therefore, the Project would not have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. As such, impacts would be less than significant. b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service? No Impact. As previously stated, the Project Site is located in an urbanized area and is currently developed as a restaurant with associated parking and landscaping. No riparian or other sensitive natural community exists on the Project Site or in the immediate surrounding area.27,28 Further, the Project Site is not located in or adjacent to a Biological Resource Area or Significant Ecological Area as defined by the County of Los Angeles.29 Additionally, there are no other sensitive natural communities or critical habitat identified by the CDFW or USFWS located on or adjacent to the Project Site.30,31,32 Therefore, the Proposed Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community, and no impact would occur. c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. Section 404 of the Clean Water Act defines wetlands as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” The Project Site is located in an urbanized area and is mostly covered by impervious surfaces except for some ornamental landscaping in front of the existing restaurant building and along the site frontages. There are no water bodies or federally protected wetlands on the Project Site or in the immediate vicinity.33,34 Therefore, the Project would not have an adverse effect on State or federally protected wetlands, and no impact would occur. 26 California Department of Fish and Wildlife (CDFW), Special Plant and Animal Lists, https://www.dfg.ca.gov/wildlife/nongame/list.html, accessed November 8, 2019. 27 City of Arcadia, Arcadia General Plan, Land Use and Community Design Element, November 2010. 28 U.S. Environmental Protection Agency (USEPA), NEPAssist, National Land Cover Database 2016 Project Site and Area land cover, map generated December 10, 2019. 29 Los Angeles County Department of Regional Planning, GIS-NET Public, Planning & Zoning Information, http://rpgis.isd.lacounty.gov/Html5Viewer/index.html?viewer=GISNET_Public.GIS-NET_Public, accessed November 8, 2019. 30 CDFW, Biogeographic Information and Observation System (BIOS), https://apps.wildlife.ca.gov/bios/, accessed November 8, 2019. 31 CDFW, CDFW Lands, https://apps.wildlife.ca.gov/lands/, accessed November 8, 2019. 32 USFWS, Environmental Conservation Online System: Information for Planning and Consultation, map generated November 22, 2019. 33 USEPA, NEPAssist, , accessed November 8, 2019. 34 USFWS, National Wetlands Inventory, , accessed November 22, 2019. Artis Senior Housing Project Draft Initial Study Page 37 April 2020 d) Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than Significant with Mitigation Incorporated . There are no waters or streams present on the Project Site. Therefore, the Proposed Project would not impact or interfere with the movement of any native resident or migratory fish. Wildlife corridors are typically made up of undeveloped wildlife habitat and open space linkages between larger patches of wildlife habitat. Habitat linkages may also include more tenuous linkages like narrow vegetated pathways or islands of habitat that act as stepping stones between larger habitat areas for some species. The Project Site has been highly disturbed and is surrounded by developed, urban land uses; however, there are 72 existing trees on the Project Site, which could provide habitat to animals capable of flight (i.e., birds).35 The Coco’s building, trees, and ornamental landscaping may provide suitable roosting and nesting habitat for bird species. Migratory nongame native bird species are protected under the federal Migratory Bird Treaty Act (MBTA) of 1918 (50 CFR Section 10.13). Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit take of all birds and their active nests including raptors and other migratory nongame birds (as listed under the federal MBTA). The Proposed Project would result in the removal of unprotected trees, the existing Coco’s building, and other landscaping, which could be used as habitat for nesting birds. While migratory bird species are considered highly mobile and would naturally avoid areas with loud construction noise, removal of potential nesting habitat would result in the potential for minor impacts. As such, Mitigation Measure BIO-1 would be implemented, which would reduce impacts on migratory wildlife species to a less-than-significant level with mitigation incorporated. BIO-1 Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City of the Planning & Community Development Administrator or Designee. e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Less Than Significant with Mitigation Incorporated. The City of Arcadia has a Tree Preservation Ordinance (TPO) that protects trees with a diameter of 12 inches or greater (or greater than 10 inches in diameter if there are multiple trunks), as well as street trees.36 Several trees are considered 35 Arbor Care, Inc., Protected Tree Report: Tree Survey, Encroachment, Protection and Mitigation 1150 West Colorado Boulevard, Arcadia, CA 91106, revised December 2019. 36 City of Arcadia, Code of Ordinances, Article IX, Chapter 7, Tree Preservation, and Chapter 8, Comprehensive Tree Management Program. Artis Senior Housing Project Draft Initial Study Page 38 April 2020 “unprotected” regardless of their size, including fruit trees, Brazilian pepper trees, palm trees, eucalyptus trees, and Italian cypress trees. Of the 72 trees located on the Project Site, 12 are considered protected under the TPO with all but two of these protected trees considered to be in good health. There are four additional protected trees that are off-site but have canopies that encroach onto the Project Site. In total, there are 16 protected trees located on the Project Site or that have canopies that extend onto the Project Site. As discussed in the Protected Tree Report, included as Appendix A of this Initial Study, these protected trees include species, such as fern pines, carrotwoods, Japanese pear, southern magnolias, deodar cedar, coast redwood, and Canary Island pines, and are primarily located along the perimeter of the Project Site. In particular, Tree No. 49 (see Appendix A), a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, is in fair condition but is showing branch die-back. The Proposed Project would remove a total of 18 unprotected trees, which include a mix of Victorian box trees, lemon-scented gum trees, a fern pine, and an evergreen pear tree. Of the 18 unprotected trees to be removed, 13 trees are located in the center of the Project Site, around the existing restaurant building; two trees are flanking the existing driveway onto Colorado Boulevard; two trees are located in a planter in the southeastern corner of the parking lot; and one dead tree stump is located on the Project Site’s Colorado Boulevard frontage. No healthy, protected trees would be removed as part of Project Site modifications. Of the 16 protected trees that are on or adjacent to the Project Site, all 12 of the on-site protected trees would experience some light grading within their immediate area, less than 6 inches deep within the dripline of the tree. The Protected Tree Report estimates that the Proposed Project would remove or sever less than 20 percent of the total root mass of each of these protected trees. Project-related construction activities would not encroach upon the four off-site protected trees. Accordingly, the Protected Tree Report determined that the Project would not adversely affect the long-term viability of the protected trees on or adjacent to the Project Site. As such, no protected trees would be removed or irrevocably damaged as part of Project-related grading and construction. While some minor damage to the protected tree root systems are anticipated as part of the Proposed Project, implementation of Mitigation Measure BIO-2 is required to prevent substantial damage to on- and off-site protected trees, via soil compaction or grading encroachment into protected tree root systems. The goal of Mitigation Measure BIO-2 would be to enclose the largest possible amount of space underneath the tree so that the heavy equipment required for demolition and construction can be routed away from root zones. Further, the TPO requires an applicant to demonstrate that a proposed project’s landscape plan is consistent with the TPO. Therefore, with implementation of Mitigation Measure BIO-2 to meet the requirements of the TPO, the Proposed Project would not conflict with the City’s TPO, and impacts would be less than significant with mitigation incorporated. BIO-2 Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: 1. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. 2. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal Artis Senior Housing Project Draft Initial Study Page 39 April 2020 posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. 3. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. 4. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. 5. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. 6. The arborist shall monitor a few critical phases of the Project, including pre- demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. 7. Additional construction best practices described in the Protected Tree Report shall be implemented. f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? No Impact. There are no adopted, approved, or proposed habitat conservation plans, natural community conservation plans, or other approved local, regional, or State conservation plans that cover habitats located in the City of Arcadia.37 Therefore, the Proposed Project would not conflict with such plans, and no impact would occur. 37 City of Arcadia, General Plan Update Draft Program EIR, Section 4.4 Biological Resources, June 2010. Artis Senior Housing Project Draft Initial Study Page 40 April 2020 V. Cultural Resources Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact CULTURAL RESOURCES: Would the project: a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5? ܆ ܆ ܆ ܈ b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? ܆ ܈ ܆ ܆ c) Disturb any human remains, including those interred outside of dedicated cemeteries? ܆ ܆ ܈ ܆ Discussion The analysis in this section is based on the “Cultural Resources Identification Memorandum for the Artis Senior Living Project” prepared by Michael Baker International in January 2020, included as Appendix C of this Initial Study. The memo report summarized the methods and results of a South Central Coastal Information Center (SCCIC) records search, literature review, and historical map review to determine whether the Project would result in significant impacts to cultural resources, including historical and archaeological resources. a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5? No Impact. No historical resources (built environment) were identified on the Project Site. The current restaurant building, built in 1976, does not meet the age requirement for evaluation for eligibility for listing in the California Register of Historical Resources (California Register) and, therefore, is not a historical resource as defined by CEQA Guidelines Section 15064.5(a). Further, there are no cultural resources listed or eligible for listing in the California Register within the immediate vicinity of the Project Site (i.e., within 1.5 blocks of the Project Site). Because physical alterations associated with the Proposed Project would not extend beyond the Project Site, there would be no impact to on-site or off-site historical resources as a result of the Project’s implementation. Therefore, the Project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5, and no impact to historical resources would occur. b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? Less than Significant Impact with Mitigation Incorporated . The Project Site is fully paved and landscaped with no exposed soils. No archaeological resources were identified on the Project Site or within a quarter-mile of the Project Site. The Project Site was first developed with a hotel and restaurant known as Eaton’s Santa Anita Hotel and Restaurant between 1940 and 1975 when it was demolished for the current 1976-built restaurant. No other historic literature or maps indicate occupation or development of the Project Site prior to circa 1940. Furthermore, neither the current building nor the previous Eaton’s restaurant building was identified as significant in the records search Artis Senior Housing Project Draft Initial Study Page 41 April 2020 or literature review (see Appendix C of this Initial Study). Accordingly, the site sensitivity for subsurface archaeological resource is considered low because the Project Site has been developed and redeveloped. However, the potential exists for unanticipated discovery of archaeological resources during Project-related ground disturbance activities. Therefore, Mitigation Measure CUL-1 is required to ensure that impacts to archaeological resources pursuant to CEQA Guidelines Section 15064.5 would be less than significant with mitigation incorporated. Mitigation Measure CUL‐1 Treatment of previously unidentified archaeological deposits. If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility. c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries? Less Than Significant Impact. The Project would not likely disturb any human remains, including those interred outside of dedicated cemeteries. Research conducted as part of the preparation of the “Cultural Resources Identification Memo Report for the Artis Senior Living Project” found no indications of any past human burial activities on or near the Project Site. However, there is the potential to discover buried human remains during Project-related earth-moving activities. According to the California Health and Safety Code Section 7050.5, there must be no further excavation or disturbance of a site or any nearby area reasonably suspected to overlie adjacent remains until the Los Angeles County coroner has determined the manner and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation or to his or her authorized representative. Project personnel/construction workers are prohibited to collect or move any human remains and associated materials. If the human remains are of Native American origin, the coroner must notify the Native American Heritage Commission (NAHC) within 24 hours of this identification. The NAHC will immediately identify a Native American most likely descendant to inspect the site and provide recommendations within 48 hours for the proper treatment of the remains and associated grave goods. Accordingly, impacts related to the disturbance of human remains, including those interred outside of dedicated cemeteries, would be less than significant with the Project’s compliance with California Health and Safety Code Section 7050.5. Artis Senior Housing Project Draft Initial Study Page 42 April 2020 VI. Energy Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact ENERGY: Would the project: a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? ܆ ܆ ܈ ܆ b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? ܆ ܆ ܆ ܈ Discussion a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less Than Significant Impact. This analysis focuses on three sources of energy that are relevant to the Proposed Project: electricity, natural gas, and transportation fuel for vehicle trips associated with Project construction and new development. The estimated construction fuel consumption is based on the Project’s construction equipment list, timing/phasing, and hours of duration for construction equipment, as well as vendor, hauling, and construction worker trips. The analysis of operational electricity/natural gas usage is based on the CalEEMod version 2016.3.2 modeling results for the Project, which quantifies energy use for the proposed occupancy. The Project’s estimated electricity/natural gas consumption is based primarily on CalEEMod’s default settings for Los Angeles County and consumption factors provided by Southern California Edison (SCE) and the Southern California Gas Company (SoCalGas) (the electricity and natural gas providers, respectively, for the City of Arcadia and the Project Site). The results of the CalEEMod modeling are included in Appendix B, Air Quality/Greenhouse Gas/Energy Worksheets. The amount of operational fuel consumption was estimated using the CARB Emissions Factor 2017 (EMFAC2017) computer program, which provides projections for typical daily fuel (i.e., diesel and gasoline) usage in Los Angeles County, and the Project’s annual vehicle miles traveled (VMT) outputs from CalEEMod. Construction Project construction would consume energy in two general forms: (1) the fuel energy consumed by construction vehicles and equipment; and (2) bound energy in construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials, such as lumber and glass. Fossil fuels for construction vehicles and other energy-consuming equipment would be used during site clearing, grading, and construction. Fuel energy consumed during construction would be temporary and would not represent a significant demand on energy resources. In addition, some incidental energy conservation would occur during construction through compliance with State requirements that heavy-duty diesel equipment not in use for more than five minutes be turned off. Project construction equipment would also be required to comply with the latest USEPA and CARB Artis Senior Housing Project Draft Initial Study Page 43 April 2020 engine emissions standards. These emissions standards require highly efficient combustion systems that maximize fuel efficiency and reduce unnecessary fuel consumption. Due to increasing transportation costs and fuel prices, contractors and owners have a strong financial incentive to avoid wasteful, inefficient, and unnecessary consumption of energy during construction. Substantial reductions in energy inputs for construction materials can be achieved by selecting building materials composed of recycled materials that require substantially less energy to produce than non- recycled materials. The Project-related incremental increase in the use of energy bound in construction materials, such as asphalt, steel, concrete, pipes and manufactured or processed materials (e.g., lumber and gas), would not substantially increase demand for energy compared to overall local and regional demand for construction materials. It is reasonable to assume that production of building materials, such as concrete, steel, etc., would employ all reasonable energy conservation practices in the interest in minimizing the cost of doing business. As indicated in Table VI-1, the Project’s fuel consumption from construction would be approximately 36,934 gallons, which would increase fuel use in the County by 0.0069 percent. As such, construction would have a nominal effect on local and regional energy supplies. It is noted that construction fuel use is temporary and would cease upon completion of construction activities. There are no unusual Project characteristics that would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or State. Therefore, construction fuel consumption would not be any more inefficient, wasteful, or unnecessary than other similar development projects of this nature. As such, impacts related to energy conservation would be less than significant. Table VI-1 Project and Countywide Energy Consumption Energy Type Project Annual Energy Consumptiona Los Angeles County Annual Energy Consumptionb Percentage Increase Countywideb Net Electricity Consumptionc -257 MWh 68,486,000 MWh -0.0004% Net Natural Gas Consumptiond -21,351 therms 2,921,000,000 therms -0.0007% Fuel Consumption x Construction Fuel Consumptione 36,934 gallons 533,800,838 gallons 0.0069% x Net Operational Automotive Fuel Consumptione,f -8,182 gallons 3,975,480,911 gallons -0.0002% Notes: a As modeled in CalEEMod version 2016.3.2. b The project net reduction in electricity and natural gas consumption are compared to the total consumption in Los Angeles County in 2018. The project’s automotive fuel consumption is compared with the projected countywide fuel consumption in 2020. Los Angeles County electricity consumption data source: California Energy Commission, Electricity Consumption by County, http://www.ecdms. energy.ca.gov/elecbycounty.aspx, accessed December 30, 2019. Los Angeles County natural gas consumption data source: California Energy Commission, Gas Consumption by County, http://www.ecdms.energy. ca.gov/gasbycounty.aspx, accessed December 30, 2019. c Net electricity consumption is calculated by subtracting the existing (i.e., Coco’s Restaurant) electricity consumption quantity from the Project’s total electricity consumption quantity. Refer to energy calculation sheets in Appendix B. d Net natural gas consumption is calculated by subtracting the existing (i.e., Coco’s Restaurant) natural gas consumption quantity from the Project’s total natural gas consumption quantity. Refer to energy calculation sheets in Appendix B. e Project fuel consumption calculated based on CalEEMod results. Countywide fuel consumption is from the CARB EMFAC2017 model. f Net operational automotive fuel consumption is calculated by subtracting the existing (i.e., Coco’s Restaurant) operational automotive fuel consumption quantity from the Project’s total operational automotive fuel consumption quantity. Refer to energy calculation sheets in Appendix B. Source: Refer to Appendix B for assumptions used in this analysis. Artis Senior Housing Project Draft Initial Study Page 44 April 2020 Operation The Project’s estimated energy consumption is summarized in Table VI-1, which shows that the Project’s electricity usage would constitute an approximate 0.0004-percent reduction from Los Angeles County’s typical annual electricity consumption and an approximate 0.0007-percent reduction from Los Angeles County’s typical annual natural gas consumption. The Project’s construction fuel consumption would increase Los Angeles County’s consumption by 0.0069 percent. However, the Project would generate a net decrease of approximately 374 daily trips when compared to the existing use (i.e., Coco’s Restaurant). As a result, the Project’s operational vehicle consumption would decrease Los Angeles County’s fuel consumption by 0.0002 percent. Building Energy Demand The Project would consume energy for interior and exterior lighting; heating, ventilation, and air conditioning (HVAC) systems; refrigeration; electronics systems; appliances; and security systems. The Project would be required to comply with Title 24 standards,38 which provide minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting. Implementation of Title 24 standards significantly reduces energy usage. Furthermore, the electricity provider, SCE, is subject to California’s Renewables Portfolio Standard (RPS), which requires investor-owned utilities, electric service providers, and community choice aggregators to increase procurement from eligible renewable energy resources to 33 percent of total procurement by 2020 and to 50 percent of total procurement by 2030. As indicated in Table VI-1, operational energy consumption would represent an approximate 0.0004- percent reduction in electricity consumption and a 0.0007-percent reduction in natural gas consumption from current countywide usage. Therefore, the Project would not result in the inefficient, wasteful, or unnecessary consumption of building energy, and impacts related to energy conservation would be less than significant. Transportation Energy Demand Pursuant to the Federal Energy Policy and Conservation Act of 1975, the National Highway Traffic and Safety Administration (NTSA) is responsible for establishing additional vehicle standards and for revising existing standards. Compliance with federal fuel economy standards is not determined for each individual vehicle model. Rather, compliance is determined based on each manufacturer’s average fuel economy for the portion of their vehicles produced for sale in the U.S. Table VI-1 provides an estimate of the daily fuel consumed by vehicles traveling to and from the Project Site. As indicated in Table VI-1, Project operations are estimated to reduce existing vehicle consumption by approximately 8,182 gallons of fuel per year, which would decrease the Los Angeles County’s automotive fuel consumption by 0.0002 percent. The Project would not result in any unusual characteristics that would result in excessive operational fuel consumption associated with vehicular travel. Fuel consumption associated with Project-related vehicle trips would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. As such, impacts related to energy conservation would be less than significant. 38 California Code of Regulations, Title 24, Part 6, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings, 2019. Artis Senior Housing Project Draft Initial Study Page 45 April 2020 b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? No Impact. The City adopted the 2019 Energy Action Plan Update (EAP), which updates the City’s 2012 Energy Action Plan. The City is part of the San Gabriel Valley Energy Wise Partnership (SGVEWP), which is a collaboration between SCE, SoCalGas, the San Gabriel Valley Council of Governments, and 29 cities in the San Gabriel Valley. Through the SGVEWP, member cities are able to participate in the SCE Energy Leader Model, which recognizes cities for increasing their energy efficiency in municipal facilities and communities, and participating in demand-response programs and long-term strategic planning. Implementation of the EAP has allowed Arcadia to reach the second highest level of energy efficiency, Gold, under the Energy Leader Model. The 2019 EAP builds on the community goals and policies in the 2012 EAP and adds additional goals and policies for City-owned properties. The 2019 EAP outlines three City energy conservation targets: reduce municipal electricity usage by 780,662 kilowatt hours by 2023; achieve Platinum level status in SCE’s Energy Leader Program; and complete three or more municipal energy-efficiency projects by 2023. As these goals are municipal targets, aimed at reducing electricity usage at City-owned and City- controlled facilities, the Proposed Project’s energy reduction features would not contribute to or obstruct the attainment of these goals. However, the Project’s overall energy-efficiency measures— e.g., installing energy-efficient appliances, heaters, and HVAC systems; using water-efficient landscaping (which would reduce the electricity used for water transport and treatment); and incorporation of building code-mandated energy-efficient designs—would generally support the City’s energy reduction goals. The Project’s energy consumption would be typical of senior living development projects in Southern California and would not result in an increased energy demand beyond the capacity of SCE or SoCalGas. As such, the Project would not conflict with or obstruct any plans for renewable energy or energy efficiency, and, as such, no impact would occur. VII. Geology and Soils Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact GEOLOGY AND SOILS: Would the project: a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ܆ ܆ ܈ ܆ ii) Strong seismic ground shaking? ܆ ܆ ܈ ܆ iii) Seismic-related ground failure, including liquefaction? ܆ ܆ ܈ ܆ Artis Senior Housing Project Draft Initial Study Page 46 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact iv) Landslides? ܆ ܆ ܆ ܈ b) Result in substantial soil erosion or the loss of topsoil? ܆ ܆ ܈ ܆ c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? ܆ ܆ ܈ ܆ d) Be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? ܆ ܆ ܈ ܆ e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? ܆ ܆ ܆ ܈ f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? ܆ ܈ ܆ ܆ Discussion a.i) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. Less Than Significant Impact. According to the City of Arcadia General Plan Safety Element, the Raymond Hill Fault Zone and the Sierra Madre Fault Zone are the only active or potentially active earthquake faults that pass through the City of Arcadia.39,40 In addition, two deep blind thrust faults are located beneath Arcadia, i.e., the relatively shallow Elysian Park Fault and the relatively deep Puente Hills Fault. These are considered blind thrust faults due to their depth and because the fault movement consists of upward or thrusting action. The Safety Element states that there is also the Eaton Wash groundwater barrier; however, this fault shows no surface geological evidence of existence and the nature of this buried fault is unknown.41 The Raymond Fault traverses a large portion of the City and has a potential to cause a 5-6-foot offset if severe ground shaking occurs. The Sierra Madre Fault crosses the northern portion of the City and could result in large ground rupture movements (possibly 10 feet or more in the event of a 7.2 magnitude earthquake).42 39 City of Arcadia, General Plan Safety Element, Figure S-1, Regional Faults, November 2010. 40 California Department of Conservation, Fault Activity Map of California, 2010. 41 City of Arcadia, General Plan Safety Element, November 2010. 42 City of Arcadia, General Plan Safety Element, November 2010. Artis Senior Housing Project Draft Initial Study Page 47 April 2020 The Project Site is located north of the Raymond Fault and south of the Sierra Madre Fault. An “inferred or possible groundwater barrier” fault runs directly west and south of the Project Site. As displayed in Figure S-2 of the Safety Element, the Project Site is not located within the Alquist-Priolo Earthquake Fault Zone for either the Sierra Madre Fault or the Raymond Fault; however, the Alquist- Priolo Earthquake Fault Zone for the Raymond Fault is located just one-half mile southeast of the Project Site.43 Further, the Project Site is not located within a Fault Hazard Management Zone, which would require geologic investigations to be performed if conventional structures that are designed for human occupancy are proposed within the zone. While the Proposed Project is near these fault zones, the Proposed Project is subject to review by the City of Arcadia Building Services Division to ensure compliance with aspects of the California Building Standards Code pertaining to seismic safety (California Code of Regulations, Title 24), which the City adopted into the City’s Code of Ordinances in 2010.44 Because the Project Site is located outside of Alquist-Priolo Earthquake Fault and Hazard Management Zones identified above and because the Project is required to adhere to building regulations dictating seismic safety, the Project would not directly or indirectly cause potential adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault. Therefore, potential impacts related to rupture of a known earthquake fault would be less than significant. a.ii) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? Less Than Significant Impact. As with most of Southern California, the Project Site is in an area that is subject to strong ground shaking due to earthquakes on local and regional faults. As stated above, the Raymond Fault and the Sierra Madre Fault are the only faults to traverse the City and are located south and north of the Project Site, respectively. The 2019 California Building Code provides procedures for earthquake-resistant structural design that include considerations for on-site soil conditions, occupancy, and the configuration of the structure including the structural system and height. With adherence to the seismic design parameters as outlined in the California Building Code, the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking. Therefore, potential impacts related to seismic ground shaking would be less than significant. a.iii) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction? Less Than Significant Impact. Liquefaction is the loss of strength in generally cohesionless (granular), saturated soils when the pressure of groundwater held within a soil or rock, in gaps between particles (referred to as “pore-water pressure”) induced in the soil by a seismic event, becomes equal to or exceeds the overburden pressure. Lateral spread or flow refers to landslides that commonly form on gentle slopes and that have rapid fluid-like flow movement, like water. In general, lateral spreading is a result of liquefaction. The primary factors that influence the potential for liquefaction include groundwater table elevation; the relative density of the soil; and the intensity and duration of ground shaking. The depth within which the 43 City of Arcadia, General Plan Safety Element, Figure S-2, Alquist-Priolo and Fault Rupture Hazard Zones, November 2010. 