Arcadia City Council
July 19, 2022

DATE: July 19, 2022

TO: Honorable Mayor and City Council

FROM: Jason Kruckeberg, Assistant City Manager/Development Services Director Lisa L. Flores, Planning & Community Development Administrator

SUBJECT: RESOLUTIONS RELATED TO MINOR USE PERMIT NO. MUP 21 -08, ARCHITECTURAL DESIGN REVIEW NO. ADR 21 -12, GENERAL PLAN CONSISTENCY NO. GPC 22-01, TENTATIVE PARCEL MAP NO. TPM 21- 02, A DENSITY BONUS AND A PUBLIC ALLEY VACATION ALONG WITH

AN ENVIRONMENTAL IMPACT REPORT UNDER THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT ( “CEQA”) FOR THE “ALEXAN
ARCADIA” MIXED-USE PROJECT LOCATED AT 150 N. SANTA ANITA AVENUE

RESOLUTION NO. 7433 ORDERING THE VACATION OF THE

EAST/WEST ALLEY WITHIN THE BLOCK BOUNDED BY SANTA ANITA

AVENUE, SANTA CLARA STREET, FIRST AVENUE AND WHEELER
AVENUE
Recommendation: Adopt

RESOLUTION NO. 7434 ADOPTING CEQA FINDINGS OF FACT,

ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM,

AND CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT
FOR THE "ALEXAN ARCADIA" MIXED -USE DEVELOPMENT WITH 319 RESIDENTIAL UNITS, INCLUDING 26 AFFORDABLE UNITS, LOCATED AT 150 N. SANTA ANITA AVENUE
Recommendation: Adopt

RESOLUTION NO. 7435 APPROVING MINOR USE PERMIT NO. MUP 21- 08, ARCHITECTURAL DESIGN REVIEW NO. ADR 21 -12, GENERAL PLAN CONSISTENCY NO. GPC 22-01, TENTATIVE PARCEL MAP NO.

TPM 21 -02, A DENSITY BONUS AND A PUBLIC ALLEY VACATION

ALONG WITH AN ENVIRONMENTAL IMPACT REPORT UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT ( “CEQA”) FOR THE
“ALEXAN ARCADIA” MIXED-USE DEVELOPMENT LOCATED AT 150 N.

SANTA ANITA AVENUE
Recommendation: Adopt

150 N. Santa Anita Ave.

Alexan Mixed-Use Project
July 19, 2022

SUMMARY

At the June 21, 2022, City Council M eeting, the City Council held a public hearing considering the Alexan Arcadia Project. The Staff Report was presented and public comments were received from the following individuals:

• Noah Garrison, on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”)

• Richard Burns, on behalf of the Southwest Regional Council of Carpenters (“SWRCC”)

• Steven DeLateur, on behalf of neighboring property owner Dr. Dong Chang

• David Fu, on behalf of neighboring property owner Dr Dong Chang

At the conclusion of the public hearing, the City Council voted 4-1 to continue the hearing to the July 19, 2022, public hearing to allow additional time for the applicants and representatives of Dr. Dong Chang to meet and discuss the existing Parking and Access Easement Agreement (“Agreement”). Representatives of Dr. Chang had requested an additional thirty (30) days to work with the applicant to determine if an agreement could be reached between the parties on several issues.

It is recommended that the City Co uncil approve Minor Use Permit No. M UP 21 -08, Architectural Design Review No. ADR 21- 12, and Tentative Parcel Map No. TPM 21- 02 along with a density bonus and street vacation, through the adoption of Resolutions No. 7433, 7434, and 7435.

DISCUSSION

Representatives of Dr. Chang and the applicant held numerous discussions following the June 21, 2022, public hearing. As requested by the City Council, both parties kept the Development Services Department apprised of their communications. As a result of their discussions, a redlined version of a new Agreement was distributed by David Fu to the Applicant on June 28, 2022. This version represents a significant change to th e Agreement in that Dr. Chang’s property would receive additional rights a nd allowances not currently found in the existing Agreement. Some of the key components of the Agreement include:

• Allows for the designation of 25 parking spaces for exclusive use of Dr. Chang’s business during specified hours of operation as well as access to an additional 15 parking spaces within the parking structure. Additionally, the plan calls for access to seven (7) ADA parking spaces. As a reminder, the existing agreement allows for access to 40 spaces, but no specific designation of spaces. The revised 150 N. Santa Anita Ave.

Alexan Mixed-Use Project
July 19, 2022

agreement would also provide for parking spaces during construction of the project for Dr. Chang’s patients and visitors, including valet parking.

• Outlines processes for expert review of plans by representatives of Dr. Chang during the plan review process.

• Provides for a deposit of up to $50,000 for reimbursement of the representatives hired by Dr. Chang for plan review (later revised to $90,000).

• Outlines procedures for complaints to be raised and dealt with between the parties.

• Includes provisions for ensuring HVAC system is maintained and repaired as necessary throughout construction.

• Includes provisions for enhanced monitoring of Dr. Chang’s building during construction for settlement and/or other damages.

The redlined agreement had also included a request to the City to provide for paid monthly parking permits (or similar arrangement) for use of spaces within the adjacent City parking lot if parking after completion of the project proved to be impacted. The City did not agree to this request. Parking spaces in the City lot are to be shared by all businesses and visitors to the Downtown area. Management of the parking lot is ongoing, and certain changes such as time restrictions and placement of ADA spaces has occurred over time in response to changing circumstances. It is not the City’s intent to begin designating parking spaces for specific users within th e surface parking lot at this time. Once the Alexan Arcadia is open and operational, it is anticipated that additional management measures may be necessary, but at this time there is no intent to designate parking spaces.

Representatives from the Alexan sent back a revised redlined version on June 12, 2022.

Although there is agreement on much of the details, some outstanding issues remain. It is important to note that the provisions of the Agreement between the parties listed above are only being provided here to give the City Council information as to the ongoing discussions between the parties. As was mentioned during the June 21, 2022, public hearing, the referenced Agreement is outside of the project approval documents, and it is the opinion of the City Attorney that a determination on the project can move forward with no changes to the Agreement. That being said, the Applicant is amendable to a revised Agreement and has been working toward that conclusion. As of the date of this staff report, the revised Agreement has not yet been signed. The City Council will receive additional information on the status of the discussions up to the date of the July 19, 2022, public hearing.

Another issue from the June 21, 2022, public hearing that was raised by one of the speakers was the presence of a former laundry service/ dry cleaner facility that used to occupy a portion of the site years ago. Following the speaker, it was represented that the 150 N. Santa Anita Ave.

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dry cleaning facility was located across the s treet in another location. This is incorrect.

This use was located on the project site. However, the EIR acknowledged this and evaluated the site. Below is language from the EIR on this facility.

Section 4.7, Hazards and Hazardous Materials of the Draft EIR and the associated Phase I Environmental Site Assessment (ESA) (see Appendix F -1 of the Draft EIR) identify the location of a former laundry/dry cleaning facility located at 122 North Santa Anita Avenue, which is currently 150 – 180 N. Santa Anita Avenue. The laundry facility is a recognized environmental condition (REC) from the Phase I ESA and is located partially beneath the existing Bank of America building and partially beneath the 8- story office tower within the Project site boundaries. The former laundry building was built in 1949, was closed in 1962, and the building was demolished in 1966.

A subsurface soil and soil vapor investigation (see Appendix F -4 of the Draft EIR) identified elevated concentrations of benzene and PCE in soil vapor at the Project site. Therefore, mitigation measures were included in the Final EIR and Mitigation Monitoring and Reporting Program (MMRP) to ensure the Project would reduce potential impacts associated with contamination to less than significant levels and would not exacerbate the existing condition of contamination in the area. The Project does not propose construction across the entirety of the Project site and would not require any earthwork/grading activities at the Bank of America or the eight -story office tower. To the extent the Project does propose soil disturbance, mitigation has been incorporated to ensure that no significant impacts would result from identified, existing contamination. For the portion of the Project site that would be subject to s oil disturbance, all soil excavation and handling would be managed under a Soil Management Plan, as required by MM -HAZ-2, which outlines the proper screening, handling, characterization, transportation, and disposal procedures for contaminated soils on sit e, the implementation of which would ensure contaminated soil impacts would be mitigated. MM HAZ -2 would ensure that disturbance of contaminated soils would occur in a manner, consistent with applicable regulations, that would not result in significant impacts resulting from such disturbance, including on adjacent uses. It should also be noted that construction must proceed consistent with applicable South Coast Air Quality Management District rules and other regulations intended to control soils and dust associated with construction. For the proposed residential building, MM - HAZ-3 requires that vapor mitigation features be implemented into building plans such that potential vapor intrusion will remain below applicable Department of Toxic Substances Control (DTSC) Screening Levels (consistent with the DTSC Vapor Intrusion Mitigation Advisory). Following completion of construction and occupancy of the buildings, indoor air monitoring will occur semiannually for one year to verify implemented measures are funct ioning properly and adequately mitigating vapor intrusion to below residential DTSC Screening Levels. MM-HAZ-3 would ensure that vapor levels would be below 150 N. Santa Anita Ave.

Alexan Mixed-Use Project
July 19, 2022

applicable DTSC performance standards and reduce potential impacts to future users of the Project.

The information above is provided for clarification purposes only. The existing EIR and Mitigation Measures address this issue and no further action needs to be taken.

Finally, at the June 21, 2022, City Council Meeting, the City Council discussed adding a new condition related to insurance coverage for the Applicant. The City Attorney read into the record a draft condition which has been slightly modified since the hearing. This condition is proposed to replace the existing C ondition No. 50, and the remainder of the Conditions shall be renumbered accordingly from No. 51 to 60 as shown in Attachment No. 3. The new Condition No. 50 is as follows:

50. For purposes of any and all of the applicant’s indemnification and defense obligations herein, the applicant shall obtain and maintain at all times general liability insurance in an amount of at least $2 million per occurrence, $10 million in the aggregate with an insurer or insurers rated A-VII or better in BEST’s insurance guide and admitted to issue insurance in the State of California. The City and its officials, officers, employees, and agents shall be named as additional insurers on endorsements issued by the applicant’s insurers and provided to the City. Said insurance shall be in place from the effective date of approval of the project by the City Council through the issuance of a final Certificate of Occupancy.

Provided directly after this updated report, is a copy of the June 21, 2022, Staff Report along with its original 10 Attachments . The recommended conditions of approval for the project can be found in Resolution No. 7435 (Attachment No. 3). There are no additional changes proposed to the conditions as a result of the discussions between the parties since the June 21, 2022, public hearing.

RECOMMENDATION

It is recommended that the City Council approve Minor Use Permit No. M UP 21 -08, Architectural Design Review No. ADR 21- 12, and Tentative Parcel Map No. TPM 21- 02 along with a density bonus and street vacation, through the adoption of the following resolutions:
• Resolution No. 7433 Ordering the Vacation of the East/West Alley within the block bounded by Santa Anita Avenue, Santa Clara Street, First Avenue, and Wheeler Avenue.

• Resolution No. 7434 Certifying the EIR and adopting the requisite environmental findings.

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Alexan Mixed-Use Project
July 19, 2022

• Resolution No. 7435 approving the project subject to the conditions of approval and mitigation measures included in the Resolution.

Attachments: June 21, 2022, City Council Staff Report No. 1: Resolution No. 7433 – Approving the alley vacation No. 2: Resolution No. 7434 – Certifying the Environmental Impact Report (includes the environmental findings of fact)
No. 3: Resolution No. 7435 – Approving the Alexan Arcadia Project with Conditions of Approval and Mitigation Measures
No. 4: Aerial Photo and Zoning Information and Photos of the Subject Property
No. 5: Planning Commission Minutes, Staff Report with no attachments, and Resolution No. 2093
No. 6: Tentative Parcel Map
No. 7: Architectural Plans and Renderings
No. 8: Alexan Arcadia Market Analysis and CBRE Retail Analysis No. 9: Link to Draft Environmental Impact Report and Technical Appendices- www.arcadiaca.gov/projects

No.10: Final EIR: Preface, Response to Comments, Changes to the Draft EIR, MMRP, Memo for Hearing Responses, and additional comment letters

DATE: June 21, 2022

TO: Honorable Mayor and City Council

FROM: Jason Kruckeberg, Assistant City Manager/Development Services Director Lisa L. Flores, Planning & Community Development Administrator

SUBJECT: RESOLUTIONS RELATED TO MINOR USE PERMIT NO. MUP 21 -08, ARCHITECTURAL DESIGN REVIEW NO. ADR 21 -12, GENERAL PLAN CONSISTENCY NO. GPC 22-01, TENTATIVE PARCEL MAP NO. TPM 21- 02, A DENSITY BONUS AND A PUBLIC ALLEY VACATION ALONG WITH

AN ENVIRONMENTAL IMPACT REPORT UNDER THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT ( “CEQA”) FOR THE “ALEXAN
ARCADIA” MIXED-USE PROJECT LOCATED AT 150 N. SANTA ANITA AVENUE

RESOLUTION NO. 7433 ORDERING THE VACATION OF THE

EAST/WEST ALLEY WITHIN THE BLOCK BOUNDED BY SANTA ANITA

AVENUE, SANTA CLARA STREET, FIRST AVENUE AND WHEELER
AVENUE
Recommendation: Adopt

RESOLUTION NO. 7434 ADOPTING CEQA FINDINGS OF FACT,

ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM,

AND CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT
FOR THE "ALEXAN ARCADIA" MIXED- USE DEVELOPMENT WITH 319 RESIDENTIAL UNITS, INCLUDING 26 AFFORDABLE UNITS, LOCATED AT 150 N. SANTA ANITA AVENUE
Recommendation: Adopt

RESOLUTION NO. 7435 MINOR USE PERMIT NO. MUP 21 -08,
APPROVING ARCHITECTURAL DESIGN REVIEW NO. ADR 21 -12,
GENERAL PLAN CONSISTENCY NO. GPC 22-01, TENTATIVE PARCEL MAP NO. TPM 21 -02, a DENSITY BONUS AND A PUBLIC ALLEY

VACATION ALONG WITH AN ENVIRONMENTAL IMPACT REPORT
UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT ( “CEQA”) FOR THE “ALEXAN ARCADIA” MIXED- USE DEVELOPMENT LOCATED AT 150 N. SANTA ANITA AVENUE
Recommendation: Adopt

150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

SUMMARY

The Applicant, Arcadia Apartments, LLC, on behalf of the property owner, Pi Properties and 111 LLC, is requesting approval of Minor Use Permit No. MUP 2 1-08, Architectural Design Review No. ADR 21-12, Tentative Parcel Map No. TPM 21-02, and General Plan Consistency No. 22-01 to construct a new mixed-use development at 150 N. Santa Anita Avenue and surrounding properties. The project includes a density bonus and a n alley vacation and will result in a seven- story mixed-use building containing 319 residential units, including 26 affordable units and eight live-work units. The existing eight-story office building will remain on site as well as the one- story Bank of America drive-through ATM use, and a plaza will be construct ed to connect these existing uses to the new building.

A parking structure will be constructed as part of the mixed -use building and will include 551 parking spaces to be shared by all uses on site.

The proposed development is consistent with the City’s General Plan, Development Code, and Subdivision Code. The Statement of Findings addresses the environmental effects associated with the proposed project, as described in the Draft Environmental Impact Report ( “EIR”). It is recommended that the City Council approve the project by adopting Resolutions No. 7433 ( concerning the alley vacation) , 7434 ( certifying the Environmental Impact Report ), and 7435 (approving the project itself ), including the conditions and mitigation measures.

BACKGROUND

The project site consists of four parcels totaling approximately 2.96 acres in size, located on the east side of N. Santa Anita Avenue, south of Santa Clara Street, and north of Wheeler Avenue. The site is zoned Downtown Mixed Use (“DMU”) along with a H8 Height Overlay, which allows construction up to 95 feet in height. The General Plan Land Use Designation of the site is Downtown Mixed Use with a residential density allowance of 80 units per acre and a Floor Area Ratio of 1.0 – refer to Attachment No. 4 for an Aerial Photo with Zoning Information and Photos of the Subject Property. The property is surrounded by commercial uses consisting of the REI retail location to the north, which is zoned DMU, as well as the Gold Line Light Rail station, parking garage and transit plaza.

To the east is a public alley and t he Arcadia Post Office site , and to the south across Wheeler Avenue is the City’s public parking lot, all zoned DMU. To the west across Santa Anita Avenue is the Rusnak Mercedes -Benz dealership (zoned as Central Business District) and other properties zoned DMU (see Figure 1 below for an aerial of the site).

150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

Figure 1 - Aerial of Subject Site

Three of the existing buildings on site – those addressed as 30 E. Santa Clara, 25 Wheeler Avenue, and 31 Wheeler Avenue – will be demolished as part of the project. The existing eight-story office building and associated one-story Bank of America building will remain on site and will share parking with the new building. Additionally, an open plaza area will be constructed to connect the existing buildings with the new mixed- use development, along with a small 750 square foot café use. The drive through ATM use will remain.

DISCUSSION

The Applicant is proposing to consolidate the existing four legal lots into two lots, one for the existing buildings along Santa Anita Avenue at 35,609 square feet in size, and one for the new mixed- use development at 92,901 square feet in size – refer to Attachment No. 6 for the Tentative Parcel Map and Attachment No. 7 for the Architectural Plans. The proposed building will be 84’ -11” in height, which is in compliance with the maximum height of 95 feet. In addition to the commercial appearance of the street frontages, the project will include refurbishment of the public alley to the east of the site into an improved accessway to the parking structure and pedestrian connection between the Arcadia Gold Line S tation and Downtown Arcadia , including an alley right -of-way dedication of five additional feet along the entire project frontage adjacent to the existing alley. See Figure 2 below for the overall site plan of the project area and Figure 3 for the renderings of the project.

150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

Figure 2 – Site Plan

150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

Figure 3 - Renderings
The project site is zoned D MU, which allows a mixed -use development subject to the approval of a Minor Use Permit ( “MUP”). A MUP is required to allow a mixed- use development in the DMU Z one. A MUP is typically processed administratively by staff ; however, since the proposed mixed-use development requires a Tentative Parcel Map as well as a density bonus and an alley vacation, the MUP is subject to both Planning Commission and City Council review. The purpose of the MUP is to ensure compatibility with the surrounding uses and to promote an active pedestrian environment with commercial uses located along street frontages. During a Study Session with the City Council concerning the project, the City Council stated that they were interested in a market or specialty food store locating in this area as a way to activate the area and provide a needed service for new residents. The A pplicant reviewed this plan with their commercial team and concluded that the space would not be successful for such a use.

A report was generated illustrating these findings, called the Alexan Arcadia Market Analysis (see Attachment No. 8). In addition, the City contracted with CBRE to provide a retail analysis of this project, which concluded that the findings in the Market Analysis are adequate (also included in Attachment No. 8). In addition, an alternative was added to the Environmental Impact Report that evaluates the ground level of the Wheeler Avenue frontage as a market use to compare impacts.

In order to provide a commercial frontage, the A pplicant has proposed eight live- work units along Wheeler Avenue. These units will provide commercial uses and provide an active streetscape along Wheeler. Residential uses are only permitted in conjunction with a commercial use and are permitted above ground floor commercial within this zone. The

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Alexan Mixed-Use Project
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subject property is one of the few properties in Arcadia which is designated with an H8 Height Overlay, allowing up to 95 feet in height. This was done to facilitate the existing eight story building on the site many years ago but, given that this Overlay Zone is in effect, no modification is necessary since the maximum height of the building is proposed at 84’-11” to the top of the parapet.

For purposes of computing Floor Area Ratio ( “FAR”), the square footage of the “work” portion of the live-work units was included with the other commercial uses on the resulting two parcels. This results in 92,534 square feet of commercial floor area, or an FAR of .72.

Given that residential area is not included in the FAR calculation, this FAR is below the maximum commercial FAR allowed of 1.0. The proposed subdivision has been reviewed by the applicable City departments and it complies with the subdivision regulations of the Arcadia Municipal Code and the State Subdivision Map Act and will not violate any requirements of the State Regional Water Quality Control Board.

Density Bonus and Affordable Housing

The proposed residential unit mix will be comprised of 64 studios, 168 one-bedroom units, 79 two-bedroom units, and 8 live-work units. These units will occupy the second through the seventh floors of the building and will range in size from 508 square feet to 1,382 square feet. Of these units, 26 will be provided as affordable housing units to be reserved for residents at the very low -income level per Los Angeles County’s affordability standards.