44 City of Arcadia, Code of Ordinances, Article VIII, Chapter 1, Building Code. Artis Senior Housing Project Draft Initial Study Page 48 April 2020 occurrence of liquefaction may impact surface improvements is generally identified as the upper 50 feet below the existing ground surface. According to the Safety Element, the Project Site is located within a liquefaction zone due to the relatively shallow groundwater depth of approximately 40 feet.45 However, the 2019 California Building Code provides requirements for earthquake-resistant structural design that include considerations for on-site soil conditions, occupancy, and the configuration of the structure including the structural system and height. Other mitigation guidance provided by the California Geological Survey (CGS) includes removal and/or densification of liquefiable soils to eliminate liquefaction hazards.46 With adherence to the seismic design parameters as outlined in the Cali fornia Building Code, incorporated into the Arcadia Municipal Code by reference, and CGS guidance, the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, such as liquefaction. Therefore, potential impacts related to seismic-related ground failure would be less than significant. a.iv) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides? No Impact. The Project Site is located in a fully urbanized area and is surrounded by single-family residential buildings, a gas station, highway infrastructure (I-210), and a medium-rise commercial building. The Project Site’s topography is relatively flat, with a slight slope to the southeast (a difference in elevation of approximately 10 feet between the northwestern corner and the southeastern corner of the Project Site). Further, the Project Site is not located within an earthquake-induced landslide hazard area, as identified by the Safety Element. Accordingly, the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. Therefore, no impact related to landslides would occur. b) Would the project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Because of the extensive ground alterations that have occurred on-site since the Project Site was originally developed, it is unlikely that any native topsoil is remaining in the near surface. There would, thus, be no impact involving loss of topsoil. During construction of the Proposed Project, the uncovered soils on-site may become exposed to wind or rainstorms and, thus, subject to erosion. The Proposed Project must comply with SCAQMD Rule 403, Fugitive Dust, to reduce the amount of particulate matter in the ambient air due to man-made fugitive dust sources by requiring actions to prevent, reduce, or mitigate fugitive dust emissions. This rule requires that construction activities include a variety of best available control measures, including measures that would prevent wind-induced erosion of uncovered soils, such as to apply chemical stabilizers to areas that would remain inactive for 10 days or longer, replant disturbed areas as soon as practical, and suspend grading when wind speeds exceed 25 miles per hour. Storm-related erosion of uncovered soils during construction activities would be prevented by complying with the County of Los Angeles’ National Pollutant Discharge Elimination System (NPDES) Construction General Permit requirements. These requirements are further discussed in Section X.a, Hydrology and Water Quality, below. In general, the NPDES permit requires construction activities to incorporate best management practices (BMPs) to prevent erosion and prevent loose soils from washing off-site. In general, BMPs for the Proposed Project would include the use of 45 City of Arcadia, General Plan Safety Element, Figure S-3, Liquefaction and Landslide Hazards, November 2010. 46 California Geological Survey, Special Publication 117A: Guidelines for Evaluating and Mitigating Seismic Hazards in California, 2008. Artis Senior Housing Project Draft Initial Study Page 49 April 2020 berms or drainage ditches to divert water around the site and preventing sediment from migrating off the site by using temporary swales, silt fences, or gravel rolls. Additionally, because the Proposed Site is greater than 1 acre, the City requires the preparation of a Stormwater Pollution Prevention Plan, which would establish erosion and sedimentation controls, such as methods to minimize the footprint of the disturbed area, controls to prevent tracking off-site, spill prevention, non-stormwater controls (i.e., vehicle washing), and methods to protect native vegetation and trees. Therefore, the potential for soil erosion during any construction activity would be reduced to less than significant through Project compliance with these existing regulations. Finally, the Proposed Project would result in almost the entire site covered in either impervious surfaces, such as the building, surrounding parking areas, outdoor structures (i.e., outdoor gathering spaces, refuse and generator enclosures, and storage shed), and concrete walkways, or managed landscaped areas. Because almost the entire site would be covered by either impervious surfaces or managed gardens/turf areas, there would be very little potential for wind- or storm-induced erosion during the long-term operation of the Project. Accordingly, the Project would not result in soil erosion or the loss of topsoil. Therefore, potential impacts related to soil erosion or the loss of topsoil would be less than significant. c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? Less Than Significant Impact. As stated above, the Project Site’s topography is relatively flat, with a slight slope to the southeast. Further, the Project Site is not located within an earthquake-induced landslide hazard area, as identified by the Safety Element. Therefore, there would be no risk resulting from on- or off-site landslide. Further, while the project is located in a liquefaction area, the Project would be required to comply with seismic design parameters as outlined in the California Building Code, incorporated into the Arcadia Municipal Code by reference. Further, compliance with CGS guidance described above for addressing liquefaction hazards would reduce potential liquefaction impacts to site improvements to a less-than-significant level. Other hazards include subsidence, which is the compaction of the ground when large amounts of groundwater or oil have been withdrawn from fine-grained sediments or when underlying limestone deposits dissolve, as well as collapsible soils, which undergo a volume reduction when the pore spaces become saturated with water, with the weight of overlying structures causing settlement. Both of these hazards can result in building settlement and damage to foundations and walls. Subsidence may cause differential settlement of the overlying structure and substantially more damage than if the structure were to settle evenly throughout. Large-scale subsidence due to fluid withdrawal (water or oil) has not been reported in or near the City.47 Therefore, it is unlikely that the Project Site is located on soils that are vulnerable to subsidence or collapse. Nevertheless, the Project would be required to comply with seismic safety design regulations required by the California Building Code or those described by the CGS guidance, such as extending piles or caissons to non-collapsible soils, or utilizing various methods of soil compaction prior to construction. These building regulations would provide appropriate building design criteria needed to protect structural integrity of structures against such geologic hazards. Accordingly, with compliance with required design criteria, the Project would not result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. Therefore, potential impacts related to unstable soils would be less than significant. 47 City of Arcadia, General Plan Update Draft Program EIR, 2010. Artis Senior Housing Project Draft Initial Study Page 50 April 2020 d) Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Less Than Significant Impact. Expansive soils are generally associated with soils, alluvium, and bedrock formations that contain clay minerals susceptible to expansion under wetting conditions and contraction under drying conditions. Depending upon the type and amount of clay present in a geologic deposit, volume changes (shrink and swell) can cause severe damage to slabs, foundations, and concrete flatwork.48 Hanford, Vista Amargosa, and Tujunga-Soboba soils that underlie the City do not have high shrink-swell potential and thus are not considered expansive. However, due to the granular (sandy) nature of the alluvium in the flatter areas of the City, expansive clays would most likely be present in older alluvial, bedrock formation soils in the hillside areas, and in sag-pond areas (e.g., the Los Angeles Arboretum and Santa Anita Racetrack areas) caused by past impoundments along the northern side of the Raymond Fault. While the Project Site is located in an area with potential to contain expansive soils, the Project would be required to adhere to seismic safety design regulations required by the California Building Code, such as those described above. Further, the City’s Building regulations provide appropriate building design criteria needed to protect structural integrity of structures against soil expansion. Accordingly, with compliance with required design criteria, the Project would not result in direct or indirect risks to life or property due to expansive soils. Therefore, potential impacts related to expansive soils would be less than significant. e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Impact. All wastewater generated by the Proposed Project would be discharged via a lateral connection to an existing sanitary sewer infrastructure in Michillinda Avenue and Colorado Boulevard. There would be no on-site wastewater disposal system. Therefore, no impact related to unstable soils due to the use of septic tanks would occur. f) Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Less Than Significant Impact with Mitigation Incorporated. Paleontological resources, as defined by the Bureau of Land Management, U.S. Department of the Interior, are the physical remains or other physical evidence of plants and animals preserved in soils and sedimentary rock formations. The Project Site has been extensively disturbed in the past and is currently covered with a restaurant structure and other improvements (such as outdoor parking areas). However, there would be some potential for encountering vertebrate paleontological resources during grading activities for the Proposed Project. To avoid the potential destruction of undiscovered paleontological resources, Mitigation Measure GEO-1 would be imposed to ensure proper identification and treatment of paleontological resources that may be discovered during grading. Therefore, with mitigation incorporated, potentially significant impacts would be reduced to less than significant. GEO-1 Paleontological Resource Monitor. If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project 48 City of Arcadia, General Plan Update Draft Program EIR, 2010. Artis Senior Housing Project Draft Initial Study Page 51 April 2020 paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. VIII. Greenhouse Gas Emissions Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact GREENHOUSE GAS EMISSIONS: Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? ܆ ܆ ܈ ܆ b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? ܆ ܆ ܈ ܆ Discussion a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Less Than Significant Impact. California is a substantial contributor of greenhouse gases (GHGs), emitting over 440 million tons of carbon dioxide (CO 2) per year.49 Methane (CH4) is also an important GHG that potentially contributes to global climate change. GHGs are global in their effect, which is to increase Earth’s ability to absorb heat in the atmosphere. As primary GHGs have a long lifetime in the atmosphere, accumulate over time, and are generally well-mixed, their impact on the atmosphere is mostly independent of the point of emission. The City of Arcadia has not adopted a numerical significance threshold for assessing impacts related to GHG emissions. Similarly, SCAQMD, CARB, or any other State or regional agency has not yet adopted a numerical significance threshold for assessing GHG emissions that is applicable to the Project. Notwithstanding, for informational purposes, the following analysis calculates the amount of GHG emissions that would be attributable to the Project using recommended air quality models, as described below. The primary purpose of quantifying the Project’s GHG emissions is to satisfy CEQA Guidelines Section 15064.4(a), which calls for a good-faith effort to describe and calculate emissions. The estimated emissions inventory is also used to determine if there would be a reduction in the Project’s incremental contribution of GHG emissions as a result of compliance with regulations and requirements adopted to implement plans for the reduction or mitigation of GHG emissions. 49 California Energy Commission, California Greenhouse Gas Emissions for 2000 to 2017 , https://www.arb.ca.gov/cc/inventory/pubs/reports/2000_2016/ghg_inventory_trends_00-16.pdf, accessed December 27, 2019. Artis Senior Housing Project Draft Initial Study Page 52 April 2020 However, the significance of the Project’s GHG emissions impacts is not based on the amount of GHG emissions resulting from the Project. Direct, Project-related GHG emissions include emissions from construction activities, area sources, and mobile sources, while indirect, Project-related GHG emissions include emissions from electricity consumption, water demand, and solid waste generation. Operational GHG estimations are based on energy emissions from natural gas usage and automobile emissions. Table VIII-1 presents the estimated CO2, N2O, and CH4 emissions of the Proposed Project. In accordance with SCAQMD guidance, projected GHGs from construction have been quantified and amortized over 30 years (representing the life of the Project), which are added to the annual average operation emissions.50 As shown in Table VIII-1, the Project would result in a GHG emissions reduction of approximately 209.75 metric tons of carbon dioxide equivalent (MT CO2e) per year when compared to the existing Coco’s Restaurant. This overall reduction in GHG emissions can be attributed to the decrease in total daily vehicle trips associated with the development as compared with existing conditions.51 This reduction in total daily vehicle trips is further discussed in Section XVII, Transportation/Traffic, of this Initial Study. Table VIII-1 Estimated Greenhouse Gas Emissions Source CO2 CH4 N2O Total Metric Tons of CO2ec Metric Tons/yeara Metric Tons/yeara Metric Tons of CO2eb Metric Tons/year1 Metric Tons of CO2eb Construction Emissions x Total Construction Emissionsc (amortized over 30 years) 21.48 0.00 0.10 0.00 0.00 21.58 Operational Emissions Existing Coco’s Restaurant Emissions x Area 0.00 0.00 0.00 0.00 0.00 0.00 x Mobile Source 395.80 0.02 0.62 0.00 0.00 396.43 x Energy 302.82 0.01 0.28 0.00 1.37 304.48 x Solid Waste 2.43 0.14 3.59 0.00 0.00 6.02 x Water Demand 12.77 0.10 2.61 0.00 0.77 16.15 Total Existing Operational Emissionsc 713.83 0.28 7.10 0.01 2.14 723.08 Proposed Artis Senior Living Facility Emissions x Area 18.64 0.00 0.04 0.00 0.10 18.77 x Mobile Source 309.49 0.02 0.41 0.00 0.00 309.91 x Energy 129.10 0.01 0.14 0.00 0.54 129.78 x Solid Waste 3.75 0.22 5.54 0.00 0.00 9.28 x Water Demand 26.33 0.14 3.43 0.00 1.04 30.81 Total Project Operational Emissionsc 487.31 0.38 9.56 0.01 1.68 498.55 Total Project Net Operational Emissions3 -226.52 0.10 2.46 0.00 -0.46 -224.53 Total Project Emissions Total Project Emissions (Construction + Net Operational) -205.04 0.10 2.56 0.00 -0.46 -202.95 Total Project-Related Emissionsc -202.95 MTCO2e Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide 50 South Coast Air Quality Management District, California Emissions Estimator Model (CalEEMod), version 2016.3.2. 51 Michael Baker International, Artis Senior Assisted Living Facility Trip Generation Analysis, dated December 17, 2019. Artis Senior Housing Project Draft Initial Study Page 53 April 2020 a Emissions calculated using the CalEEMod version 2016.3.2. b Carbon dioxide equivalent values calculated using the EPA Website, Greenhouse Gas Equivalencies Calculator, https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator, accessed January 22, 2020. c Totals may be slightly off due to rounding. Refer to Appendix B for detailed model input/output data. Because the Proposed Project would result in a net reduction in overall Project-related emissions, the Project would not generate GHG emissions that would have a significant impact on the environment. Rather, the Project would represent a reduction in GHG emissions as compared to existing conditions. Therefore, impacts would be less than significant. b) Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Less Than Significant Impact. As described above, there is no applicable adopted or accepted numerical threshold of significance for GHG emissions. Therefore, a methodology for evaluating the Project’s impacts related to GHG emissions focuses on its consistency with Statewide, regional, and local plans adopted for the purpose of reducing and/or mitigating GHG emissions. This evaluation of consistency with such plans is the sole basis for determining the significance of the Project’s GHG- related impacts on the environment. 2017 CARB Scoping Plan The goal to reduce GHG emissions to 1990 levels by 2020 (Executive Order S-3-05) was codified by the California legislature as the 2006 Global Warming Solutions Act (Assembly Bill [AB] 32).52 In 2008, CARB approved a Scoping Plan as required by AB 32, which was updated in 2017.53 This update focuses on implementation of a 40 percent reduction in GHGs by 2030 compared to 1990 levels. To achieve this, the 2017 Scoping Plan draws on a decade of successful programs that addresses the major sources of climate-changing gases in every sector of the economy, such as clean cars and trucks, renewable energy, reduction of pollutants such as hydrofluorocarbon refrigerants and methane, and cleaner fuels. Achieving the 2030 target under the updated Scoping Plan will also spur the transformation of the California economy and fix its course securely on achieving an 80 percent reduction in GHG emissions by 2050, consistent with the global consensus of the scale of reductions needed to stabilize atmospheric GHG concentrations at 450 ppm carbon dioxide equivalent, and reduce the likelihood of catastrophic climate change. Table VII-2 evaluates applicable reduction actions/strategies by emissions source category to determine how the Project would be consistent with or exceed reduction actions/strategies outlined in the 2017 Scoping Plan. 52 California Air Resources board, California’s 2017 Climate Change Scoping Plan , November 2017. 53 The Climate Change Scoping Plan was approved by CARB on December 11, 2008. Artis Senior Housing Project Draft Initial Study Page 54 April 2020 Table VIII-2 Project Consistency with the 2017 CARB Scoping Plan Actions and Strategies Project Consistency Analysis SB 350 Clean Energy and Pollution Reduction Achieve a 50 percent RPS by 2030, with a doubling of energy efficiency savings by 2030. Consistent. The Project would not be an electrical provider or delay the goals of Senate Bill (SB) 350. Furthermore, the Project would utilize electricity from Southern California Edison (SCE), which would be required to comply with SB 350. As the Project would use the electricity from SCE, the Project would be in compliance with SB 350. Low Carbon Fuel Standard (LCFS) Increase stringency of carbon fuel standards; reduce the carbon intensity of fuels by 18 percent by 2030, which is up from 10 percent in 2020. Consistent. Motor vehicles driven by the Proposed Project’s employees, residents, and visitors would be required to use LCFS-compliant fuels; thus, the Project would be in compliance with this goal. Mobile Source Strategy (Cleaner Technology and Fuels Scenario) Maintain existing GHG standards of light- and heavy-duty vehicles while adding an addition 4.2 million zero-emission vehicles (ZEVs) on the road. Increase the number of ZEV buses, delivery trucks, or other trucks. Consistent. The Project would be required to comply with the CALGreen Residential Mandatory Measure 4.106.4 Electric vehicle (EV) charging for new construction. As such, the Project would support the use of ZEV vehicles and would not conflict with the goals of the Mobile Source Strategy. Short-Lived Climate Pollutant (SLCP) Reduction Strategy Reduce the GHG emissions of methane and hydrofluorocarbons by 40 percent below the 2013 levels by 2030. Furthermore, reduce the emissions of black carbon by 50 percent below the 2013 levels by the year 2030. Consistent. The Project does not involve sources that would emit large amounts of methane (refer to Table VIII-1). Furthermore, the Project would comply with all CARB and SCAQMD hydrofluorocarbon regulations. As such, the Project would not conflict with the SLCP reduction strategy. SB 375 Sustainable Communities Strategies Increase the stringency of the 2035 GHG emissions per capita reduction target for MPOs. Consistent. As shown in Table VIII-3, the Project would be consistent with the SCAG 2016 RTP/SCS and would not conflict with the goals of SB 375. Source: California Air Resources Board, California’s 2017 Climate Change Scoping Plan, November 2017. SCAG 2016-2040 RTP/SCS The 2016-2040 RTP/SCS is expected to help California reach its GHG reduction goals, with reductions in per capita transportation emissions of 9 percent by 2020 and 13 percent by 2035.54 Furthermore, although there are no per capita GHG emission reduction targets for passenger vehicles set by CARB for 2040, the 2016-2040 RTP/SCS GHG emission reduction trajectory shows that more aggressive GHG emission reductions are projected for 2040.55 At the regional level, the 2016-2040 RTP/SCS is an applicable plan adopted for the purpose of reducing GHGs. In order to assess the Project’s consistency with the 2016-2040 RTP/SCS, Table VIII-3 evaluates the Project’s land use assumptions for consistency with those included in the 2016-2040 RTP/SCS. Generally, Projects are considered consistent with the provisions and general policies of applicable City and regional land use plans and regulations, such as SCAG’s 2016-2040 RTP/SCS, if they are compatible with the general intent of the plans and would not 54 California Air Resources Board, Regional Greenhouse Gas Emission Reduction Targets Pursuant to SB 375, Resolution 10-31. 55 Southern California Association of Governments, 2016–2040 Regional Transportation Plan/Sustainable Communities Strategy, p. 153, April 2016. Artis Senior Housing Project Draft Initial Study Page 55 April 2020 preclude the attainment of their primary goals. Table VIII-3 demonstrates the Project’s consistency with applicable actions and strategies set forth in the 2016-2040 RTP/SCS. Table VIII-3 Project Consistency with the 2016-2040 RTP/SCS Actions and Strategies Responsible Party(ies) Project Consistency Analysis Land Use Actions and Strategies Encourage the use of range-limited battery electric and other alternative fueled vehicles through policies and programs, such as neighborhood-oriented development, complete streets, and electric (and other alternative fuel) vehicle supply equipment in public parking lots. Local Jurisdictions, Councils of Government, SCAG, County Transportation Commission (CTCs) Consistent. The Project would not impair the City or SCAG’s ability to encourage the use of alternatively- fueled vehicles through various policies and programs. Specifically, the Project would be required to comply with the CALGreen Residential Mandatory Measure 4.106.4 Electric vehicle (EV) charging for new construction. Collaborate with the region’s public health professionals to enhance how SCAG addresses public health issues in its regional planning, programming, and project development activities. SCAG, State, Local Jurisdictions Consistent. The Project would not impair the ability of the City, SCAG, or State to collaborate with the region’s public health professionals regarding the integration of public health issues in regional planning. Support projects, programs, and policies that support active and healthy community environments that encourage safe walking, bicycling, and physical activity by children, including but not limited to development of complete streets, school siting policies, joint use agreements, and bicycle and pedestrian safety education. Local Jurisdictions, SCAG Consistent. The Project would include opportunities for healthy, physical activities for its patrons, including walking paths, landscaped open space areas, and an outdoor plaza. Support projects, programs, policies, and regulations that encourage the development of complete communities, which includes a diversity of housing choices and educational opportunities, jobs for a variety of skills and education, recreation and culture, and a full range of shopping, entertainment, and services all within a relatively short distance. Local Jurisdictions, SCAG Consistent. As the Project proposes the development of a senior living facility, the Project would provide increased housing choices and job opportunities. Transportation Network Actions and Strategies Explore and implement innovative strategies and projects that enhance mobility and air quality, including those that increase the walkability of communities and accessibility to transit via non-auto modes, including walking, bicycling, and neighborhood electric vehicles or other alternative fueled vehicles. SCAG, CTCs, Local Jurisdictions Consistent. Per CALGreen, the Project would be required to provide electric vehicle (EV) charging spaces. Therefore, the Project would serve to reduce vehicle trips that generate GHG emissions, thereby contributing to a reduction in GHG emissions. Collaborate with local jurisdictions to provide a network of local community circulators that serve new transit-oriented development (TOD), high-quality transit areas (HQTAs), and neighborhood commercial centers. Thus, providing an incentive for residents and employees to make trips on transit. SCAG, CTCs, Local Jurisdictions Consistent. The Project would not impair the ability of SCAG, CTCs, or the City to provide such a network of local community circulators that serve new TOD, HQTAs, and neighborhood commercial centers. Artis Senior Housing Project Draft Initial Study Page 56 April 2020 Table VIII-3 (Continued) Project Consistency with the 2016-2040 RTP/SCS Actions and Strategies Responsible Party(ies) Project Consistency Analysis Develop first-mile/last-mile strategies on a local level to provide an incentive for making trips by transit, bicycling, walking, or neighborhood EV or other ZEV options. CTCs, Local Jurisdictions Consistent. The Project would not impair the CTCs or the City’s ability to develop first-mile/last-mile strategies. In support of this action/strategy, the Project would provide EV parking on-site. Transportation Demand Management (TDM) Actions and Strategies Encourage the development of telecommuting programs by employers through review and revision of policies that may discourage alternative work options. Local Jurisdictions, CTCs Consistent. The project would not impair the CTCs or City’s ability to encourage the development of telecommuting programs by employers. Emphasize active transportation and alternative fueled vehicle projects as part of complying with the Complete Streets Act (AB 1358). State, SCAG, Local Jurisdictions Consistent. The Project would not impair the CTCs or City’s ability to develop infrastructure plans and education programs to promote active transportation options and other alternative fueled vehicles. Transportation System Management (TSM) Actions and Strategies Work with relevant state and local transportation authorities to increase the efficiency of the existing transportation system. SCAG, Local Jurisdictions, State Consistent. The Project would not impair the ability of the State, SCAG, or City to work with relevant transportation authorities to increase the efficiency of the existing transportation system. Source: Southern California Association of Governments, 2016–2040 Regional Transportation Plan/Sustainable Communities Strategy, April 2016. In summary, the plan consistency analyses provided above demonstrates that the Project complies with the plans, policies, regulations, and GHG reduction actions/strategies outlined in the 2017 CARB Scoping Plan and SCAG 2016-2040 RTP/SCS. Therefore, the Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing emissions of GHGs. Furthermore, because the Project would result in a net reduction of GHG emissions and the Project is consistent with the aforementioned plans, policies, and regulations, the Project’s incremental increase in GHG emissions as described above would not result in a significant impact on the environment. Therefore, Project-specific impacts with regard to consistency with climate change programs and policies would be less than significant. IX. Hazards and Hazardous Materials Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact HAZARDS AND HAZARDOUS MATERIALS: Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? ܆ ܆ ܈ ܆ b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? ܆ ܆ ܈ ܆ Artis Senior Housing Project Draft Initial Study Page 57 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? ܆ ܆ ܆ ܈ d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? ܆ ܆ ܆ ܈ e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? ܆ ܆ ܆ ܈ f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? ܆ ܆ ܈ ܆ g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? ܆ ܆ ܆ ܈ Discussion a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Less Than Significant Impact. Materials are generally considered hazardous if they are poisonous (toxicity), can be ignited by open flame (ignitability), corrode other materials (corrosivity), or react violently, explode, or generate vapors when mixed with water (reactivity). The term “hazardous material” is defined in California Health and Safety Code as any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment (Section 25501(n)(1)). The code additionally states that a hazardous material becomes a hazardous waste once it is abandoned, discarded, or recycled. The transportation, use, and disposal of hazardous materials, as well as the potential release of hazardous materials to the environment, are closely regulated through State and federal laws. Such laws include those incorporated into the California Health and Safety Code, such as the California Hazardous Materials Release Response Plans and Inventory law and the California Hazardous Waste Control law, as well as other regulations governing hazardous waste promulgated by State and federal agencies, such as the Los Angeles County Department of Public Works, California Department of Toxic Substances Control (DTSC), California Division of Occupational Safety and Health, the Regional Water Quality Control Board, and the USEPA. Artis Senior Housing Project Draft Initial Study Page 58 April 2020 The Proposed Project would include a memory care facility, along with associated surface parking and landscaping areas. Maintenance of the facility and grounds by employees and contractors would likely involve the routine transport, use, and disposal of minor quantities of typical household hazardous materials, such as cleaning products, solvents, adhesives, refrigerants, paints, other chemical materials used in building maintenance, small amounts of oil and fuels from internal combustion engines, pesticides and herbicides, sharp or used needles, and electronic waste. This level of hazardous materials use would be typical for institutional uses and has not been identified as a significant threat to the environment. Regulations, such as those mentioned above, strictly regulate the use, transportation, and disposal of hazardous waste; they include training for employees in how to properly handle and dispose of hazardous materials, as well as filing floor plans with the Los Angeles County Fire Department showing locations of hazardous material storage. Given the age of the existing restaurant building on-site (constructed in the 1970s), there is potential for the building to contain asbestos-containing materials (ACM) and/or lead-based paint (LBP). If ACM or LBP is found during the demolition phase of construction, the applicant would be required to comply with 40 CFR Part 61, Cal OSHA rule 1529, and South Coast Air Quality Management District Rule 1403 when it comes to identification, removal, handling, and disposal of ACM. The applicant must also comply with requirements detailed in 24 CFR Part 35, Cal OSHA rule 1532.1, and 40 CFR Part 745 regarding evaluation, testing, and reducing lead-based paint hazards. Compliance with these regulations would ensure that Project-related contamination would be effectively disposed of during the demolition phase and would, therefore, have no effect on the health and safety of area residents. Based on the type of land use proposed, the relatively minor anticipated level of use, storage, and disposal of hazardous materials, and the requirement to comply with various State and federal laws regulating hazardous materials, the Project would not result in a significant impact involving the routine transport, use, or disposal of hazardous materials. Therefore, potential impacts related to hazardous materials would be less than significant. b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Less Than Significant Impact. Locations known to contain toxic substances and contamination are identified using data from DTSC. The Project Site is not identified as a clean-up site or located within one-half mile of a clean-up site listed in the DTSC EnviroStor database.56 However, the GeoTracker database, maintained by the California State Water Resources Control Board (SWRCB), identified five clean-up sites within one-half mile of the Project Site. These clean-up sites are located at 3706 Foothill Boulevard (two clean-up sites at this address), 3698 Colorado Boulevard, 4000 Foothill Boulevard, and 3880 Colorado Boulevard and are all leaking underground storage tank (LUST) clean-up sites. According to the SWRCB, each of these clean-up sites was addressing soil contamination associated with leaking gasoline tanks. Each site has been cleaned up (as of 2008), and each of the individual cases closed. Because Project-related ground disturbance would be limited to the Project Site, which is not listed on hazardous waste disposal or clean-up databases maintained by the State, the Project 56 California Department of Toxic Substances Control (DTSC), EnviroStor Database search, accessed October 21, 2019. Artis Senior Housing Project Draft Initial Study Page 59 April 2020 would not result in reasonably foreseeable upset of existing contamination located at the clean-up sites in the Project vicinity. Construction activities may also include refueling and minor maintenance of construction equipment on-site, which could lead to minor fuel and oil spills; however, as described in the response to Checklist Question X.a, below, a variety of routine construction control measures would be incorporated, including spill prevention/containment, sedimentation and erosion controls, and irrigation controls, to prevent conditions that would release hazardous materials into the environment during Project construction. Additionally, as stated above, operation of the proposed institutional facility would not result in substantial use, transport, or disposal of hazardous materials. Further, any such use, transport, and disposal of hazardous materials would be strictly regulated by State and federal laws. As such, there would not be a significant hazard to the public involving the accidental release of hazardous materials into the environment during Project operation. Therefore, the Proposed Project would not result in any reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment, and impacts would be less than significant. c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact. The nearest school to the Project Site is Hugo Reid Primary School, which is located approximately one-half mile south of the Project Site (located at 1153 de Anza Place).57 Therefore, there are no existing or proposed schools within one-quarter mile of the Project Site, and no impact would occur. d) Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. The Project Site is not included on the Cortese list, which is the list of sites compiled by DTSC under Government Code Section 65962.5. As such, the Project Site is not included on DTSC’s list of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code; land designated as hazardous waste property or border zone property pursuant to Article 11; information received regarding waste disposals on public land; all sites listed pursuant to Section 25356 of the Health and Safety Code; or all sites included in the Abandoned Site Assessment program.58,59 As such, the Proposed Project would not create a significant hazard to the public or the environment, and no impact would occur. 57 City of Arcadia, General Plan Parks, Recreation, and Community Resources Element, Figure PR-4: AUSD School Locations, November 2010. 58 California Department of Toxic Substances Control (DTSC), Cortese List: Section 65962.5(a), https://calepa.ca.gov/sitecleanup/corteselist/section-65962-5a/, accessed October 21, 2019. 59 California DTSC, EnviroStor Hazardous Waste and Substance Site List, 2019. Artis Senior Housing Project Draft Initial Study Page 60 April 2020 e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. The nearest airport to the Project Site is the San Gabriel Airport (also known as El Monte Airport), which is approximately 4.5 miles southeast. Therefore, the Project Site is not within 2 miles of a public airport and would not result in a safety hazard or excessive noise for people residing or working in the Project area, and no impact would occur. f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Less Than Significant Impact. The Project Site is currently occupied by a restaurant building, which is currently receiving police, fire, and paramedic services provided by the City of Arcadia. Access to the Project Site is currently available on Michillinda Avenue and Colorado Boulevard. The Proposed Project would have one ingress and egress point onto Colorado Boulevard, with available right-turn and left-turn egress options. Project inhabitants would have access to major thoroughfares such as Michillinda Avenue, I-210, and Foothill Boulevard (identified as a Principal Travel Corridor by the City’s General Plan) during an emergency evacuation. Further, the Proposed Project would be consistent with the General Plan land use and zoning designations. Therefore, development of the Project Site as proposed would not impair implementation of an adopted emergency response plan or evacuation plan. As such, potential impacts related to emergency response or evacuation would be less than significant. g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? No Impact. The Project Site is not located within a Very High Fire Hazard Severity Zone, as identified by the California Department of Forestry and Fire Protection.60,61 Very High Fire Hazard Severity Zones in the City of Arcadia are concentrated on the northeast side of the City, in the foothills near the Cities of Monrovia and Sierra Madre, approximately 2.1 miles northeast of the Project Site. The Project Site is in a fully urbanized area with an urban street network, a fully pressurized water system, and managed landscaping limited to decorative trees and shrubs. The Project Site does not include and is not surrounded by wildland areas, such as low-density hillside areas with large quantities of uncultivated, combustible plants. Therefore, the Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. As such, no impact related to wildland fire would occur. 60 California Department of Forestry and Fire Protection, Very High Fire Hazard Severity Zones in LRA Arcadia, September 2011. 61 City of Arcadia, General Plan Safety Element, Figure S-6: Fire Hazard Zones, November 2010. Artis Senior Housing Project Draft Initial Study Page 61 April 2020 X. Hydrology and Water Quality Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact HYDROLOGY AND WATER QUALITY: Would the project: a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? ܆ ܆ ܈ ܆ b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? ܆ ܆ ܈ ܆ c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: ܆ ܆ ܈ ܆ i) result in substantial erosion or siltation on- or off-site? ܆ ܆ ܈ ܆ ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? ܆ ܆ ܈ ܆ iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? ܆ ܆ ܈ ܆ iv) impede or redirect flood flows? ܆ ܆ ܈ ܆ d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? ܆ ܆ ܆ ܈ e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? ܆ ܆ ܈ ܆ Discussion a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less Than Significant Impact. The Los Angeles Regional Water Quality Control Board (LARWQCB) prepares and maintains a basin plan which identifies narrative and numerical water quality objectives to protect all beneficial uses of the waters of that region. The basin plan strives to achieve the identified water quality objectives through implementation of Waste Discharge Requirements (WDRs) and by employing three strategies for addressing water quality issues: control of point source pollutants, control of nonpoint source pollutants, and remediation of existing Artis Senior Housing Project Draft Initial Study Page 62 April 2020 contamination. The project site is located in the Los Angeles region and is, therefore, covered under the Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan). Point sources of pollutants are well-defined locations at which pollutants flow into water bodies (discharges from wastewater treatment plants and industrial sources, for example). These sources are controlled through regulatory systems including permitting under California’s WDRs and the NPDES program; permits are issued by the appropriate RWQCB and may set discharge limitations or other discharge provisions. According to the Basin Plan, nonpoint sources of pollutants are typically derived from project site runoff caused by rain or irrigation and have been classified by the USEPA into one of the following categories: agriculture, urban runoff, construction, hydromodification, resource extraction, silviculture, and land disposal. The Project could have both short- and long-term impacts on water quality. Short-term impacts would occur during the construction phase of the Project, when the pollutants of greatest concern are sediment, which may run off the Project site due to site grading or other site preparation activities, and hydrocarbon or fossil fuel remnants from the construction equipment. In addition, on-site watering activities to reduce airborne dust could contribute to pollutant loading in surface runoff. However, construction runoff is regulated by the NPDES Construction General Permit, which requires identification of a variety of water quality control BMPs to be specified on construction plans and implemented throughout construction. Measures are required to keep stormwater out of construction zones; conduct regular site maintenance and “good housekeeping practices” to prevent, minimize, and dispose of solid and liquid wastes; capture and control any site runoff so that water pollutants don’t enter storm drains; and have response procedures in place in the event of accidental spills of water contaminants. This permit applies to all construction which disturbs an area of at least 1 acre and is administered by the relevant RWQCB. As stated in response to Checklist Question VII.b of this Initial Study, the City would require the preparation of a Stormwater Pollution Prevention Plan for the Proposed Project, which would establish erosion and sedimentation controls, such as methods to minimize the footprint of the disturbed area, controls to prevent tracking off-site, spill prevention, non-stormwater controls (i.e., vehicle washing), and methods to protect native vegetation and trees. Further, the City would require a NPDES Construction General Permit for discharge of stormwater associated with Project construction activities. Through these existing, mandatory regulatory compliance measures, potential water quality impacts during construction would be avoided or reduced to less than significant levels and would avoid conflicts with water quality standards established by the LARWQCB. Long-term impacts would result from operation of the completed Project. Such impacts could result from stormwater runoff of impervious surfaces on the Project site. The Project is considered a Planning Priority Project as it is a development equal to or greater than 1 acre in size that adds more than 10,000 square feet of impervious surface area. As such, the Project would require a Low Impact Development Plan (LID Plan), which would be reviewed and approved through the City’s plan check process, to comply with the following requirements:62 ƒ Retain stormwater runoff on-site for the Stormwater Quality Design Volume (SWQDv) defined as the runoff from: 62 City of Arcadia, Code of Ordinances, Article VII, Chapter 8, Part 2, Section 7828, Low Impact Development – Control of Runoff Required for Planning Priority Projects. Artis Senior Housing Project Draft Initial Study Page 63 April 2020 o The 85th percentile 24-hour runoff event as determined from the Los Angeles County 85th percentile precipitation isohyetal map; or o The volume of runoff produced from a 0.75 inch, 24-hour rain event, whichever is greater. ƒ Minimize hydromodification impacts to natural drainage systems. ƒ When, as determined by the City, 100 percent on-site retention of the SWQDv is technically infeasible, the infeasibility shall be demonstrated in the submitted LID plan. If partial or complete on-site retention is technically infeasible, the Project Site may biofiltrate 1.5 times the portion of the remaining SWQDv that is not reliably retained on-site. BMPs required by the City’s LID ordinance include ensuring sidewalks fronting the Project Site are clear of dirt or litter; cleaning parking lots with 25 or more spaces as frequently and thoroughly as practicable; diverting surface and roof flows to landscaped areas before discharge; and treating any portion of the SWQDv that cannot be retained or biofiltered on-site in order to reduce pollutant loading. Therefore, with conformance to the City’s LID requirements and incorporation of required construction and post-construction BMPs, the Project would not result in the violation of any water quality standards or WDRs, and impacts would be less than significant. b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less Than Significant Impact. The City is a retail water supplier that serves the majority of its residents. In 2016, the City prepared the most recent Urban Water Management Plan (UWMP) in cooperation with other water-serving agencies in the surrounding region. The City is a subagency of the Upper San Gabriel Valley Municipal Water District (Upper District), a wholesale water agency. The UWMP states that the City currently derives its water supply from groundwater wells that produce water from two groundwater basins: the Main San Gabriel Basin (the City’s main groundwater source) and the Raymond Basin. In the 2014-2015 fiscal year, the City pumped a total of 12,010 acre-feet from the Main Basin and 3,316 acre-feet from the Raymond Basin.63 Further, the City can purchase imported water from the Metropolitan Water District of Southern California (MWD); however, the City does not typically use this alternative (the last time water was imported was in the 2009-2010 fiscal year) because the City’s groundwater supplies are sufficient to meet water demands.64 The City owns and operates seven active groundwater wells in the Main Basin, with a collective capacity of 15,200 gallons per minute (gpm). Additionally, there are seven groundwater wells in the Raymond Basin, with a collective capacity of 4,300 gpm.65 The UWMP concluded that based on current management practices, including reduced pumping in the Raymond Basin, the City would be able to rely on the Main Basin, the Raymond Basin, and imported water for adequate supply for 20 years (as of publication of the UWMP in 2016), under single-year and multiple-year drought scenarios. There are no groundwater wells on the Project Site and none are proposed. Further, the Proposed Project would not involve a General Plan amendment or zone change. The City’s UWMP has 63 City of Arcadia, 2015 Urban Water Management Plan , prepared by Stetson Engineers, Inc., Page 6-1, June 2016. 64 City of Arcadia, 2015 Urban Water Management Plan , prepared by Stetson Engineers, Inc., June 2016. 65 City of Arcadia, 2015 Urban Water Management Plan , prepared by Stetson Engineers, Inc., June 2016. Artis Senior Housing Project Draft Initial Study Page 64 April 2020 accounted for future water consumption of existing and planned land uses, such as the Proposed Project. Operation of the Proposed Project would not interfere with groundwater recharge. The Project Site is located in an urbanized area and is currently developed with a restaurant building and a surface parking lot. The Proposed Project would replace these existing improvements with an approximately 44,000-square-foot assisted living and memory care facility surrounded by surface parking, drive aisles, outdoor walking paths and community areas, and managed landscaping. As such, the Proposed Project would reduce, but not substantially change, the amount of impervious surface area on-site to affect groundwater levels beneath the Project Site. If groundwater levels were to be affected, the effect would be minimal and likely beneficial given the Project’s reduction in overall impervious surfaces as compared with existing conditions. Therefore, the Project would not substantially deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. Impacts to groundwater would be less than significant. c.i) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site? Less Than Significant Impact. The Project Site is fully developed and landscaped and does not contain any natural drainage courses. There is also no historical evidence of localized ponding or flooding on the Project Site. Because the Project Site is currently fully developed, the Proposed Project would not result in a substantial alteration of the existing drainage pattern, as the Proposed Project would continue to discharge excess stormwater into the City’s storm sewer system. Construction and operation of the Proposed Project could result in some erosion or siltation on- or off-site. As stated in the response to Checklist Question VII.b of this Initial Study, erosion of uncovered soils during construction activities would be prevented by complying with the NPDES Construction General Permit requirements, which require construction activities to incorporate BMPs to prevent erosion off-site. Additionally, because the Proposed Site is greater than 1 acre, the City requires the preparation of a Stormwater Pollution Prevention Plan, which would establish erosion and sedimentation controls. Otherwise, the operation of the Proposed Project would result in almost the entire site covered in either impervious surfaces, such as the building, surrounding parking areas, outdoor structures (i.e., outdoor gathering spaces, refuse and generator enclosures, and storage shed), and concrete walkways, as well as managed landscaped areas. Because almost the entire site would be covered by either impervious surfaces or managed gardens/turf areas, there would be very little potential for erosion during long-term operation of the Project. Therefore, the Project would not substantially alter the existing drainage pattern of the Project Site or area in a manner that would result in erosion or siltation, on- or off-site, and impacts related to erosion and siltation would be less than significant. Artis Senior Housing Project Draft Initial Study Page 65 April 2020 c.ii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Less Than Significant Impact. As stated in response to Checklist Question X.c.i, the existing, relatively flat Project Site is fully developed with a restaurant building and an impervious, surface parking lot. Therefore, the Proposed Project, which would include a slight reduction in impervious surfaces due to the increase in landscaped areas, would not result in a substantial alteration of the existing drainage pattern of the Project Site. Because the Project Site is not located within a Federal Emergency Management Agency (FEMA) Flood Hazard Zone (the Project Site is located in a Zone X, Area of Minimal Flood Hazard), there is no evidence that the site or the immediately surrounding area is subject to flooding.66 Therefore, potential impacts of the Proposed Project on local drainage and flooding would be less than significant. c.iii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Less Than Significant Impact. See the responses to Thresholds X.c.i and X.c.ii, above. The existing, relatively flat Project Site is fully developed with a restaurant building and an impervious, surface parking lot. Therefore, the Proposed Project, which would include a slight reduction in impervious surfaces, would not result in a substantial alteration of the existing drainage pattern of the Project Site. As the Proposed Project would increase the total amount of pervious landscape areas on the Project Site, it would not contribute additional runoff as compared with existing conditions. Further, the Project would be required to develop a LID Plan, which would retain stormwater runoff on-site for the SWQDv defined as the runoff from the 85th percentile 24-hour runoff event. Further, the SWPPP discussed above would prevent discharge of sediment or other water pollution commonly generated by Project construction. Therefore, the Proposed Project would not alter the existing drainage pattern of the site or area in a manner which would create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems. As such, potential impacts of the Proposed Project on stormwater drainage systems would be less than significant. c.iv) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows? Less Than Significant Impact. As stated above, the Project Site is located within a Zone X, Area of Minimal Flood Hazard, according to the FEMA Flood Insurance Rate Map for the area. Further, because the project would not substantially alter the existing drainage pattern of the Project Site, the Project would not alter the site or area in a manner which would impede or redirect flood flows, and impacts would be less than significant. 66 Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map 06037C1400F, September 26, 2008. Artis Senior Housing Project Draft Initial Study Page 66 April 2020 d) Would the project in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? No Impact. A seiche is the sudden oscillation of water that occurs in an enclosed, landlocked body of water due to wind, earthquake, or other factors. There are no reservoirs or other bodies of water near the Project Site that could result in seiche impacts to the Project; therefore, the Project would not place structures in areas subject to inundation by seiche. A tsunami is an unusually large wave or set of waves that is triggered in most cases by a seaquake or an underwater volcanic eruption. The Project Site is located more than 25 miles away from the Pacific Ocean. Given this distance, the Project would not place structures in areas subject to inundation by tsunami. Finally, as stated above, the Project Site is located within a Zone X, Area of Minimal Flood Hazard, according to the FEMA Flood Insurance Rate Map for the area. However, the Project Site is located within a designated inundation area for the Morris S. Jones Reservoir. As stated in the General Plan Safety Element, the dams above Arcadia are regulated and monitored for structural safety by the California Department of Water Resources, in accordance with Division 3 of the California State Water Code. Such regulation reduces the chance of catastrophic failure and inundation of downstream areas, such as the Project Site.67 Water quality controls on-site, such as maintenance of landscape areas, and proper storage of any hazardous materials would prevent the release of pollutants in the unlikely event that the Project Site would be inundated by catastrophic dam failure. Therefore, the Project Site is not located within a flood hazard, tsunami, or seiche zone and would have no impact as it relates to the release of pollutants due to flood-, tsunami-, or seiche-related inundation. e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Less Than Significant Impact. As stated above, the City of Arcadia’s 2015 UWMP states that the Main Basin groundwater supply is the City’s main source of water, accounting for approximately 78 percent of the City’s water supply. The Main Basin Watermaster, an organization created in the 1970s to resolve water demand issues that arose in the San Gabriel Basin, is tasked with general management of the groundwater basin, including addressing volatile organic compound (VOC) contamination that was discovered in the 1970s and 1980s. The Watermaster’s Five Year Water Quality and Supply Plan is an annually updated document that projects both water supply and water quality. In the 2019 plan update (2019 Supply Plan), the Watermaster reports that total groundwater production for the Main Basin in fiscal year 2018-2019 was 189,100 acre-feet, which is lower than the 10-year average of 203,000 acre-feet.68 While groundwater production has experienced a general long-term increase, corresponding to a population increase in the Main Basin’s service area, a gradual decrease in production since the late 2000s is likely resulting from increased water conservation practices by consumers. The 2019 Supply Plan shows that 2018-2019 fiscal year groundwater production in the City of Arcadia was approximately 10,774 acre-feet and projects groundwater demands to fluctuate between 9,565 and 10,953 acre-feet between the 2019-2020 and the 2023-2024 fiscal years.69 Further, the groundwater elevations at all seven of the Main Basin groundwater wells in the City of Arcadia are projected to increase between 2018 and 2024, indicating a projected increase in water supplies.70 Lastly, 67 City of Arcadia, General Plan Safety Element, November 2010. 68 Main San Gabriel Basin Watermaster, Five-Year Water Quality and Supply Plan, Figure 10, November 2019. 69 Main San Gabriel Basin Watermaster, Five-Year Water Quality and Supply Plan, Appendix A, November 2019. 70 Main San Gabriel Basin Watermaster, Five-Year Water Quality and Supply Plan, Appendix B, November 2019. Artis Senior Housing Project Draft Initial Study Page 67 April 2020 the 2019 Supply Plan details how the Watermaster coordinates with local and regional agencies to monitor groundwater quality and potential groundwater well contamination points. Because the Proposed Project would not result in a substantial increase in potable water demand, and because it would not involve the use, disposal, or storage of hazardous chemicals that could impact water quality, the Proposed Project would not interfere with the Main Basin Watermaster’s 2019 Supply Plan, and impacts would be less than significant. XI. Land Use and Planning Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact LAND USE AND PLANNING: Would the project: a) Physically divide an established community? ܆ ܆ ܆ ܈ b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? ܆ ܆ ܈ ܆ Discussion a) Would the project physically divide an established community? No Impact. As shown in Figure A-13, Aerial View of the Project Site and Surroundings, of this Initial Study, the Project Site is located within a fully urbanized area where the built environment consists of single-family residential uses to the east and south, commercial uses to the west, and I-210 to the north. The physical arrangement of the surrounding private lots, streets, and utility infrastructure has been established for many years. The Proposed Project would use an existing public street (Colorado Boulevard) for access to the senior living facility and would connect to existing utilities in adjacent streets. The Proposed Project would not result in the construction of a linear feature, such as railroad tracks, a flood control channel, or a major roadway, or the removal of a means of access that would result in a physical division of an established community. No physical alterations to any land use or the physical structure of this part of the City of Arcadia are proposed outside of the Project Site. Therefore, the Proposed Project would not physically divide an established community and there would be no impact. b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Less Than Significant Impact. As stated in the Project Description of this Initial Study, the existing General Plan land use designation for the Project Site is Commercial, with a corresponding zoning of C-G, General Commercial. A residential care facility is allowed within the C-G, General Commercial with an approved CUP.71 The Project Site is also included within two existing overlay zones, the Architectural Design Overlay Zone and the Automobile Parking Overlay Zone. The Architectural Design Overlay Zone states that various building design characteristics (such as building exterior materials, roof pitch, window size, landscaping, and automobile parking area) shall be subject to 71 City of Arcadia, Development Code Section 9102.03.020. Artis Senior Housing Project Draft Initial Study Page 68 April 2020 Planning Commission review and approval. Further, the Architectural Design Overlay Zone states that only one free-standing sign shall be permitted and located within 100 feet of the northern and western property lines, the maximum building height shall not reach 30 feet above ground level, and no structure erected or permitted shall exceed 19,500 square feet of ground floor area.72,73 The Automobile Parking overlay zone states that the overlay area shall be limited to ground level parking only. As part of the Project, the Applicant has requested a zone change to remove these two overlay zones. Regardless, the Project would not represent a substantial change in urban form over existing conditions. More specifically, the eastern portion of the Project Site, which is currently included within the Automobile Parking Overlay Zone, would remain as surface parking under the Proposed Project conditions. The southern portion of the Project Site, which is also included within the Automobile Parking Overlay Zone, would include developed open space with no above-ground structures except a small storage shed in the southeastern corner of the Project Site and an eight-foot-high decorative fence around the perimeter of the open space area. Further, the majority of the proposed memory care facility located on the northeastern portion of the Project Site would be limited to 30 feet in height, consistent with the existing Architectural Design Overlay Zone, with only the north-central portion of the facility extending to 37.5 feet in height (with an additional 2.5-foot-high decorative cupola). With the removal of these two overlay zones, development on the Project Site would be regulated by the development standards of the underlying General Commercial (C-G) zone, such as regulations regarding building height and setback distance from residential land uses. These development standards include, but are not limited to, a 40-foot building height maximum and a 20- foot building setback when abutting residential uses. Based on the Project details included in the Project Description, the Project would be consistent with the development standards and regulation of the underlying General Commercial (C-G) zone upon approval of a CUP. Further, the Arcadia General Plan Parks, Recreation, and Community Resources Element does not identify any land use restrictions for the Project Site that would require conservation of the Project Site for purposes of protecting wildlife habitat or other natural resources. There are no policies in the Safety Element that establish land use restrictions for the Project Site pertaining to avoidance of environmental hazards on or near the Project Site. The Project Site is not within an area where special land use policies or zoning standards have been created for the purpose of avoiding or mitigating environmental effects, nor is it within a local coastal program. As such, the Project would not conflict with an applicable land use plan, policy, or regulation established for the purpose of avoiding or mitigating an environmental effect, and impacts related to land use and planning would be less than significant. 