Senate Bill 1818 amended the State’s Density Bonus program, and it offers incentives for the development of affordable housing for low -income, moderate- income, and senior citizen households. The Arcadia Development Code refers to the applicable Government Code when referencing density bonus law and the program allows developments to receive a density bonus over and above the allowable base density if the appropriate number of affordable units are provided. In this case, the developer is proposing 11% of the units be set aside as affordable housing for very low-income households. With 11% of the units affordable at this level, the project qualifies for a 35% density bonus per the State. The table below shows the unit summary, including the allowable density.

Residential Component Calculation Number of Units
Base Density 80 du/acre 236
SB 1818 Unit Count 35% 319
Housing Type Provided
Market Rate Units 293
Affordable Units 26

This is a density that is allowed by -right if the affordable units are provided. The project proposes 319 total residential units, meeting the maximum density allowed with the density bonus. In order to ensure that the allowable units are included, the Development Code requires the developer to identify the method for maintaining the affordability of the 150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

units over time. To this end, t he developer will be recording a Density Bonus Housing Agreement, which will be reviewed by the City Attorney to ensure that the 26 affordable units will be rented to individuals who qualify at very low-income levels. The affordable term commences on the occupancy date and continues for 55 years. These units will be spread throughout the project and the covenant will be recorded prior to the issuance of a Certificate of Occupancy.

In addition, for providing affordable units, the Government Code and the Arcadia Development Code allow developers to seek concessions or waivers to certain zoning requirements along with density bonuses . This can include relaxation of development standards such as parking or height, setbacks, or lot coverage, among others . In this case, the only development standard that is being altered by the developer is parking.

However, since the project is located in close proximity to the light rail station a nd is providing affordable housing units, the developer is able to provide the units with less associated parking than the Code requires. This issue is described in more detail below in the parking section, but is mentioned here because, if necessary, the developer could request a concession that would be reviewed by the Planning Commission and City Council. No concession is necessary, however.

Parking

The proposed project would redevelop a site containing existing surface parking for the office building. As a result, a total of 183 existing surface parking spaces would be replaced in the parking structure, with an additional six surface spaces remaining adjacent to the building. The proposed parking structure will provide a total of 551 parking spaces, contained in two subterranean levels and the first two levels of the new building. These spaces are designed to be internal to the site, as the ground level on both street frontages will include the live -work portion along Wheeler Avenue and the amenity portion of the residential project along Santa Clara Street.

For the residential component of a mixed- use development, the Arcadia Development Code generally requires 1.5 spaces per unit and 1 guest space for every 3 units. However, AB 2345 amended the Density Bonus Law to provide that a city may not require more than 0.5 spaces per unit, including guest and disability parking, for a development that includes at least 11% very low -income units, is within one- half mile from a major transit stop, and has unobstructed access to that transit stop. Accordingly, given the project’s provision of affordable housing and proximity to a major transit stop, for 319 units, the required residential parking is 160 spaces. In addition to the 160 required spaces, the Applicant will provide an additional 193 spaces for a total of 353 spaces. Of those 353 residential parking spaces, State and local codes require that six (6) be accessible spaces and two (2) be van accessible spaces.

Using the D ensity Bonus Law, the required parking would be to replace the existing commercial spaces (183 spaces) plus the 160 residential spaces , for a total of 343 spaces. With 551 spaces proposed, the development is meeting the legal requirements. 150 N. Santa Anita Ave.

Alexan Mixed-Use Project
June 21, 2022

The table below provides a summary of the allocation of the parking spaces being provided versus what is required per law.

Parking Required Spaces
Commercial Parking to be replaced.

Eight-Story Office Building, drive through building, Café 183
Residential Parking per Density Bonus Law 160

TOTAL REQUIRED

343
Parking Provided Spaces
Commercial Parking to be replaced.

Eight-Story Office Building, drive through building, Café 183
Residential Parking for:
• 72 studios/live work units
• 247 one and two-bedroom units
368

TOTAL PROVIDED

551

Although the project meets the parking requirements per AB 2345, a more detailed analysis was performed on expected parking demand and the sharing of parking spaces between the proposed land uses. This can be found in Appendix K -2 of the EIR, the Transportation Technical Memorandum. To summarize, the demand for parking was reviewed on a 24-hour period based on utilization demand figures obtained for each land use through the Institute of Traffic Engineers (“ITE”) Parking Generation Manual. Because the commercial uses are only operating in the daytime, many of the spaces are effectively “shared” during a normal business day and evening. The study anticipates the highest demand for the commercial use is between 10:00 AM on weekdays and Saturday, and for the residential use overnight between 12:00 AM and 4:00 AM on weekdays and Saturday. The combined weekday peak shared demand for all uses together would be at 10:00 AM on weekdays and would result in a peak parking demand of 404 spaces.

Similarly, peak parking demand on Saturday for all uses would occur overnight when most residents were present, resulting in a demand for 376 spaces. Therefore, the demand for all uses would still fall well below the overall parking supply proposed of 551 spaces. The fact that the project is within a few hundred feet of the light rail station adds credibility to this analysis and the overall parking needs. That being said, the Transportation Technical Memorandum provides a recommendation that 376 parking spaces be provided for residential uses to accommodate the maximum demand period. Accommodating this as part of the required parking management plan has been added as a Condition of Approval for the Project.

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The Code also requires bicycle parking for mixed -use developments at a rate of 0.2 spaces per residential unit and 5% of non-residential parking. Based on 319 residential units and 171 non-residential parking spaces, 82 bicycle parking spaces are required.

The project will provide 82 bicycle parking spaces located on level 1 of the development.

This complies with the Code and meets the minimum requirement. Additionally, the project will meet all ADA and Energy Efficient vehicle requirements, including charging stations for both residents and guests.

Another issue that is of import for this project is construction parking and replacement parking during construction. The Applicant has identified a number of possibilities for replacement parking, including the Gold Line (or L Line) Arcadia station, the Sierra Madre Villa Station, and Santa Anita Park. Staging of construction vehicles is expected to occur within the project boundaries. Given the size of the site, the staging should be able to be handled without disrupting the surrounding parking lot or commercial uses. A detailed replacement parking and construction parking and staging plan will be required prior to the issuance of a building permit for the project.

Traffic and Circulation

Vehicular circulation to the Project site and parking structure is proposed with two two - directional access points as well as two exit-only locations. Vehicular access and egress to the Project site would be available from the alley on the eastern edge of the Project site from Santa Clara. Additionally, vehicles would be able to exit the parking structure to an exit-only driveway onto Santa Clara on the northwest portion of the site, adjacent to the existing office building. The other entrance is available on the southwest corner of the site via Wheeler Avenue. Vehicles would be able to both enter and exit from this point, but the drive aisle on to Santa Anita at this location will be an exit only from the garage.

These access and egress points have been evaluated in the traffic study and reviewed by the City Engineer and will be adequate for the project and its associated uses.

In terms of traffic, both the trips generated by the existing uses and the newly generated trips were evaluated to determine any expected impacts on the traffic flow through the area. A total of six intersections were analyzed as part of this project, including the intersections of Santa Anita Avenue and Huntington Drive, Wheeler Avenue and Santa Clara Avenue, and the intersections of First Avenue and those same three cross streets.

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Alexan Mixed-Use Project
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Figure 4 – Intersections that were Studied

A Level of Service (“LOS”) analysis was conducted on these intersections. Based on the results of the LOS, site access, and parking analyses presented in Appendix K -2 of the EIR (The Transportation Technical Memorandum) , the following summarizes the key findings:

• The proposed Project would generate 1,424 net daily trips, 132 net AM peak hour trips (38 inbound and 94 outbound), and 166 net PM peak hour trips (100 inbound and 66 outbound).

• The six study area intersections currently and are forecast to operate at LOS E or better under all analysis scenarios, which meets the City’s traffic impact thresholds for the Downtown mixed-use district.

• The proposed Project would not result in unacceptable queueing conditions into or out of the Project site; however, the following recommendations are made:

o To restrict northbound left-turning movements from the ATM driveway exit onto Santa Clara Street given the proximity of the Santa Anita Avenue/Santa Clara Street intersection.

o Provide wayfinding signage at all parking garage ingress points for customers prior to entering the garage.

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o Provide wayfinding signage within the parking garage such that customers are directed to the ATM drive-thru, and other users of the site are channeled to parking spaces and garage exits.

The full text of the traffic study and associated tables can be found in Appendix K -2, but no significant impacts are expected as a result of the traffic generated by this project.

Architectural Design

The project is designed in a contemporary architectural style with an array of exterior finishes consisting of stone tile veneer , architectural finished concrete, smooth and textured stucco, wood- like screens and decorative metal elements (see Figure 5). This portion of Downtown Arcadia is eclectic and consists primarily of one-story and two-story buildings in various architectural styles. However, the existing eight -story office building on site as well as the adjacent Gold Line Par king Structure , the Mercedes -Benz dealership, and new four -story office building to the north of the site provide urban, contemporary elements that the new building will fit into. The proposed mixed- use development was designed to create a streetscape environment that will promote pedestrian activity and provide a complementary mix of residential and commercial uses.

The project meets the City’s Design Guidelines and achieves compatibility with the surrounding neighborhood as well as the existing streetscape.

Figure 5 – Rendering

As shown in Figure 5 above, the project includes thoughtful treatments of the ground levels along both Santa Clara Street to achieve differentiation between the residential levels of the building and the commercial feel of the streetscape. Along Wheeler, live -

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work units are provided that include large, two- level windows and strong st one veneer treatments that convey a workspace appearance. The corner along Wheeler is anchored with a cantilevered element that frames a lobby and provides a unique treatment for the residential levels above. The Santa Clara frontage provides the “active” portions of the residential use, including the building lobby, fitness area, and lounge area. Walkways and glazing accentuate this area and provide an interface with the right-or-way. Also, the large courtyard area in the northern portion of the building provides a visual break for the streetscape at the third level of the building and provides positive articulation and openness for the units. This de-emphasizes the massing from this elevation and provides light for many of the units.

The upper levels of the buildings are appropriately designed to create a distinction between the residential uses from the ground floor commercial /amenity spaces. In addition, the parking levels will be adequately concealed as the structure is wrapped with the commercial storefronts and access is taken for the most part off the alley and internal drives. The color and material palette provide neutral colors and accent finishes that complement the area and the adjacent eight -story office building. Overall, the proposed overall design is consistent with the City’s Design Guidelines and is compatible with the surrounding area.

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 Applicant/Owner to the satisfaction of the Building Official, City Engineer, Planning & Community Development Administrator, Fire Marshal, and Public Works Services Director, or their respective designees. These requirements are memorialized in the proposed Conditions of Approval.

Open Space

The Code requires a minimum of 100 square feet of open space for each residential unit in the D MU Zone (31,900 square feet total). The proposed mixed- use development provides a mix of public and private open space throughout the project that exceeds this requirement. Private balconies are provided for many of the units in addition to an interior courtyard area, a pool courtyard, and a roof deck. The public spaces include a barbeque area in addition to the pool area, a lawn/grassy area, and landscaped and hardscape areas with various seating and lounging areas. While the private balconies and patios are located to provide privacy from the office building to the west, the public open spaces are sited to offer views of the mountains and also include gaming areas and opportunities for entertainment. The public open spaces total 17,398 square feet while the private open space makes up 23,957 square feet for a total of 41,355 square feet. The project provides significantly more open space than what is required by Code, with the intent to provide residents with usable outdoor areas for recreational activities.

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The project also proposes two additional common areas that provide open areas for the project, the plaza between the new building and the existing office building and the alley to the east of the project. While both these areas do provide vehicular access points to the parking garage, they also serve as pedestrian accessways. The plaza between the building provides easy access to the office building from the parking garage and includes seating and gathering areas which will be served well by the new café to be added. The alley on the east side of the property is a public alley that will be used as a direct access point from the Gold Line Station to Downtown Arcadia and will also serve as a place for pedestrians and cyclists to move through the area. Additionally, this alley will be improved by the Applicant with decorative features and amenities that are consistent with the City’s plans for other alleys in the Downtown area for the benefit of pedestrians and bicyclists.

FINDINGS

Minor Use Permit
Section 9107.09.050(B) of the Development Code requires that for a Minor Use Permit to be granted, it must be found that all of the following prerequisite conditions can be satisfied:

1. The proposed use is consistent with the General Plan and any applicable specific plan.

Facts to Support This Finding: Approval of the proposed mixed- use project would be consistent with the General Plan Land Use Designation of Downtown Mixed Use, which allows a residential dens ity of 8 0 units per acre and a commercial floor area ratio of 1.0. This land use designation allows mixed -use developments and strongly encourages a pedestrian-oriented environment with a complementary mix of commercial and residential uses. The proposed live -work units will help generate increased activity along Wheeler Avenue and will convey a commercial appearance along the street. The proposed mixed-use development will not adversely affect the comprehensive General Plan and is consistent with the following General Plan goals and policies:

Land Use and Community Design Element

• 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-1.8: Encourage development types that support transit and other alternative forms of transportation, including bicycling and walking. • Policy LU-4.2: Encourage residential development that enhances the visual character, quality, and uniqueness of the City’s neighborhoods and districts. • Policy LU-4.3: Require the provision of adequate private and common open space for residential units. Require sufficient on-site recreational facilities to 150 N. Santa Anita Ave.

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meet the daily needs of residents, if possible, commensurate with the size of the development.
• Policy LU- 6.4: Encourage design approaches that create a cohesive, vibrant look and that minimize the appearance of expansive parking lots on major commercial corridors for new or redeveloped uses. • Policy LU-6.5: Where mixed use is permitted, promote commercial uses that are complementary to adjacent residential uses.

2. The proposed use is allowed within the applicable zone, subject to the granting of a Minor Use Permit, and complies with all other applicable provisions of this Development Code and the Municipal Code.

Facts to Support This Finding: The subject site is zoned Downtown Mixed Use (“DMU”), which allows for mixed- use developments subject to the approval of a Minor Use Permit ( “MUP”). The proposed project complies with all the development standards of the D MU Zone, including but not limited to setbacks, height, open space, parking dimensions and aisleways . The project provides the requisite number of very low -income units to qualify for a density bonus and relaxation of parking requirements under SB 1818 and AB 2345. As such, the project meets the Municipal Code requirements as well as State law.

3. 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 subject site is 128,510 square feet in size and is located in the Downtown Mixed Use (“DMU”) Zone. The site is surrounded by commercial uses consisting of the Rusnak Mercedes -Benz dealership to the west across Santa Anita Avenue, which is zoned Central Business District, as well as other office uses zoned for DMU. A retail use (“REI”) is located to the north across Santa Clara along with the Gold Line Parking Structure and rail station. To the south of the project is commercial parking owned by the City which serves the commercial uses along Huntington Drive to the south as well as the other buildings along Wheeler Avenue. To the east is the post office site and another mixed- use project. All of the surrounding properties are zoned DMU, with the exception of Rusnak Mercedes-Benz. The project embodies what the goals of the DMU zone are, with a mix of and commercial uses. The project will also provide residential uses that will support the commercial uses in this area. Therefore, the development and operation of the mixed- use development will be compatible with the existing and future land uses in the vicinity.

4. 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, 150 N. Santa Anita Ave.

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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 project site is 128,510 square feet in size and can physically accommodate the proposed mixed- use development. The residential component of the project will provide a density of 108 units per acre, which is in compliance with the maximum density for the area due to the density bonus permitted as a result of the affordable housing units being provided. The commercial component of the project will have a floor area ratio ( “FAR”) of 0. 72, which is in compliance with the maximum allowable FAR of 1.0. Additionally, the amount of on-site parking that will be provided for this project exceeds the minimum required by State law for projects providing affordable housing units that are in close proximity to the Gold Line Station. A parking demand analysis was provided as part of the Environmental Impact Report for the project. The analysis concluded that ample parking is provided to serve the shared uses of the site at all times, and further recommended that the peak residential demand of 376 spaces be met through the parking management plan. Therefore, the site is physically suitable to accommodate the proposed mixed-use development.

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 site is located on the south side of Santa Clara Street through to the north side of Wheeler Avenue to the west of Santa Anita Avenue. These streets are adequate in width and pavement type to carry emergency vehicles and traffic generated by the proposed use on the site.

c. Public protection services (e.g., fire protection, police protection, etc.).

Facts to Support This Finding: The Fire and Police Departments have reviewed the application and determined that there will be no impacts to public protection services. The need for new or altered Fire or Police services is usually associated with substantial population growth. The proposed mixed-use development is not anticipated to cause substantial population growth; therefore, no impacts to public protection services are anticipated. Development of Downtown Arcadia has been anticipated and planned for since the General Plan was updated in 2010. Mixed use developments and residential units have been expected since that time on the part of public protection services. Calls for service and response t imes remain unaffected in this area.
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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: As part of the development , new utility connections, including connections for potable water and storm drainage, will be required. Implementation of best management practices during construction and operation would ensure impact s to water quality do not occur. The site can be adequately served by all required ut ilities through interconnection with existing utilities within City rights -of-way abutting the site.

5. 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 mixed- use development is not anticipated to have adverse effects on the public health or welfare, or the surrounding neighborhood. The project will be compatible with the surrounding commercial and residential uses in the general area. Additionally, t he Environmental Impact Report prepared for the project assessed all the potential impacts from the project and it was determined that there would be no significant impacts to traffic, noise, air quality, or water quality. Therefore, the proposed use will not adversely affect the public convenience, health, interest, safety or general welfare of adjacent uses in the vicinity and zone of the subject property.

Tentative Parcel Map
The proposal includes a parcel map to consolidate the four existing lots into two and to vacate a public alley – see Attachment No. 6 for Tentative Parcel Map No. TPM 21-02.

The proposed subdivision complies with the subdivision regulations of the Arcadia Municipal Code and the Subdivision Map Act and will not violate any requirements of the State Regional Water Quality Control Board. The following findings are required for approval of a Tentative Parcel Map:

6. The proposed map, subdivision design, and improvements are consistent with the General Plan, any applicable specific plan, and the Subdivisions Division of the Development Code.

Facts in Support of the Finding: Approval of the proposed mixed- use development with a tentative parcel map to divide the ground parcels is consistent with the Downtown Mixed Use Land Use designation as it is intended to 150 N. Santa Anita Ave.

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accommodate mixed- use development s. The project has been reviewed for compliance with the City’s General Plan, Development Code, and the State Subdivision Map Act. It has been determined that the proposed subdivision is consistent with the General Plan Downtown Mixed-Use Land Use designation and the Downtown Mixed-Use zoning standards. The site is physically suitable for this type of development and the architectural design of the building is compatible with the scale and character of the surrounding area. The proposed Tent ative Parcel Map complies with the Subdivision Map Act regulations and there is no specific plan applicable to this project. The project will not adversely affect the comprehensive General Plan and is consistent with the following General Plan goals and policies:

Land Use and Community Design Element

• 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-1.8: Encourage development types that support transit and other alternative forms of transportation, including bicycling and walking. • Policy LU-4.2: Encourage residential development that enhances the visual character, quality, and uniqueness of the City’s neighborhoods and districts. • Policy LU-4.3: Require the provision of adequate private and common open space for residential units. Require sufficient on-site recreational facilities to meet the daily needs of residents, if possible, commensurate with the size of the development.
• Policy LU- 6.4: Encourage design approaches that create a cohesive, vibrant look and that minimize the appearance of expansive parking lots on major commercial corridors for new or redeveloped uses. • Policy LU-6.5: Where mixed use is permitted, promote commercial uses that are complementary to adjacent residential uses.

7. The site is physically suitable for the type and proposed density of development.

Facts in Support of the Finding: The project site is approximately 128,510 square feet in size and is physically suitable for the proposed mixed- use development. The MU zone allows a maximum residential density of 8 0 units per acre and a floor area ratio ( “FAR”) of 1.0 for non- residential uses. However, the Arcadia Municipal Code and State law allow a density bonus process and parking relaxation if affordable housing is provided and the findings for the density bonus can be made in this case. The density of 108 dwelling units per acre fits within the physical constraints of the site and the project proposes a commercial FAR of 0.72 and a height of 84’11”, both within the limitations required by the site. Therefore, the project is in compliance with the Development Code and the site is physically suitable for the proposed development.
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8. The design of the subdivision and the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

Facts in Support of the Finding: The proposed Tent ative Parcel Map to consolidate and reform existing parcels for the proposed mixed-use development is a minor subdivision of an infill site within an urbanized area; therefore, it will not cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

9. The design of the subdivision or type of improvements is not likely to cause serious public health or safety problems.

Facts in Support of the Finding: The proposed subdivision will consolidate and reform existing parcels in a commercial infill setting for a proposed mixed- use development. The construction of the proposed development will be carried out in compliance with Building and Fire Codes and all other applicable regulations. The City’s existing infrastructure will adequately serve the new development. In addition, the project meets all health and safety requirements, and will not cause any public health or safety problems.

10. The design of the subdivision or the type of improvements will not conflict with easements acquired by the public at large for access through or use of, property within the proposed subdivision (This finding shall apply only to easements of record or to easements established by judgement of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision).

Facts in Support of the Finding: The proposed design of the subdivision does not conflict with easements acquired by the public at large for access through or use of property within the proposed subdivision. Part of the project is the vacation of an existing public alley within the site. This alley is not currently used substantially nor is it necessary for the public good in any way. There are no conflicts with any other easements on the subject property.

11. The discharge of sewage from the proposed subdivision into the community sewer system will not resul t in violation of existing requirements specified by the State Regional Water Quality Control Board.

Facts in Support of the Finding: The Arcadia Public Works Services Department determined that the City’s existing infrastructure will adequately serve the new development, and the requirements of the State Regional Water Quality Control Board will be satisfied.
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12. The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities.

Facts in Support of the Finding: The proposed tentative tract map and mixed- use development have been reviewed by Building Services to ensure compliance with the California Building Code, which includes requirements associated with heating and cooling requirements.

13. The proposed subdivision, its design, density, and type of development and improvements conforms to the regulations of the City’s Development Code and the regulations of any public agency having jurisdiction by law.

Facts in Support of the Finding: The proposed parcel map as conditioned, and following the application of a density bonus, complies with the density requirements of the City’s Development Code, and all the improvements required for the site and each unit will comply with the regulations in the City’s Development Code.

Density Bonus

The proposal includes a density bonus of 35%, which is allowed based on the provisi on of 11% of the units being designated for very low -income residents. The findings below are required for a density bonus to be permitted.

14. The Project will be consistent with the General Plan, except as provided by this section with regard to maximum density, density bonuses, and other incentives and concessions.

Facts in Support of the Finding: The project is consistent with the Downtown Mixed Use land use designation in the General Plan, as well as the zoning requirements of the DMU Z one. The Project meets the following policies of the General Plan Land Use Element: LU-1.1, LU-1.8, LU-4.2, LU 4.3, LU-6.4, and LU-

6.5. 15. The approved number of dwellings can be accommodated by existing and planned infrastructure capacities.

Facts in Support of the Finding: The project proposes 319 dwelling units, which includes 26 affordable units and 8 live-work units. All relevant utility providers and service providers reviewed the proposed project and have declared that the project can be served with existing and /or planned infrastructure. The Arcadia General Plan has anticipated mixed- use development in Downt own Arcadia since 2010.

The infrastructure has been reviewed and analyzed with this in mind and the project can be accommodated.

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16. Adequate evidence exists to indicate the project will provide affordable housing in a manner consistent with the purpose and intent of this Section.

Facts in Support of The Finding. The Applicant has submitted a draft Density Bonus Housing Agreement, which specifies that 26 units will be provided for very low-income residents. This document must be recorded prior to the issuance of a Certificate of Occupancy for the project and shall run with the property. This will provide the necessary surety that these units will remain affordable over time.

17. In the event that the City does not grant at least one financial concession or incentive as defined in Government Code Section 65915 in addition to the density bonus, that additional concessions or incentives are not necessary to ensure affordable housing costs as defined in Health and Safety Code Section 50052.5, or for rents for the targeted units to be set as specified in Government Code 65915(C.).

Facts in Support of the Finding: The project is proposing a density bonus of 35% based on the provision of 11% affordable units at the very low-income level, which is allowable per State law. In addition, the project is utilizing the parking relaxation requirements allowed through AB 2345 due to the provision of affordable housing and proximity to transit. As such, the project can meet all other zoning requirements and standards and no concessions or incentives are necessary to meet the targeted affordability.

18. There are sufficient provisions to guarantee that the units will remain affordable for the required time period.

Facts in Support of the Finding: The developer has submitted a draft Density Bonus Housing Agreement which will be finalized and agreed to by both parties prior to recordation. The document will be required to be recorded prior to the issuance of a Certificate of Occupancy for the project.

Public Alley Vacation and General Plan Consistency

As part of the project, the public alley running east-west from the eastern boundary of the site is proposed to be vacated. At the April 5, 2022, City Council Meeting, the City Council announced its intent to hold a public hearing on this matter. In advance of that, State law (Government Code Section 65402) requires that the Planning Commission is to review the vacation request and determine if the vacation is consistent with the General Plan’s Circulation Element. In this case, the public alley is not used broadly by the public and serves no purpose within the development. The alley was previously in place to provide access to the original lots and their associated buildings; however, all of these buildings are proposed for demolition and the alley is no longer necessary. Any utilities in the alley will be abandoned and are no longer necessary for the City or adjoining parcels. This has been made clear on the associated Tentative Parcel Map for the P roject. However, 150 N. Santa Anita Ave.

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because the utilities still exist within the alley, the City must retain an easement to ensure that they are protected until such time as all utilities can be removed. This will involve a future action by the City Council to Quitclaim the easement.

If the public alley was to remain in place now that the buildings will be demolished, it would preclude the ability of the developer to build a cohesive project that includes a joint parking garage to provide parking for the residential use and the existing commercial office buildings. By vacating the alley, the City is allowing the lots to be effectively joined to create an assembly of parcels that allow the mixed- use project to be built, furthering the City’s goal to attrac t mixed-use development in Downtown Arcadia. At their meeting on May 10, 2022, the Planning Commission found that the vacation of the alley in question is compliant with the Arcadia General Plan and meets the following policies of the General Plan Circulation Element:

• Policy CI-1.2: Implement street design standards on arterial corridors consistent with the Master Plan of Roadways to address bicycle facilities, sidewalks, and on- street parking that are context sensitive to adjacent land uses and districts, and to all roadway users, where appropriate.

• Policy CI-7.1: Ensure that parking requirements in the City’s zoning regulations appropriately reflect the needs of businesses, residents, and institutions, and the evolving nature of personal transportation (for example, electric or other alternative fuel vehicles, car sizes, increased bicycle use).

• Policy CI -7.2: Accommodate shared use of public and private parking facilities within business districts and where joint use of parking lots is appropriate given the uses sharing the facilities.

In order to accept this street vacation, the City Council can adopt Resolution No. 7433.

ENVIRONMENTAL ASSESSMENT

An Environmental Impact Report ( “EIR”) was prepared for this project by Dudek to evaluate potential environmental impacts that would result from implementation of the project (State Clearinghouse No. 2021070271). Please see the link to the EIR and associated technical studies as Attachment No. 9 to this Staff Report.

The EIR provides an introduction, review of the environmental setting for the project, a project description, a review of all the required sections for environmental analysis, and a review of alternatives. The sections of environmental analysis that were reviewed include:
• Aesthetics
• Air Quality
• C ultural Resources
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• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Noise
• Population and Housing
• Public Services and Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
Upon a complete review of all of the topics listed above, the EIR concluded that there are a number of mitigation measures required for the project. With the incorporation of these mitigation measures, however, the project will have no significant impacts. As such, a Mitigation Monitoring and Reporting Program ( “MMRP”) will be provided to ensure that these mitigations occur. A summary of the required mitigations is provided below. For a full description of the mitigations, please see the EIR (link provided as Attachment No. 9):
• MM-CUL-1: Requirement for a Worker Environmental Awareness Program to educate those on the site as to archaeological resources that may be uncovered during grading, excavation or construction and requirements for procedures to protect any archaeological resources.
• MM-GEO-1: Requirement for retention of a paleontologist to educate workers and prepare guidelines for awareness of potential paleontological resources and procedures of they are located.
• MM-HAZ-1: Ensure that demolition contractor incorporates proper abatement requirements for hazardous materials during demolition. • MM-HAZ-2: Soil Management Plan related to the potential presence of contaminated materials during excavation.
• MM-HAZ-3: Soil Vapor Mitigation design features prior to grading permit. • MM-TRA-1: Requirement for City-approved construction traffic control plan. • MM-TCR-1: Retention of a Native American monitor from the Kizh Nation prior to any ground disturbance activities to ens ure protection of any Tribal cultural resources.
• MM-TCR-2: Ensure any human remains are reported to Coroner and proper protections are in place.
• MM-TCR-3: Protocols in the event that human remains are discovered which are relevant to the Tribe.

The Draft EIR was distributed for public review on February 24, 2022, and the public review period was from February 24, 2022, through April 11, 2022. Comment letters were 150 N. Santa Anita Ave.

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received from the following interested parties. Copies of all of the comment letters are included within Attachment No. 10.
• Caltrans
• Lozeau Drury on behalf of Supporter’s Alliance for Environmental Responsibility • David Fu on behalf of property owner Dong Chang, MD
• Mitchell Tsai on behalf of the Southwest Regional Council of Carpenters A Response to each of the comments received is also included within Attachment No. 10.

PUBLIC NOTICE/COMMENTS
A public hearing notice for this item was published in the Arcadia Weekly newspaper and mailed to the property owners located within 300 feet of the subject property on April 7 and again on April 21, 2022. The project had originally been scheduled for the April 26, 2022, Planning Commission public hearing but was moved to May 10, 2022. In order to be clear with the hearing date, the second notice was published and mailed on April 21 advertising the May 10 date. No additional comments were received until the day of the Planning Commission hearing, when Mitchell Tsai on behalf of the Southwest Regional Council of Carpenters submitted a 260-page letter and technical report, which was nearly identical to their letter submitted during the EIR Comment Period. Similarly, Lozeau Drury submitted a 22- page letter the day of the hearing along with their own technical report from the same firm. Responses to all these comments are provided as part of Attachment No. 10.

On May 26, 2022, a public hearing notice for the City Council hearing was published in t
he Arcadia Weekly newspaper and mailed to the property owners located within 300 feet of the subject property. As of June 16, 2022, one letter of support was received from the Downtown Arcadia Improvement Association.

PLANNING COMMISSION HEARING

The Planning Commission held a public hearing on this matter on May 10, 2022. Two speakers appeared at the meeting in opposition to the project, attorney David Fu representing Dr. Dong Chang and attorney Noah Garrison representing Lozeau Drury illustrating some of the issues raised in the submitted letter – refer to Attachment No. 10.

After taking testimony, the Planning Commission discussed the project at length, including questions concerning parking demand and provision, entry and exit points, operational aspects of the ATM site, the nature of the public alley to the east of the site, and the live work units. Commissioner Thompson felt that the project met all of the findings for approval but had concerns about future commercial parking demand that may increase as the project will raise the profile of the area once completed.

The Planning Commission voted 4- 0, Chair Lin absent, to recommend approval of the project to the City Council.
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FISCAL IMPACT

While a direct estimate of the impact is not available, the P roject will have a positive revenue impact in that additional property taxes will be collected due to the substantial increase in appraised value on site. The Project will also generate user fees, park impact fees, transportation impact fees, and building permit revenue. Following construction, a modest increase in sales taxes will be expected as a result of the commercial component of the P roject. Ancillary fiscal benefit will also result from the spending patterns of new residents in Downtown Arcadia, which will have both private and public fiscal benefits. It is not known if the revenue enhancements will fully offset the demand for services from the residents and businesses on the site; however, multifamily units of the type proposed generally do not have a high demand for public services.

RECOMMENDATION

It is recommended that the City Council approve Minor Use Permit No. MUP 21 -08, Architectural Design Review No. ADR 21 -12, and Tentative Parcel Map No. TPM 21- 02 along with a density bonus and street vacation, through the adoption of the following resolutions:
• Resolution No. 7433 Ordering the Vacation of the East/West Alley within the block bounded by Santa Anita Avenue, Santa Clara Street, First Avenue, and Wheeler Avenue.

• Resolution No. 7434 Certifying the EIR (Add proper language)

• Resolution No. 7435 approving the project (add proper language) subject to the following conditions of approval and mitigation measures:

Conditions of Approval and Mitigation Measures

1. The Applicant/Property Owner shall prepare and execute a Density Bonus Housing Agreement that will ensure that at least 26 units are reserved on site as housing for very low -income residents. The Density Bonus Housing Agreement must be recorded in the Office of the Los Angeles Recorder’s office prior to the issuance of a Certificate of Occupancy for the project. Prior to recordation, the Applicant/Owner shall submit the Agreement to the City for review and approval by the City and shall obtain the City Attorney’s approval thereof. For this purpose, the Applicant/Owner shall submit to the City with the proposed Agreement a deposit of $7,500 for purposes of such review, of which any funds remaining after review of the Agreement by the City shall be returned to the Applicant/Owner.

2. A declaration of covenants, conditions , and restrictions (“CC&Rs”) providing for reciprocal parking and access between both properties shall be prepared by the 150 N. Santa Anita Ave.

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Applicant and recorded against both properties in the Office of the Los Angel es County Recorder’s Office after the final map has been recorded. Prior to their recordation, the Applicant/Owner shall submit the CC&R’s to the City for review and approval by the City, and shall obtain the City Attorney’s approval thereof. For this purpose, the Applicant/Owner shall submit to the City with the proposed CC&Rs a deposit of $3,000 for purposes of such review, of which any funds remaining after review of the CC&R’s by the City shall be returned to the Applicant/Owner.

3. The Applicant/Property Owner shall provide wayfinding signage at all parking garage ingress points for customers prior to entering the garage and providing wayfinding signage within the parking garage such that customers are directed to the ATM drive- thru, and other users of the site are channeled to parking spaces and garage exits.

4. Where parking serves more than one accessible entrance, accessible parking spaces shall be dispersed and located on the shortest accessible route to the accessible entrances.

5. A wheel stop shall be provided for each parking space adjacent to and facing a wall, building, walkway, utility cabinet, or structure. The wheel stops shall be set a minimum of 36 inches from the forward end of the parking space and shall be six inches high and in accordance with the City’s Development Code. All parking stalls shall also be double-striped to provide a parking stall with a 9-foot width, measured to the center of the lines. Said plan shall be subject to review and approval by the Planning and Community Development Administrator, or designee, prior to submitting the plans into Building Services for plan-check.

6. 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 a qualified biologist. The size of the protective barrier will be determined by the biologist based on the location of the nest, type of 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 the nest is no longer occupied and all juveniles have fledged. This measure shall be implemented to the satisfaction of the Planning & Community Development Administrator, or designee.

7. The Final Parcel Map must be approved and recorded by the Los Angeles County Recorder’s Office prior to issuance of a building permit.

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8. The final landscape plans must be submitted at the same time as the building and architectural plans to Building Services for plan check. The P roject shall be developed and maintained by the Applicant/Property Owner in compliance with all the recommended tree protection measures and maintenance (prior, during and after construction), as listed in the Arborist Report, dated September 2021.

9. The Project shall comply with Chapter 35A Multi-Family Construction Standards as amended in the Arcadia Municipal Code Section 8130.20.

10. During all Project site construction, all construction‐ related activities, including maintenance of construction equipment and the staging of haul trucks, shall be limited to 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. No construction is permitted on Sundays and holidays specified in the City’s Municipal Code.

11. The Project shall be developed and maintained by the Applicant/Property Owner in a manner that is consistent with the plans submitted and conditionally approved for Minor Use Permit No. MUP 21 -08, Architectural Design Review No. ADR 21 -12, and Tentative Parcel Map No. TPM 21- 02), subject to the satisfaction of the Planning & Community Development Administrator or designee. Noncompliance with the plans, provisions and conditions of approval shall be grounds for immediate suspension or revocation of any approvals.

12. The Applicant/Property Owner 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. This shall be determined by the Planning and Community Development Administrator and Public Works Services Director during construction and up until issuance of a Certificate of Occupancy.

13. Prior to issuance of a building permit, the Applicant/Property Owner shall submit a parking management plan providing how replacement parking for the existing uses on site s hall be provided, including signed leases with adjacent properties as needed. The parking management plan shall include a staging plan for construction parking and staging and conditions for the management of replacement and construction parking so as to minimize impacts on surrounding public parking areas and street parking. The plan shall acknowledge and reference the existing parking and maintenance easement agreement between the subject property and the property at 100 N. Santa Anita Avenue, and shall acknowledge the ADA parking needs of the property at 100 N. Santa Anita Avenue and provide ADA spaces as close as is feasible to that property. Sa id plan shall be subject to review and approval by the Planning and Community Development Administrator, or designee.

14. Prior to the issuance of a Certificate of Occupancy, a parking management plan shall be provided that illustrates how the peak residential demand of 376 parking 150 N. Santa Anita Ave.

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spaces for the residential uses will be met. Additionally, at least 82 bicycle parking spaces shall be provided.

15. The plans submitted for Building plan check shall comply with the latest adopted edition of the following codes as applicable:
a. California Building Code
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

16. All utility conductors, cables, conduits, and wiring supplying electrical, cable and telephone service to the building shall be installed underground except risers which are adjacent to and attached to a building.

17. The grading plans shall indicate all site improvements and shall indicate complete drainage paths of all drainage water run-off.

18. The Applicant shall conduct pre -construction surveys prior to excavation, and existing improvements on the adjacent property at 100 N. Santa Anita Avenue shall be inspected and the pre- construction condition s hall be documented.

During construction, all recommendations of the geotechnical investigation shall be followed and the building at 100 N. Santa Anita Avenue shall be monitored during drilling and pile installation, and periodically throughout construction.

Professionals representing 100 N. Santa Anita Avenue may participate in the preconstruction survey and monitoring activity at their own expense.

19. Prior to the issuance of a grading permit, the Applicant/ Property Owner shall remove or abandon that portion of the City sewer line lying within five feet of the proposed building footprint up to the nearest downstream manhole, and all affected sewer services that connect to the abandoned sewer main in the parking lot shall be re-established by the Applicant/Owner. The preliminary design on re- establishing the affected services shall be subject to review and approval by Public Works Services Department and Planning Services Division prior to issuance of a grading permit.

20. The Applicant/Property Owner will be required to pay the City’s Map and Final Approval Fee prior to approval of the Final Map.

21. Prior to occupancy, the developer shall repair any damages caused by the development to the asphalt street frontages from property line to property line 150 N. Santa Anita Ave.

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including but not limited to trench cuts and construction traffic, per the direction of the City Engineer.

22. As part of the Final Parcel Map, the developer shall dedicate additional right -of- way as follows:
a. Santa Anita Avenue – A three-foot dedication and a two- foot non-exclusive easement for public utility purposes.
b. Santa Clara Street – adjacent to Bank of America building – four-foot additional dedication.
c. Santa Clara Street – adjacent to new building – one-foot additional dedication and five-foot easement.
d. North/South Alley – five-foot public access/walkway easement adjacent to the alley.
e. All driveways – sufficient easements to accommodate ADA sidewalk access f. Street/Driveway corners – triangular cutbacks as necessary for ADA accessible ramp purposes
g. All portions of sidewalks with obstructions – sufficient easements where public right-of-way does not exist to accommodate public sidewalk around obstacles.

23. Prior to the approval of the Final Parcel Map the developer shall either construct or post security for all public improvements as follows:

a. Remove and replace existing sidewalk, curb and gutter along all property frontages from property line to property line to the satisfaction of t he City Engineer. Include additional sidewalk to provide adequate clearances around all obstacles.
b. Construct new ADA accessible ramps at all corner and driveways. c. Coordinate with Public Works Services on protection of street trees along Wheeler Avenue and the installation of any new street trees. d. Remove and replace all drive approaches per City standard plan. e. Remove and replace the pavement in the alley adjacent to the development in conformance with the City’s Downtown Alleys Improvement Plan.

24. The buil ding shall be fully 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 and adjacent to sleeping areas in residential units. Visual appliances will be provided in any units classified as being accessible.
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25. An emergency responder radio coverage system is required.

26. Class 1 standpipes shall be provided in all stairwells to the roof level.

27. A knox box shall be provided at a location to be approved by the Fire D epartment.

Knox switches shall be provided for any automatic vehicular gates.

28. Fire extinguishers with a minimum rating of 2A:10BC shall be provided in all common areas. Minimum travel distance shall be 75 feet.

29. Illuminated exit signage and emergency lighting shal l be provided for the parking area and all other common paths of egress.