72 City of Arcadia Resolution No. 4440, signed and approved July 2, 1974. 73 City of Arcadia Ordinance No. 1510, signed and approved July 16, 1974. Artis Senior Housing Project Draft Initial Study Page 69 April 2020 XII. Mineral Resources Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact MINERAL RESOURCES: Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? ܆ ܆ ܆ ܈ b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? ܆ ܆ ܆ ܈ Discussion a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? No Impact. The Project Site is located within a fully urbanized area and is currently developed with a restaurant building and a surface parking lot. The City’s General Plan EIR Mineral Resources Section states that there are no oil, gas, or geothermal resources within the City of Arcadia.74 The only oil well in the City of Arcadia is owned by the Vosburgh Oil Corporation and is plugged and abandoned.75 Because this well is abandoned and located approximately 2.5 miles southeast of the Project Site, the Project Site is not located within any known oil, gas, or geothermal resource areas, and the Project Site is already developed with a non-extraction use, the Project would not result in the loss of availability of a known mineral resource that would be of regional or Statewide value. Therefore, no impact to mineral resources would occur. b) Would the project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? No Impact. As stated above, the Project Site is located in a fully urbanized area and is currently developed with a restaurant building and a surface parking lot. The City’s General Plan EIR Mineral Resources section states that the Project Site is located within a Mineral Resource Zone-3 (MRZ-3) area, which is composed of the northwestern and southern portions of the City where the available data which would be used to determine the significance of mineral deposits are unavailable.76 Other areas of the City, including areas along the Sierra Madre Wash, Santa Anita Wash, and the San Gabriel River, are designated as MRZ-2 because significant mineral deposits may be present and development in such areas should be controlled. The City’s General Plan EIR identifies four sites within the City that are located within MRZ-2 zones and remain undeveloped at the time of the General Plan update in 2010. These are the Los Angeles County flood control wash and infiltration basin, the former Rodeffer sand and gravel excavation site, the Peck Road Spreading Basins/Water Conservation Park, and the Livingston-Graham sand and gravel excavation site. The Project Site is not located within or adjacent to these MRZ-2 locations. Therefore, the Proposed Project would not result in the loss of 74 City of Arcadia, General Plan Update Draft Program EIR, Section 4.10 Mineral Resources, July 2010. 75 California Department of Conservation, Department of Oil, Gas, and Geothermal Resources, Well Finder online mapping application, map generated December 3, 2019. 76 City of Arcadia, General Plan Update Draft Program EIR, Exhibit 4.10-1, July 2010. Artis Senior Housing Project Draft Initial Study Page 70 April 2020 availability of a locally important mineral resource recovery site delineated on a local general plan. As such, no impact to mineral resources would occur. XIII. Noise Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact NOISE: Would the project result in: a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? ܆ ܈ ܆ ܆ b) Generation of excessive groundborne vibration or groundborne noise levels? ܆ ܆ ܈ ܆ c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? ܆ ܆ ܆ ܈ Discussion a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Less Than Significant Impact with Mitigation Incorporated. The Project vicinity consists of residential and commercial uses. The primary sources of stationary noise in the Project vicinity are urban activities (e.g., mechanical equipment, HVAC units, and parking areas). The noise associated with these sources may represent a single-event noise occurrence, or short-term or long- term/continuous noise. The majority of existing noise in the Project vicinity is generated by vehicular sources along I-210 and Colorado Boulevard. According to the Arcadia General Plan, traffic noise levels along I-210 and Colorado Boulevard range from 60 to 85 dBA CNEL. Additionally, aircraft overflights and trains are a source of noise in the City of Arcadia. To quantify existing ambient noise levels in the Project vicinity, three noise measurements were taken on December 11, 2019 (see Table XIII-1). The noise measurement sites were representative of typical existing noise exposure within and immediately adjacent to the Project Site. Ten-minute measurements were taken between 10:00 a.m. and 11:30 a.m. Short-term (Leq) measurements are considered representative of the noise levels throughout the day. Artis Senior Housing Project Draft Initial Study Page 71 April 2020 Table XIII-1 Noise Measurements Site No. Location Leq (dBA) Lmin (dBA) Lmax (dBA) Peak (dBA) Time 1 In front of 1159 Altura Terrace, Arcadia, CA 91007 73.5 93.3 47.8 100.3 10:09 a.m. 2 Northeast corner of Catalpa Road and North Altura Road 55.5 67.7 51.3 87.2 10:26 a.m. 3 Corner of 21 South Michillinda Avenue, adjacent to Michillinda Avenue 66.8 79.9 58.8 99.4 10:57 a.m. Notes: dBA = A-weighted decibels; Leq = Equivalent Sound Level; Lmin = Minimum Sound Level; Lmax = Maximum Sound Level Source: Michael Baker International, December 11, 2019, available as Appendix D of this Initial Study. Construction Construction of the Proposed Project would occur over approximately 19 months and would include demolition, grading, paving, building construction, and architectural coating. Ground-borne noise and other types of construction-related noise impacts would typically occur during the grading phase. This phase of construction has the potential to create the highest levels of noise. Typical noise levels generated by construction equipment are shown in Table XIII-2. It should be noted that the noise levels identified in Table XIII-2 are maximum sound levels (Lmax), which are the highest individual sounds occurring at an individual time period. Operating cycles for these types of construction equipment may involve one or two minutes of full power operation followed by three to four minutes at lower power settings. Other primary sources of acoustical disturbance would be due to random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts). Table XIII-2 Maximum Noise Levels Generated by Construction Equipment Type of Equipment Acoustical Use Factor1 Lmax at 10 Feet (dBA) Lmax at 50 Feet (dBA) Concrete Saw 20 104 90 Crane 16 93 81 Concrete Mixer Truck 40 93 79 Backhoe 40 92 78 Dozer 40 96 82 Excavator 40 95 81 Forklift 40 92 78 Paver 50 91 77 Roller 20 94 80 Tractor 40 98 84 Water Truck 40 94 80 Grader 40 99 85 General Industrial Equipment 50 99 85 Notes: dBA = A-weighted decibels; Lmax = Maximum Sound Level 1. Acoustical Use Factor (percent): Estimates the fraction of time each piece of construction equipment is operating at full power (i.e., its loudest condition) during a construction operation. Source: Federal Highway Administration, Roadway Construction Noise Model (FHWA-HEP-05-054), January 2006. Artis Senior Housing Project Draft Initial Study Page 72 April 2020 Pursuant to Arcadia Municipal Code Article IV, Chapter 2, Disorderly Conduct, Nuisances, Etc., construction activities may only occur between the hours of 7:00 a.m. and 6:00 p.m. Monday through Friday, and between 8:00 a.m. and 5:00 p.m. on Saturday. Construction activities are prohibited on Sundays and holidays. These permitted hours of construction are included in the Arcadia Municipal Code in recognition that construction activities undertaken during daytime hours are a typical part of living in an urban environment and do not cause a significant disruption. The potential for construction-related noise to affect nearby residential receptors would depend on the location and proximity of construction activities to these receptors. Construction would occur throughout the Project Site and would not be concentrated or confined in the area directly adjacent to sensitive receptors. Therefore, construction noise would be acoustically dispersed throughout the Project Site and not concentrated in one area near adjacent sensitive uses. It should be noted that the noise levels depicted in Table XIII-2 are maximum noise levels, which would occur sporadically when construction equipment is operated in proximity to sensitive receptors. The closest existing sensitive receptors are residents adjoining (i.e., approximately 10 feet) the Project Site to the east and south. As indicated in Table XIII-2, typical construction noise levels would range from approximately 91 to 104 dBA at this distance. Although construction noise is allowed during the City’s allowable construction hours and is not considered to be a significant impact during those hours, the Project could expose adjoining residential uses to temporary high noise levels (91 to 104 dBA) during construction activities. Consequently, Mitigation Measure NOI-1 is recommended to reduce short-term construction noise impacts through noise reduction methods. Mitigation Measure NOI-1 requires all construction equipment to be equipped with properly operating and maintained mufflers, stationary construction equipment to be located such that emitted noise is directed away from the nearest noise sensitive receptors, and equipment staging is in areas farthest away from sensitive receptors. Implementation of Mitigation Measure NOI-1 would ensure that construction noise impacts at nearby sensitive receptors do not interfere with normal residential activities. Therefore, with implementation of Mitigation Measure NOI-1, noise impact from construction activities would be considered less than significant. Operation Mobile Noise The existing Coco’s Restaurant generates approximately 582 trips per day, and the Proposed Project would generate approximately 208 trips per day.77 Therefore, the Proposed Project would generate a net decrease of approximately 374 daily trips when compared to the existing use. As such, the Project’s trip generation would reduce existing traffic volumes and, in turn, reduce traffic noise levels along local roadways. Therefore, Project-related traffic noise would be less than significant. In addition to the mobile sources of noise identified above, the Project vicinity may also be impacted by noise generated by emergency ambulance visits to the Project Site. While there may be a perception that the proposed use would result in a greater number of ambulance visits to the area than the existing commercial use, it is not possible and highly speculative to predict medical emergencies that require visits from emergency vehicles. Ambulances traveling to and from the Project Site would likely use high-volume transit corridors, such as Colorado Boulevard and Michillinda Avenue, to access the Project Site, rather than passing through the residential neighborhoods to the east and south. Further, the decision to use a siren and lights is made by the vehicle driver and is dependent upon traffic 77 Michael Baker International, Artis Senior Assisted Living Facility Trip Generation Analysis, December 17, 2019. Artis Senior Housing Project Draft Initial Study Page 73 April 2020 conditions and the welfare of the patient. As such, emergency response vehicles may not engage the siren in every instance and would likely turn off the siren upon arriving at the facility. Thus, because an ambulance siren may not be engaged in every emergency response situation, and because a siren would likely be turned off upon arrival, noise impacts resulting from ambulance visits to the Project Site are anticipated to be infrequent and short-lived in nature. Additionally, the proposed memory care facility would employ medical staff who would be able to address non-life-threatening medical emergencies, such as minor injuries and falls, thus reducing the number of visits from rapid-response emergency vehicles. Regular trips by Project residents to health care facilities would be accommodated through family members or other non-emergency medical transport services, none of which would be equipped with sirens. Finally, Arcadia Municipal Code Section 4610.1(I) exempts emergency vehicles from the restrictions placed on sound amplifying equipment. Therefore, Project-related ambulance noise associated with the Project would be less than significant. Stationary Noise Stationary noise sources associated with the Proposed Project would include mechanical equipment, slow-moving trucks, and parking activities. These noise sources are typically intermittent and short in duration and would be comparable to existing sources of noise experienced in the Project vicinity. Mechanical Equipment Typically, mechanical equipment can result in noise levels of approximately 55 dBA at 50 feet from the source. Mechanical equipment (e.g., HVAC units and emergency generators) for the Project would be located in fully enclosed spaces throughout the proposed senior living facility. Therefore, the Project would not place mechanical equipment near sensitive receptors (i.e., existing residences adjoining the Project Site to the east and south). As such, noise from mechanical equipment would not be perceptible at the closest sensitive receptors. Impacts from mechanical equipment would be less than significant. Slow-Moving Trucks The Proposed Project may involve occasional deliveries and trash/recycling pickups from slow- moving trucks. Typically, a medium two-axle delivery truck can generate a maximum noise level of 75 dBA at a distance of 50 feet.78 This maximum noise level is assumed to be generated by a truck that is operated by an experienced “reasonable” driver with typically applied accelerations. Noise associated with deliveries and trash/recycling pickups would be consistent with the existing noise environment, as these activities already occur at the commercial uses in the surrounding area. Additionally, slow- moving truck noise would be intermittent, short in duration, and would not generate excessive noise levels over an extended period of time. Therefore, impacts resulting from truck delivery activities would be less than significant. Parking Areas Traffic associated with senior living facility parking areas is typically not of sufficient volume to exceed community noise standards, which are based on a time-averaged scale such as the Day-Night Sound Level (Ldn) scale. However, the instantaneous maximum sound levels generated by a car door slamming, engine starting up, and car pass-bys may be an annoyance to adjacent noise-sensitive receptors. Estimates of the maximum noise levels associated with some parking activities are presented 78 Measurements taken by Michael Baker International in 2006. Artis Senior Housing Project Draft Initial Study Page 74 April 2020 in Table XIII-3. The Project proposes a surface parking lot with approximately 55 regular parking stalls and 4 parking stalls that comply with Americans with Disabilities Act (ADA) requirements. Table XIII-3 Maximum Noise Levels Generated by Parking Lots Noise Source Maximum Noise Levels at 10 Feet from Source Maximum Noise Levels at 50 Feet from Source Car door slamming 75.0 dBA Leq 61 dBA Leq Car starting 74.0 dBA Leq 60 dBA Leq Car idling 67.0 dBA Leq 53 dBA Leq Notes: dBA = A-weighted Decibels; Leq = Equivalent Sound Level Source: Kariel, H. G., “Noise in Rural Recreational Environments,” Canadian Acoustics 19(5), 3-10, 1991. It should be noted that parking lot noise generates instantaneous noise levels compared to noise standards in the Ldn scale, which are averaged over time. As a result, actual noise levels over time resulting from parking lot activities would be far lower. The adjoining residences to the east and south would be located approximately 10 feet from the proposed surface parking lot. As such, parking lot noise levels would be approximately 67 to 75 dBA at these sensitive receptors. However, parking lot activities and associated noise levels are intermittent and sporadic, and an existing parking lot is located within the same distance to the nearest adjoining residences as the proposed surface parking lot. Therefore, as the Project would not introduce a new source of noise in the Project vicinity, and parking lot noise would be infrequent, noise impacts would be less than significant. Mitigation Measure NOI-1 Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Planning Division, that the Project complies with the following: x Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. x The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on-site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Planning & Community Development Administrator (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. Artis Senior Housing Project Draft Initial Study Page 75 April 2020 x During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. x Prior to issuance of any Grading or Building Permit, the Project applicant shall demonstrate to the satisfaction of the Community Development Director (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. x Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels? Less Than Significant Impact. Project construction can generate varying degrees of ground-borne vibration, depending on the construction procedure and construction equipment used. Operation of construction equipment generates vibrations that spread through the ground and diminish in amplitude with distance from the source. The effect on buildings located in the vicinity of the construction site often varies depending on soil type, ground strata, and construction characteristics of the receiver building(s). The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibrations from construction activities rarely reach levels that damage structures. Construction vibration impacts include human annoyance and building damage. Human annoyance occurs when construction vibration rises significantly above the threshold of human perception for extended periods of time. Building damage can be cosmetic or structural. Ordinary buildings that are not particularly fragile would not experience any cosmetic damage (e.g., plaster cracks) at distances beyond 30 feet. This distance can vary substantially depending on the soil composition and underground geological layer between vibration source and receiver. In addition, not all buildings respond similarly to vibration generated by construction equipment. For example, buildings that are constructed with typical timber frames and masonry show that a vibration level of up to 0.2 inch-per- second peak particle velocity (PPV) is considered safe and would not result in any construction vibration damage.79 The City currently does not have a significance threshold to assess construction vibration impacts.80 Therefore, this analysis uses the Federal Transit Administration (FTA) architectural damage criterion for continuous vibrations at non-engineered timber and masonry buildings of 0.2 inch-per-second PPV and human annoyance criterion of 0.2 inch-per-second PPV in accordance with California Department of Transportation (Caltrans) guidance.81 The FTA has 79 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018. 80 City of Arcadia Municipal Code Article IX, Division 3, Section 9103.13, Performance Standards, exempts vibration generated from construction activities. 81 California Department of Transportation, Transportation and Construction Vibration Guidance Manual, Table 20, September 2013. Artis Senior Housing Project Draft Initial Study Page 76 April 2020 published standard vibration velocities for construction equipment operations. The vibration levels produced by construction equipment is illustrated in Table XIII-4. Table XIII-4 Typical Vibration Levels for Construction Equipment Equipment Approximate peak particle velocity at 28 feet (inches/second)a Approximate peak particle velocity at 40 feet (inches/second)a Vibratory roller 0.177 0.104 Large bulldozer 0.075 0.044 Loaded trucks 0.064 0.038 Jackhammer 0.030 0.017 Small bulldozer 0.003 0.001 Notes: a Calculated using the following formula: PPV equip = PPVref x (25/D)1.5 where: PPV (equip) = the peak particle velocity in in/sec of the equipment adjusted for the distance PPV (ref) = the reference vibration level in in/sec from Table 7-4 of the FTA Transit Noise and Vibration Impact Assessment Manual D = the distance from the equipment to the receiver Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018. Ground-borne vibration decreases rapidly with distance. The nearest structures are located approximately 28 feet to the south and 40 feet to the east of the proposed construction activities. As indicated in Table XIII-4, vibration velocities from typical heavy construction equipment used during Project construction would range from 0.003 (a small bulldozer) to 0.177 (vibratory roller) inch-per- second PPV at the nearest structure (i.e., 28 feet) from the source of activity, which would not exceed FTA’s 0.2 inch-per-second PPV threshold. Further, construction vibration would not cause excessive human annoyance as the highest ground-borne vibration nearest sensitive receptors (i.e., 0.177 inch- per-second PPV) would not exceed the 0.2 inch-per-second PPV human annoyance criteria. Therefore, the proposed construction activities associated with the Project would not expose sensitive receptors to excessive ground-borne vibration levels. As such, vibration impacts associated with construction would be less than significant. c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? No Impact. The nearest airport to the Project Site is the San Gabriel Airport (also known as El Monte Airport), which is approximately 4.5 miles to the southeast. According to the County of Los Angeles’ Airports and Airport Influence Areas Map , the Project Site is not located within the El Monte Airport Influence Area.82 Additionally, the Project Site is not located within the vicinity of a private airstrip or related facilities. Therefore, Project implementation would not expose people residing or working in the Project area to excessive noise levels associated with aircraft, and no impacts would occur. 82 County of Los Angeles, Airports and Airport Influence Areas Map, http://planning.lacounty.gov/assets/upl/project/ALUC_Airports_Aug2018_rev3.pdf, accessed December 26, 2019. Artis Senior Housing Project Draft Initial Study Page 77 April 2020 XIV. Population and Housing Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact POPULATION AND HOUSING: Would the project: a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? ܆ ܆ ܈ ܆ b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? ܆ ܆ ܆ ܈ Discussion a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Less Than Significant. The Proposed Project would construct an 80-bed senior-living, memory care facility; however, it would not include construction of growth-inducing infrastructure, such as roadway or utility extensions to areas not already provided with such services. The Project is anticipated to generate approximately 80 residents and approximately 40 employees.83,84 Because the Project is consistent with the underlying zoning and General Plan designation for the parcel, the population growth associated with the Project would have been anticipated and planned for in the City of Arcadia General Plan. Further, the SCAG 2016-2040 RTP/SCS provides population and employment growth estimates for municipalities within its jurisdiction, including the City of Arcadia. The 2016-2040 RTP/SCS estimates that population in Arcadia will increase from 56,700 in 2012 to 65,900 by 2040, and employment would increase from 28,900 in 2012 to 34,400 in 2040.85 Using these growth forecasts, the Proposed Project would account for approximately 0.9 percent of forecasted population growth between 2012 and 2040 and 0.7 percent of forecasted employment growth between 2012 and 2040 in the City of Arcadia. As such, the Proposed Project would not result in substantial unplanned population growth in the area, either directly or indirectly and impacts would be less than significant. b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? No Impact. The Project Site currently contains a restaurant building and surface parking lots and does not currently contain any housing units. Thus, there are no current on-site residents or housing 83 Employees were calculated using the Southern California Association of Government’s Employment Density Report, which provided an average employee density of 14.24 employees per acre for Special Care Facilities in Los Angeles County. As the Project Site is 2.79 acres in size, the estimated number of employees serving the project would be 40. 84 Southern California Association of Governments (SCAG), Employment Density Study Summary Report, Table B-1, Employment Densities (employees per acre) by Anderson Code, All Counties, 2001. 85 Southern California Association of Governments, Appendix, Demographics and Growth Forecast, Table 11, April 2016. Artis Senior Housing Project Draft Initial Study Page 78 April 2020 units on the Project Site that would be displaced as part of the Proposed Project. Therefore, there would be no impact. XV. Public Services Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact PUBLIC SERVICES: a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: ܆ ܆ ܆ ܆ i) Fire protection? ܆ ܆ ܈ ܆ ii) Police protection? ܆ ܆ ܈ ܆ iii) Schools? ܆ ܆ ܆ ܈ iv) Parks? ܆ ܆ ܆ ܈ v) Other public facilities? ܆ ܆ ܆ ܈ Discussion a.i) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection? Less Than Significant Impact. The development of 80 assisted living and memory care residential units, along with landscaping, outdoor living areas, drive aisles, and a surface parking lot, would incrementally increase the demand for fire protection and emergency medical services. In compliance with Standard Condition 4.13-1 in the City’s General Plan EIR, new development in the City must comply with the California Fire Code and Arcadia Fire Department regulations pertaining to building construction, fire flows and pressures, hydrant placement, and other requirements that would reduce the creation of fire hazards and would facilitate emergency response. Further, building plans and structures are reviewed by the Arcadia Fire Department for compliance with applicable safety and emergency access standards. This review would determine if fire flow (1,000 gallons per minute for two hours for residential construction), access, and fire hydrant placement would be sufficient or if expanded facilities are required. Upon review of the Project’s Site plan, the Arcadia Fire Department determined that site circulation and emergency access would be sufficient to accommodate a fire engine. Artis Senior Housing Project Draft Initial Study Page 79 April 2020 Therefore, with compliance with California Fire Code and Arcadia Fire Department regulations governing hydrant placement, fire flows, and building construction, and with the Arcadia Fire Department’s review and approval of the Project Site’s access and circulation plans, the Project would have a less-than-significant impact on service ratios, response times, or other performance objectives for fire protection and emergency medical services. a.ii) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection? Less Than Significant Impact. The development of 80 assisted living and memory care residential units, along with landscaping, outdoor living areas, drive aisles, and a surface parking lot, would incrementally increase the demand for police protection (such as Project Site security and responding to minor crimes). Law enforcement is provided by the Arcadia Police Department, with the nearest police station located approximately 1.7 miles southeast of the Project Site, at 250 West Huntington Drive. The Arcadia Police Department is equipped with an 18-bed, pre-arraignment jail, an evidence lab, a computer forensics lab, and other investigative equipment.86 The Police Department is staffed by 68 sworn officers and 33 non-sworn support staff for an officer to population ratio of 1.36 sworn officers per 1,000 persons.87 As discussed in Section XIV, Population and Housing, above, the Proposed Project is anticipated to generate approximately 80 residents and approximately 40 employees. The Proposed Project would also include on-site security resources, such as security guards and orderlies, to patrol the grounds, monitor locked entry and exit points to the property, and protect residents. Therefore, the Proposed Project is anticipated to have limited need for police services, other than to address infrequent minor crimes or vandalism issues on the property. Further, the Proposed Project would be required to comply with Policy S-5.11 of the Arcadia General Plan, which states that new development projects would be required “to pay their fair share of costs associated with any necessary increases in public safety equipment, facilities, and staffing to provide life safety protection.”88 Therefore, because the Proposed Project would include security personnel to address Project-specific security concerns, and because any other Project-related police service demands would be mitigated by the required fair share fees paid by the Project applicant, impacts would be less than significant. a.iii) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools? No Impact. The Project Site is located within the Arcadia Unified School District; however, the Project would include demolition of an existing restaurant building and construction of 80 memory care residential units. Because the 80 units would be inhabited by seniors affected by memory loss, 86 City of Arcadia, General Plan Update Draft Program EIR, Section 4.13, Public Services, 2010. 