30. Minimum fire flow is 1,500 gpm at 20 psi.

31. A minimum of one elevator capable of accommodating a 24- inch by 84- inch ambulance stretcher/gurney shall be provided.

32. New public hydrants shall be provided on Santa Clara Street and Wheeler Avenue on the street frontage of the property.

33. The project is responsible for contributing a fair share payment toward the installation of a cloud- based traffic mitigation system being completed by the Fire Department. This fair share payment shall be attributed to the six (6) immediately adjacent intersections evaluated in the Traffic Study for the project and the payment shall not exceed $6,300.

34. The Applicant/Owner shall provide calculations to determine the maximum domestic demand, maximum commercial demand and maximum fire demand in order to verify the required water service size required.

35. The Applicant/Owner shall provide separate water services and meters for specific residential, commercial, and irrigation uses. Backflow protection (approved reduced pressure backflow preventer) shall be installed for all three services.

36. Domestic water service for residential units shall be provided by a common master meter. Any condominiums shall require a separate water service and meter for common area landscape irrigation.

37. All fire protection requirements shall be as stipulated by the Arcadia Fire Department. In the event that fire suppression is common to the complex, a separate fire service with Double Check Detector Assembly ( “DCDA”) shall be required as directed by the Fire Marshal.

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38. A Water Meter Clearance Application shall be submitted to the Public Works Services Department prior to final permit issuance.

39. New water service installations shall be installed by the Applicant/Owner.

Installation shall be according to the specifications of the Public Works Services Department, Engi neering Section. Abandonment of existing water services, if necessary, shall be carried out by the Applicant/Owner, according to Public Works Services Department, Engineering Section specifications.

40. If connecting to a City sewer main, the Applicant/Owner shall utilize existing sewer lateral(s) if possible. If any existing sewer lines serving other properties must be relocated, repaired, or upsized in any way, the Applicant/Owner shall be responsible for this work and for maintaining sewer service for any i mpacted properties throughout construction.

41. If any drainage fixture elevation is lower than the elevation of the next upstream manhole cover, an approved backwater valve is required.

42. All existing street trees shall remain and be protected on Wheeler Avenue. No trees required on Santa Anita Avenue or Santa Clara Street.

43. The proposed P roject is subject to the State Water Resources Control Board’s NPDES General Construction Permit requirements:

a. Applicant submit Notice of Intent along with applicable fees to the State. b. Applicant to prepare a Stormwater Pollution Prevention Plan. c. City will not issue a grading permit until Waste Discharge ID # can be furnished.

44. The Applicant/Owner shall size the trash enclosure(s) accordingly. Separate bins/carts shall be provided for trash, recycling, and green waste/ food waste.

Placement and volume of bins/carts shall be subject to review and approval of the Public Works Services Department.

45. The Project requires a Low Impact Development (“LID”) plan which shall comply with the Los Angeles County Department of Public Works 2014 LID standard manual and show the selected measures on the grading plan. Potential strategies include using infiltration trenches, bioretention planter boxes, roof drains connected to a landscaped area, pervious concrete pavers, etc.

46. 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 to the satisfaction of the Building Official, City Engineer, Planning & Community Development Administrator, Fire Marshal, and Public Works Services Director. Any 150 N. Santa Anita Ave.

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changes to the existing facility may be subject to having fully detailed plans submitted for plan check review and approval by the aforementioned City officials and employees and may subject to building permits.

47. Noncompliance with the plans, provisions, and conditions of approval for MUP 21- 08, ADR 21 -12, TPM 21- 02, a Density Bonus , and a Street Vacation shall be grounds for immediate suspension or revocation of any approvals..

48. To the maximum extent permitted by law, Applicant must defend, indemnify, and hold 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 MUP 21-08, ADR 21-12, TPM 21-02, a Density Bonus and a Street Vacation on the Project site, and which may arise from the direct or indirect oper ations 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.

49. 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 promptly notify the Applicant of the claim, action, or proceedings and will fully cooperate in the defense of the matter. Once notified, 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, Applicant shall provide to 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. City may draw funds from the deposit for such fees, costs, and expenses.

Within 5 business days of each and every notice from City that the deposit has fallen below the initial amount, Applicant shall replenish the deposit each and every time in order for City’s legal team to continue working on the matter. City shall only refund to Applicant/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 that the Applicant reasonably approves. The parties hereby agree to cooperate in defending such action. The City will not voluntarily assist in any such third- party challenge(s) or take any position 150 N. Santa Anita Ave.

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adverse to the Applicant in connection with 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, whether or not at the request of the Applicant.

50. Approval of MUP 21-08, ADR 21 -12, TPM 21- 02, a Density Bonus , and a Street Vacation shall not be in effect unless the Applicant/Property Owner have executed and filed the Acceptance Form with the City on or before 30 calendar days after the City Council 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 is detailed in the MMRP.

51. MM-CUL-1 - Prior to commencement of construction activities, an inadvertent discovery clause, written by an archaeologist, shall be added to all construction plans associated with ground disturbing activities and the Project A pplicant shall retain a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Sta ndards for Archaeology, to prepare a Worker Environmental Awareness Program (“WEAP”). The WEAP shall be submitted to the City of Arcadia Planning and Community Development department (City) for review and approval.

All construction personnel and monitors shall be presented the WEAP training prior to the start of construction activities. The WEAP shall be prepared to inform all personnel working on the proposed Project about the archaeological sensitivity of the area, to provide specific details on the kinds of archaeological materials that may be identified during construction, to explain the importance of and legal basis for the protection of significant archaeological resources, and to outline the actions to be taken in the event of a discovery of cultural resources. Each worker shall also learn the proper procedures to follow in the event that cultural resources or human remains are uncovered during ground- disturbing activities. These procedures include work curtailment or redirection, and the immediate cont act of the site supervisor and archaeological monitor.

The WEAP shall require that a qualified archaeologist be retained and on- call to respond to and address any inadvertent discoveries identified during initial excavation in native soils, which underly the 2-4 feet below ground surface (bgs) of artificial fill soils. As it pertains to archaeological monitoring, this definition excludes movement of sediments after they have been initially disturbed or displaced by project-related construction. If potential archaeological resources (i.e., sites, features, or artifacts) are exposed during construction activities for the proposed 150 N. Santa Anita Ave.

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Project, the City shall be notified and all construction work occurring within 50 feet of the find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, can evaluate the significance of the find and determine whether or not additional study is warranted. The archaeologist shall be empowered to temporarily stop or redirect grading activities to allow removal of abundant or large artifacts. Depending upon the significance of the find under the California Environmental Quality Act (“CEQA”) (14 CCR 15064.5[f]; PRC, Section 21082), the archaeologist may simply record the find and allow work to continue. If the discovery proves significant under CEQA, additional work, such as preparation of an archaeological treatment plan and data recovery, may be warranted. The archaeologist shall also be required t o curate any discovered specimens in a repository with permanent retrievable storage and submit a written report to the City of Arcadia for review and approval prior to occupancy of the first building on the site. Once approved, the final report shall be filed with the South Central Coastal Information Center (“SCCIC”).

52. MM-GEO-1 - Prior to commencement of any grading activity on-site, the Applicant shall retain a qualified paleontologist per the Society of Vertebrate Paleontology (“SVP”) (2010) guidelines. The paleontologist shall prepare a Paleontological Resources Impact Mitigation Program (“PRIMP”) for the Project. The PRIMP shall be consistent with the SVP (2010) guidelines and shall outline requirements for preconstruction meeting attendance and worker environmental awareness training, where monitoring is required within the Project area based on construction plans and/or geotechnical reports, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including s ediment sampling for microvertebrate fossils), reporting, and collections management. The qualified paleontologist shall attend the preconstruction meeting and a paleontological monitor shall be on- site during all rough grading and other significant ground- disturbing activities in previously undisturbed, Pleistocene alluvial deposits. These deposits may be encountered at depths as shallow as 5-10 feet below ground surface. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontological monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot radius buffer. Once documentation and collection of the find is com pleted, the monitor will remove the rope and allow grading to recommence in the area of the find.

53. MM-HAZ-1 - Prior to the issuance of a demolition permit, the Project Applicant/Owner or their designated contractor shall ensure that the demolition contract incorporate abatement procedures for the removal of materials containing asbestos, as identified in previous surveys, and identification and removal of polychlorinated biphenyls, haz ardous material, hazardous wastes, and universal waste items. All abatement work shall be done in accordance with federal, state, and local regulations, including those of the U.S. Environmental Protection Agency (which regulates disposal), Occupational Safety and Health Administration, U.S. 150 N. Santa Anita Ave.

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Department of Housing and Urban Development, California Occupational Safety and Health Administration (which regulates employee exposure), and the South Coast Air Quality Management District. Confirmation of adequate removal of such materials shall be provided to the City prior to the issuance of a building permit.

54. MM-HAZ-2 - Prior to the issuance of a grading permit, the Project Applicant/Owner or their designated contractor shall prepare a soil management plan ( “SMP”) that outlines the proper screening, handling, characterization, transportation, and disposal procedures for contaminated soils on site. The SMP shall include health and safety and t raining procedures for workers who may come in contact with contaminated soils. The health and safety procedures shall also include periodic breathing zone monitoring and monitoring for VOCs using a handheld organic vapor analyzer and include required actions to be taken if concentrations of VOCs exceed applicable screening levels for health and safety of onsite workers. The SMP will be based on the findings of the Soil and Soil Vapor Investigation prepared for the Project, will outline areas of known or suspected soil contamination, and will be implemented by the A pplicant or their designated contractor for all confirmed and suspected contaminated soils which require excavation and offsite disposal.

Contaminated soil shall be managed and disposed of in accordance with applicable federal, state, and local regulations.

55. MM-HAZ-3 - Prior to the issuance of a grading permit, vapor mitigation design features shall be implemented in accordance with the Department of Toxic Substances Control ( “DTSC”) Vapor Intrusion Mitigation Advisory for all future residential buildings and enclosed structures. The construction contractor shall incorporate vapor mitigation design features into building plans that reduce potential vapor intrusion in buildings and enclosed structures on the Project site below DTSC Screening Levels. Vapor mitigation systems may be passive or active in nature, so long as they are designed to prevent vapor contamination on the Project site in accordance with applicable DTSC regulations at the time the systems are designed. Vapor mitigation systems must be reviewed and approved by the permitting agency(ies) (City of Arcadia, County of Los Angeles) prior to construction and prior to issuance of certificate of occupancy. Operation of the Project shall maintain functionality of these features as required to continue protection from vapor intrusion. Following completion of construction and occupancy of the buildings, indoor air monitoring will occur semiannually for one year to verify implemented measures are functioning properly and adequately mitigating vapor intrusion to below residential DTSC Screening Levels. Results shall be submitted to the City of Arcadia for confirmation of the adequacy of the designed systems. If indoor air samples reveal vapor intrusion occurring at levels above applicable DTSC Screening Levels, modifications shall be made, as necessary, to the designed system to improve the efficacy in reducing vapor intrusion to below applicable screening levels.

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56. MM-TRA-1 - Prior to the issuance of demolition or grading permits, the Project Applicant/Developer shall develop and implement a City -approved Construction Traffic Control Plan. The Plan shall be prepared in accordance with applicable City guidelines and shall address the potential for constr uction-related vehicular traffic, as well as pedestrian and bicycle circulation disruption in the public right -of-way.

The Plan shall describe safe detours and shall include protocols for implementing the following: temporary traffic controls (e.g., a flag person during heavy truck traffic for soil export) to maintain smooth pedestrian and traffic flow; dedicated on-site turn lanes for construction trucks and equipment leaving the site; scheduling of peak construction truck traffic that affects traffic flow on the arterial system to off -peak hours; consolidation of truck deliveries; and/or rerouting of construction trucks away from congested streets or sensitive receptors.

57. MM-TCR-1 - The project Applicant shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation (“Tribe” or “Kizh”). The monitor shall be retained prior to the commencement of any “ground- disturbing activity” for the subject project at all project locations (i.e., both on- site and any off -site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. “Ground- disturbing activity” refers to ground disturbance occurring from 1 foot above native soils and below, and it does not include movement of sediments after the y have been initially disturbed or displaced by current Project-related construction.

A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground- disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural -related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe.

Monitor logs will identify and describe any discovered TCRs, including but not limited to, Nati ve American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

On-site tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to the Kizh from a designated point of contact for the project Applicant or lead agency that all ground- disturbing activities as defined above and phases that may involve ground-disturbing activities on the project site or in connection with 150 N. Santa Anita Ave.

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the project are complete; or (2) a determination and written notification by the Kizh to the project Applicant or lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh Tribal Cultural Resour ces ( “TCRs”). Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers and retains all discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. The Tribe shall have up to 48 hours to recover and retain any discovered Kizh TCRs, after which time construction activities in the immediate vicinity of the discovery may continue.

58. MM-TCR-2 - Native American human remains are defined in P ublic Resources Code Section 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.

In accordance with Health and Safety Code Section 7050.5, any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

Consistent with California Public Resources Code Section 5097.98(d)(2), any items associated with the human remains that are placed or buried with the Native American human remains are to be treated in the same manner as the remains, but do not by themselves constitute human remains.

Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

59. MM-TCR-3 - If the Tribe is designated by the Native American Heritage Commission (“NAHC”) as the Most Likely Descendant (“MLD”), the Koo- nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human 150 N. Santa Anita Ave.

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remains. Accordingly, if the Tribe is designated as the MLD for discovered human remains, the prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected.

If the project cannot be diverted, it may be determined that burials will be removed.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the event preservation in place is not possible despite good faith efforts by the project Applicant/developer and/or landowner, before ground- disturbing activities may resume on the project site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects. If the Tribe is designated by the NAHC as the MLD, the following condition will apply: Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. Where the Tribe is designated as the MLD, the site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

If the Tribe is designated by the NAHC as the MLD, t he following condition will apply: The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prep ared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery and data recovery-related forms of documentation shall be approved in advance by the Tribe. 150 N. Santa Anita Ave.

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If any data recovery is performed, once complete, a final report sh all 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.

During ground- disturbing activities Construction contractor NAHC’s “Most Likel y Descendant” Tribe.

Attachment No. 1: Resolution No. 7433 – Approving the alley vacation Attachment No. 2: Resolution No. 7434 – Certifying the Environmental Impact Report (includes the environmental findings of fact)
Attachment No. 3: Resolution No. 7435 – Approving the Alexan Arcadia Project with Conditions of Approval and Mitigation Measures
Attachment No. 4: Aerial Photo and Zoning Information and Photos of the Subject Property
Attachment No. 5: Planning Commission Minutes, Staff Report with no attachments , and Resolution No. 2093
Attachment No. 6: Tentative Parcel Map
Attachment No. 7: Architectural Plans and Renderings
Attachment No. 8: Alexan Arcadia Market Analysis and CBRE Retail Analysis Attachment No. 9: Link to Draft Environmental Impact Report and Technical Appendices – www.arcadiaca.gov/projects
Attachment No. 10: Final EIR: Preface, Response to Comments, Changes to the Draft EIR, MMRP, Memo for Hearing Responses, and additional
comment letters

SECTION 5. a Public Hearing was duly held on June 21, 2022 at 7:00 p.m. in the Council Chambers of Arcadia City Hall, 240 West Huntington Drive, Arcadia, California, at which time the City Council received all comments and evidence offered by persons interested in the proposed vacation.

SECTION 6. Pursuant to the Streets and Highways Code Section 8324, the City Council finds from all evidence submitted that the public east/west alley within the block bounded by Santa Anita Avenue, Santa Clara Street, First Avenue and Wheeler Avenue is unnecessary for present or prospective public use and, therefore, it is ordered that it be vacated.

SECTION 7. Pursuant to the Streets and Highways Code Section 8340 and 8341, the City Council of the City of Arcadia finds that the public convenience and necessity require the reservation and exception of a public utility easement from the vacation.

SECTION 8. The City Clerk of the City of Arcadia shall certify to the adoption of this Resolution and shall cause a certified copy thereof to be recorded without acknowledgement, certificate of acknowledgement, or further proof in the Office of the County Recorder of Los Angeles County after the aforementioned conditions have been satisfied.

SECTION 9. From and after the date this Resolution No. 7433 is recorded, this public east/west alley within the block bounded by Santa Anita Avenue, Santa Clara Street, First Avenue and Wheeler Avenue will no longer constitute public right-of-way.

SECTION 10. The City Clerk shall certify to the adoption of this Resolution. 2 Passed, approved, and adopted this 19th day of July, 2022.

ATTEST:

City Clerk
APPROVED AS TO FORM:
�;:,_ � �Stephen P. Deitsch
City Attorney
Mayor of the City of Arcadia
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LEGAL DESCRIPTION1
ALLEY VACATION 2
3 A portion of that certain 20.00 foot wide alley situated in Block 76 of Map of Arcadia, in 4 the City of Arcadia, County of Los Angeles, State of California, as per map recorded in 5 Book 15, Pages 89 through 90, inclusive, of Miscellaneous Records, in the Office of the 6 County Recorder of said County, described as follows: 7 8 Bounded westerly by the easterly line of Parcel 2, of Parcel Map No. 2415, in said city as 9 per map recorded in book 34, Page 64, of Parcel Maps, in the office of said county 10 recorder; bounded northerly by the southerly line of Lots 27 and 28, Block 76, of said 11 Map of Arcadia; bounded southerly by the northerly line of Lots 7 and 8, of said Block 12 76; and bounded easterly by the easterly lines of said Lots 8 and 27 as produced to the 13 centerline of said alley. 14
15 This legal description is delineated on the accompanying “Exhibit Map”, is made a part 16 hereof for reference purposes, and is not intended to be used in the conveyance of land in 17 violation of the Subdivision Map Act of the State of California. 18 19 20
Prepared under the direction of 21
22 _______________________________________ 23
Daniel L. Rahe, PLS 9425 24
PSOMAS 25
26 27
28 29
30 5/19/2022
EXHIBIT "A"
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"ALLEY VACATION"

IN THE CITY OF ARCADIA

COUNTY OF LOS ANGELES, STATE OF CALIFORNIA

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Attachment No. 2
Resolution No. 7434 – EIR

Exhibit A
Findings of Fact for the Final EIR

FINDINGS OF FACT
Alexan Mixed-Use Development Project Final EIR
(SCH No. 2021070271)
Prepared for:

City of Arcadia
240 W. Huntington Drive
Arcadia, California 91007
Contact: Lisa Flores, Planning and Community Development Administrator Prepared by:
38 North Marengo Avenue
Pasadena, California 91101
Contact: Kristin Starbird, Senior Project Manager
MAY 2022

Alexan Mixed-Use Development Project Final EIR
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i
Table of Contents

SECTION PAGE NO.

1 INTRODUCTION ..................................................................................................................................................... 1

1.1 Purpose ................................................................................................................................................... 1

1.1.1 Record of Proceedings .............................................................................................................. 2

1.1.2 Custodian and Location of Records ......................................................................................... 2 2 CEQA FINDINGS OF INDEPENDENT JUDGEMENT .............................................................................................. 3

2.1 Independent Review and Analysis ......................................................................................................... 3

2.2 Impacts Determined to Be Less Than Significant with Mitigation ........................................................ 3

2.2.1 Cultural Resources .................................................................................................................... 4

2.2.2 Geology and Soils ...................................................................................................................... 6

2.2.3 Hazards and Hazardous Materials ........................................................................................... 8

2.2.4 Transportation ......................................................................................................................... 12

2.2.5 Tribal Cultural Resources ........................................................................................................13

2.3 Impacts Determined to Be Less Than Significant ...............................................................................17

2.3.1 Aesthetics ................................................................................................................................17

2.4.2 Agriculture and Forestry Resources .......................................................................................21

2.4.3 Air Quality .................................................................................................................................21

2.3.4 Biological Resources .................................................................................................... ...........26

2.4.5 Cultural Resources .................................................................................................................. 27

2.3.6 Energy ......................................................................................................................................30

2.3.7 Geology and Soils ....................................................................................................................33

2.3.8 Greenhouse Gas Emissions ....................................................................................................39

2.3.9 Hazards and Hazardous Materials .........................................................................................41

2.3.10 Hydrology and Water Quality ...................................................................................................42

2.3.11 Land Use ..................................................................................................................................49

2.3.12 Mineral Resources ..................................................................................................................51

2.3.13 Noise ........................................................................................................................................52

2.3.14 Population and Housing ..........................................................................................................56

2.3.15 Public Services and Recreation ...............................................................................................60

2.3.16 Transportation ......................................................................................................................... 68

2.3.17 Tribal Cultural Resources ........................................................................................................73

2.3.18 Utilities and Service Systems .................................................................................................74

2.3.19 Wildfire .....................................................................................................................................82 3 FINDINGS ON PROJECT ALTERNATIVES ............................................................................................................83

3.1 Alternatives Carried Forward for Consideration ..................................................................................83

3.1.1 Alternative A - No Project/Existing Development ...................................................................83 Alexan Mixed-Use Development Project Final EIR
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ii

FINDINGS OF FACT

3.1.2 Alternative B - Increased Commercial-Use Alternative: Conversion of Live/Work Units to Commercial............................................................................................................................. 85

3.2.2 Environmentally Superior Alternative .................................................................................... 86 4 GENERAL CEQA FINDINGS ................................................................................................................................ 87

4.1 Findings Regarding Recirculation ........................................................................................................ 87

4.2 Legal Effects of Findings ..................................................................................................................... 88 5 CONCLUSION ..................................................................................................................................................... 89 6 REFERENCES CITED .......................................................................................................................................... 91 Alexan Mixed-Use Development Project Final EIR
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1 1 Introduction

This statement of Findings of Fact (Findings) addresses the environmental effects associated with the proposed Alexan Mixed-Use Development Project (proposed Project), as described in the Draft Environmental Impact Report (EIR). These Findings are made pursuant to the Californ ia Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.), specifically California Public Resources Code, Sections 21081, 21081.5, and 21081.6, and the CEQA Guidelines (14 CCR 15000 et seq.), specifically Sections 15091 and 15093. The Draft EIR examines the full range of potential effects of construction and operation of the Project and identifies mitigation practices that could be employed to reduce, minimize, or avoid those potential effects.

1.1 Purpose
California Public Resources Code, Section 21081, and CEQA Guidelines Section 15091 require that the lead agency, in this case the City of Arcadia (City), prepare written findings for identified significant effects, accompanied by a brief explanation of the rationale for each finding. Specifically, CEQA Guidelines Section 15091 states, in part, that:
a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR. 2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. 3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.

In accordance with California Public Resource Code, Section 21081, and CEQA Guidelines Section 15093, whenever significant effects cannot be mitigate d to below a level of significance, the decision -making agency is required to balance, as applicable, the benefits of the project against its unavoidable environmental risks when determining whether to approve the project. If the benefits of a project outweigh the unavoidable adverse environmental effects, the adverse effects may be considered “acceptable.” In that case, the decision-making agency may prepare and adopt a Statement of Overriding Considerations (SOC), pursuant to the CEQA Guidelines.

The Project does not result in any impacts that cannot be mitigated to a level of less than significant; therefore, a Statement of Overriding Considerations is not required.

The EIR identified potentially significant effects that could result from the Project. The City finds that the inclusion of certain mitigation measures as part of the approval of the Project will reduce all impacts to less- than- significant levels.

As required by CEQA, the City, in adopting these Findings, also adopts a Mitigation Monitoring and Reporting Program (MMRP) for the Project. The City finds that the MMRP, which is incorporated by reference and made a part of these Findings, meets the requirements of California Public Resources Code, Section 21081.6, by providing for the implementation and monitoring of measures intended to mitigate potentially significant effects of the Project.

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2 FINDINGS OF FACT

In accordance with the CEQA Statutes and Guidelines, the City adopts these Findings for the Project. Pursuant to California Public Resources Code, Section 21082.1(c)(3), the City also finds that these Findings reflect the City’s independent judgment as the lead agency for the Project.

1.1.1 Record of Proceedings
For the purposes of CEQA and the Findings herein set forth, the record of proceedings for the Project consists of those items listed in CEQA Section 21167.6(e). The record of proceedings for the City’s decision on the Project consists of the following documents, at a minimum and without limitation, which are incorporated by reference and made part of the record supporting these Findings:

(a) The Notice of Preparation, Notice of Availability, and all other public notices issued by the City in conjunction with the Project
(b) The Draft EIR for the Project and all technical appendices and documents relied upon or incorporated by reference
(c) All written comments submitted by agencies, organizati ons, or members of the public during the public review comment period on the Draft EIR and the City’s responses to those comments (d) The Final EIR for the Project
(e) The MMRP for the Project
(f) All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project prepared by the City or consultants to the City with respect to the City’s compliance with the requirements of CEQA and with respect to the City’s action on the Project (g) All documents submitted to the City by other public agencies or members of the public in connection with the Draft EIR
(h) Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public hearings held by the City in connection with the Project
(i) Any documentary or other evidence submitted to the City at such information sessions, public meetings, and public hearings
(j) All resolutions adopted by the City regarding the Project, and all staff reports, analyses, and summaries related to the adoption of those resolutions
(k) Matters of common knowledge to the City, including, but not limited to federal, state, and local laws and regulations
(l) Any documents expressly cited in these Findings, in addition to those cited above; and any other materials required for the record of proceedings by CEQA Section 21167.6(e)

1.1.2 Custodian and Location of Records
The documents and other materials that constitute the Record of Proceedings for the City’s actions related to the Project are located at the City of Arcadia, 240 W. Huntington Drive, California 91007. The City Clerk is the custodian of the Record of Proceedings for the Project.

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3 2 CEQA Findings of
Independent Judgement

2.1 Independent Review and Analysis
Under CEQA, the lead agency must (1) independently review and analyze the EIR; (2) circulate draft documents that reflect its independent judgment; (3) as part of the certification of an EIR, find that the report or declaration reflects the independent judgment of the lead agency; and (4) submit copies of the documents to the State Clearinghouse if there is state agency involvement or if the project is of statewide, regional, or area-wide significance (California Public Resources Code, Section 21082.1[c]).

These Findings reflect the City’s independent judgment. The City has exercised independent judgment in accordance with CEQA Section 21082.1(c)(3) in retaining its own environmental consultant in the preparation of the EIR, as well as reviewing, analyzing, and revising material prepared by the consultant.

Having received, reviewed, and considered the information in the Final EIR, as well as any and all other information in the record, the City hereby makes findings pursuant to and in accordance with CEQA Sections 21081, 21081.5, and 21081.6.

2.2 Impacts Determined to Be Less Than Significant
with Mitigation
This section identifies significant adverse impacts of the Project that require findings to be made under CEQA Section 21081(a) and CEQA Guidelines Section 15091(a)(1 ). Based on substantial evidence, the City finds that adoption of the mitigation measures set forth in this sect ion will reduce the identified significant impacts to less- than-significant levels:

Cultural Resources

x Archaeological Resources
x Cumulative Effect
Geology and Soils
x Paleontological Resources
x Cumulative Effect

Hazards and Hazardous Materials

x Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the Potential for Upset Conditions
x Reasonably Foreseeable Upset and Accident Conditions Involving the Release of Hazardous Materials x Cumulative Effect

FINDINGS OF FACT
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4 Transportation

x Inadequate Emergency Access
Tribal Cultural Resources
x California Public Resource Code, Section 5024.1
x Cumulative Effect
Other impacts addressed for Aesthetics, Agriculture and Fo restry Resources, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenh ouse Gas Emissions, Hazards and Hazardous Materials, H y d r o l o g y a n d W a t e r Q u a l i t y , L a n d U s e , M i n e r a l R e s o u r c e s , P o p u l a t i o n a n d H o u s i n g , P u b l i c S e r v i c e s a n d Recreation, Transportation, Utilities and Service Systems, and Wildfire are addressed under Section 2.3, Impacts Determined to Be Less Than Significant.

2.2.1 Cultural Resources

2.2.1.1 Potentially Significant Impacts to Cultural Resources Archaeological Resources

The CHRIS records search identified 17 previously conducted cultural resources technical investigations within a 0.5- mile radius records search area. Of these, four studies overlap the Project site; however, individual sites were not identified within the current Project site as a result of these studies. Additionally, the South Central Coast Information Center (SCCIC) records indicate that 63 previously recorded cultural resources exist within the surrounding 0.5-mile search radius. Of the resources identified all are built environment resources with one historic-era archaeological site.

No previously recorded prehistoric or historic-era archaeological resources were identified within the Project site or 0.5- mile records search radius. Additionally, the Native American Heritage Commission (NAHC) was contacted to request a search of its Sacred Land Files (SLF), which were negative. The NAHC also suggested contacting two Native American individuals and/or tribal organizations who may have direct knowledge of cultural resources in or near the Project site.

Based on the results provided above, the potential of encountering and impacting unknown archaeological resources during Project implementation is low given the level of disturbance from the mid-twentieth century; however, it is always possible that unanticipated discoveries could be encountered during ground-disturbing activities associated with the proposed Project. Although the entirely of the Project site was previously investigated, none of these previous investigations were completed prior to the development of the site, indicating that the opportunity to observe native or undisturbed soils during the years of these previous investigations (1996 to 2010) was not possible. However, if such unanticipated discoveries were encountered, impacts to encountered resources could be potentially significant.

However, with implementation of Mitigation Measure (MM-) CUL-1, which includes preparation and implementation of a Worker Environmental Awareness Program (WEAP), all construction personnel will be appropriately informed of required responses to unanticipated cultural resources, should these be encountered. Additionally, MM-CUL-1, requires an inadvertent discovery clause, written by an archaeologist, to be added to all construction plans associated with ground disturbing activities would ensure that a qualified archaeologist is retained and on-call to respond to any inadvertent discoveries during Project construction; and requires that all construction work occurring within 50 feet of any find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, can evaluate the significance of the find. Thus, potentially significant impacts to archaeological resources would be reduced to less than significant levels with mitigation incorporated.

FINDINGS OF FACT
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Cumulative Effect

For archaeological resources, cumulative projects may require extensive excavation in culturally sensitive areas, and thus, may result in adverse effects to known or previously unknown, inadvertently discovered archaeological resources. There is the potential for accidental discovery of other archaeological resources by the proposed Project as well as by cumulative projects. Because all significant cultural resources are unique and non-renewable, all adverse effects or negative impacts contribute to a dwindling resource base. Through implementation of MM-CUL-1, which would require investigation and handling by a qualified archaeologist in the event that an unknown resource is encountered, the project-level impact to archeological resources would be reduced to less than significant.

Further, other individual related projects occurring in the vicinity of the Project site that require discretionary review would also be subject to the same requirements of CEQA as the proposed Project and any impacts to archaeological resources would be mitigated, as applicable. These determinations would be made on a case-by-case basis, and the effects of cumulative development on historical and archaeological resources would be mitigated to the extent feasible in accordance with CEQA and other applicable legal requirements. Therefore, impacts on archaeological resources would not be cumulatively considerable with mitigation incorporated (MM-CUL-1).

2.2.1.2 Mitigation Measures
MM-CUL-1 Prior to commencement of construction activities, an inadvertent discovery clause, written by an archaeologist, shall be added to all construction plans associated with ground disturbing activities and the Project applicant shall retain a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, to prepare a Worker Environmental Awareness P r o g r a m ( W E A P ) . T h e W E A P s h a l l b e s u b m i t t e d t o t h e C i t y o f A r c a d i a D e v e l o p m e n t S e r v i c e s Department (City) for review and approval. All construction personnel and monitors shall be presented the WEAP training prior to the start of construction activities. The WEAP shall be prepared to inform all personnel working on the proposed Project about the archaeological sensitivity of the area, to provide specific details on the kinds of archaeological materials that may be identified during construction, to explain the importance of and legal basis for the protection of significant archaeological resources, and to outline the actions to be taken in the event of a discovery of cultural resources. Each worker shall also learn the proper procedures to follow in the event that cultural resources or human remains are uncovered during ground-disturbing activities. These procedures include work curtailment or redirection, and the immediate contact of the site supervisor and archaeological monitor.

The WEAP shall require that a qualified archaeologist be retained and on-call to respond to and address any inadvertent discoveries identified during initial excavation in native soils, which underly the 2-4 feet below ground surface (bgs) of artificial fill soils. As it pertains to archaeological monitoring, this definition excludes movement of sediments after they have been initially disturbed or displaced by project-related construction.

If potential archaeological resources (i.e., sites, features, or artifacts) are exposed during construction activities for the proposed Project, the City shall be notified and all construction work occurring within 50 feet of the find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, can evaluate the significance of the find and determine whether or not additional study is warranted. The archaeologist shall be empowered to temporarily stop or redirect grading activities to allow removal Alexan Mixed-Use Development Project Final EIR 11663.03

FINDINGS OF FACT
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of abundant or large artifacts. Depending upon th e significance of the find under the California Environmental Quality Act (CEQA) (14 CCR 15064.5[f]; PRC, Section 21082), the archaeologist may simply record the find and allow work to continue. If the discovery proves significant under CEQA, additional work, such as preparation of an archaeological treatment plan and data recovery, may be warranted. The archaeologist shall also be required to curate any discovered specimens in a repository with permanent retrievable storage and submit a written report to the City of Arcadia for review and approval prior to occupancy of the first building on the site. Once approved, the final report shall be filed with the South Central Coastal Information Center (SCCIC).

2.2.1.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse impacts were developed for the potentially significant impacts described in Section 2.2.2.1. This feasible measure, MM-CUL-1, is listed in Section 2.2.2.2.

The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential cultural resources impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in or incorporated into the Project that will mitigate or avoid potentially significant impacts on cultural resources.

2.2.1.4 Facts in Support of the Findings Related to Cultural Resources Implementation of MM-CUL-1 would reduce potentially significant impacts to archaeological resources by addressing the inadvertent discovery of archeological re sources. There would be no significant, unavoidable impacts related to cultural resources after implementation of this mitigation measure.

2.2.2 Geology and Soils

2.2.2.1 Potentially Significant Impacts to Geology and Soils Paleontological Resource

The Project site is underlain by Quaternary gravel and sand (map unit Qg; <11,700 years old), derived as alluvial fans and major stream channels and is not anticipated to be underlain by unique geological features. The Natural History Museum of Los Angeles County (LACM) did not report any paleontological localities from within the Project site, but they did report fossil specimens were recovered in the nearby area. In addition to the LACM localities, desktop research for the Project area indicated there are additional paleontological deposits close to the Project site. Given the proximity of past fossil discoveries in the surrounding area and the potential for significant vertebrate fossils below any artificial fill present within the Project site, the proposed Project is considered potentially sensitive for supporting paleontological resources at any depth. In the event that intact paleontological resources are located on the Project site, ground-disturbing activities associated with construction of the Project, such as grading during site preparation, excavations and trenching for pipelines or utilities, have the potential to destroy a unique paleontological resource or site. Without mitigation, th e potential damage to paleontological resources during construction would be a potentially significant impact. However, upon implementation of Mitigation Measure (MM)- GEO-1, impacts would be reduced to below a level of significance. MM-GEO-1 requires a preparation of a Paleontological Resources Impact Mitigation Program that requires preconstruction meeting attendance and

Alexan Mixed-Use Development Project Final EIR 11663.03

FINDINGS OF FACT
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7 worker environmental awareness training, where monitoring is required within the Project site, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. With incorporation of MM-GEO-1, impacts would be less than significant.

Cumulative Effect

Potential cumulative impacts on geology and soils would result from projects that combine to create geologic hazards, including unstable geologic conditions, or contribute substantially to erosion. The majority of impacts from geologic hazards, such as rupture of a fault line, liquefac tion, landslides, expansive soils, and unstable soils, are site-specific and are therefore generally mitigated on a project-by-project basis. Each cumulative project would be required to adhere to required building engineering design per the most recent version of the California Building Code or CBC in order to ensure the safety of building occupants and avoid a cumulative geologic hazard.

Additionally, as needed, projects would incorporate indivi dual mitigation or geotechnical requirements for site- specific geologic hazards present on each individual cumulative project site. Similarly, MM-GEO-1 would ensure that potential impacts to paleontological resources would be less than significant and other cumulative projects that would have a potential to impact soils that are sensitive for significant fossils would also require mitigation.

Therefore, a potential cumulative impact related to site-specific geologic hazards, such as seismically induced ground failure, subsidence, soil collapse, and expansive soils, as well as paleontological resources, would not occur.

Therefore, the proposed Project, in combination with other cumulative projects, would not contribute to a significant cumulative impact associated with geology and soils.

2.2.2.2 Mitigation Measures
MM-GEO-1 Prior to commencement of any grading activity on-site, the Applicant shall retain a qualified paleontologist per the Society of Vertebrate Paleontology (SVP) (2010) guidelines. The paleontologist shall prepare a Paleontological Resources Impact Mitigation Program (PRIMP) for the Project. The PRIMP shall be consistent with the SVP (2010) guidelines and shall outline requirements for preconstruction meeting attendance and worker environmental awareness training, where monitoring is required within the Project area based on construction plans and/or geotechnical reports, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. The qualified paleontologist shall attend the preconstruction meeting and a paleontological monitor shall be on-site during all rough grading and other significant ground-disturbing activities in previously undisturbed, Pleistocene alluvial deposits. These deposits may be encountered at depths as shallow as 5–10 feet below ground surface. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontological monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot radius buffer. Once documentation and collection of the find is completed, the monitor will remove the rope and allow grading to recommence in the area of the find.

2.2.2.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), a feasible measure that can minimize significant adverse impacts was developed for the potentially significant impacts described in Section 2.2.2.1. This feasible measure, MM-GEO-1, is listed in Section 2.2.2.2.

FINDINGS OF FACT
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8 The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential paleontological resources impacts of the Project to less than significant le vels. Accordingly, the City finds that, pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the Project that mitigate or avoid potentially significant paleontological -related impacts of the Project identified in the EIR.

2.2.2.4 Facts in Support of the Findings Related to Geology and Soils Potential impacts to geology and soils would be less than significant. Incorporation of MM-GEO-1 would reduce construction-related impacts to paleontological resource s to a less-than-significant level. There would be no significant, unavoidable impacts related to geology and soils after implementation of these mitigation measures.

2.2.3 Hazards and Hazardous Materials

2.2.3.1 Potentially Significant Impacts to Hazards and Hazardous Materials Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the Potential for Upset Conditions

Short-Term Construction Impacts

Construction would require the use of heavy equipment and machinery. Hazardous materials would be stored in designated construction staging areas within the boundaries of the Project site and the construction contractor must ensure that they would be transported, handled, used, stored, and disposed of in accordance with all applicable federal, state, and local laws and regulations.

Three buildings on the Project site are scheduled for demolition as part of the proposed Project and an existing building would be renovated. Based on information provided in the Phase I ESA and the asbestos survey, asbestos is present in all the buildings proposed for demolition but no lead-based paint was identified. Universal wastes, such as light fixtures and thermostats that may be present would require collection and off-site disposal prior to demolition. Hazardous wastes, such as spent chemicals or petroleum, may also require collection and off-site disposal prior to demolition and rehabilitation. Additionally, many commercial buildings contain small amounts of (polychlorinated biphenyls) PCBs and mercury that would require proper management prior to demolition. Should remaining hazardous materials and hazardous wastes associated with site maintenance be present, including petroleum products and cleaning supplies, these would be disturbed during the demolition process if not removed.

These materials, if not properly removed, could be transported offsite with demolition debris, and therefore the proposed Project has the potential to create a significant hazard to the public or the environment through the routine transport or disposal of hazardous materials associated wi th demolition activities. In accordance with mitigation measure MM-HAZ-1, demolition would include abatement procedures for the removal of materials containing asbestos, as identified in previous surveys, and identification and removal of PCBs, hazardous material, hazardous wastes, and universal waste items. Abatement must be conducted by licensed contractors, and materials must be transported offsite for recycling and/or disposal by licensed transporters in accordance with federal, state, and local laws. With implementation of MM-HAZ-1, impacts associated with the routine transport of asbestos, PCBs, universal wastes, and hazardous materials for offsite disposal during construction would be less than significant with mitigation incorporated.

FINDINGS OF FACT
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9 Reasonably Foreseeable Upset and Accident Conditions

Short-Term Construction Impacts

The proposed Project has the potential to expose the publ ic and the environment to hazards associated with on- site releases of hazardous materials including asbest os PCB-containing items, universal wastes, and other hazardous materials and wastes present in the building scheduled for demolition. Management of hazardous materials and waste during pre-demolition surveys and abatement activities would be addressed by MM-HAZ-1.

Hazardous materials present in the office building to be renovated, including the items identified for the existing Verizon Wireless cell tower and dental offices, are not expected to be impacted by construction, as this building is not scheduled for demolition, and renovation would only occur on the first floor lobby area which does not contain these hazardous items. However, MM-HAZ-1 would be implemented in the areas scheduled for renovation.