87 City of Arcadia, General Plan Update Draft Program EIR, Section 4.13, Public Services, 2010. 88 City of Arcadia, General Plan Safety Element, Policy S-5.11, page 8-37, November 2010. Artis Senior Housing Project Draft Initial Study Page 80 April 2020 there would be no school-age children living on the Project Site. The Project may indirectly result in the increase of school-age children living in Arcadia through the addition of approximately 40 employees. A portion of these employees may choose to live in Arcadia; however, the City is surrounded by urban areas that offer many housing options in other school districts. As such, the number of school-age children associated with the Proposed Project that would live within the Arcadia Unified School District would be negligible. Therefore, impact on schools would not occur. a.iv) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks? No Impact. As previously discussed, the Proposed Project would involve demolition of an existing restaurant use and construction of an 80-unit memory care facility. The Project would include an enclosed landscaped outdoor area with gardens, walking paths, and a gazebo on the south side of the Project Site for use by the Project’s residents. As such, the Proposed Project would provide outdoor recreation space for Project residents and would, therefore, not create a substantial adverse physical impact on City park facilities. No impact to parks would occur. a.v) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities? No Impact. The Project would involve the development of an 80-unit memory care facility, which would provide on-site services, such as activities rooms and outdoor recreation space, for Project residents. As such, Project residents are anticipated to have limited mobility and are not expected to substantially increase the demand on public facilities, such as libraries and other government buildings. Therefore, no impact other public facilities would occur. XVI. Recreation Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact RECREATION: a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? ܆ ܆ ܆ ܈ b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? ܆ ܆ ܆ ܈ Artis Senior Housing Project Draft Initial Study Page 81 April 2020 Discussion a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? No Impact. As discussed in response to Checklist Question XV.a.iv, above, the Proposed Project would involve demolition of an existing restaurant building and construction of an 80-unit memory care facility. As such, Project residents are expected to have limited mobility and are not expected to increase the demand on municipal park facilities. Further, the Proposed Project would provide an enclosed, outdoor recreation area for residents, which would include walking paths, gardens, and a plaza. Therefore, the Proposed Project is anticipated to have no impact on park or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? No Impact. As stated above in response to Checklist Question XVI.a, the Project is not anticipated to increase the demand on municipal parks and recreational facilities in Arcadia. The Proposed Project would include construction of an outdoor, enclosed recreation space for Project residents that would include walking paths, gardens, and a plaza. The environmental impacts associated with construction of these outdoor amenities are included in the Project analysis discussed in this Initial Study. Therefore, there would be no additional impacts associated with constructing these outdoor recreation amenities beyond those already discussed. XVII. Transportation/Traffic Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact TRANSPORTATION: Would the project: a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? ܆ ܆ ܈ ܆ b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? ܆ ܆ ܈ ܆ c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? ܆ ܆ ܈ ܆ d) Result in inadequate emergency access? ܆ ܆ ܈ ܆ Artis Senior Housing Project Draft Initial Study Page 82 April 2020 Discussion a) Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, taking into account all modes of transportation including transit, roadways, bicycle and pedestrian facilities?? Less Than Significant Impact. Construction Project construction is proposed to be completed in approximately 19 months. The phases of construction include demolition, grading, paving, building construction, and architectural coating. Demolition, grading, and paving are anticipated to take three months to complete; building construction would be completed in 12 months; and architectural coating would be completed in four months. The grading phase would occur over 10 days and would result in 1,485 cubic yards of cut and 3,350 cubic yards of fill. Therefore, 1,865 cubic yards of soil would be imported to the Project Site during the grading phase. The City of Arcadia limits construction activities to between the hours of 7:00 a.m. and 6:00 p.m. on weekdays and between the hours of 8:00 a.m. and 5:00 p.m. on Saturday; therefore, construction-related traffic would occur only during those time periods, on an intermittent basis, depending on the scope and intensity of the work taking place.89 While construction traffic would temporarily affect traffic flow on the surrounding street network, particularly along the truck haul routes, the impacts would be temporary and would fluctuate in intensity throughout the construction day and vary throughout the overall construction program, with less traffic generated in phases following the demolition and grading phases. Because the construction traffic impacts associated with the Proposed Project would be temporary, they would not significantly affect the performance of the vehicular transportation network with respect to level of service standards or other metrics related to congestion and travel delay. Operation Project-related, long-term traffic impacts include those of employee, visitor, and delivery vehicles associated with the proposed memory care facility. A trip generation analysis, conducted for the Proposed Project, compared anticipated trip generation associated with the Proposed Project to traffic count data collected for the existing restaurant and bakery building.90 The analysis used the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10 th Edition (2017) to determine the trip generation rates appropriate for an assisted living facility. The results of the Project trip generation analysis are provided in Table XVII-1. 89 City of Arcadia, Municipal Code Article IV, Chapter 2, Part 6, Nighttime Construction. 90 Michael Baker International, Inc., Technical Memorandum: Artis Senior Assisted Living Facility Trip Generation Analysis , December 17, 2019, available as Appendix E of this Initial Study. Artis Senior Housing Project Draft Initial Study Page 83 April 2020 Table XVII-1 Estimated Number of Project Trips Land Use Source ITE Code Intensity Daily Trips AM Peak Hour Trips PM Peak Hour Trips Total In Out Total In Out Total In Out Assisted Living (Proposed Project) ITE Trip Generation Manual, 10th Edition 254 80 Beds 208 104 104 15 9 6 21 8 13 Coco’s Bakery Restaurant (Existing) Traffic Count Data -- 13,000 Square Feet 582 297 285 26 17 9 32 19 13 Estimated New Trips (Proposed Project minus Existing) -374 -193 - 181 -11 -8 -3 -11 -11 0 Sources: Michael Baker International, Technical Memorandum: Artis Senior Assisted Living Facility Trip Generation Analysis, December 17, 2019, available as Appendix E of this Initial Study; ITE, Trip Generation Manual, 10th Edition, 2017. As shown in Table XVII-1, the Proposed Project is eligible for a trip credit since the existing restaurant building is currently in operation. Therefore, while the Proposed Project would result in an estimated 208 total daily vehicle trips, the number of new trips associated with the Project would be less than zero because the existing restaurant use currently generates 374 more daily trips than would be expected from the Proposed Project. Therefore, the Project would have a less-than-significant impact regarding trip generation. Regarding trip distribution, the existing Project Site has two access points, as shown in Figure A-7. The West Colorado Boulevard driveway provides full access (right- and left-turn for both ingress and egress) and the Michillinda Avenue driveway provides partial access (right-turn ingress and right-turn egress only). The Proposed Project would have a single, full-access driveway along West Colorado Boulevard, which would be shifted slightly east of the existing driveway. While the Project would concentrate all Project-related ingress and egress to the West Colorado Boulevard driveway, the overall estimated reduction in Project-related trips as compared with the existing restaurant use would result in a negligible impact on intersection impacts at this driveway. Specifically, the anticipated change in site trips entering and exiting the site at the West Colorado Boulevard driveway would range from negative four to three during the a.m. and p.m. peak hours. As such, it is anticipated that these minimal changes in site trips would not impact intersection operations at the proposed West Colorado Boulevard driveway. Further, all traffic associated with the Project Site would be removed from the existing Michillinda Avenue driveway. Therefore, the Proposed Project would have a less-than- significant impact on trip distribution and intersection performance. Finally, the Proposed senior living facility would include 80 units and would be dedicated to people afflicted with Alzheimer’s disease or other memory disorders. The outdoor spaces on the south side of the Proposed Project, which would be accessible to residents, would be contained/secured and monitored by facility staff. As such, there would be little to no impact on surrounding bus, pedestrian, or bicycle transit systems as a result of resident demand. Project employees would have a small impact on bus, pedestrian, or bicycle systems; however, the difference between the number of employees and visitors that would utilize transit or bicycle infrastructure to access the Project as compared with the number of employees and patrons using transit or bicycle infrastructure to access the existing restaurant is anticipated to be negligible. Further, the Proposed Project would not alter the existing Artis Senior Housing Project Draft Initial Study Page 84 April 2020 bus stop in the West Colorado Boulevard right-of-way on the north side of the Project Site. As such, there would be no impact on transit, bicycle, or pedestrian facilities as a result of the Proposed Project. In summary, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, taking into account all modes of transportation including transit, roadways, bicycle and pedestrian facilities, and, as such, impacts related to transportation would be less than significant. b) Would the project conflict with CEQA Guidelines Section 15064.3, subdivision (b)? Less Than Significant Impact. By July 1, 2020, transportation impact assessments prepared in accordance with CEQA will be required to determine if a Proposed Project would conflict with CEQA Guidelines Section 15064.3(b), which outlines a new set of criteria for analyzing transportation impacts using vehicle miles traveled (VMT) as the primary measure of transportation impact. VMT is generally defined as the amount and the distance of automobile travel associated with a Project. The City has not adopted guidelines to set new significance criteria for transportation impacts based on VMT for land use projects and plans in accordance with this checklist question. However, since the Project will be considered for approval prior to July 1, 2020, the Project is not required to demonstrate compliance with CEQA Guidelines Section 15064.3(b). Nevertheless, as discussed in Checklist Question XVII.a, above, the Project would replace an existing Coco’s restaurant with an 80-bed assisted living facility. As shown above, when compared to existing conditions, the Project would result in a substantial reduction in daily trips. Given the overall substantial reduction in trips based on the trip generation analysis, the Project's impact on Citywide and regional VMT would be considered less than significant. c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less Than Significant Impact. The Proposed Project is located on a 2.79-acre property at the corner of a major intersection. The Project proposes a surface parking lot with drive aisle and a drop-off circle in front of the main entrance (northern building elevation). The Project would not generate incompatible uses of area roadways, such as large farm equipment, that could impair circulation or safety on area roads. Further, there is no internal street network proposed as part of the Project and, therefore, no potential hazards associated with a geometric design feature, such as a sharp curve, would occur within the Project Site. The Project would result in a single entrance and exit driveway onto West Colorado Boulevard, as described above; however, this driveway would be designed to meet the mandatory design standards of the City of Arcadia as it relates to width, intersection control, and sight distance. Therefore, adherence to applicable City requirements would ensure the Proposed Project would not result in any hazardous geometric design feature, and impacts would be less than significant. d) Would the project result in inadequate emergency access? Less Than Significant Impact. Project-related building plans and structures would be reviewed by the Arcadia Fire Department for compliance with applicable safety and emergency access standards. This review would determine if fire flow, access, and fire hydrant placement are sufficient or if expanded facilities are required. Further, the Project Site is located in an urban setting, surrounded by multiple arterial roadways that could lead to the Proposed Project’s driveway on West Colorado Boulevard. As such, because the Project Site would be designed to accommodate emergency response vehicles and because it is located in an urban environment where the surrounding street network Artis Senior Housing Project Draft Initial Study Page 85 April 2020 allows for access to the Project Site from multiple directions, impacts related to emergency access would be less than significant. XVIII. Tribal Cultural Resources Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact TRIBAL CULTURAL RESOURCSE: a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or ܆ ܆ ܆ ܈ 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. ܆ ܆ ܈ ܆ Discussion a.i) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? No Impact. The Project Site is currently developed with a restaurant building constructed in 1976 along with a paved surface parking and vehicle driveways. As discussed in Section V, Cultural Resources, the current restaurant building does not meet the age requirement for evaluation for eligibility for listing in the California Register or in a local register. Further, a records search at the South Central Coastal Information Center (SCCIC) determined that there are no documented historic or prehistoric cultural resources on or within a quarter-mile radius of the Project Site. Therefore, the Project would not cause an adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in Artis Senior Housing Project Draft Initial Study Page 86 April 2020 terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register or in a local register of historical resources. a.ii) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. Less Than Significant Impact. Approved by Governor Brown on September 25, 2014, AB 52 established a formal consultation process for California Native American tribes to identify potential significant impacts to tribal cultural resources as defined in PRC Section 21074, as part of CEQA. As specified in AB 52, lead agencies must provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a project site if the tribe has submitted a written request to be notified. The tribe must respond to the lead agency within 30 days of receipt of the notification if it wishes to engage in consultation on the project, and the lead agency must begin consultation within 30 days of receiving the request for consultation. In compliance with AB 52, on January 10, 2020, the City of Arcadia sent a notice to the Gabrieleño Band of Mission Indians–Kizh Nation (Gabrieleño) and the Gabrielino-Tongva Tribe. On January 23, 2020, Andrew Salas, of the Gabrieleño submitted a formal request to consult with the City. The City did not receive a consultation request from the Gabrielino-Tongva Tribe within the 30 day consultation request period. The tribal consultation process commenced on April 1, 2020 via a conference call attended by Andrew Salas and Matt Teutimez of the Gabrieleño, Lisa Flores and Vanessa Quiroz of the City of Arcadia, and John Bellas and Madonna Marcelo of Michael Baker International (the City’s environmental consultant). During the phone consultation, City staff discussed the receipt of the Gabrieleño’s request for consultation, described the scope of the Project, and provided general information, including proposed excavation activities. In response, the Gabrieleño provided their knowledge of Arcadia and the Project area, including Rancho Santa Anita (within the boundaries of which the Project Site is located), the former Gabrieleño Native American village, the sacred village of Sheshiikwanonga/ Sisitcanongna, and trade routes in the vicinity of the Project Area, indicating that these trade routes were considered cultural landscapes that are protected under AB 52 as a tribal cultural resources. On April 2, 2020, City staff requested, via e-mail, the documents that were referenced by the Gabrieleño representatives during the phone consultation. On April 2, 2020, the Gabrieleño provided the articles, maps, and explanatory text that were verbally explained during the phone consultation. Review of the maps and articles provided by the Gabrieleño included information about trade routes and identified structures within the greater Arcadia area; however, these resources did not demonstrate that there is an existing tribal cultural resource within the Project Site. As such, no evidence has been submitted which identifies the specific location of the Project Site as sensitive or containing tribal cultural resources, and no criteria have been provided to indicate why the Project area should be Artis Senior Housing Project Draft Initial Study Page 87 April 2020 considered sensitive enough such that monitoring for tribal cultural resources would be required to avoid adverse impacts. CEQA only requires mitigation measures if substantial evidence exists of potentially significant impacts. CEQA Guidelines Section 15126.4(a)(4)(A) states “there must be an essential nexus (i.e., connection) between the mitigation measure and a legitimate government interest.” Therefore, based upon the record, the City has determined that no substantial evidence exists to support a conclusion that the Proposed Project may cause a significant impact on tribal cultural resources. As such, the City has no basis under CEQA to impose any related mitigation measures. Nevertheless, while no tribal cultural resources are anticipated to be affected by the Project, the City will voluntarily impose mitigation measures as an additional protection to address the inadvertent discovery of tribal cultural resources. These voluntarily-imposed mitigation measures, Mitigation Measure TCR-1 through Mitigation Measure TCR-4, are described in further detail below. TCR-1 Retail a Native American Monitor/Consultant. The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians-Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. TCR-2 Unanticipated Discovery of Tribal Cultural and Archaeological Resources. Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place or recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If Artis Senior Housing Project Draft Initial Study Page 88 April 2020 preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary Objects. 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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. 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. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 Artis Senior Housing Project Draft Initial Study Page 89 April 2020 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. TCR-4 Professional Standards. Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in Southern California. The qualified archaeologist shall ensure that all other personnel are appropriately trained and qualified. XIX. Utilities and Service Systems Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact UTILITIES AND SERVICE SYSTEMS: Would the project: a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? ܆ ܆ ܈ ܆ b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? ܆ ܆ ܈ ܆ Artis Senior Housing Project Draft Initial Study Page 90 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? ܆ ܆ ܈ ܆ d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? ܆ ܆ ܈ ܆ e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? ܆ ܆ ܈ ܆ Discussion a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less Than Significant Impact. Water The City of Arcadia provides water service to a majority of the City and currently derives its water supply from groundwater wells that produce water from two groundwater basins, the Main San Gabriel Basin and the Raymond Basin, with the Main San Gabriel Basin as the City’s primary groundwater source.91 According to the City’s 2015 Urban Water Management Plan (UWMP), the City has not experienced water supply deficiencies as a result of current management practices in the Main San Gabriel Basin and the Raymond Basin. As determined in the 2015 UWMP, the minimum water supplies available at the end of an average water year, single dry year, and multiple dry years would be at least equal to, if not greater than, the City’s water demand. In addition, as concluded in the 2015 UWMP, based on current management practices and reduced pumping in the Raymond Basin, the City will be able to rely on the Main San Gabriel Basin, the Raymond Basin, and imported water for adequate supply through year 2035 under single year and multiple year droughts. As shown in Table XIX-1, the Proposed Project does not meet the criteria to prepare a project- specific Water Supply Assessment under Senate Bill (SB) 610.92 In addition, as presented in Table XIX-1, the Proposed Project would result in a net reduction in water consumption due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the Project would 91 City of Arcadia, 2015 Urban Water Management Plan , June 2016. 92 SB 610 requires urban water suppliers to prepare a WSA for projects that include, but not limited to, the following: more than 500 dwelling units; shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space; commercial office buildings employing more than 1,000 persons or having more than 250,000 square feet of floor space; or hotels, motels, or both, having more than 500 rooms. Artis Senior Housing Project Draft Initial Study Page 91 April 2020 not require or result in the relocation or construction of new or expanded water treatment facility, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to water consumption and water supply would be less than significant. Table XIX-1 Water Consumption and Wastewater Generation Estimatesa Land Use Unit Rateb Quantity (gpd) Existing Coco’s Restaurant Restaurant 13,088 sf 1,000 gpd/1,000 sf 13,088 gpd Proposed Project Assisted Living Facility 80 beds 125 gpd/bedc 10,000 gpd Net Consumption/Generation (Proposed – Existing) -3,088 gpd Notes: gpd = gallons per day; sf = square feet a Based on a review of other projects and water supply assessment reports prepared for projects in the Los Angeles Metropolitan area, the amount of wastewater generated by a project has been estimated to be approximately the same as the amount of water consumed by such project. It is noted that some amount is lost due to evapotranspiration and landscaping irrigation; however, these quantities are minimal compared to the consumption and generation by the actual uses. b Rates from the Sanitation Districts of County of Los Angeles. c Rate for convalescent homes was utilized. Wastewater Wastewater generated by the City is treated by the Sanitation Districts of Los Angeles County (Sanitation Districts). Wastewater is collected within the City’s local sewer collection system, which tie into one of the Sanitation Districts’ regional truck sewer lines traversing the City.93 The regional truck sewer lines deliver wastewater to one or more water reclamation plants owned by the Sanitation Districts for treatment, including the Whittier Narrows Water Reclamation Plant (WNWRP) and the Joint Water Pollution Control Plant (JWPCP). As presented above in Table XIX-1, the Proposed Project would result in a net reduction in wastewater generation due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the Project would not require or result in the relocation or construction of new or expanded wastewater treatment facility, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to wastewater generation, specifically to the WNWRP and the JWPCP, would be less than significant. Storm Drains The Project Site currently drains to an existing private storm drain located at the southeastern corner of the Project Site. As discussed above in Section X, Hydrology and Water Quality, of this Initial Study, the Project would slightly reduce the amount of impervious surfaces on the Project Site due to the increase in the amount of pervious landscape areas proposed by the Project as compared to existing conditions. Further, the Project’s LID Plan would be reviewed and approved by the City during the plan-check process, ensuring that the Project’s drainage plan would conform to local and regional regulations governing Project Site discharge to storm drains. Specifically, the LID Plan would result in stormwater runoff retention on-site for the runoff from the 85 th percentile 24-hour runoff 93 City of Arcadia, 2015 Urban Water Management Plan , June 2016. Artis Senior Housing Project Draft Initial Study Page 92 April 2020 event. Only stormwater overflow from the Project Site would drain to the existing private storm drain at the southeastern corner of the Project Site. Therefore, the Project would not contribute to additional runoff as compared to existing conditions. Accordingly, the Project would not require or result in the relocation or construction of new or expanded storm drain facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to storm drains would be less than significant. Electricity and Natural Gas Southern California Edison (SCE) and Southern California Gas Company (SoCalGas) provide electricity and natural gas services to the Project Site, respectively. As presented in Table VI-1 in Section VI, Energy, of this Initial Study, the Proposed Project would result in a net reduction in electricity and natural gas consumption due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the Project would not require or result in the relocation or construction of new or expanded power or natural gas lines, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to electricity and natural gas would be less than significant. Telecommunications Telecommunication services are provided by private companies, the selection of which is at the discretion of the Applicant. Upgrades to existing telecommunication facilities and construction of new facilities to meet the demand of users are determined by telecommunication providers and is subject to its own environmental review. Accordingly, Project impacts to telecommunication facilities would be less than significant. b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less Than Significant Impact. As discussed above, the 2015 UWMP concluded that the City will be able to rely on the Main San Gabriel Basin, the Raymond Basin, and imported water for adequate supply through year 2035 under single year and multiple year droughts. In addition, as shown in Table XIX-1, the Proposed Project would result in a net reduction in water consumption due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, there would be sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years. Therefore, impacts to water supplies would be less than significant. c) Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant Impact. As presented above, the Proposed Project would result in a net reduction in wastewater generation due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the Project would not affect the capacity of the WNWRP or the JWPCP for treatment of wastewater. Therefore, impacts related to wastewater treatment would be less than significant. Artis Senior Housing Project Draft Initial Study Page 93 April 2020 d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? e) Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste? Less Than Significant Impact. The Project Site is currently served by a commercial hauler, which collects and transports waste generated by the existing restaurant to multiple local landfills. The City’s General Plan Update Program Environmental Impact Report determined that there would be no significant adverse impact on landfill capacity and that continuation of existing City and County programs and implementation of pertinent goals, policies, and implementation actions in the General Plan Update would provide for future developments’ compliance with solid waste regulations.94 In addition, the Project would be required to comply with federal, State, and local management and reduction statutes and regulations related to solid waste to ensure that the solid waste stream diverted to landfills and recycling facilities is reduced in accordance with existing regulations. Furthermore, as shown in Table XIX-2, the Proposed Project would result in a net reduction in solid waste generation due to the change in land use from a high turnover restaurant to an assisted living facility. Accordingly, the Project 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. Therefore, impacts related to solid waste generation would be less than significant. Table XIX-2 Solid Waste Generation Estimates Land Use Unit Ratea Quantity (lbs per day) Existing Coco’s Restaurant Restaurant 409 seatsb 1 lb/seat/day 409 Proposed Project Assisted Living Facility 80 personsc 5 lbs/person/day 400 Net Solid Waste Generation (Proposed – Existing) -9 Notes: lb = pound; sf = square feet a California Department of Resources Recycling and Recovery (CalRecycle), Estimated Solid Waste Generation Rates, https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates, accessed January 27, 2020. b CalRecycle rate that assumes 50% of restaurant is seating and 15 sf per seat. c Based on an 80-bed facility, resulting in 80 full-time residents. 