Construction activities would not be conducted in areas where hazardous materials are stored, and impacts associated with existing hazardous materials would be managed under MM-HAZ-1, therefore impacts would be less than significant with mitigation incorporated.

The Soil and Soil Vapor Investigation identified elevated concentrations of benzene and Tetrachloroethylene (PCE) in soil vapor above applicable residential and commercial/industrial screening levels. A potential accident condition could occur during excavation and earth moving activities exposing onsite construction workers to contaminated soil vapor. The soil management plan (SMP) required by MM-HAZ-2 will also include health and safety procedures, including breathing zone monitoring, to prevent exposure of onsite workers to elevated concentrations of benzene and PCE. Along with adherence to federal, state, and local laws and regulations, and implementation of MM-HAZ-1 and MM-HAZ-2, short-term construction impacts associated with potential upset and accident conditions involving the release of hazardous materials to the environment would be less than significant with mitigation incorporated.

Long-Term Operational Impacts

The Soil and Soil Vapor Investigation identified concentrations of benzene and PCE in soil indicating a potential vapor intrusion risk to proposed residential structures to be constructed on the Project site. PCE and benzene concentrations were detected in soil vapor above the Department of Toxic Substances Control (DTSC) screening levels for commercial exposure near the existing commercial buildings. These buildings would remain operational and the current commercial use would not change as part of the proposed Project. Construction would include excavation of soils and construction of new buildings; ho wever, these activities are not anticipated to exacerbate existing soil vapor conditions beneath the existing buildings to remain because the Project site is already completely paved and covered with buildings, therefore pathways of soil vapor exposure in current buildings would not change.

MM-HAZ-3 requires vapor mitigation to be designed and implemented for new structures on the Project site, which will reduce the potential for vapor intrusion to a less than significant level. In accordance with MM-HAZ-3 indoor air monitoring following construction and occupancy is required to verify vapor intrusion is adequately mitigated. With implementation of MM-HAZ-3 Project operational impacts are not anticipated to create a foreseeable upset or accident condition that would release hazardous material s to the environment, and impacts would be less than significant with mitigation incorporated.

Cumulative Effects

FINDINGS OF FACT
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10 There are a variety of hazardous material and public health and safety issues that are relevant and applicable to the Project. Many potential impacts related to hazardous materials and public health and safety risks would be minimized due to compliance with federal, state, and local regulatory requirements.

Cumulative Projects would also be subject to federal, state, and local regulations related to hazardous materials and other public health and safety issues the same as the proposed Project. Adherence to these regulatory requirements would reduce incremental impacts associated with public exposure to health and safety hazards in each of the affected Project areas. Additionally, most hazardous material and safety-related risks are localized, generally affecting a specific site and immediate surrounding area, thus minimizing the potential for an impact to combine with another Project to create a cumulative scen ario. Additionally, implementation of MM-HAZ-1 through MM-HAZ-3 would ensure that Project-related activities would not result in significant impacts; therefore, the proposed Project would not contribute to a cumulatively considerable environmental impact related to hazards and hazardous materials.

2.2.3.2 Mitigation Measures
MM-HAZ-1 Prior to the issuance of a demolition permit, the Project applicant/developer or their designated contractor shall ensure that the demolition contractor’s contract incorporate abatement procedures for the removal of materials containing asbestos, as identified in previous surveys, and identification and removal of polychlorinated bi phenyls, hazardous material, hazardous wastes, and universal waste items. All abatement work shall be done in accordance with federal, state, and local regulations, including those of the U.S. Environmental Protection Agency (which regulates disposal), Occupational Safety and Health Administration, U.S. Department of Housing and Urban Development, California Occupational Safety and Health Administration (which regulates employee exposure), and the South Coast Air Quality Management District. Confirmation of adequate removal of such materials shall be provided to the City prior to the issuance of a building permit.

MM-HAZ-2 Prior to the issuance of a grading permit, the Project applicant/developer or their designated contractor shall prepare a soil management plan (SMP) that outlines the proper screening, handling, characterization, transportation, and disposal procedures for contaminated soils on site. The SMP shall include health and safety and training procedures for workers who may come in contact with contaminated soils. The health and safety procedu res shall also include periodic breathing zone monitoring and monitoring for VOCs using a handheld organic vapor analyzer and include required actions to be taken if concentrations of VOCs exceed applicable screening levels for health and safety of onsite workers. The SMP will be based on the findings of the Soil and Soil Vapor Investigation prepared for the Project, will outline areas of known or suspected soil contamination, and will be implemented by the applicant or their designated contractor for all confirmed and suspected contaminated soils which require excavation and offsite disposal. Contaminated soil shall be managed and disposed of in accordance with applicable federal, state, and local regulations.

MM-HAZ-3 Prior to the issuance of a grading permit, vapor mitigation design features shall be implemented in accordance with the Department of Toxic Substances Control (DTSC) Vapor Intrusion Mitigation Advisory for all future residential buildings and enclosed structures. Draft Supplemental Guidance issued by DTSC indicates long term mitigation may include subslab venting or depressurization systems with or without vapor barriers (subslab liners), and sewer VI mitigation such as venting, check

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11 valves, and sewer pipe linings. The construction contractor shall incorporate vapor mitigation design features into building plans that reduce potential vapor intrusion in buildings and enclosed structures on the Project site below DTSC Screening Levels. Vapor mitigation systems may be passive or active in nature, so long as they are designed to prevent vapor contamination on the Project site in accordance with applicable DTSC regulations at the time the systems are designed. Vapor mitigation systems shall be designed, built, installed, operated, and maintained in conformance with standard geologic, engineering, and construction princi ples and practices by appropriately licensed professionals and shall be reviewed and approved by the permitting agency(ies) (City of Arcadia, County of Los Angeles) prior to construction and prior to issuance of certificate of occupancy.

Operation of the Project shall maintain functional ity of these features as required to continue protection from vapor intrusion. Following completion of construction and occupancy of the buildings, indoor air monitoring will occur semiannually for one year to verify implemented measures are functioning properly and adequately mitigating vapor intrusion to below residential DTSC Screening Levels. Results shall be submitted to the City of Arcadia for confirmation of the adequacy of the designed systems. If indoor air samples reveal vapor intrusion occurring at levels above applicable DTSC Screening Levels, modifications shall be made, as necessary, to the designed system to improve the efficacy in reducing vapor intrusion to below applicable screening levels.

2.2.3.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse impacts were developed for the potentially significant impacts described in Section 2.3.4.1. These feasible measures, MM-HAZ-1, MM-HAZ-2, and MM-HAZ-3 are listed in Section 2.2.3.2.

The City finds that these mitigation measures are feasib le, are adopted, and will reduce the Project’s potential impacts related to hazards and hazardous materials to less than significant levels. Accordingly, the City finds that, pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in or incorporated into the Project that will mi tigate or avoid potentially significant impacts related to hazards and hazardous materials.

2.2.3.4 Facts in Support of the Findings Related to Hazards and Hazardous Materials The abatement of hazardous materials identified on the Project site would remove the potential for exposure of the public and the environment to accidental release of hazardous materials, as required by MM-HAZ-1. Construction and demolition activities would be completed in accordance with the Soils Management Plan, as required by MM-HAZ- 2, and vapor mitigation design features will be implemented in accordance with the DTSC Vapor Intrusion Mitigation Advisory for all future residential buildings an d enclosed structures, required by MM-HAZ-3. Therefore, impacts related to routine transport, use or disposal of hazardous materials and foreseeable upset and accident conditions involving a release of hazardous materials to the environment would be mitigated to a less-than- significant level. All other impacts would be less than significant. There would be no significant, unavoidable impacts related to hazards and hazardous materials after implementation of these mitigation measures.

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12 2.2.4 Transportation

2.2.4.1 Potentially Significant Impacts to Transportation Inadequate Emergency Access.

Construction

Short-Term Site Access

Short-term adverse traffic and parking impacts could occur in the Project vicinity during construction of the Project.

Additional trips generated by the truck deliveries and construction employees could affect traffic flow in the study area; construction activity could impact traffic near the Project site; and pedestrian traffic flow near the Project site could also be altered as a result of construction.

x Although the influx of equipment and materials to the Project site could create temporary adverse effects to the adjacent roadway, potential impacts associated with construction of the Project would be limited to those locations immediately adjacent to the Project site. Pedestrian access to the existing office buildings and bank uses on the Project site would be open, although temporary sidewalk closures around the portions of the Project site may be required in specific locations for limited time periods. To ensure adequate safeguards for pedestrian, bicycle and vehicular circulation and emergency vehicle access during short- term construction activities, Mitigation Measure (MM- ) TRA-1 is required. MM-TRA-1 requires preparation of a Construction Traffic Control Plan to address pedestrian, bicycle, and vehicular circulation during construction activities. Implementation of MM-TRA-1 would reduce potential impacts related to emergency access to less than significant.

2.2.4.2 Mitigation Measures
MM-TRA-1 Prior to the issuance of demolition or grading permits, the Project applicant/developer shall develop and implement a City-approved Construction Traffic Control Plan. The Plan shall be prepared in accordance with applicable City guidelines and shall address the potential for construction-related vehicular traffic, as well as pedestrian and bicycle circulation disruption in the public right-of-way. The Plan shall describe safe detours and shall include protocols for implementing the following: temporary traffic controls (e.g., a flag person during heavy truck traffic for soil export) to maintain smooth pedestrian and traffic flow; dedicated on-site turn lanes for construction trucks and equipment leaving the site ; scheduling of peak construction truck traffic that affects traffic flow on the arterial system to off-peak hours; consolidation of truck deliveries; and/or rerouting of construction trucks away from congested streets or sensitive receptors.

2.2.4.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), a feasible measure that can minimize significant adverse impacts was developed for the potentially significant impacts described in Section 2.2.4.1. This feasible measure, MM-TRA-1, is listed in Section 2.2.4.2.

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13 The City finds that this mitigation measure is feasible, is adopted, and will reduce the potential transportation- related impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1 ), changes or alterations have been required in or incorporated into the Project that will mitigate or avoid potentially significant impacts related to transportation.

2.2.4.4 Facts in Support of the Findings Related to Transportation With incorporation of MM-TRA-1, potential significant impacts related to short-term access to the Project site would be reduced to less than significant. All other potential environmental impacts to Transportation would be less than significant. There would be no significant, unavoidable im pacts related to transportation after implementation of this mitigation measure.

2.2.5 Tribal Cultural Resources

2.2.5.1 Potentially Significant Impacts to Tribal Cultural Resources Register of Historical Resources and Public Resource Code Section 5024.1

Visual observation of the current condit ions within the proposed Project site indicate that all areas have been disturbed as a result of urban development. Neither the CHRIS records search nor the pedestrian survey was able to identify any archaeological resources within the Projec t site. Pursuant to California Assembly Bill (AB) 52 and Senate Bill (SB) 18, the City contacted the two NAHC Native American individuals and/or tribal organizations provided on August 13, 2021; the Gabrieleño Band of Mission Indians – Kizh Nation and the Gabrielino Tongva Tribe. No response was received from the Gabrielino Tongva Tribe.

Two consultation meetings were held between the City and the Gabrieleño Ba nd of Mission Indians - Kizh Nation (Kizh Nation) by way of conference calls on September 28, 2021, and November 17, 2021. The Kizh Nation expressed concerns regarding the potential for inadvertent finds of unknown TCRs during excavation activities for the Project. However, no specific TCRs were identified by the Kizh Nation within or surrounding the Project site. The Kizh Nation provided further information and documentation regarding the Project area, and expressed concerns that construction ground disturbance and excavation associated with the Project may result in the inadvertent discovery of and impacts to an unknown TCR buried within the Project site. They also stated their particular concern if excavation is proposed within native soils. The City determined that the documents provided by the Kizh Nation do not substantiate the presence of a specific, known TCR that could be determined significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Se ction 5024.1. Since no sufficient evidence was presented to determine that a known TCR exists within or near the Project site, no significance determination could be made based on importance to a California Native American tribe.

Consultation under AB 52 did not identify any specific, known TCRs within the Project site. However, because the proposed Project would involve excavations to a depth of up to 26 feet below ground surface, Project construction would involve some disturbance to native soils whether intact or previously disturbed. While no known archaeological and/or TCRs are located on the Project site, there remains some potential for a previously undiscovered resource to be encountered during excavation, particularly within native soils. In consideration of the information provided by the Kizh Nation during tribal co nsultation and in an abundance of caution, mitigation measures MM-TCR-1 through MM-TCR-3 have been incorporated to ensure anticipatory measures are taken in the event that unknown TCRs are inadvertently encountered du ring Project construction-related earthwork activities.

Therefore, impacts to TCRs would be less than significant with mitigation incorporated.

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MM-TCR-1 requires the project applicant to retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation (“Tribe” or “Kizh”)prior to the commencement of any “ground-disturbing activity” for the Project. Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers and retains all discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

MM-TCR- 2 requires compliance with Health and Safety Code Section 7050.5, in the event of any discoveries of human skeletal material. MM-TCR-3 sets forth the procedure to follow in the event any human skeletal remains are unearthed and determined to be Native American.

Cumulative Effects

Cumulative impacts on tribal cultural resources consider whether impacts of the proposed Project together with other related projects identified within the vicinity of the Project site, when taken as a whole, substantially diminish the number of such resources within the same or similar context or property type. There are no known tribal cultural resources on the Project site and the area is considered to be of low potential to contain unanticipated cultural or tribal cultural resources. No archaeological resources have been documented by the SCCIC within the Project site or a surrounding 0.5-mile records search area.

O t h e r i n d i v i d u a l r e l a t e d p r o j e c t s o c c u r r i n g i n t h e v i c i n i t y o f t h e P r o j e c t s i t e w o u l d a l s o b e s u b j e c t t o t h e s a m e requirements of CEQA as the proposed Project and any impacts to tribal cultural resources would be mitigated, as applicable. These determinations would be made on a case-by-case basis, and the effects of cumulative development on historical and archaeological resources would be mitigated to the extent feasible in accordance with CEQA and other applicable legal requirements. Therefore, impacts on TCRs would not be cumulatively considerable with mitigation incorporated as MM-TCR-1, MM-TCR-2, and MM-TCR-3.

2.2.5.2 Mitigation Measures
MM-TCR-1 The project applicant shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation (“Tribe” or “Kizh”). The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground- disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. “Ground- disturbing activity” refers to ground disturbance occurring from 1 foot above native soils and below, and it does not include movement of sediments after they have been initially disturbed or displaced by current Project-related construction.

A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground- disturbing activities, the type of construction ac tivities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, Alexan Mixed-Use Development Project Final EIR 11663.03

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15 including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

On-site tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant or lead agency that all ground- disturbing activities as defined above and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant or lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh TCRs.

Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers and retains all discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. The Tribe shall have up to 48 hours to recover and retain any discovered Kizh TCRs, after which time construction activities in the immediate vicinity of the discovery may continue.

MM-TCR-2 Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.

In accordance with Health and Safety Code Section 7050.5, any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

Consistent with California Public Resources Code section 5097.98(d)(2), any items associated with the human remains that are placed or buried with the Native American human remains are to be treated in the same manner as the remains, but do not by themselves constitute human remains.

Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

MM-TCR-3 If the Tribe is designated by the Native American Heritage Commission (“NAHC”) as the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the pre paration of the soil for burial, the burial of

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16 funerary objects with the deceased, and the ceremonial burning of human remains. Accordingly, if the Tribe is designated as the MLD for discovered human remains, the prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the event preservation in place is not possible despite good faith efforts by the project applicant/developer and/or landowner, before ground-disturbing activities may resume on the project site, the landowner shall arrange a designated site locati on within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possib le. These items should be retained and reburied within six months of recovery. Where the Tribe is designated as the MLD, the site of reburial/ repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) de tailed descriptive notes and sketches. All data recovery and data recovery-related forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

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17 2.2.5.3 Findings per CEQA Guidelines
Consistent with CEQA Guidelines Section 15126.4(a)(1), feasible measures that can minimize significant adverse impacts were developed for the potentially significant impacts described in Section 2.2.5.1. These feasible measures, MM-TCR-1, as well as MM-TCR-2 and MM-TCR-3, are listed in Section 2.2.5.2.

The City finds that these mitigation measures are feasible, are adopted, and will reduce the potential tribal cultural resource impacts of the Project to less than significant levels. Accordingly, the City finds that, pursuant to CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1 ), changes or alterations have been required in or incorporated into the Project that will mitigate or avoid potentially significant impacts on tribal cultural resources.

2.2.5.4 Facts in Support of the Findings Related to Tribal Cultural Resources The implementation of MM-TCR-1, MM-TCR-2, and MM-TCR-3 would reduce potential impacts to tribal resources to less-than-significant levels. There would be no significant, unavoidable impacts related to tribal cultural resources after implementation of these mitigation measures.

2.3 Impacts Determined to Be Less Than Significant
Based on the analysis contained in the EIR, the following issue areas have been determined to fall within the “less- than-significant impact” category for all thresholds: Aest hetics, Agriculture and Forestry Resources, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use, Mineral Resources, Population and Housing, Public Services and Recreation, Transportation, Ut ilities and Service Systems, and Wildfire.

Other impacts for Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Transportation, and Tribal Cultural Resources not addressed below are addressed in Section 2.2.

2.3.1 Aesthetics
Scenic Vistas

The Project site is currently developed and located within a highly urbanized, relatively flat portion of the City, as such, immediate views of and from adjacent and nearby parcels are not particularly scenic. The County of Los Angeles General Plan does not identify any officially designated scenic vistas (County of Los Angeles 2014).

Likewise, the City’s General Plan does not identify any offi cially designated scenic vistas within City boundaries, although they do indicate that unobstructed views of the historic Santa Anita Park Racetrack and the San Gabriel Mountains are particularly important to the City’s aesthetic character and should be favored for preservation (City of Arcadia 2010). The proposed Project would result in visual changes on the Project site due to increased intensity of use; however, these changes would not adversely affect a scenic vista. Due to the urban, developed character of the existing viewshed, the presence and proximity of existing developments, and existing topography in the area, the proposed Project would not have a substantial adverse impact to existing scenic vistas, designated or otherwise.

The proposed Project is also located within a Transit Priority Area (TPA) and, as such, the proposed Project’s impacts on aesthetics would not be considered significant impa cts pursuant to PRC Section 21099(d). The Project would have no impact on any scenic views. No mitigation is required.

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Scenic Resource Damage within a State Scenic Highway

The proposed Project is not within the immediate vicinity of a state designated scenic highway. According to Caltrans, the County of Los Angeles has two officially de signated state scenic highways and 11 eligible scenic highways (Caltrans 2019). Route 2 and Route 27, the County of Los Angeles’s two designated scenic highways, are 9 miles northwest and 30 miles west of the Project site, re spectively. Caltrans classifies the I-210 as an Eligible State Scenic Highway, but not officially designated, where it traverses the City (Caltrans 2019), and portions of the highway are visible to the north and northeast from the upper floors of the existing 8-story office building. Likewise, the existing office building located on the Project site is visible from portions of the highway. However, because the I-210 has not been officially designated, this review is not obligated to consider any impacts to scenic resources within its viewshed, significant or otherwise. The proposed Project is within a TPA and, as such, the proposed Project’s impacts on aesthetics would not be considered significant impacts pursuant to PRC Section 21099(d).

The Project would have no impact on any scenic resources within a state scenic highway. No mitigation is required.

Regulations Governing Scenic Quality

California Public Resources Code Section 21071 defines an “urbanized area” as “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.” As further discussed in Section 4.11, Population and Housing, there were an estimated 56,681 residents in the City in 2020 (U.S. Census Bureau 2021). The Southern California Association of Governments (SCAG) forecasts 62,200 residents in the City by 2045 (SCAG 2020a). However, the City is adjacent to the City of Pasadena to the west. The combined population of the City of Arcadia and Pasadena is well over 100,000 persons.
1 Therefore, the following analysis considers whether the proposed Project would conflict with applicable zoning or other regulations governing scenic quality.

The City has adopted an update to the Design Guidelines for various development types, which was finalized in October 2019. The Commercial and Mixed-Use Design Guidelines provide direction to project applicants about site planning and building placement; public and private open spaces; pedestrian and vehicular access; and massing and scale. Other topics addressed include guidelines related to architectural style, awnings, rooflines, articulation, windows/doors, colors/materials, landscaping, equipment and service areas, site furnishing, lighting, and public art. The guidelines are intended as a reference point for a common understanding of the minimum qualitative design expectations within the City.

The Project site is located within the H Special Height Overlay Zone, specifically within the Zone H8 height district, which allows for a maximum development height of 96 feet. The seven-story structure would be constructed to 80 feet in height. As previously noted, the existing eight-story office building located on the west end of the Project site would remain intact. At a maximum height of seven stories, the proposed Project building would not exceed the height of the existing adjacent office building and is therefore consistent with existing structures in regard to building height. As noted above, the Project is also subject to Massing and Scale guidance included in the 2019 Commercial and Mixed-Use Design Guidelines document.

The Project includes a Paseo corridor area that would include new paving, lighting, trees, and plantings in order to provide an enhanced pedestrian experience that would link the existing buildings together with the new proposed Project building. The second Corridor Alleyway is an existing alley for vehicular travel, but the Project would provide

1 The U.S. Census Bureau estimated that the residential population of Pasadena in 2019 was 141,029, resulting in a combined population of 198,968 (using 2019 population estimates) (U.S. Census 2021).

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for pedestrian connectivity through the alley as well as signage for wayfinding and screen plantings or other artistic vertical screens at the parking garage. The third area includes street trees and new parkway plantings, as well as seating along Wheeler Avenue and Santa Clara Street. Lastly, the fourth, fifth, and sixth areas include the recreational amenities for the residents.

The Project proposes landscaping throughout the exterior ground level, the Level 3 north and south courtyards (further illustrated in Figure 3-3c, Level-3 and Levels-4/5/6), as well as the Level 7 roof deck. The landscape plan would include the planting of approximately 56 new ornamental trees with low to medium water requirements (including cork oak, yew pine, California sycamore, and Australian willow), approximately 7,848 square feet (sf) of shrubs and ground cover with low to medium water requirements (including various species of manzanita, Turkish sage, yellow yucca, and autumn moor grass), and the installation of approximately 2,015 sf of artificial turf.

The proposed Project would be consistent with the City’s General Plan policies, Development Code, and Municipal Code Sections that pertain to the preservation of the aesthetic character of the City. The proposed Project would be in visual agreement with the land uses of the surrounding area and consistent with the City’s land use and zoning designations.

Furthermore, when compared to existing conditions, the proposed Project design would add architectural and landscape features that would improve the visual quality of the Project site and the surrounding Project area. The proposed Project’s exterior aesthetic qualities include an updated mid-century modern look with clean lines, the integration of neutral colors and building materials, and a cohesive design scheme throughout the Project site. Finally, the proposed Project is within a TPA and, as such, the proposed Project’s impacts on aesthetics would not be considered significant impacts pursuant to PRC Section 21099(d). For these reasons, the proposed Project would not conflict with applicable zoning and/or other regulations governing scenic quality, and impacts would be less than significant.

Lighting and Glare

Lighting is of most concern when it ma y spill over or trespass from a Project site onto sensitive surrounding land uses, such as residential properties, resulting in a potential nuisance. The proposed Project is located within the Downtown area and is surrounded by existing mixed us e and/or commercial development. Existing sources of daytime and nighttime light include streetlights, business identification signs and lit windows from commercial and mixed-use residential developments. Given the urban nature of the site vicinity and existing sources of interior and exterior lighting and glare, any incremental increases from the proposed Project would be less than significant. Any lighting that would be implemented as part of the proposed Project would adhere to the City’s Development Code, Section 9103.01.120, which establishes the standards for exterior lighting in the City. In summary, the standards r e q u i r e : l i g h t i n g b e s h i e l d e d o r r e c e s s e d s o t h a t g l a r e i s c o n t a i n e d w i t h i n t h e p r o p e r t y b o u n d a r i e s ; l i g h t i n g b e directed downward away from adjoining properties; lighting must be appropriate in scale, intensity, and height; lighting cannot be blinking/flashing or have high-intensity brightness; and fixtures must be full-cutoff fixtures to avoid glare and up-light.

Similarly, extraneous glare associated with the use of highly reflective building materials (glass, steel, etc.) could result in nuisance to surrounding land uses. The proposed Project would include reflective building materials such as glass and steel; however, these materials would be utilized in a manner consistent with Development Code Section 9103.10.070, which requires that any proposed land use or activity producing glare be shielded so that glare is not perceptible beyond the property line. Additionally, the proposed Project is within a TPA and, therefore, the proposed Project’s impacts on aesthetics would not be considered significant impacts pursuant to PRC Section 21099(d). As such, and in compliance with City regulations, the proposed Project would have a less than significant impact regarding the creation of a new source of substantial light or glare, which would adversely affect day or nighttime views in the area. For these reasons, the proposed Project would not result in significant impacts related to adverse effects on day or nighttime views, and impacts would be less than significant.

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Cumulative Effects

Scenic Vistas/Scenic Quality

Despite being heavily built out, there are a number of scenic resources in the broader San Gabriel Valley as well as in the City itself, including mountains, foothills, ridgelines, parks, open spaces, and sports venues such as the local public golf courses and the historic Santa Anita Racetrack. The City General Plan cites unobstructed views of the Racetrack and the San Gabriel Mountains as important contributors to its aesthetic character (City of Arcadia 2010).

However, due to the existing urban, developed character of the City, the proposed Project site, and surrounding Project site area, as well as the specific design proto cols (Commercial and Mixed-Use Design Guidelines, 2019) applicable to the proposed Project, the Project would not have a substantial adverse effect on existing scenic views of the San Gabriel Mountains. The proposed Project site cannot be viewed from the Santa Anita Park Racetrack, nor can the racetrack be viewed from the Project site, and modest views of and from the northeast corner Arcadia County Park would not be further degraded due to existing obstructions form mature trees and other urban, commercial, and mixed-use development.

Due to the built-out nature of the City, cumulative projects within the surrounding Project area would be considered infill development. As these projects are implemented, a more dense and urban character would occur within the Downtown Core and broader Downtown area. Land use in tensification at these sites would not substantially degrade the scenic quality of the viewshed. Further, th ese projects would be required to comply with the development standards of the City Arcadia Development Code that include setbacks and height limits and may similarly be subject to the City’s Site Plan and Design Review.

The proposed Project would be consistent with applicable City goals and policies concerning scenic quality, and similar to the Project, future projects in the cumulative study area would be required to demonstrate compliance with applicable scenic quality regulations. If non-compliance with a particular regulation would result in a significant impact, mitigation would be required to reduce impacts to the extent feasible. Therefore, impacts would be less than significant, and the Project would not result in a cumu latively considerable impact related to scenic vistas or conflicts with scenic quality regulations. No mitigation is required.

Light or Glare

The existing urbanized Project setting supports numerous nighttime lighting sources and contains buildings and facilities constructed of potentially reflective materials, including metal paneling and glass. The Project would have the potential to result in an incremental increase in light associated with the new development. However, the surrounding area is largely developed in nature and located in an urban environment. Thus, it currently includes sources of interior and exterior lighting and glare, and any incremental increases from the proposed Project would be less than significant. In addition, any lighting that would be implemented as part of the proposed Project and cumulative projects would adhere to the City’s Development Code, Section 9103.01.120, In summary, due to the existing urban conditions, and the less than significant impacts of the proposed Project, it would not result in a cumulatively considerable impact related to light and glare. No mitigation is required.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on aesthetics as it relates to scenic vistas, scenic resource damage within a state scenic highway, regulations governing scenic quality, lighting and glare, and cumulative aesthetic impacts; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

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2.4.2 Agriculture and Forestry Resources
The Project site is located in an urban area on a site that is fully developed with buildings and asphalt paving and is designated Downtown Mixed Use (DMU) in the City’s General Plan and is also zoned DMU. There are no existing agriculture or forestry activities on the site. No readily available opportunities for agricultural or forestry operations exist on site or in the surrounding area. According to the California Department of Conservation’s California Important Farmland Finder, most of Los Angeles County, including the City of Arcadia, is not mapped as part of the state’s Farmland Mapping and Monitoring Program; thus, the Project site does not contain Prime Farmland, Unique Farmland, or Farmland of State Importance (collectively “Important Farmland”) (DOC 2020), nor does it contain any parcels under a Williamson Act contract (DOC 2018). Additionally, the Project site nor the surrounding area contain forestland or timberland. Therefore, impacts associated with agricultural and forestry resources would not occur.

Finding

Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to agriculture and forestry resources; therefore, agriculture and forestry resources was not addressed in the Draft EIR. No mitigation would be required and no significant, unavoidable adverse impacts would occur.

2.4.3 Air Quality
Conflict with or obstruct implementation of the applicable air quality plan

The Project site is located within the South Coast Air Basin (SCAB) under the jurisdiction of the Southern California Air Quality Management District (SCAQMD), which is the local agency responsible for administration and enforcement of air quality regulations for the area. The SCAQMD administers the Air Quality Management Plan (AQMP) for the SCAB, which is a comprehensive document outlining an air pollution control program for attaining all state and federal air quality standards. The most recent adopted AQMP is the 2016 AQMP (SCAQMD 2017), which the SCAQMD Governing Board adopted in March 2017 (SCAQMD 2017).

The purpose of a consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans, and, thus, if it would interfere with the region’s ability to comply with federal and state air quality standards. The SCAQMD has established criteria for determining consistency with the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3, in the SCAQMD CEQA Air Quality Handbook. The criteria are as follows (SCAQMD 1993):
x Consistency Criterion No. 1: The project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay the timely attainment of air quality standards of the interim emissions reductions specified in the AQMP. x Consistency Criterion No. 2: The project will not exceed the assumptions in the AQMP or increments based on the year of project buildout and phase.

Consistency Criterion No. 1

As discussed below, the proposed Project would not result in construction or operational criteria air pollutant emissions that would exceed the SCAQMD mass daily thresholds. Because it would not exceed the SCAQMD criteria air pollutant mass thresholds, the Project would not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, and thus, the proposed Project would not conflict with Consistency Criterion No. 1 of the SCAQMD CEQA Air Quality Handbook (SCAQMD 1993).

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Consistency Criterion No. 2

The second criterion regarding the proposed Project’s potential to exceed the assumptions in the AQMP is primarily assessed by determining consistency between the proposed Project’s land use designations and potential to generate population growth. In general, a project would be consistent with, and would not conflict with or obstruct implementation of, the AQMP if the growth in socioeconomic factors is consistent with the underlying regional plans used to develop the AQMP (per Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook). The SCAQMD primarily uses demographic growth forecasts for various socioeconomic categories (e.g., population, housing, employment by industry) developed by the Southern California Association of Governments (SCAG) for its RTP/SCS (SCAG 2016). SCAG bases its growth forecasts on general plans for cities and counties in the SCAB. The SCAQMD uses these growth forecasts for the development of the AQMP emissions inventory (SCAQMD 2017). The SCAG 2016 RTP/SCS, and associated Regional Growth Forecast, are generally consistent with the local plans; therefore, the 2016 AQMP is generally consistent with local government plans. Note that although the Connect SoCal (2020–2045 RTP/SCS) is the most recent RTP/SCS, the SCAQMD is still in the early stages of updating its AQMP (anticipated to be released in 2022). Therefore, the SCAG 2016 RTP/SCS and associated Regional Growth Forecast would be applicable in this analysis of the potential to conflict with the SCAQMD 2016 AQMP.

The City’s General Plan identifies the site as Downtown Mixed Use. According to the City’s General Plan, the Downtown Mixed-Use designation permits service and retail uses, commercial businesses, professional offices, and residential uses within the City’s downtown. Therefore, th e proposed Project is consistent with the General Plan land use designation for the Project site. The proposed Project would be consistent with downtown land uses and would be in compliance with the Land Use Element goals and policies of the City’s General Plan. The zoning for the Project site is also Downtown Mixed Use, which permits the same use types as the Downtown Mixed Use land use designation. As such, the proposed Project would be consistent with the current zoning and land use designation.

Accordingly, the project would meet Consistency Criter ion No. 2 of the SCAQMD CEQA Air Quality Handbook.

Therefore, implementation of the project would not result in a conflict with, or obstruct implementation of, the applicable air quality plan (i.e., the 2016 AQMP).

The proposed Project would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or conflict with Consistency Criterion No. 1. In addition, implementation of the project would not exceed the demographic growth forecasts in the SCAG 2016 RTP/SCS; therefore, the project would also be consistent with the SCAQMD 2016 AQMP, which based future emission estimates on the SCAG 2016 RTP/SCS. Thus, the project would not conflict with Consistency Criterion No. 2. The project would not exceed the SCAQMD significance thresholds during construction or operations; therefore, impacts related to the project’s potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant.

Cumulatively Considerable Net Increase of Criteria Pollutants

Construction Emissions

Construction of the proposed Project would result in the temporary addition of pollutants to the local airshed caused by on-site sources (e.g., off-road construction equipment, soil disturbance, and VOC off-gassing) and off-site sources (e.g., on-road haul trucks, vendor trucks, and wo rker vehicle trips). Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions.

Criteria air pollutant emissions associated with temporar y construction activity were quantified using CalEEMod.

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with each phase and reported as the maximum daily emissions estimated during the construction period spanning 2023 through 2025. Construction schedule assumptions, including phase type, duration, and sequencing, were based on information provided by the applicant and CalE EMod default values, and is intended to represent a reasonable scenario based on the best information available.

Implementation of the proposed Project would generate air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM 10 and PM2.5 emissions. The proposed Project would be required to comply with SCAQMD Rule 403 to control dust emissions generated during the grading activities. Standa rd construction practices that would be employed to reduce fugitive dust emissions include watering of the active sites two times per day depending on weather conditions. Internal combustion engines used by construction equipment, vendor trucks (i.e., delivery trucks), and worker vehicles would result in emissions of VOCs, NO
x, CO, PM 10, and PM 2.5. The application of architectural coatings, such as exterior application/interior paint and other finishes, and application of asphalt pavement would also produce VOC emissions.

I n c o m p l i a n c e w i t h S C A Q M D r u l e s , d a i l y c o n s t r u c t i o n e m i s s i o n s w o u l d n o t e x c e e d t h e S C A Q M D s i g n i f i c a n c e thresholds for VOC, NO
x, CO, SO x, PM 10, or PM 2.5 during construction in all construction years. Construction- generated emissions would be temporary and would not represent a long-term source of criteria air pollutant emissions. As such, impacts would be less than significant.

Operational Emissions

Operation of the proposed Project would generate VOC, NO x, CO, SO x, PM10, and PM 2.5 emissions from mobile sources, including vehicle trips; area sources, includin g the use of consumer products, natural gas hearths, and landscape maintenance equipment; and energy sources. As discussed in Section 4.2.4, pollutant emissions associated with long-term operations were quantified using CalEEMod. Project-generated mobile source emissions were estimated in CalEEMod based on Project-specific trip rates. CalEEMod default values generated from Project- specific land use quantities were used to estimate emissions from area and energy sources for the proposed Project and the existing operational land uses that will cease operation and for which the facilities will be demolished as part of the proposed Project.

The Project’s net combined daily area, energy, mobile, vehicle testing, and off-road emissions would not exceed the SCAQMD operational thresholds for VOC, NOx, CO, SOx, PM10, and PM2.5. Impacts associated with Project-generated operational criteria air pollutant emissions would be less than significant.

A i r p o l l u t a n t e m i s s i o n s a s s o c i a t e d w i t h c o n s t r u c t i o n a c t i v i t y o f f u t u r e p r o j e c t s w o u l d b e r e d u c e d t h r o u g h implementation of control measures required by the SCAQMD. Cumulative PM 10 and PM2.5 emissions would be reduced because all future projects would be subject to SCAQMD Rule 403 (Fugitive Dust), which sets forth general and specific requirements for all construction sites in the SCAQMD. The maximum daily PM10 and PM2.5 emissions would not exceed the significance thresholds during proposed Project construction activities. Fugitive dust, as well as vehicle and equipment exhaust, generated during Project construction would contribute to the SCAB’s nonattainment designation for PM10 and PM2.5; however, this contribution would not be considered cumulatively considerable.

With regard to operational cumulative impacts associated with nonattainment pollutants, in general, if a project is consistent with the community and/or general plans, it has been accounted for in the attainment demonstration

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24 contained within the state implementation plan and would therefore not cause a cumulatively significant impact on the ambient air quality. As addressed above, the proposed Project would be consistent with the growth projections anticipated in SCAQMD’s 2016 AQMP. Accordingly, the proposed Project would not result in a cumulatively considerable contribution to the nonattainment pollutants in the SCAB.

Based on the preceding considerations, the proposed Project would not result in a cumulatively considerable increase in emissions of nonattainment pollutants, and impacts would be less than significant during construction and operation.

Expose Sensitive Receptors to Substantial Pollutant Concentrations

Localized Significance Threshold

Sensitive receptors are those individuals more susceptible to the effects of air pollution than the population at large. People most likely to be affected by air pollution include children, the elderly, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD, sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes (SCAQMD 1993).

The closest off-site sensitive receptors to the proposed Project are single-family residences approximately 900 feet to the west and 650 to the south, as well as schools including: Excelsior School (41 West Santa Clara Street, Arcadia, CA 91007) approximately 630 feet to the west and Arroyo Pacific Academy (325 North Santa Anita Avenue, Arcadia, CA 91006) located approximately 655 feet to the
north.

Construction activities associated with the proposed Proj ect would result in temporary sources of on-site fugitive dust and construction equipment emissions. To account fo r onsite operation of vendor trucks, haul trucks, and worker vehicle trips a distance of 1,000 feet of on-site vehicle operation was included in the localized significance threshold (LST) analysis. Based on the LST construction ac tivities would not generate emissions in excess of site- specific LSTs; therefore, site-specific impacts during construction and operation of the proposed Project would be less than significant.

Carbon Monoxide Hotspots

CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would be at least over 100,000 vehicles per day. Because the Project would generate a net increase in 909 residents, it is not anticipated to increase daily traffic volumes at any study intersection to more than 100,000 vehicles per day. The proposed Project would be considered growth-accommodating rather than growth-inducing in that the proposed Project’s 319 new residential units would accommodate 909 residents, which are anticipated to be a mix of current and future residents to the City. If all 909 residents would be new to the City, the Project would be within the overall population growth projections included in SCAG’s Connect SoCal. In addition, the entire Project would be screened from a project-level vehicle miles trav eled (VMT) analysis because the Project is in a Low VMT generating area within a TPA. Therefore, a VMT analysis is not required and impacts to VMT can be presumed to be less than significant. For these reasons, a CO hotspot is not anticipated to occur and associated impacts would be less than significant. In addition, due to continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily decreasing. Based on these considerations, the proposed Project would result in a less-than-significant impact to air quality with regard to potential CO hotspots

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25 Health Impacts of Other Criteria Air Pollutants

Construction and operation of the proposed Project would result in emissions that would not exceed the SCAQMD thresholds for any criteria air pollutants, including NO x, CO, SOx, PM10, or PM2.5. Project-generated VOC emissions during short-term construction would result in the exceedances of the SCAQMD threshold but compliance with SCAQMD Rule 1113 would restrict the VOC content of coatings for construction applications.

VOCs and NOx are precursors to O3, for which SCAB is designated as nonattainment with respect to the NAAQS and CAAQS. The health effects associated with O3 are generally associated with reduced lung function. The contribution of VOCs and NOx to regional ambient O3 concentrations is the result of complex photochemistry. The increases in O3 concentrations in SCAB due to O3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O 3 concentrations would also depend on the time of year that the VOC emissions would occur because exceedances of the O
3 ambient air quality standards tend to occur April through October when solar radiation is highest. The holistic effect of a single project’s emissions of O3 precursors is speculative due to the lack of quantitative methods to assess this impact. Nonetheless, the VOC and NOx emissions associated with Project construction and operation could minimally contribute to regional O3 concentrations and the associated health impacts. Because of the minimal contribution during construction and operation, health impacts would be considered less than significant.

Construction and operation of the proposed Project would also not exceed thresholds for PM10 or PM2.5 and would not contribute to exceedances of the NAAQS and CAAQS for particulate matter or would obstruct SCAB from coming into attainment for these pollutants. The proposed Project would also not result in substantial DPM emissions during construction and operation, and therefore would not result in significant health effects related to DPM exposure.

Additionally, the proposed Project would be required to comply with SCAQMD Rule 403, which limits the amount of fugitive dust generated during construction. Due to the minimal contribution of particulate matter during construction and operation, health impacts would be considered less than significant.