94 City of Arcadia, General Plan Update Draft Program EIR, September 2010, p. 4.16-33. Artis Senior Housing Project Draft Initial Study Page 94 April 2020 XX. Wildfire Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact WILDFIRE: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project: a) Substantially impair an adopted emergency response plan or emergency evacuation plan? ܆ ܆ ܆ ܈ b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? ܆ ܆ ܆ ܈ c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? ܆ ܆ ܆ ܈ d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? ܆ ܆ ܆ ܈ Discussion a) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan? No Impact. As stated in Section IX.g, above, the Project Site is not located within or adjacent to a Very High Fire Hazard Severity Zone (VHFHSZ), as designated by the California Department of Forestry and Fire Protection.95 VHFHSZs in the City of Arcadia are concentrated on the northeastern side of the City, in the foothills near the Cities of Monrovia and Sierra Madre, approximately 2.1 miles northeast of the Project Site. The Project Site is in a fully urbanized area with an urban street network, a fully pressurized water system, and managed landscaping limited to decorative trees and shrubs. As such, wildland fires would not occur on or near the Project Site. Regardless, in any disaster warranting evacuation, the exact emergency routes used would depend on a number of variables, including the type, scope, and location of the incident. It is the responsibility of emergency service and/or appropriate public officials to adequately assess the situation so that safe and efficient evacuation routes are selected. As the Project Site is in a fully urbanized area with multiple major arterial streets and a major highway within close proximity, the Proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan, and no impact would occur. 95 California Department of Forestry and Fire Protection, Very High Fire Hazard Severity Zone in Local Responsibility Area, September 2011. Artis Senior Housing Project Draft Initial Study Page 95 April 2020 b) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? No Impact. The Project Site is not within or near a VHFHSZ. Therefore, the Proposed Project would not have the potential to expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire due to slope, prevailing winds, and other factors, or exacerbate wildfire risks. As such, no impact would occur. c) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? No Impact. The Project Site is not within or near a VHFHSZ. Therefore, the Proposed Project would not require the installation or maintenance of associated infrastructure that may exacerbate fire risk or result in temporary or ongoing impacts to the environment. As such, no impact would occur. d) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? No Impact. The Project Site is not within or near a VHFHSZ. The Project Site is within a flat, urbanized area that is adjacent to existing commercial and residential structures. Therefore, the Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. As such, no impact would occur. XXI. Mandatory Findings of Significance Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact MANDATORY FINDINGS OF SIGNIFICANCE: a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? ܆ ܈ ܆ ܆ Artis Senior Housing Project Draft Initial Study Page 96 April 2020 Potentially Significant Impact Less Than Significant Impact with Mitigation Incorporated Less Than Significant Impact No Impact b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? ܆ ܆ ܈ ܆ c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? ܆ ܈ ܆ ܆ Discussion a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Less Than Significant Impact With Mitigation Incorporated. Based on the analysis in Section IV, Biological Resources, of this Initial Study, the Proposed Project would not have substantial impacts to special-status species, stream habitat, and wildlife dispersal. A mitigation measure is proposed (i.e., Mitigation Measure BIO-1) to ensure that tree removal would not pose a significant impact on migratory wildlife species. Furthermore, the Proposed Project would not affect the local, regional, or national populations or ranges of any plant or animal species and would not threaten any plant communities. Similarly, as discussed in Section V, Cultural Resources, and Section VII, Geology and Soils, of this Initial Study, with the incorporation of Mitigation Measures CUL-1 and GEO-1, the Proposed Project would not have substantial impacts to historical, archaeological, or paleontological resources and, thus, would not eliminate any important examples of California history or prehistory. Therefore, the Proposed Project would not result in a Mandatory Finding of Significance due to impacts to biological, cultural, or paleontological resources. b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? Less Than Significant Impact. A significant cumulative impact may occur if the Project, in conjunction with related projects in the region, would result in impacts that are less than significant when viewed separately but would be significant when viewed together. When considering the Proposed Project in combination with other past, present, and reasonably foreseeable future projects in the vicinity of the Project Site, the Proposed Project does not have the potential to cause impacts that are cumulatively considerable. As detailed in the above discussions, the Proposed Project would not result in any significant and unmitigable impacts in any environmental categories. In all cases, the impacts associated with the Project are limited to the Project Site and are of such a negligible degree that they would not result in a significant contribution to any cumulative impacts. In some cases, the Artis Senior Housing Project Draft Initial Study Page 97 April 2020 Project would result in a net reduction when compared to existing conditions (i.e., related to emissions, water consumption, and wastewater and solid waste generation). Therefore, the Proposed Project would not result in a Mandatory Finding of Significance due to cumulative impacts. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? Less Than Significant Impact With Mitigation Incorporated . As detailed above, the Proposed Project does not have the potential to result in direct or indirect substantial adverse effects on human beings. Although construction noise is allowed during the City’s allowable construction hours and is not considered to be a significant impact during those hours, the Project could expose adjoining residential uses to temporary high noise levels (91 to 104 dBA) during construction activities. However, Mitigation Measure NOI-1 is recommended to reduce short-term construction noise impacts through noise reduction methods to a less-than-significant level. In all other environmental issue areas, the Proposed Project does not approach or exceed any significance thresholds typically associated with direct or indirect effects on people, such as air, water, or land pollution, natural environmental hazards, transportation-related hazards, or adverse effects to emergency service response. Therefore, the Proposed Project would not result in a Mandatory Finding of Significance due to direct or indirect effects on human beings. Artis Senior Housing Project Draft Initial Study Page 98 April 2020 SECTION E. LIST OF MITIGATION MEASURES Biological Resources BIO-1 Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City of the Planning & Community Development Administrator or Designee. BIO-2 Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: 1. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. 2. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. 3. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. 4. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. 5. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. 6. The arborist shall monitor a few critical phases of the Project, including pre- demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. Artis Senior Housing Project Draft Initial Study Page 99 April 2020 7. Additional construction best practices described in the Protected Tree Report shall be implemented. Cultural Resources CUL-1 Treatment of previously unidentified archaeological deposits: If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility. Geology and Soils GEO-1 Paleontological Resource Monitor: If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. Noise NOI-1 Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Planning Division, that the Project complies with the following: 1. Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. 2. The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on-site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Artis Senior Housing Project Draft Initial Study Page 100 April 2020 Planning & Community Development Administrator (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. 3. During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. 4. Prior to issuance of any Grading or Building Permit, the Project applicant shall demonstrate to the satisfaction of the Community Development Director (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. 5. Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. Tribal Cultural Resources TCR-1 Retail a Native American Monitor/Consultant. The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians-Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. TCR-2 Unanticipated Discovery of Tribal Cultural and Archaeological Resources. Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place Artis Senior Housing Project Draft Initial Study Page 101 April 2020 or recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary Objects. 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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. 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 Artis Senior Housing Project Draft Initial Study Page 102 April 2020 made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. TCR-4 Professional Standards. Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in Southern California. The qualified archaeologist shall ensure that all other personnel are appropriately trained and qualified. Artis Senior Housing Project Draft Initial Study Page 103 April 2020 SECTION F. REFERENCES Arbor Care, Inc., Protected Tree Report: Tree Survey, Encroachment, Protection and Mitigation 1150 West Colorado Boulevard, Arcadia, CA 91106, revised March 2020. California Air Resources board, California’s 2017 Climate Change Scoping Plan, November 2017. California Code of Regulations, Title 24, Part 6, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings, 2019. California Department of Conservation, California Important Farmland Finder, accessed November 8, 2019, https://maps.conservation.ca.gov/DLRP/CIFF/. California Department of Conservation, Department of Oil, Gas, and Geothermal Resources, Well Finder online mapping application, map generated December 3, 2019. California Department of Conservation, Fault Activity Map of California, 2010. California Department of Conservation, The California Land Conservation Act of 1965 2016 Status Report, December 2016. California Department of Fish and Wildlife (CDFW), Special Plant and Animal Lists, https://www.dfg.ca.gov/wildlife/nongame/list.html, accessed November 8, 2019. California Department of Forestry and Fire Protection, Very High Fire Hazard Severity Zone in Local Responsibility Area, September 2011. California Department of Toxic Substances Control (DTSC), Cortese List: Section 65962.5(a), https://calepa.ca.gov/sitecleanup/corteselist/section-65962-5a/, accessed October 21, 2019. California Department of Toxic Substances Control (DTSC), EnviroStor Database search, accessed October 21, 2019. California Department of Transportation, Transportation and Construction Vibration Guidance Manual, Table 20, September 2013. California DTSC, EnviroStor Hazardous Waste and Substance Site List, 2019. California Energy Commission, California Greenhouse Gas Emissions for 2000 to 2017, https://www.arb.ca.gov/cc/inventory/pubs/reports/2000_2016/ghg_inventory_trends_00 -16.pdf, accessed December 27, 2019. California Geological Survey, Special Publication 117A: Guidelines for Evaluating and Mitigating Seismic Hazards in California , 2008. CDFW, Biogeographic Information and Observation System (BIOS), https://apps.wildlife.ca.gov/bios/, accessed November 8, 2019. CDFW, CDFW Lands, https://apps.wildlife.ca.gov/lands/, accessed November 8, 2019. Artis Senior Housing Project Draft Initial Study Page 104 April 2020 City of Arcadia Municipal Code Article IX, Division 3, Section 9103.13, Performance Standards, exempts vibration generated from construction activities. City of Arcadia Ordinance No. 1510, signed and approved July 16, 1974. City of Arcadia Resolution No. 4440, signed and approved July 2, 1974. City of Arcadia, 2015 Urban Water Management Plan, prepared by Stetson Engineers, Inc., June 2016. City of Arcadia, Arcadia General Plan Land Use and Community Design Element, November 2010. City of Arcadia, Arcadia General Plan Parks, Recreation, and Community Resources Element , November 2010. City of Arcadia, Arcadia Municipal Code Article IX, Division 3, Section 9103.11, Signs. City of Arcadia, Arcadia Municipal Code Section 9102.03.020. City of Arcadia, Code of Ordinances, Article IX, Chapter 7, Tree Preservation, and Chapter 8, Comprehensive Tree Management Program. City of Arcadia, Code of Ordinances, Article VII, Chapter 8, Part 2, Section 7828, Low Impact Development – Control of Runoff Required for Planning Priority Projects. City of Arcadia, Code of Ordinances, Article VIII, Chapter 1, Building Code. City of Arcadia, General Plan Safety Element, November 2010. City of Arcadia, General Plan Update Draft Program EIR, 2010. City of Arcadia, Municipal Code Article IV, Chapter 2, Part 6, Nighttime Construction. City of Arcadia, Municipal Code Section 9102.03.020. County of Los Angeles, Airports and Airport Influence Areas Map, August 2018. Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map 06037C1400F, September 26, 2008. Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual , September 2018. 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&RQFOXVRU\VWDWHPHQWVXQVXSSRUWHGE\IDFWXDOLQIRUPDWLRQGRQRWIDFLOLWDWHWKHSXUSRVHDQGJRDO RI&(4$RQSXEOLFGLVFORVXUHDQGDUHQRWPHDQLQJIXOLQIRUPDWLYHRUXVHIXOWRGHFLVLRQPDNHUV DQGWKHSXEOLFZKRDUHLQWHUHVWHGLQWKH3URSRVHG3URMHFW 6RXWK&RDVW$40'VWDIILVDYDLODEOHWRZRUNZLWKWKH/HDG$JHQF\WRDGGUHVVDQ\DLUTXDOLW\ TXHVWLRQVWKDWPD\DULVHIURPWKLVFRPPHQWOHWWHU3OHDVHFRQWDFWPHDWOVXQ#DTPGJRYVKRXOG \RXKDYHDQ\TXHVWLRQV 5HVSRQVHWR&RPPHQW1R 7KH&LW\¶VUHVSRQVHVWRWKH$40'FRPPHQWVDUHSURYLGHGLQWKLV5HVSRQVHWR&RPPHQWV$OO ZULWWHQ FRPPHQWV UHFHLYHG KDYH EHHQ DGHTXDWHO\ UHVSRQGHG WR LQDFFRUGDQFH ZLWK &(4$ *XLGHOLQHV6HFWLRQ7KHGHWHUPLQDWLRQRIWKHVLJQLILFDQFHRILPSDFWVLQWKH,QLWLDO6WXG\ SDUWLFXODUO\DVLWUHODWHVWRDLUTXDOLW\UHPDLQVYDOLGDQGDSSOLFDEOHWRWKH3URSRVHG3URMHFW 7KHUHIRUHQRIXUWKHUDQDO\VLVLVZDUUDQWHG1RRWKHUDJHQF\DQGSXEOLFFRPPHQWVZHUHUHFHLYHG GXULQJWKH'UDIW,601'¶VSXEOLFUHYLHZSHULRG SENT VIA E-MAIL: May 5, 2020 vquiroz@arcadiaca.gov Venessa Quiroz, Planner City of Arcadia, Planning Department 240 W. Huntington Drive Arcadia, CA 91006 Mitigated Negative Declaration (MND) for the Proposed Artis Senior Living Care Facility South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above-mentioned document. The following comments include recommended revisions to the air quality analysis and health risk assessment that the Lead Agency should include in the Final MND. South Coast AQMD Staff’s Summary of Project Description The Lead Agency proposes to a 44,192-square-foot senior living care facility with 80 rooms on 2.79 acres (Proposed Project). Based on a review of Figure A-2, Project Location Map, in the MND and aerial photographs, South Coast AQMD staff found that the Proposed Project is located immediately south of Interstate 210 (I-210) and within 100 feet from a gasoline service station. Construction is expected to take 19 months1. South Coast AQMD Staff’s Summary of Air Quality Analysis In the Air Quality Analysis section, the Lead Agency quantified the Proposed Project’s construction and operational emissions and compared those emissions to South Coast AQMD’s recommended regional and localized air quality CEQA significance thresholds. Based on the analyses, the Lead Agency found that the Proposed Project’s construction and operational air quality impacts would be less than significant. South Coast AQMD Staff’s Comments Based on reviews of the Air Quality Analysis in the MND, South Coast AQMD staff recommends that the Lead Agency perform a mobile source health risk assessment (HRA) to disclose the potential health risks in the Final MND, incorporate strategies to reduce exposures by senior residents to toxic air contaminants from vehicles and trucks traveling on I-210, and protect public health of those living at the Proposed Project. Detailed comments are provided as follows. Health Risk Assessment (HRA) from Freeways and Other Sources of Air Pollution 1. Notwithstanding the court rulings, South Coast AQMD staff recognizes that the Lead Agencies that approve CEQA documents retain the authority to include any additional information they deem relevant to assessing and mitigating the environmental impacts of a project. Because of South Coast AQMD’s concern about the potential public health impacts of siting sensitive populations within close proximity of I-210, South Coast AQMD staff recommends that the Lead Agency review and consider the following comments when making local planning and land use decisions. Sensitive receptors are people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptors include schools, daycare centers, nursing homes, elderly care 1 MND. Page 30 Comment No. 1 Comment No. 2 Venessa Quiroz May 5, 2020 2 facilities, hospitals, and residential dwelling units. As stated above, the Proposed Project will include the operation of a senior living care facility. Based on a review of Figure A-2 in the MND, South Coast AQMD staff found that the Proposed Project immediately south of I-210. Senior residents living at the Proposed Project will be exposed to diesel particulate matter (DPM) emitted from vehicles and trucks traveling on I-210. The California Air Resources Board has identified DPM as a toxic air contaminant (TAC) based on its carcinogenic effects2. Additionally, the Proposed Project is located within 100 feet of a gasoline service station to the west. Senior residents will also be exposed to other TACs such as benzene. Therefore, South Coast AQMD staff recommends that the Lead Agency consider health impacts on future senior residents living at the Proposed Project and perform a mobile source HRA3 analysis to disclose the potential health risks in the Final MND4. This recommendation will facilitate the purpose and goal of CEQA on public disclosure and enable decision-makers with meaningful information to make an informed decision on project approval. It will also foster informed public participation by providing the public with useful information that is needed to understand the potential health risks from living in close proximity to a high-volume freeway. Guidance Regarding Residences Sited Near a High-Volume Freeway or Other Sources of Air Pollution 2. To facilitate stronger collaboration between Lead Agencies and South Coast AQMD to reduce community exposure to source-specific and cumulative air pollution impacts, South Coast AQMD adopted the Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning in 20055. This Guidance document provides suggested policies that local governments can use in their General Plans or through local planning to prevent or reduce potential air pollution impacts and protect public health. In addition, guidance on siting incompatible land uses (such as placing residential uses near freeways and gasoline service stations) can be found in the California Air Resources Board (CARB)’s Air Quality and Land Use Handbook: A Community Health Perspective (Handbook)6. In the Handbook, CARB recommends avoiding siting new sensitive land uses such as the Proposed Project within 500 feet of a freeway7, and 300 feet of a large gasoline dispensing facility (defined as a facility with a throughput of 3.6 million gallons per year or greater.) A 50-foot separation is recommended for typical gasoline dispensing facilities8. Therefore, South Coast AQMD staff recommends that the Lead Agency review the guidance documents when making local planning and land use decisions. 2 California Air Resources Board. August 27, 1998. Resolution 98-35. Accessed at: http://www.arb.ca.gov/regact/diesltac/diesltac.htm. 3 South Coast Air Quality Management District. Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis. Accessed at: http://www.aqmd.gov/home/regulations/ceqa/airquality-analysis-handbook/mobile-source-toxics-analysis. 4 South Coast AQMD has developed the CEQA significance threshold of 10 in one million for cancer risk. When South Coast AQMD acts as the Lead Agency, South Coast AQMD staff conducts a HRA, compares the maximum cancer risk to the threshold of 10 in one million to determine the level of significance for health risk impacts, and identifies mitigation measures if the risk is found to be significant. 5 South Coast AQMD. May 2005. Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning. Accessed at: http://www.aqmd.gov/docs/default-source/planning/air-quality-guidance/complete-guidance-document.pdf. 6 California Air Resources Board. Air Quality and Land Use Handbook: A Community Health Perspective. Accessed at: http://www.arb.ca.gov/ch/handbook.pdf. 7 Ibid. Page 10. 8 Ibid. Page 32. Comment No. 2 (Continued) Comment No. 3 Venessa Quiroz May 5, 2020 3 Health Risk Reduction Strategies 3. Many strategies are available to reduce exposures to DPM, including, but are not limited to, building filtration systems with Minimum Efficiency Reporting Value (MERV) 13 or better, or in some cases, MERV 15 or better is recommended; building design, orientation, location; vegetation barriers or landscaping screening, etc. Enhanced filtration units are capable of reducing exposures. Installation of enhanced filtration units can be verified during occupancy inspection prior to the issuance of an occupancy permit. 4. Enhanced filtration systems have limitations. South Coast AQMD staff recommends that the Lead Agency consider the limitations of the enhanced filtration. For example, in a study that South Coast AQMD conducted to investigate filters9, a cost burden is expected to be within the range of $120 to $240 per year to replace each filter. The initial start-up cost could substantially increase if an HVAC system needs to be installed. In addition, because the filters would not have any effectiveness unless the HVAC system is running, there may be increased energy costs to the residents. It is typically assumed that the filters operate 100 percent of the time while residents are indoors, and the environmental analysis does not generally account for the times when the residents have their windows or doors open or are in common space areas of the project. In addition, these filters have no ability to filter out any toxic gases from vehicle exhaust. Therefore, the presumed effectiveness and feasibility of any filtration units should be carefully evaluated in more detail prior to assuming that they will sufficiently alleviate exposures to toxic emissions. 5. Because of the limitations, to ensure that enhanced filters are enforceable throughout the lifetime of the Proposed Project as well as effective in reducing exposures to DPM emissions, South Coast AQMD staff recommends that the Lead Agency provide additional details regarding the ongoing, regular inspection, maintenance, and monitoring of filters in the Final MND. To facilitate a good faith effort at full disclosure and provide useful information to future sensitive receptors who will live in close proximity to I-210 and a gasoline service station, the Lead Agency should include the following information in the Final MND, at a minimum: x Disclosure on potential health impacts to prospective senior residents from living in proximity to a freeway and other sources of air pollution, and the reduced effectiveness of air filtration system when windows are open and when senior residents are outdoor; x Identification of the responsible implementing and enforcement agency such as the Lead Agency for ensuring that enhanced filters are installed on-site at the Proposed Project before a permit of occupancy is issued; x Identification of the responsible implementing and enforcement agency such as the Lead Agency’s building and safety inspection unit to provide periodic, regular inspection on filters; x Provide information and guidance to the Project developer or proponent on the importance of filter installation and ongoing maintenance; x Provide information to the Project developer or proponent about where the MERV filers can be purchased; x Disclosure on increased costs for purchasing enhanced filtration systems; x Disclosure on increased energy costs for running the HVAC system with MERV filters; x Disclosure on recommended schedules (e.g., once a year or every six months) for replacing the enhanced filtration units; 9This study evaluated filters rated MERV 13 or better. Accessed at: http://www.aqmd.gov/docs/default- source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf. Also see 2012 Peer Review Journal article by South Coast AQMD: http://d7.iqair.com/sites/default/files/pdf/Polidori-et-al-2012.pdf. Comment No. 4 Venessa Quiroz May 5, 2020 4 x Identification of the responsible entity such as residents or property management to ensure filters are inspected for replacement and maintenance on time, if appropriate and feasible; x Develop ongoing cost sharing strategies, if available, for replacing the enhanced filtration units; x Set up criteria for assessing progress in installing, replacing, and maintaining the enhanced filtration units; and x Set up process for evaluating the effectiveness of the enhanced filtration units at the Proposed Project. Conclusion Pursuant to CEQA Guidelines Section 15074, prior to approving the Proposed Project, the Lead Agency shall consider the MND for adoption together with any comments received during the public review process. Please provide South Coast AQMD with written responses to all comments contained herein prior to the adoption of the Final MND. When responding to issues raised in the comments, response should provide sufficient details giving reasons why specific comments and suggestions are not accepted. There should be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information do not facilitate the purpose and goal of CEQA on public disclosure and are not meaningful, informative, or useful to decision makers and the public who are interested in the Proposed Project. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact me at lsun@aqmd.gov, should you have any questions. Sincerely, Lijin Sun Lijin Sun, J.D. Program Supervisor, CEQA IGR Planning, Rule Development & Area Sources LS LAC200501-05 Control Number Comment No. 4 (Continued) Comment No. 5 SENT VIA E-MAIL: May 5, 2020 vquiroz@arcadiaca.gov Venessa Quiroz, Planner City of Arcadia, Planning Department 240 W. Huntington Drive Arcadia, CA 91006 Mitigated Negative Declaration (MND) for the Proposed Artis Senior Living Care Facility South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above-mentioned document. The following comments include recommended revisions to the air quality analysis and health risk assessment that the Lead Agency should include in the Final MND. South Coast AQMD Staff’s Summary of Project Description The Lead Agency proposes to a 44,192-square-foot senior living care facility with 80 rooms on 2.79 acres (Proposed Project). Based on a review of Figure A-2, Project Location Map, in the MND and aerial photographs, South Coast AQMD staff found that the Proposed Project is located immediately south of Interstate 210 (I-210) and within 100 feet from a gasoline service station. Construction is expected to take 19 months1. South Coast AQMD Staff’s Summary of Air Quality Analysis In the Air Quality Analysis section, the Lead Agency quantified the Proposed Project’s construction and operational emissions and compared those emissions to South Coast AQMD’s recommended regional and localized air quality CEQA significance thresholds. Based on the analyses, the Lead Agency found that the Proposed Project’s construction and operational air quality impacts would be less than significant. South Coast AQMD Staff’s Comments Based on reviews of the Air Quality Analysis in the MND, South Coast AQMD staff recommends that the Lead Agency perform a mobile source health risk assessment (HRA) to disclose the potential health risks in the Final MND, incorporate strategies to reduce exposures by senior residents to toxic air contaminants from vehicles and trucks traveling on I-210, and protect public health of those living at the Proposed Project. Detailed comments are provided as follows. Health Risk Assessment (HRA) from Freeways and Other Sources of Air Pollution 1. Notwithstanding the court rulings, South Coast AQMD staff recognizes that the Lead Agencies that approve CEQA documents retain the authority to include any additional information they deem relevant to assessing and mitigating the environmental impacts of a project. Because of South Coast AQMD’s concern about the potential public health impacts of siting sensitive populations within close proximity of I-210, South Coast AQMD staff recommends that the Lead Agency review and consider the following comments when making local planning and land use decisions. Sensitive receptors are people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptors include schools, daycare centers, nursing homes, elderly care 1 MND. Page 30 Venessa Quiroz May 5, 2020 2 facilities, hospitals, and residential dwelling units. As stated above, the Proposed Project will include the operation of a senior living care facility. Based on a review of Figure A-2 in the MND, South Coast AQMD staff found that the Proposed Project immediately south of I-210. Senior residents living at the Proposed Project will be exposed to diesel particulate matter (DPM) emitted from vehicles and trucks traveling on I-210. The California Air Resources Board has identified DPM as a toxic air contaminant (TAC) based on its carcinogenic effects2. Additionally, the Proposed Project is located within 100 feet of a gasoline service station to the west. Senior residents will also be exposed to other TACs such as benzene. Therefore, South Coast AQMD staff recommends that the Lead Agency consider health impacts on future senior residents living at the Proposed Project and perform a mobile source HRA3 analysis to disclose the potential health risks in the Final MND4. This recommendation will facilitate the purpose and goal of CEQA on public disclosure and enable decision-makers with meaningful information to make an informed decision on project approval. It will also foster informed public participation by providing the public with useful information that is needed to understand the potential health risks from living in close proximity to a high-volume freeway. Guidance Regarding Residences Sited Near a High-Volume Freeway or Other Sources of Air Pollution 2. To facilitate stronger collaboration between Lead Agencies and South Coast AQMD to reduce community exposure to source-specific and cumulative air pollution impacts, South Coast AQMD adopted the Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning in 20055. This Guidance document provides suggested policies that local governments can use in their General Plans or through local planning to prevent or reduce potential air pollution impacts and protect public health. In addition, guidance on siting incompatible land uses (such as placing residential uses near freeways and gasoline service stations) can be found in the California Air Resources Board (CARB)’s Air Quality and Land Use Handbook: A Community Health Perspective (Handbook)6. In the Handbook, CARB recommends avoiding siting new sensitive land uses such as the Proposed Project within 500 feet of a freeway7, and 300 feet of a large gasoline dispensing facility (defined as a facility with a throughput of 3.6 million gallons per year or greater.) A 50-foot separation is recommended for typical gasoline dispensing facilities8. Therefore, South Coast AQMD staff recommends that the Lead Agency review the guidance documents when making local planning and land use decisions. 2 California Air Resources Board. August 27, 1998. Resolution 98-35. Accessed at: http://www.arb.ca.gov/regact/diesltac/diesltac.htm. 3 South Coast Air Quality Management District. Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis. Accessed at: http://www.aqmd.gov/home/regulations/ceqa/airquality-analysis-handbook/mobile-source-toxics-analysis. 4 South Coast AQMD has developed the CEQA significance threshold of 10 in one million for cancer risk. When South Coast AQMD acts as the Lead Agency, South Coast AQMD staff conducts a HRA, compares the maximum cancer risk to the threshold of 10 in one million to determine the level of significance for health risk impacts, and identifies mitigation measures if the risk is found to be significant. 5 South Coast AQMD. May 2005. Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning. Accessed at: http://www.aqmd.gov/docs/default-source/planning/air-quality-guidance/complete-guidance-document.pdf. 6 California Air Resources Board. Air Quality and Land Use Handbook: A Community Health Perspective. Accessed at: http://www.arb.ca.gov/ch/handbook.pdf. 7 Ibid. Page 10. 8 Ibid. Page 32. Venessa Quiroz May 5, 2020 3 Health Risk Reduction Strategies 3. Many strategies are available to reduce exposures to DPM, including, but are not limited to, building filtration systems with Minimum Efficiency Reporting Value (MERV) 13 or better, or in some cases, MERV 15 or better is recommended; building design, orientation, location; vegetation barriers or landscaping screening, etc. Enhanced filtration units are capable of reducing exposures. Installation of enhanced filtration units can be verified during occupancy inspection prior to the issuance of an occupancy permit. 4. Enhanced filtration systems have limitations. South Coast AQMD staff recommends that the Lead Agency consider the limitations of the enhanced filtration. For example, in a study that South Coast AQMD conducted to investigate filters9, a cost burden is expected to be within the range of $120 to $240 per year to replace each filter. The initial start-up cost could substantially increase if an HVAC system needs to be installed. In addition, because the filters would not have any effectiveness unless the HVAC system is running, there may be increased energy costs to the residents. It is typically assumed that the filters operate 100 percent of the time while residents are indoors, and the environmental analysis does not generally account for the times when the residents have their windows or doors open or are in common space areas of the project. In addition, these filters have no ability to filter out any toxic gases from vehicle exhaust. Therefore, the presumed effectiveness and feasibility of any filtration units should be carefully evaluated in more detail prior to assuming that they will sufficiently alleviate exposures to toxic emissions. 5. Because of the limitations, to ensure that enhanced filters are enforceable throughout the lifetime of the Proposed Project as well as effective in reducing exposures to DPM emissions, South Coast AQMD staff recommends that the Lead Agency provide additional details regarding the ongoing, regular inspection, maintenance, and monitoring of filters in the Final MND. To facilitate a good faith effort at full disclosure and provide useful information to future sensitive receptors who will live in close proximity to I-210 and a gasoline service station, the Lead Agency should include the following information in the Final MND, at a minimum: x Disclosure on potential health impacts to prospective senior residents from living in proximity to a freeway and other sources of air pollution, and the reduced effectiveness of air filtration system when windows are open and when senior residents are outdoor; x Identification of the responsible implementing and enforcement agency such as the Lead Agency for ensuring that enhanced filters are installed on-site at the Proposed Project before a permit of occupancy is issued; x Identification of the responsible implementing and enforcement agency such as the Lead Agency’s building and safety inspection unit to provide periodic, regular inspection on filters; x Provide information and guidance to the Project developer or proponent on the importance of filter installation and ongoing maintenance; x Provide information to the Project developer or proponent about where the MERV filers can be purchased; x Disclosure on increased costs for purchasing enhanced filtration systems; x Disclosure on increased energy costs for running the HVAC system with MERV filters; x Disclosure on recommended schedules (e.g., once a year or every six months) for replacing the enhanced filtration units; 9This study evaluated filters rated MERV 13 or better. Accessed at: http://www.aqmd.gov/docs/default- source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf. Also see 2012 Peer Review Journal article by South Coast AQMD: http://d7.iqair.com/sites/default/files/pdf/Polidori-et-al-2012.pdf. Venessa Quiroz May 5, 2020 4 x Identification of the responsible entity such as residents or property management to ensure filters are inspected for replacement and maintenance on time, if appropriate and feasible; x Develop ongoing cost sharing strategies, if available, for replacing the enhanced filtration units; x Set up criteria for assessing progress in installing, replacing, and maintaining the enhanced filtration units; and x Set up process for evaluating the effectiveness of the enhanced filtration units at the Proposed Project. Conclusion Pursuant to CEQA Guidelines Section 15074, prior to approving the Proposed Project, the Lead Agency shall consider the MND for adoption together with any comments received during the public review process. Please provide South Coast AQMD with written responses to all comments contained herein prior to the adoption of the Final MND. When responding to issues raised in the comments, response should provide sufficient details giving reasons why specific comments and suggestions are not accepted. There should be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information do not facilitate the purpose and goal of CEQA on public disclosure and are not meaningful, informative, or useful to decision makers and the public who are interested in the Proposed Project. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact me at lsun@aqmd.gov, should you have any questions. Sincerely, Lijin Sun Lijin Sun, J.D. Program Supervisor, CEQA IGR Planning, Rule Development & Area Sources LS LAC200501-05 Control Number State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region 3883 Ruffin Road San Diego, CA 92123 (858) 467-4201 www.wildlife.ca.gov Conserving California’s Wildlife Since 1870 May 21, 2020 Vanessa Quiroz Associate Planner 240 W. Huntington Drive Arcadia, CA 91007 vquiroz@arcadiaca.gov Subject: CEQA Filing Fee Exemption Request Project Name: Artis Senior Living Project SCH Number and/or local agency ID number: N/A Dear Ms. Quiroz: Based on a review of the project referenced above, the California Department of Fish and Wildlife has determined that for the purposes of the assessment of CEQA filing fees (Fish and G. Code § 711.4(c)) the project has the potential to affect fish and wildlife, or their habitat, and the project as described requires payment of a CEQA filing fee pursuant to the California Code of Regulations, Title 14, Section 753.5(d). At the time of filing of the Notice of Determination with the county clerk or Office of Planning and Research (State Clearinghouse), the appropriate CEQA filing fee will be due and payable. Please see the following website for a list of current fees: https://www.wildlife.ca.gov/Conservation/CEQA/Fees. This determination is for the purpose of assessment of CEQA filing fees and is independent of a lead agency’s conclusion or determination regarding a project’s effect on the environment pursuant to CEQA Guidelines section 15064. If you have any questions, please contact Andrew Valand at (562) 342-2142 or by email at Andrew.Valand@wildlife.ca.gov. Sincerely, For Victoria Tang Sr. Environmental Scientist, Supervisor          California Environmental Quality Act MITIGATION MONITORING AND REPORTING PROGRAM Artis Senior Living Project Lead Agency: City of Arcadia 240 W. Huntington Drive Arcadia, CA 91007 (626) 574-5422 Contact: Vanessa Quiroz, Associate Planner Prepared by: 3760 Kilroy Airport Way Suite 270 Long Beach, CA 90806 Office: (562) 200-7165 Fax: (562) 200-1766 Artis Senior Housing Project Mitigation Monitoring and Reporting Program Page 1 May 2020 I. Introduction To ensure that the mitigation measures identified in a project’s Initial Study are implemented, the California Environmental Quality Act (CEQA) requires the Lead Agency for a project to adopt a program for monitoring or reporting on the measures it has imposed to mitigate or avoid significant environmental effects. As specifically set forth in Section 15097(c) of the CEQA Guidelines, the public agency may choose whether its program will monitor mitigation, report on mitigation, or both. “Monitoring” is generally an ongoing or periodic process of project oversight, while “reporting” generally consists of a written compliance review that is presented to the decision-making body or authorized staff person. An Initial Study/Mitigated Negative Declaration (IS/MND) has been prepared to address the Artis Senior Housing Project’s (Project) potential environmental impacts. The evaluation of the Project includes mitigation measures to avoid or substantially lessen potentially significant impacts to less- than-significant levels. Specifically, the IS/MND includes mitigation measures related to the following environmental issue areas: Biological Resources, Cultural Resources, Geology and Soils, Noise, and Tribal Cultural Resources. This Mitigation Monitoring and Reporting Program (MMRP) is designed to monitor implementation of these Project-specific mitigation measures. II. Purpose The overall intent of this MMRP is to: x Verify compliance with mitigation measures identified in the IS/MND prepared for the Proposed Project; x Provide a framework to document implementation of the identified mitigation measures; x Provide a record of mitigation requirements; x Identify monitoring and enforcement agencies; x Establish and clarify administrative procedures for the clearance of mitigation measures; and x Establish the frequency and duration of monitoring. III. Organization As shown in Table 1, each mitigation measure for the Proposed Project is listed by environmental issue area, with accompanying information identifying the: x Enforcement Agency – the agency with the power to enforce the Project’s mitigation measures. x Monitoring Agency – the agency to which reports involving compliance and implementation of the mitigation measures are made. x Monitoring Phase – the phase of the Project (e.g., pre-construction, construction, architectural coatings, occupation, etc.) during which the mitigation measure shall be monitored. x Monitoring Frequency – the frequency at which the mitigation measure shall be monitored during the phase identified in the prior column. x Action Indicating Compliance – the action or actions by which the enforcement/monitoring agency indicates that compliance with the identified mitigation measure has been determined. Artis Senior Housing Project Mitigation Monitoring and Reporting Program Page 2 May 2020 Table 1 – Mitigation Monitoring and Reporting Program No. Mitigation Measures Enforcement Agency Monitoring Agency Monitoring Phase Monitoring Frequency Action Indicating Compliance Biological Resources BIO-1 Tree removal shall not occur during the local nesting season (February 1 to September 15 for nesting birds and February 1 to June 30 for nesting raptors), to the extent practicable. If any construction or tree removal occurs during the nesting season, a nesting bird survey shall be conducted by a qualified biologist prior to commencement of grading or removal of any trees on the property. If the biologist determines that nesting birds are present, restrictions may be placed on construction activities in the vicinity of the nest observed until the nest is no longer active, as determined by the biologist based on the location of the nest, type of the construction activities, the existing human activity in the vicinity of the nest, and the sensitivity of the nesting species. Grading and/or construction may resume in this area when a qualified biologist has determined that the nest is no longer occupied, and all juveniles have fledged. This measure shall be implemented to the satisfaction of the City of the Planning & Community Development Administrator or Designee. City of Arcadia Development Services Department City of Arcadia Development Services Department Pre- Construction/ Construction During all grading and tree-removal activities Submittal of compliance documentation by a qualified biologist BIO-2 Prior to issuance of a building permit, the applicant shall demonstrate that the Project landscaping plan and planned construction are consistent with the City’s Tree Protection Ordinance and the Protected Tree Study. The tree protection activities shall include the following: 1. Prior to demolition, the contractor and consulting arborist shall meet on-site to make sure tree protection zones are established around all protected trees to be preserved and to review the goals for the tree protection plan. 2. Tree protection zone fences shall be placed around each protected tree. Fences shall be at least 4 feet tall and constructed of chain-link fencing secured on metal posts. Where fences are not feasible (e.g., in haul routes or areas where workers will need frequent access), soil and root protection material can be installed. 3. The contractor shall maintain the fences and/or soil protection material throughout the completion of the Project. No staging of materials or equipment or washing out shall occur within the fenced protected zones. 4. Trees should be irrigated throughout the year. A deep watering that provides good soil moisture to a depth of 16 inches is optimal. The trees shall be deeply water once every 21 to 28 days during the summer and fall seasons when rain is unlikely. 5. For Tree No. 49, a protected deodar cedar located on the Project Site’s Colorado Boulevard frontage, the deadwood shall be removed to prevent the dead branches from falling. However, no reduction pruning in the live crown of the tree is required. The tree shall be monitored for its health during the life of the Project, and irrigation shall occur at the same frequency of the other trees. 6. The arborist shall monitor a few critical phases of the Project, including pre-demolition, to direct the installation of protective fences and soil protection measures; grading and excavation; any utility or drainage trenching that is required within a tree protection zone; and a final evaluation during the landscape installation phase. 7. Additional construction best practices described in the Protected Tree Report shall be implemented. City of Arcadia Development Services Department City of Arcadia Development Services Department Pre- Construction/ Construction During Plan Check and construction Submittal of compliance documentation by a Certified Arborist Cultural Resources CUL-1 Treatment of previously unidentified archaeological deposits: If suspected prehistoric or historical archaeological deposits are discovered during construction, all work within 25 feet of the discovery shall be redirected and a Secretary of the Interior Professional Qualified archaeologist and/or Registered Professional Archaeologist shall assess the situation and make recommendations regarding the treatment of the discovery. Impacts to significant archaeological deposits shall be avoided if feasible, but if such impacts cannot be avoided, the deposits shall be evaluated for their eligibility for the California Register of Historical Resources. If the deposits are not eligible, no further protection of the find is necessary. If the deposits are eligible, impacts shall be avoided or mitigated. Acceptable mitigation may consist of, but is not necessarily limited to, systematic recovery and analysis of archaeological deposits, recording the resource, preparation of a report of findings, and accessioning recovered archaeological materials at an appropriate curation facility City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by a qualified archaeologist Artis Senior Housing Project Mitigation Monitoring and Reporting Program Page 3 May 2020 Table 1 – Mitigation Monitoring and Reporting Program No. Mitigation Measures Enforcement Agency Monitoring Agency Monitoring Phase Monitoring Frequency Action Indicating Compliance Geology and Soils GEO-1 Paleontological Resource Monitor: If paleontological resources (fossils) are discovered during Project grading, work shall be halted in that area until a qualified paleontologist can be retained to assess the significance of the find. The Project paleontologist shall monitor remaining earth-moving activities at the Project Site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the CEQA Guidelines and offered for curation at an accredited facility approved by the City of Arcadia. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by qualified Paleontologist Noise NOI-1 Prior to issuance of a Grading Permit, the Project applicant shall demonstrate, to the satisfaction of the City of Arcadia Building Division, that the Project complies with the following: 1. Construction contracts specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State-required noise attenuation devices. 2. The contractor shall provide evidence that a construction staff member will be designated as a noise disturbance coordinator and will be present on-site during construction activities. The noise disturbance coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the noise disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early or bad muffler) and shall implement reasonable measures to resolve the complaint, as deemed acceptable by the Building Official (or designee). All notices that are sent to residential units immediately surrounding the construction site and all signs posted at the construction site shall include the contact name and the telephone number for the noise disturbance coordinator. All necessary signage and notices shall be posted on or sent to residential units immediately surrounding the construction site no less than two weeks prior to the start of noise-generating construction activities on the Project Site. 3. During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers. 4. Prior to issuance of any Grading or Building Permit, the Project applicant sh all demonstrate to the satisfaction of the Building Official (or designee) that construction noise reduction methods shall be used where feasible. These reduction methods may include shutting off idling equipment, installing temporary acoustic barriers around stationary construction noise sources, maximizing the distance between construction equipment staging areas and occupied residential areas, and utilizing electric air compressors and similar power tools. 5. Construction haul routes shall be designed to avoid noise-sensitive uses (e.g., residences and convalescent homes) to the extent feasible. City of Arcadia Development Services Department City of Arcadia Development Services Department Pre- Construction/ Construction During Plan Check and construction Approval of a grading permit Tribal Cultural Resources TCR-1 Retain a Native American Monitor/Consultant. The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant, who is both approved by the Gabrieleño Band of Mission Indians- Kizh Nation Tribal Government and listed under the Native American Heritage Commission’s (NAHC) Tribal Contact list for the area of the project location. This list is provided by the NAHC. The monitor/consultant shall only be present on-site during the construction phases that involve ground disturbing activities. Ground disturbing City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by tribal monitor Artis Senior Housing Project Mitigation Monitoring and Reporting Program Page 4 May 2020 Table 1 – Mitigation Monitoring and Reporting Program No. Mitigation Measures Enforcement Agency Monitoring Agency Monitoring Phase Monitoring Frequency Action Indicating Compliance activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal Monitor/consultant shall complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultur al materials identified. The on-site monitoring shall end when the Project Site grading and excavation activities are completed or when the tribal representatives and monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources. TCR-2 Upon discovery of any tribal cultural or archaeological resources, construction activities shall cease in the immediate vicinity of the find until the find can be assessed. All tribal cultural and archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians-Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians-Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request preservation in place or recovery for educational purposes. Work may continue on other parts of the Project Site while evaluation and, if necessary, additional protective mitigation takes place (CEQA Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources. For unique archaeological resources, preservation in place is the preferred manner of treatment in accordance with PRC Section 21083.2(b). If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. All tribal cultural resources shall be returned to the tribe. Any historic archaeological material that is not Native American in origin shall be curated at a public, nonprofit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to the tribe or a local school or historical society in the area for educational purposes. City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by tribal monitor TCR-3 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 PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation 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 that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed. Upon discovery of human remains, the tribal and/or archaeological monitor/ consultant/consultant shall immediately divert work at minimum of 150 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) shall then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work shall continue to be diverted while the coroner determines whether the remains are human and subsequently Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner shall notify the NAHC as mandated by State law, who will then appoint a Most Likely Descendent (MLD). If the Gabrieleño Band of Mission Indians – Kizh Nation is designated 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 City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by tribal monitor Artis Senior Housing Project Mitigation Monitoring and Reporting Program Page 5 May 2020 Table 1 – Mitigation Monitoring and Reporting Program No. Mitigation Measures Enforcement Agency Monitoring Agency Monitoring Phase Monitoring Frequency Action Indicating Compliance 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. 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. Prior to the continuation of ground disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall 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 shall 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 shall be removed. The tribe shall work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery are approved by the tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations shall either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to 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. Each occurrence of human remains and associated funerary objects shall be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony shall be removed to a secure container on site if possible. These items shall be retained and reburied within six months of recovery. 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. TCR-4 Archaeological and Native American monitoring and excavation during construction projects shall be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of Interior’s Standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in Southern California. The qualified archaeologist shall ensure that all other personnel are appropriately trained and qualified. City of Arcadia Development Services Department City of Arcadia Development Services Department Construction During all ground disturbing activities Submittal of compliance documentation by tribal monitor $WWDFKPHQW1R7 Comment Letters $WWDFKPHQW1R7 From:David Li To:Mailbox - Planning Subject:The Ivy Arcadia Date:Friday, May 31, 2024 7:17:52 PM CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. To Whom It May Concern: I am a resident of The Santa Anita Village community in Arcadia. Our residence is close to the proposed project The Ivy Arcadia, at the former Coco's restaurant location. I am writing to express my concerns with the proposed changes to the project since initial approval. The added square footage, especially the newly proposed 3 story plan, will have significant undesirable effects to our community. The added story will direct invade our privacy, allowing viewing into our backyards and houses. In addition, this will block our view of the mountains, which we cherish. Furthermore, the added traffic would pose safety issues to our community. Indirectly, the combination of these factors will impact the value of our homes. We oppose these new changes wholeheartedly. We hope the planning office will take our concerns into account and urge you to abolish these new changes. Sincerely, David Li 1162 Altura Terrace Arcadia, CA. 91007 From:James Wheeler To:Mailbox - Planning Subject:The Ivy Arcadia - Revised Proposal Date:Sunday, June 2, 2024 8:49:45 AM CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Dear Mr. Arreola, My name is James Wheeler. I am a resident of the City and my residence shares a boundary with the above project which is designated to occupy the site of the former Coco's restaurant. I have recently been made aware of the Developer's proposal to increase the size, scale and scope of The Ivy Arcadia project to a size far exceeding that of the original proposal approved by the City Council in 2020. I want to express my concern about the proposed revisions and communicate both my opposition to the revised project and desire that the Planning Commission and City Council reject the recommendation to proceed. My concern is that the sum of the proposed changes, but particularly the addition of a third story to the building, will diminish privacy for surrounding residents and I, force a lifestyle change upon my family and others, take away mountain views, create excessive noise from workers, visitors and emergency vehicle traffic, and diminish property values. I also want to highlight the following specific concerns as I do not find statements made by the Developer about the revised proposal to be credible. Per the City's website, the revised proposal will increase the building's size from approximately 44,000 square feet to 107,000 sqft, an increase of 143%. Beds will increase from approximately 80 to 114, an increase of 42%, and parking spots from 58 to 70, an increase of 20%. The property will increase in height from 37 feet to over 50 feet, as viewed from the South portion of the parcel. 50 staff members will offer services 24 hours. The Developer has said the project "does not pencil out" if scaled down and changes to the proposal will be "too costly". However, most of the added square footage is planned for on-site amenities which will sit vacant much of the time the building is open. I find the proposal and scale is excessive when comparing the 143% increase in square footage against a meager 42% increase in beds. Further, given the topography of the building site, the proposed three story building will sit uphill of surrounding single-story residences. The height of the building combined with the lower elevations of surrounding residences will cause the building to tower over the neighborhood and compromise the neighborhood's aesthetics. I believe zoning guidelines generally require a graded transition from lower to higher-height buildings. This new proposal falls short of these guidelines, and it is not plausible that the three story building will be compatible with the look and "feel" of the surrounding single-story homes, as the Developer has suggested. The height difference will be stark. Consider the example of the Dunn-Edwards paint store at Michillinda and Colorado against the surrounding area. I estimate the relative final height of the proposed three story building from my own backyard will exceed 60 feet. The Developer has said the proposed height of the new building is the same as that originally approved in 2020. This is not fully correct. In fact, the Planning Commisioner, Mr. Tsoi, pushed back against the Developer during the Commision's May 14, 2024 meeting and stated his belief that the building will be higher than described given the building's position on the lot and the lot's topography relative to the surrounding residences. He urged the Developer to recalculate the building's height, inclusive of the proposed grade changes. Again, I estimate the relative height of the proposed three story building from my own backyard will exceed 60 feet, not 40 feet as claimed. The Developer has stated they will expand green spaces to buffer the taller building from the neighborhood, but their submitted plans do not reflect this. In fact, the Developer plans to remove trees along property lines to the East and South which will make the building more visible to those surrounding residences. The Developer has talked about building taller block walls to lessen the impact of the building's presence, but has also spoke of hauling in tons of soil to flatten and raise the building site. I am not clear as to how raising the level of the lot and building taller block walls will benefit the neighbors. There has been no mention of the height of the proposed walls or what we neighbors will see when we look out our windows, but I imagine a 12' foot block wall instead of the 6' walls we now have. The Developer has stated the building will not obstruct residents' mountain views because residents cannot see the mountains from their properties anyway. This is not true. I can see the mountains from my backyard without problem. Constructing a taller building and increasing the height of block walls will certainly block the views my neighbors and I currently have. The Developer has stated they will amend the interior layout of the building such that South and East facing units / rooms, specifically those on the second and third floors, will be turned inward and windowed corridors built along the building's perimeter to prevent Ivy residents from having direct views into backyards and windows of surrounding residences. This statement has not been offered in writing, hence the interior looking layout cannot be guaranteed. Furthermore, the idea of the windowed corridors was haphazardly discussed at the May 14 Planning Commission Meeting, but no details were given. And, residents walking the external corridors can still peer through the windows into surrounding residences, especially given the increased building height. The Developer has stated they have spoken to Lower Rancho HOA leadership and members who expressed "excitement for the project". In fact, many, if not all, of the residences impacted by the proposal are not included in the HOA and were not aware of the proposed design change until recently, nor are we excited about it. The Developer made no effort to contact those directly impacted by the change until after we residents provided public comment during the Planning Commission's May 14, 2024 meeting. Since then, the Developer has been aggressive in its attempts to meet with local home owners and sway opinion toward approval of the project by offering "free" renderings of the property from their backyards, and promises to mitigate concerns by adding trees, higher block walls, etc. None of this has been offered in writing, hence cannot be guaranteed. The Developer has created additional parking spaces on the property by repositioning them along the East and South sides of the lot's perimeter, directly behind the block wall separating the lot from surrounding residences. Given Ivy employees will be working around the clock, and from past experiences when Coco's was open, we residents expect a substantial increase in vehicle noise that will include (and has in the past) vehicle start ups, engines revving, radios / music, talking / laughing, alarms, etc. at all ours of day and night. The Developer attempted to shift accountability for the parking lot layout and claimed the layout was due to "City requirements" rather than a result of the Developer's own desire to increase square footage and bed count. I believe the Developer did not consider the parking impact to surrounding residents and, in fact, could have shifted planned parking spaces more to the North and West perimeters of the lot, and along the North and West sides of the building. In summary, I object to the plan revision and increased height of the proposed building (3 stories) for the reasons described above, and hope both the Planning Commission and City Council rescind their support of the revised project by rejecting the revision to the original plans for the property. I and my neighbors do not support the revised plan. Thank you for your time and consideration, James Wheeler 1147 Altura Terrace 310-738-0153 From:Ling Zeng To:Mailbox - Planning Subject:Be opposed to proposed 3 story development on site of former coco’s restaurant. Date:Wednesday, June 5, 2024 3:04:36 PM CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Hello dear Arcadia Planning staff, We are residents of 1156 Altura terrace Arcadia, CA 91007. We are unable to attend the meeting on May 14th due to traveling . We would like to express our concern that the building’ new plan on extending additional unit which increasing the height will affects the privacy and property value of the residents. LING ZENG 06/05/2024 From:Mailbox - Planning To:Edwin Arreola Cc:Lisa Flores; Fiona Graham Subject:FW: Concerns Regarding Project: The Ivy Arcadia Date:Monday, June 10, 2024 3:28:09 PM Hi Edwin, We have received the comment below regrading the Ivy project. I will also forward it to the Commissioners. Thank you, Ivette -----Original Message----- From: Helen Kuo <helen1kuo@gmail.com> Sent: Monday, June 10, 2024 3:21 PM To: Mailbox - Planning <planning@ArcadiaCA.gov> Subject: Concerns Regarding Project: The Ivy Arcadia CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Dear Arcadia Development Services, My name is Yue-Lan Kuo and I currently reside at 1159 Altura Terrace in Arcadia. It has recently come to my attention that there has been a proposal to increase the building size of the planned assisted living care facility that will be located on 1150 W. Colorado Boulevard. I am writing to express my concern regarding this proposal. The increase in building size will likely result in increased noise and traffic in the neighborhood. Additionally, the increase in building height may allow the building a direct view into our backyard and house, reducing our privacy. My neighbors have also reached out and expressed similar concerns. Please reconsider this proposal as it may lower the quality of living of existing residents. Thank you, Yue-Lan Kuo Cell: (626) 572-7864 Email: helen1kuo@gmail.com <mailto:helen1kuo@gmail.com> From:Edwin Arreola To:Edwin Arreola Subject:FW: CalHDF public comment re 1150 W. Colorado Boulevard for 11Jun2024 Planning Commission meeting Date:Wednesday, August 14, 2024 3:02:20 PM Attachments:Arcadia - HAA Letter - 1150 W. Colorado Blvd.pdf -----Original Message----- From: James Lloyd <james@calhdf.org> Sent: Monday, June 10, 2024 3:36 PM To: Mailbox - Planning <planning@ArcadiaCA.gov> Cc: lfores@arcadiaca.gov; Arcadia City Clerk <CityClerk@arcadiaca.gov>; Rachelle Arellano <rarellano@arcadiaca.gov>; Dominic Lazzaretto <domlazz@arcadiaca.gov> Subject: CalHDF public comment re 1150 W. Colorado Boulevard for 11Jun2024 Planning Commission meeting CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Dear Arcadia Planning Commission, Please see attached CalHDF's public comment regarding the proposed 100-unit senior assisted living facility, "The Ivy Arcadia '' at 1150 W. Colorado Blvd, calendared as agenda item 1 for the consent calendar for the 11 June 2024 Planning Commission meeting. Sincerely, James M. Lloyd Director of Planning and Investigation james@calhdf.org <mailto:james@calhdf.org> Jun 10, 2024 City of Arcadia 240 W Huntington Drive Arcadia, CA 91007 Re: Proposed Senior Assisted Living Facility at 1150 W. Colorado Boulevard By email:planning@ArcadiaCA.gov Cc:lfores@ArcadiaCA.gov,CityClerk@ArcadiaCA.gov,rarellano@ArcadiaCA.gov, domlazz@ArcadiaCA.gov DearArcadiaPlanningCommission, TheCaliforniaHousingDefenseFund(“CalHDF”)submitsthislettertoinformthe Commissionthatithasanobligationtoabidebyallrelevantstatehousinglawswhen evaluatingtheproposed100-unitseniorassistedlivingdevelopmentat1150WestColorado Boulevard(“theproject”), includingtheHousingAccountabilityAct(Gov.Code§65589.5,the “HAA”)andtheDensityBonusLaw(“DBL”). TheHAArequiresapprovalofzoningandgeneral plancompliantprojectsunless ʉindings canbemaderegardingspeciʉic, objective, written health and safety hazards. The project fallswithintheHAA’sambit,asitcomplieswiththeZoningCodeandGeneralPlanas outlinedinthestag report. Thus, theCommissionmust approvetheproject unlessit makes writtenhealthandsafety ʉindings, asdescribedabove–whichitcannotdo, sincethe preponderanceoftheevidenceintherecorddoesnotsupportsucha ʉinding. Ofnote, increaseddensity, concessions, andwaiversthataprojectisentitledtoundertheDBL(Gov. Code, § 65915) do not render the project noncompliant with the zoning code or general plan, forpurposesoftheHAA. (Gov. Code,§65589.5,subd.(j)(3).) CalHDFalsowritestoemphasizethattheDBLogerstheproposeddevelopmentcertain protections.TheCouncilmustrespecttheseprotections.Inadditiontograntingtheincrease inresidentialunitsallowedbytheDBL,theCouncilmustnotdenytheprojecttheproposed waivers/concessionswithrespectto floorarearatio, unlessitmakeswritten ʉindingsas required by Gov. Code, § 65915, subd. (e)(1) that the waiver would have a speciʉic, adverse 360 Grand Ave #323, Oakland 94610 www.calhdf.org impactuponhealthorsafety,andforwhichthereisnofeasiblemethodtosatisfactorily mitigateoravoidthespeciʉicadverseimpact. Inparticular, theCommissionmaynotdenytheprojectduetosubjectivedesignreview standards,suchasaesthetics,astheHAAonlypermitsconsiderationofobjectivestandards (Gov. Code § 65589.5, subd. (j).) The HAAdeʉines“objective” as“involvingnopersonal or subjectivejudgment byapublicofʉicialandbeinguniformlyveriʉiablebyreferencetoan externalanduniformbenchmarkorcriterionavailableandknowablebyboththe developmentapplicantorproponentandthepublicofʉicial.”(Id.atsubd.(h)(9).)Itwouldbe impossibleforanapplicanttoknow ex ante that the Commission would object to the proposedCapeCodarchitecturalstyle,theproject’srelativearchitectural “compatibility” withthesurroundingneighborhood,thefactthatthebuildingwouldbethreestoriestall,or thedegreeoffaçadearticulationproposed,allofwhicharereferencedasgroundsfor disapproval inproposeddisapproval resolutionnumber2146. Theseobjectionsaretherefore invalidgroundsfordisapprovaloftheprojectundertheHAA. Instead,theCommissionmustapprovethearchitectural designreviewpermitinorderto facilitatetheproject, consistentwithitsobligationsundertheHAA. Afailuretodoso exposestheCitytolegalactionbytheapplicantandhousingorganizationssuchasCalHDF. (Id.atsubd.(k)(1)(A)(i);see,e.g.,CaliforniaHousingDefenseFundv.CityofLaCañada Flintridge,CaseNo.23STCP02614,RulingIssuedMar.4,2024[compellingcitytoprocess applicationforhousingdevelopmentprojectundertheHAA].) Asyouarewellaware,Californiaremainsinthethroesofastatewidecrisis-levelhousing shortage.Newhousingsuchasthisisapublicbeneʉit;itwillbringincreasedtaxrevenueand itwouldhouseourmostvulnerableresidents,seniorcitizens.Whilenooneprojectwillsolve thestatewidehousingcrisis, theproposeddevelopmentisastepintherightdirection. CalHDFurgestheCommissiontoapproveit,consistentwithitsobligationsunderstatelaw. CalHDF is a 501(c)3 non-proʉitcorporationwhosemissionincludesadvocatingforincreased accesstohousingforCaliforniansatallincomelevels,includinglow-incomehouseholds. YoumaylearnmoreaboutCalHDFat www.calhdf.org. Sincerely, DylanCasey CalHDFExecutiveDirector 2of3 James M. Lloyd CalHDFDirectorofPlanningandInvestigations 3of3 From:Matt Gelfand on behalf of matt@caforhomes.org To:Lisa Flores; Edwin Arreola; michael.maurer@bbklaw.com Subject:RE: Correspondence from Californians for Homeownership Date:Tuesday, June 11, 2024 1:39:41 PM Attachments:2024-6-11 - Letter to Planning Commission.pdf CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Folks, We have sent the attached letter to the Planning Commission. I write to you separately to speak with a bit more candor. It is 2024. You all know by now that a local agency cannot use the bases listed in these proposed findings to justify denying this project. By preparing this draft, you are marching the City toward litigation. The better course—and the only lawful one—is to simply advise the Commission that there is way for you to draft findings of denial that are consistent with your professional duties to ensure that the City acts lawfully. I really hope you consider saying as much this evening. Matt Gelfand From: Matt Gelfand <admin@caforhomes.org> Sent: Tuesday, June 11, 2024 1:33 PM To: 'planning@arcadiaca.gov' <planning@arcadiaca.gov> Cc: 'lflores@arcadiaca.gov' <lflores@arcadiaca.gov>; 'earreola@arcadiaca.gov' <earreola@arcadiaca.gov>; 'michael.maurer@bbklaw.com' <michael.maurer@bbklaw.com> Subject: Correspondence from Californians for Homeownership Hello, Please provide the attached comment to the Planning Commission in connection with Consent Calendar Item 1 on its agenda today. All the best, Matthew Gelfand -- Matthew Gelfand Counsel, Californians for Homeownership 525 S. Virgil Avenue Los Angeles, CA 90020 matt@caforhomes.org Tel: (213) 739-8206 Californians for Homeownership is a 501(c)(3) non-profit organization that works to address California’s housing crisis through impact litigation and other legal tools. MATTHEW GELFAND, COUNSEL MATT@CAFORHOMES.ORG TEL: (213) 739-8206 June 11, 2024 VIA EMAIL Planning Commission City of Arcadia 240 West Huntington Dr. P.O. Box 60021 Arcadia, CA 91066 Email: planning@arcadiaca.gov RE: The Ivy Arcadia (1150 W. Colorado Blvd.) To the Planning Commission: Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools to address California’s housing crisis. We are writing regarding the Ivy Arcadia project. The City’s approval of this project is governed by the Housing Accountability Act, Government Code Section 65589.5. For the purposes of Government Code Section 65589.5(k)(2), this letter constitutes our written comments on the project. The Housing Accountability Act generally requires the City to approve a housing development project unless the project fails to comply with “applicable, objective general plan, zoning, and subdivision standards and criteria, including design review standards, in effect at the time that the application was deemed complete.” Gov. Code § 65589.5(j)(1). To count as “objective,” a standard must “involve[e] no personal or subjective judgment by a public official and be[] uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” Gov. Code § 65589.5(h)(8). In making this determination, the City must approve the project if the evidence “would allow a reasonable person to conclude” that the project met the relevant standard. Gov. Code § 65589.5(f)(4). Projects subject to modified standards pursuant to a density bonus are judged against the City’s standards as modified. Gov. Code § 65589.5(j)(3). The City is subject to strict timing requirements under the Act. If the City desires to find that a project is inconsistent with any of its land use standards, it must issue written findings to that effect within 30 to 60 days after the application to develop the project is determined to be complete. Gov. Code § 65589.5(j)(2)(A). If the City fails to do so, the project is deemed consistent with those standards. Gov. Code § 65589.5(j)(2)(B). If the City determines that a project is consistent with its objective standards, or a project June 11, 2024 Page 2 is deemed consistent with such standards, but the City nevertheless proposes to reject it, it must make written findings, supported by a preponderance of the evidence, that the project would have a “specific, adverse impact upon the public health or safety,” meaning that the project would have “a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.” Gov. Code § 65589.5(j)(1)(A); see Gov. Code § 65589.5(k)(1)(A)(i)(II). Once again, “objective” means “involving no personal or subjective judgment by a public official and being uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” Gov. Code § 65589.5(h)(8). Even if the City identifies legally sufficient health and safety concerns about a project, it may only reject the project if “[t]here is no feasible method to satisfactorily mitigate or avoid the adverse impact . . . other than the disapproval of the housing development project . . . .” Gov. Code § 65589.5(j)(1)(B). Thus, before rejecting a project, the City must consider all reasonable measures that could be used to mitigate the impact at issue. For projects that provide housing for lower-income families, the Act is even more restrictive. In many cases, the City must approve such a project even if it fails to meet the City’s objective land use standards. See Gov. Code § 65589.5(d). These provisions apply to the full range of housing types, including single-family homes, market-rate multifamily projects, and mixed-use developments. Gov. Code § 65589.5(h)(2); see Honchariw v. Cty. of Stanislaus, 200 Cal. App. 4th 1066, 1074-76 (2011). And the Legislature has directed that the Act be “interpreted and implemented in a manner to afford the fullest possible weight to the interest of, and the approval and provision of, housing.” Gov. Code § 65589.5(a)(2)(L). When a locality rejects or downsizes a housing development project without complying with the rules described above, the action may be challenged in court in a writ under Code of Civil Procedure Section 1094.5. Gov. Code § 65589.5(m). The legislature has significantly reformed this process over the last few years in an effort to increase compliance. Today, the law provides a private right of action to non-profit organizations like Californians for Homeownership. Gov. Code § 65589.5(k). A non-profit organization can sue without the involvement or approval of the project applicant, to protect the public’s interest in the development of new housing. A locality that is sued to enforce Section 65589.5 must prepare the administrative record itself, at its own expense, within 30 days after service of the petition. Gov. Code § 65589.5(m). And if an enforcement lawsuit brought by a non-profit organization is successful, the locality must pay the organization’s attorneys’ fees. Gov. Code § 65589.5(k)(2). In certain cases, the court will also impose fines that start at $10,000 per proposed housing unit. Gov. Code § 65589.5(k)(1)(B)(i). In recent years, there have been a number of successful lawsuits to enforce these rules: x In Honchariw, 200 Cal. App. 4th 1066, the Court of Appeal vacated the County of Stanislaus’s denial of an application to subdivide a parcel into eight lots for the June 11, 2024 Page 3 development of market-rate housing. The court held that the county did not identify any objective standards that the proposed subdivision would not meet, and therefore violated the Housing Accountability Act in denying the application. x In Eden Housing, Inc. v. Town of Los Gatos, Santa Clara County Superior Court Case No. 16CV300733, the court determined that Los Gatos had improperly denied a subdivision application based on subjective factors. The court found that the factors cited by the town, such as the quality of the site design, the unit mix, and the anticipated cost of the units, were not objective because they did not refer to specific, mandatory criteria to which the applicant could conform. x San Francisco Bay Area Renters Federation v. Berkeley City Council, Alameda County Superior Court Case No. RG16834448, was the final in a series of cases relating to Berkeley’s denial of an application to build three single family homes and its pretextual denial of a demolition permit to enable the project. The Court ordered the city to approve the project and to pay $44,000 in attorneys’ fees. x In 40 Main Street Offices v. City of Los Altos, Santa Clara County Superior Court Consolidated Case Nos. 19CV349845 & 19CV350422, the court determined that the Los Altos violated the Housing Accountability Act, among other state housing laws, by failing to identify objective land use criteria to justify denying a mixed- use residential and commercial project. The City was ultimately forced to pay approximately $1 million in delay compensation and attorneys’ fees in the case. x In Californians for Homeownership v. City of Huntington Beach, Orange County Superior Court Case No. 30-2019-01107760-CU-WM-CJC, a case brought by our organization, the court ruled that Huntington Beach violated the Housing Accountability Act when it rejected a 48-unit condominium project based on vague concerns about health and safety. Following the decision, the City agreed to pay $600,000 in attorneys’ fees to our organization and two other plaintiffs. Based on the above legal framework, state law requires the City to approve this project. If you do not, we are likely to initiate litigation under the Housing Accountability Act. Sincerely, Matthew Gelfand cc: Lisa L. Flores, Dep. Dev. Svcs. Dir. (by email to lflores@arcadiaca.gov) Edwin Arreola, Acting Senior Planner (by email to earreola@arcadiaca.gov) Michael Maurer, Esq., City Attorney (by email to michael.maurer@bbklaw.com) $WWDFKPHQW1R8 Letter to City Council from Cox Castle dated August 14, 2024 $WWDFKPHQW1R8 105167\17821195v1 www.coxcastle.com Los Angeles | Orange County | San Francisco Cox, Castle & Nicholson LLP 3121 Michelson Drive, Suite 200 Irvine, California 92612 -5678 P: 949.260.4600 F: 949.260.4699 Christopher Burt 949.260.4606 CBurt@coxcastle.com August 14, 2024 VIA E-MAIL Arcadia City Council City of Arcadia 240 West Huntington Drive P.O. Box 60021 Arcadia, CA 91066 Re: The Ivy Arcadia Project (ADR 23-13 and CUP 23-09) Dear Mayor Cao and City Councilmembers: This firm represents O & I Development, LLC (“O&I”), the applicant proposing The Ivy Arcadia project, a three-story senior assisted living/memory care facility with 100 residential units and 114 beds. The project is proposed to be located at 1150 W. Colorado Boulevard, a commercially zoned site located at the intersection of Colorado Boulevard and Michillinda Avenue, two major thoroughfares within the City of Arcadia (“City”). The project will be presented to the City Council on August 20, 2024. I write this letter to emphasize three salient issues related to the City Council’s consideration of the project: 1. First, O&I made noteworthy project changes and conducted significant neighborhood outreach to address resident concerns about the project and provide comfort that the project will not adversely impact the neighborhood. Those revisions were in addition to the original design of the project, which was sensitive to the surrounding community. For instance, the project proposes setbacks far in excess of what is required by the Arcadia Municipal Code (“AMC”). 2. Second, the proposed project is a “housing development project” subject to the Housing Accountability Act (“HAA”). As such, the City Council cannot deny the project – which is consistent with all applicable objective standards – unless the agency concludes that the project would have a specific, adverse impact on the public health or safety. (Govt. Code § 65589.5(j)(1).) The project would not result in a specific, adverse impact on the public health or safety, and the City Council’s discretion is limited by the HAA. (Govt. Code § 65589.5(a)(3) [HAA expressly states that “the conditions that would have a specific, adverse impact upon the public health and safety … arise infrequently”].) 105167\17821195v1 Arcadia City Council August 14, 2024 Page 2 3. Third, the proposed project provides a much-needed housing type within the City and Southern California, one that serves an aging population. The units will range from 396 square foot studios to 1,146 square foot two-bedroom units. I. Applicant’s Project Changes The project was first presented to the City Planning Commission on May 14, 2024, with a staff recommendation for approval given the project’s consistency with the underlying General Plan designation, zoning, and applicable development standards. However, ignoring that recommendation and instead heeding the concerns expressed by a few residents, the Planning Commission voted to recommend denial of the proposed project. The resident concerns largely related to building height and purported view, neighborhood consistency, and privacy concerns, but also other minor design issues. Because staff’s recommendation was for approval, a resolution recommending denial had to be drafted. Therefore, the project was scheduled to return to the Planning Commission on June 11, 2024. O&I, hearing the concerns expressed at the earlier hearing, immediately started engaging surrounding residents and incorporating design changes that directly responded to stated concerns. First, O&I’s representative contacted residents to hear their specific concerns, including hosting a June 3rd community meeting (with invites sent to all residences within a 300 -foot radius of the project site). That meeting was attended by 18 homeowner s. O&I also met with individual homeowners at their residences, discussing individual concerns and receiving feedback. Second, with that feedback, O&I made strategic design revisions to address resident concerns. Those revisions include, among other things: a. Electrical Charging Parking Spaces: The initial design included EV parking spaces along the eastern property line. The EV spaces were relocated to the eastern side of the building close to the pedestrian sidewalk and away from the adjacent residences. b. Resident Balconies. The community expressed concern that the southern and eastern façade had multiple traditional balconies. However, the majority of the units have “Juliette” balconies, which are an attractive architectural embellishment rather than a traditional balcony, which functions as an outdoor living amenity. There are only two traditional balconies on the each the southern and eastern elevations (for a total of four traditional balconies). The remainder are Juliette, which were specifically included for design articulation purposes and because future residents that require assistance with daily living are unlikely to use full balconies. 105167\17821195v1 Arcadia City Council August 14, 2024 Page 3 c. Parking Spaces: The Planning Commission and residents expressed concern about the parking spaces proposed near the southern and eastern property lines. O&I removed six (6) spaces along the southern property line and four (4) along the eastern property line. d. Enhanced Green Screening: A number of residents expressed a strong desire for green screening along their property line. The project proposes to retain 54 of the existing trees on-site and plant 83 additional trees to enhance screening. O&I offered to do view simulations for concerned residents, showing that the existing and proposed landscaping would substantially screen the project from view. e. Perimeter Wall Safety: The original project design included limited space between the project’s proposed retaining wall and the existing wall. O&I was able to successfully re-engineer the perimeter boundary, successfully eliminating th e need for new retaining walls. f. Dog Park Smell: O&I moved the dog park further away from the property line. Also, as with all O&I’s communities, the dog park will be meticulously maintained to ensure cleanliness and hygiene by a dedicated maintenance team. The above demonstrates that, although the project complies with all objective development standards, the project applicant has engaged significantly in the public process to design a project that is sensitive to the surrounding community. However, notwithstanding O&I’s efforts, the Planning Commission still recommended the City Council deny the proposed project. II. The Project Is Subject to the HAA The proposed project is a housing development project subject to the HAA, which was enacted to facilitate housing projects and limit arbitrary denial of such projects. (California Renters Legal Advocacy & Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 844 [the HAA “cabins the discretion of a local agency to reject proposals for new housing”].) For the HAA, a “housing development project” is a use consisting of any of the following: (1) residential units only, (2) mixed-use developments consisting of residential and nonresidential uses with at least 2/3rds of the square footage designated for residential uses, and (3) transitional housing or supportive housing. (Govt. Code § 65895.5(h)(2).) An assisted living/memory care (“ALMC”) facility is a housing devel opment project because it consists of residential uses and ancillary supportive/service uses that, even construed as nonresidential uses, do not take the project out of the HAA (because more than 2/3rds of the square footage is for residential uses/units). The Civil Code defines a “senior citizen housing development” as “a residential development developed … for, senior citizens that has at least 35 dwelling units.” (Civil Code § 51.3 [emphasis added].) A “dwelling unit” or “housing” is defined 105167\17821195v1 Arcadia City Council August 14, 2024 Page 4 to mean “any residential accommodation other than a mobile home.” (Id. [emphasis added].) The project is clearly a “housing development project” under the HAA.1 Because the project is a housing development project, the City may not deny or condition a proposed project because of an alleged inconsistency with a subjective development standard. (Id. at 831 [HAA restricts “the ability of local governments to deny an application to build housing if the proposed project complies with general plan, zoning, and design revie w standards that are objective”].) A standard is subjective, as opposed to objective, if it cannot be applied without personal interpretation or subjective judgment. (Bankers Hill 150 v. City of San Diego (2022) 74 Cal.App.5th 755, 778.) To that end, the Planning Commission’s recommendation for denial, which was based on subjective conclusion that the project “is not compatible in terms of design, height, and scale with the residential land use in the vicinity” of the project site, violates the HAA. (Resolution No. 2146.) The project is, in fact, consistent with all applicable objective standards. It does exceed the maximum FAR of 0.50, but the project is also a Density Bonus Law (“DBL”) project and is entitled to waiver of that standard. (Govt. Code § 65915.) Importantly, a project’s deviation from a development standard pursuant to the DBL is not grounds to conclude that the project is not consistent with all applicable objective standards. The HAA expressly states that the HAA and DBL function together, and that the receipt of a density bonus, incentive, concession, or waiver, or reduction of development standard under the DBL “shall not constitute a valid basis on which to find a proposed housing development project is inconsistent, not in compliance, or not in conformity” with an applicable standard. (Govt. Code § 65589.5(j)(3).) If a housing development project complies with applicable objective standards, an agency may only deny or reduce the density of the proposed project if it finds, by a preponderance of the evidence in the record, that (1) the project would have a specific, adverse impact on the public health or safety, and (2) that there is no feasible method to satisfactorily mitigate or avoid the adverse impact identified other than denial or approval of the project at a lower density. (Govt. Code § 65589.5(j)(1)(A); Save Lafayette v. City of Lafayette (2022) 85 Cal.App.5th 842, 850.) A “specific, adverse” impact is defined narrowly to mean “a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.” (Id. However, specific, adverse impacts are a rarity, a fact the HAA recognizes. (Govt. Code § 65589.5(a)(3) [“the conditions that would have a specific, adverse impact upon the public health and safety … arise infrequently”].) Thus, agencies proposing to disapprove or limit density of a proposed project face an extremely high burden. 1 The trial court in Yes In My Back Yard v. City of Simi Valley reached this exact conclusion, holding that ALMC facility is a housing development project under the HAA. (Ventura County Superior Court Case No. 56 -2020- 00539590-CU-WM-VTA.) 105167\17821195v1 Arcadia City Council August 14, 2024 Page 5 There is no evidence that the proposed project would, as designed to be consistent with objective standards, would result in a specific, adverse impact on the public health and safety. Therefore, the City’s discretion regarding the proposed project is limited by the HAA and the City Council may not deny the project or reduce its density (or FAR here, which is used to calculate density). In fact, quite the opposite is true. The project is thoughtfully designed (and was redesigned) to ensure consistency with the surrounding area, which intermingles devoutly commercial uses (as the existing General Plan designation and zoning reflect) and residential uses. With that thoughtful design, which is actually less intensive than other uses that could be established by-right, the project proposes a much needed residential product that will serve aging residents. I appreciate your time and attention to this matter. O&I looks forward to presenting The Ivy Arcadia project to the City Council on August 20, 2024. Sincerely, Cox, Castle & Nicholson LLP Christopher Burt cc: Michael Maurer, City Attorney Jason Kruckeberg, Development Services Director Lisa Flores, Deputy Development Services Director