Construction and operation of the proposed Project would not contribute to exceedances of the NAAQS and CAAQS for NO2. Health impacts that result from NO2 and NOx include respiratory irritation, which could be experienced by nearby receptors during the periods of heaviest use of off-road construction equipment. However, Project construction would be relatively short term, and off-road construction equipment would be operating at various portions of the site and would not be concentrated in one portion of the site at any one time. In addition, existing NO2 concentrations in the area are well below the NAAQS and CAAQS standards. Construction and operation of the proposed Project would not create substantial, localized NO x impacts. Therefore, potential health impacts associated with NO2 and NOx would be less than significant.

CO tends to be a localized impact associated with congested intersections. The associated potential for CO hotspots was discussed previously and is determined to be a less than significant impact. Thus, the proposed Project’s CO emissions would not contribute to significant health effects associated with this pollutant.

In summary, construction and operation of the proposed Project would not result in exceedances of the SCAQMD significance thresholds for criteria pollutants and potent ial health impacts associated with criteria air pollutants would be less than significant.

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26 Health Impacts of Toxic Air Contaminants

P r o j e c t c o n s t r u c t i o n a c t i v i t i e s w o u l d r e s u l t i n a R e s i d e n t i a l M a x i m u m I n d i v i d u a l C a n c e r R i s k o f 9 . 5 2 i n 1 million, which is less than the significance threshold of 1 0 i n 1 m i l l i o n . P r o j e c t c o n s t r u c t i o n w o u l d r e s u l t i n a Residential Chronic Hazard Index of 0.005, which is be low the 1.0 significance threshold. Impacts would be less than significant.

Other Emissions

Construction Impacts

Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the p r o p o s e d P r o j e c t . P o t e n t i a l o d o r s p r o d u c e d d u r i n g c o n s t r u c t i o n w o u l d b e a t t r i b u t a b l e t o c o n c e n t r a t i o n s o f unburned hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt pavement application. Such odors would disperse rapidly from the Project site and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impa cts associated with odors during construction would be less than significant.

Operational Impacts

Land uses and industrial operations that typically are associated with odor complaints include agricultural uses, wastewater treatment plants, food-processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding facilities (SCAQMD 1993). The propos ed Project does not propose the aforementioned odor- generating land uses during the operational phase of the proposed Project. Furthermore, the proposed Project would comply with SCAQMD Rule 402, Nuisance, which prohibits the release of odors which may cause annoyance to a considerable number of persons, as well as other SCAQMD rules related to odor generation from restaurant activities.

Therefore, the potential for the proposed Project to generate an odor impact is considered less than significant.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on air quality as it relates to criteria pollutants, sensitive receptors, and other emissions; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

2.3.4 Biological Resources
Under the existing conditions, the Project site is almost entirely developed with paved surfaces and buildings. A limited amount of landscaped areas is located within the Project site and along the public rights-of-way, consisting of small areas of ornamental trees, shrubs, and turf. This vegetation is ornamental in nature, entirely surrounded by urban development, and does not form a cohesive plant community that would provide quality suitable habitat for candidate, sensitive or special status wildlife species, or would support wildlife movement. No wetlands or other jurisdiction waters are within the Project site (USFWS 2020). Further, all development activities would be required to comply with all applicable requirements set forth by the City, including the City’s street tree regulations. All development activities are subject to the requirement to protect nesting birds, in compliance with the Migratory Bird Treaty Act, which prohibits the accidental or “incidental” taking or killing of migratory birds (USC 2021). Therefore, impacts associated with biological resources would not occur.

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27 Finding

Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to biological resources; therefore, biological resources were not addressed in the Draft EIR. No mitigation would be required, and no significant, unavoidable adverse impacts would occur.

2.4.5 Cultural Resources
Historical Resources

Three properties within the proposed Project site are developed with built environment resources over 45 years old and were identified as requiring recordation and evaluation for historical significance: 150 N Santa Anita Avenue (APN 5773-006-036), 31-33 Wheeler Avenue (APN 5773-006-005), and 25 Wheeler Avenue (APN 5773-006-004).

One property immediately adjacent to the Project site, 100 N Santa Anita Avenue (APN 5773-006-029), was identified as a built environment resource that is over 45 years old. This property was identified as requiring recordation and evaluation for historical significance.

NRHP/CRHR Statement of Significance

Criterion A/1: That are associated with events that have made a significant contribution to the broad patterns of our history.

Archival research indicated that the buildings under evaluation within or immediately adjacent to the Project site were constructed between 1959 and 1972, however, none of these buildings are associated with historical events that have made a significant contribution to the broad patterns of our history. The 150 North Santa Anita Avenue property seems to have been the culmination of years-long planning efforts to redevelop the portion of Santa Anita Avenue north of Huntington Drive’s downtown commercial corridor into Towne Center. Despite the long planning period, 150 N Santa Anita Avenue does not appear to have shaped the broader patterns of development of the City of Arcadia or had any effect on the development of the downtown commercial corridor, which was full developed by the 1950s. The 25 and 31-33 Wheeler Avenue properties appear related to the general trend of post-World War II commercial growth in Arcadia. While specific associations must be considered, research did not reveal any reason to believe the Wheeler Avenue properties’ specific associations with commercial growth were significant. In addition, while the 100 North Santa Anita Avenue property—adjacent to the Project site —was designed in a Tudor Revival style, association with a trend or style is not sufficient for historic significance. Therefore, the properties within and/or adjacent to the Project site do not appear eligible under NRHP Criterion A, CRHR Criterion 1, or City of Arcadia Historic Landmark Criterion 1.

Criterion B/2: That are associated with the lives of persons significant in our past.

To be found eligible under Criterion B/2, one or more of the properties must be directly tied to an important person and the place where that individual conducted or produced the work for which he or she is known. Archival research indicates that the 31-33 Wheeler Avenue was first owned by Thomas Cosentino, and subsequently by numerous owners and occupants for short periods. Archival research did not provide any evidence that Cosentino, subsequent occupants, or any person(s) associated any of the evaluated properties, were known to be historically important figures at the national, state, or local level. Due to a lack of identified significant associations with important persons in history, the properties under evaluation on and adjacent to the Project site do not appear eligible under NRHP Criterion B, CRHR Criterion 2, or City of Arcadia Historic Landmark Criterion 2.

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28 Criterion C/3: That embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction.

Considered as individual parts and as a whole, the evaluated properties on and adjacent to the Project site do not appear to be excellent examples of any of the styles represented, including Corporate Modern, Mid-Century Modern, and/or Tudor Revival, nor do these properties appear to be unique examples of a style or property type, period, or method of construction within Arcadia or to the su rrounding communities. No information about the named architects of 150 North Santa Anita Avenue, Fleming & Fryer of Newport Beach or William J. Fleming, was revealed to indicate the buildings are the work of master architects. Similar conclusions were reached about architects Jack Hale (31–33 Wheeler Avenue) and Willis K. Hutchison & Associates (100 North Satna Anita Avenue). No information about the architects or builders of 25 Wheeler Avenue were available from historical permits, newspapers or other methods of archival research. The buildings also do not possess high artistic value. In consideration of the final component of Criterion C/3, the properties do not appear to contribute to a potential historic district. There is no visual cohesion or shared development history due to varying construction dates, more recent development, or nearby development of a different character. Therefore, the properties under evaluation on and adjacent to the Project site do not appear eligible under NRHP Criterion C, CRHR Criterion 3, or City of Arcadia Historic Landmark Criterion 3.

Criterion D/4: That have yielded, or may be likely to yield, information important in prehistory or history.

The properties under evaluation on and adjacent to the Project site are not significant under Criterion D of the NRHP or Criterion 4 of the CRHR as a source, or likely source, of important historical information nor do they appear likely to yield important information about historic construction methods, materials, or technologies.

Integrity Discussion

To be eligible for listing in the National Register, properties must retain their physical integrity from the period in which they gained significance. In the case of architectura lly significant properties, the period of significance is normally the date of construction. For historically significant properties, the length of the historic associations usually measures the period of significance. As none of the evaluated properties are significant under any National Register criterion, they do not have a period of significance and the integrity of the buildings does not require examination. It is worth noting, however, that the properties do retain certain aspects of integrity, including location, design and feeling. The buildings have never moved from their original locations and have had very few alterations, notable changes or modifications to their original overall form, plan, space, structure, and style. They also appear to have retained much of their original materials, and for several buildings, the workmanship of the original builders is visible. To a certain extent, the buildings are still able to convey a sense of the time periods in which they were built. However, the buildings lack important historical associations and have experienced substantial changes to their setting over time as the area along Santa Anita Avenue underwent a modest infill and revitalization in the late 1990s through the 2000s, leading to the demolition of several surrounding commercial and industrial properties and replacing them with modern commercial retail stores or parking structures. In summary, the properties do not retain the requisite integrity for designation, and do not rise to the level of significance required for designation at the national, state, or local levels.

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29 Summary of Findings

No cultural resources were identified within or adjacent to the Project site as a result of the CHRIS records search, NAHC SLF search, extensive archival research, field survey, and property significance evaluation. Neither the 150 N Santa Anita Avenue (APN 5773-006-036), 31-33 Wheeler Avenue (APN 5773-006-005), or 25 Wheeler Avenue (APN 5773-006-004) Project site properties, nor the adjacent 100 North Santa Anita Avenue (APN 5773-006-029) property appear eligible for NRHP, CRHR, or City designation due to a lack of significant historical associations, architectural merit, and physical integrity. Therefore, the properties are not considered historical resources for the purposes of CEQA. Further, no potential indirect impacts to historical resources were identified. The Project would not cause a substantial adverse change in the significance of a historical resource, or otherwise result in a direct impact to a historical resource. No other adjacent resource s were identified as a result of the records search or survey that could be indirectly impacted by the proposed Project. Therefore, the Project would have a less-than- significant impact on historical resources. No mitigation is required.

Disturbance of Human Remains

No prehistoric or historic burials were identified within the Project site as a result of the CHRIS records search.

However, in the unexpected event that human remains are found, those remains would require proper treatment, in accordance with applicable laws. Procedures of conduct following the discovery of human remains on non-federal lands are mandated by California Health and Safety Code §7050.5, PRC §5097.98 and the California Code of Regulations (CCR) §15064.5(e). According to the provisions in CEQA, should human remains be encountered, all work in the immediate vicinity of the burial must cease, and any necessary steps to ensure the integrity of the immediate area must be taken. The Los Angeles County Coroner must then be immediately notified. The Coroner determines whether the remains are Native American. If the Coroner determines the remains are Native American, the Coroner has 24 hours to notify the NAHC, who will, in tu rn, notify the person they identify as the most likely descendent (MLD) of any human remains. Further actions are determined, in part, by the desires of the MLD. The MLD has 48 hours to make recommendations regarding the disposition of the remains following notification from the NAHC of the discovery. If the MLD does not make recommendations within 48 hours, the owner shall, with appropriate dignity, reinter the remains in an area of the property secure from further disturbance. Alternatively, if the owner does not accept the MLD’s recommendations, the owner or the descendent may request mediation by the NAHC. Compliance with these existing regulations would ensure that impacts to human remains resulting from the proposed Project would be less than significant. No mitigation is required.

Cumulative Effects

The CHRIS records search was completed by staff at the SCCIC on May 4, 2021. The records search identified seventeen (17) previously conducted cultural resources technical investigations within the records search area. Four of these previous investigations overlap the entirety of the proposed Project site and no cultural resources were identified within the proposed Project site as a result of the overlapping studies. Additionally, the SCCIC records indicate that sixty-three (63) previously recorded cultural resources were identified within the proposed Project’s 0.5-mile buffer. These resources include one historic-era archaeological site and sixty-two (62) historic built environment resources. None of these resources are within or adjacent to the proposed Project site. As there are no known historical or archaeological resources on the Project site, the Project site is not part of an existing or known grouping or district of historical or archaeological resources that would be impacted as part of the cumulative impacts of other projects.

The proposed Project was determined to have less-than-significant direct impacts on human remains. Existing regulations are adequate to address the potential for impacts due to the inadvertent discovery of human remains

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30 on the Project site. Other individual projects occurring in the vicinity of the Project site would also be subject to the same state requirements to contact appropriate agencies and coordinate with the County Coroner. Therefore, the proposed Project would not result in any cumulatively considerable impacts related to human remains.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on cultural resources as it relates to historical resources and disturbance of human remains, therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

2.3.6 Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy

Electricity
Construction
Temporary electric power for lighting, heating/cooling, and electronic equipment, such as computers inside temporary construction trailers, as well as lighting for co nstruction activities, would be required during short-term construction activities. The electricity demand at any given time would vary throughout the construction period based on the construction activities being performed and would cease upon completion of construction. When not in use, electric equipment would be powered off so as to avoid unnecessary energy consumption. All sources of electricity would be from existing power lines that serve the site and no new infrastructure would be required. There is nothing unusual about construction of the proposed Project that would result in a wasteful, inefficient, and unnecessary use of electrical energy. The electricity used for construction activities would be temporary and would have a negligible contribution to the proposed Project’s overall energy consumption. Impacts to electricity during construction would be less than significant, and no mitigation is required.

Operations

The operational phase would require electricity for multiple purposes including building heating and cooling, lighting, appliances, electronics, and water and wastewater conveyance. As discussed in Section 4.2 under Approach and Methodology (Operational Emissions), CalEEMod default values for electricity consumption for the proposed Project’s land uses were utilized which account for compliance with the 2019 Title 24 standards. The project includes 100-kW on-site solar system included in the CalEEMod analysis.

Buildout of the proposed Project is estimated to have a total electrical demand of 3,225,503kWh per year (or 3.32 million kWh per year) for proposed Project usage without netting out the existing land use electrical use. This estimate, therefore, is a conservative estimate of additional operational electricity demand because it does not reduce electricity estimates for buildings that will be demolished. The County’s annual electricity use was approximately 20 billion kWh in 2019.

Therefore, the proposed Project’s electrical consumption would be a small percentage (0.016%) of the County’s current annual use. Southern California Edison (SCE) forecasts that its total energy consumption in 2026 (the Project buildout year) will be approximately 120,000 gigawatt hours of electricity (CEC 2018). Based on the Project’s estimated electrical consumption of 3,225,503 kWh/year, the Project’s increase in electricity would account for approximately 0.0027% of SCE’s total projected consumption during 2026 for the Project’s buildout year. 2 2 Project’s consumption (3.226 gigawatt hours) divided by SCE’s projected consumption (120,000 gigawatt hours).

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31 In addition, the proposed Project would be built in accordance with the current Building Energy Efficiency Standards (Title 24) at the time of construction, which include robust requirements for energy efficiency. Also, the provisions of the CALGreen code apply to the planning, design, op eration, construction, use and occupancy of every newly constructed building or structure. In mixed occupancy buildings, such as the proposed Project, each portion of a building must comply with the specific green building measures applicable to each specific occupancy. The project would also include a 100-kW onsite solar system. Therefore, due to the inherent increase in efficiency of building code regulations, the proposed Project would not result in a wasteful, inefficient, or unnecessary use of energy.

Impacts related to operational electricity use would be less than significant.

Natural Gas
Construction
Natural gas is not anticipated to be required during construction of the proposed Project. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed below under the “petroleum” subsection. Any minor amounts of natural gas that may be consumed as a result of proposed Project construction would be substantially less than that required for proposed Project’s operation and would have a negligible contribution to the proposed Project’s overall energy consumption.

Operations

Natural gas consumption during proposed Project operation would be required for various purposes, including building heating and cooling. Default natural gas generation rates in CalEEMod for the proposed Project were utilized which acc ou nt f or c o mpli anc e w it h t he 2 0 19 Titl e 24 st a ndards. T he pr opo sed Proj ect w ould co ns u me ap proxi m atel y 4,614,782 kBTU per year without netting out the existing land use natural gas consumption. Therefore, the c o n s u m p t i o n e s t i m a t e i s c o n s e r v a t i v e b e c a u s e i t d o e s n o t a c c o u n t f o r b u i l d i n g s t h a t w o u l d b e d e m o l i s h e d . A s previously discussed, the County annual natural gas consumption is estimated to be 3 billion therms per year.

Therefore, the proposed Project’s estimated increase in natural gas consumption of 4,614,782 kBTU (or 46,148 therms) per year would be a small percentage (0.0015%) of SoCalGas’ annual supply to County customers. In addition, the proposed Project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Title 24, Part 11, contains energy measures that are applicable to the proposed Project. The proposed Project would be required to meet Title 24 requirements applicable at that time, as required by state regulations through the plan review process. Therefore, due to the inherent increase in efficiency of building code regulations, the proposed Project would not result in a wasteful, inefficient, or unnecessary use of natural gas. Impacts related to operational natural gas use would be less than significant.

Petroleum
Construction
Petroleum would be consumed throughout construction of the proposed Project. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction, and VMT associated with the transportation of construction materials and construction worker commutes would also result in petroleum consumption. Heavy-duty construction equipment associated with construction activities, vendor trucks, and haul trucks would rely on diesel fuel. Construction workers wo uld travel to and from the Project site throughout the duration of construction. It was assumed that construction workers would travel in gasoline-powered vehicles.

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32 Heavy-duty construction equipment of various types would be used during construction. CalEEMod was used to estimate construction equipment usage. Based on that analysis, diesel-fueled construction equipment would operate for an estimated 32,759 hours. Fuel consum ption from construction equipment was estimated by converting the total CO 2 emissions from each construction phase to gallons using conversion factors for CO 2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor for diesel is 10.21 kilograms per metric ton CO2 per gallon (The Climate Registry 2020).

The proposed Project is estimated to consume approximately 187,433 gallons of petroleum during the construction phase. For disclosure, by comparison, approximately 60 billion gallons of petroleum would be consumed in California over the course of the proposed Project’s construction phase (26 months), based on the California daily petroleum consumption estimate of approximately 75.6 million gallons per day (EIA 2021c). Thus, the total expected petroleum use from the proposed Project’s construction represents approximately 0.0003% of California’s consumption of petroleum over the construction duration. In accordance CARB’s Airborne Toxics Control Measure, the proposed Project would be required to restrict heavy-duty diesel vehicle idling time to 5 minutes, which would reduce petroleum usage. Overall, because petroleum use during construction would be temporary, and would not be wasteful or inefficient, impacts would be less than significant.

Operations

Mobile sources from buildout of the proposed Project would result in approximately 210,119 gallons of petroleum fuel usage per year. For disclosure, by comparison, Cali fornia as a whole consumes approximately 27.6 billion gallons of petroleum per year (EIA 2021c).

Over the lifetime of the proposed Project, the fuel efficiency of vehicles is expected to increase. As such, the amount of petroleum consumed as a result of vehicular trips to and from the Project site during operation would decrease over time. There are numerous regulations in place that require and encourage increased fuel efficiency. For example, CARB has adopted an approach to passenger vehicles that combines the control of smog-causing pollutants and GHG emissions into a single, coordinated package of standards. The approach also includes efforts to support and accelerate the number of plug-in hybrids and zero-emissions vehicles in California (CARB 2011). As such, operation of the proposed Project is expected to use decreasing amounts of petroleum over time due to advances in vehicle fuel economy standards.

In summary, the proposed Project would increase petroleum use during operation, but due to efficiency increases the amount of petroleum consumed would diminish over time. Petroleum consumption associated with the proposed Project would not be considered inefficient or wasteful and would result in a less than significant impact.

Conflict or Obstruct Plan for Renewable Energy

The proposed Project would comply with all applicable regulatory requirements including Title 24 of the California Code of Regulations contains energy efficiency standards for residential and nonresidential buildings based on a state mandate to reduce California’s energy demand. Specifically, Title 24 addresses a number of energy efficiency measures that impact energy used for lighting, water heating, heating, and air conditioning, including the energy impact of the building envelope such as windows, doors, wall/floor/ceiling assemblies, and roofs. Part 6 of Title 24 specifically establishes energy efficiency standards for residential and nonresidential buildings constructed in the S t a t e o f C a l i f o r n i a i n o r d e r t o r e d u c e e n e r g y d e m a n d a n d c o n s u m p t i o n . P a r t 1 1 o f T i t l e 2 4 a l s o i n c l u d e s t h e CALGreen standards, which established mandatory mi nimum environmental performance standards for new construction projects. The proposed Project would comply with Title 24, Part 6 and Part 11, per state regulations.

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33 Additionally, the proposed Project would receive electricit y from SCE, which has the mandate to comply with SB 100. This policy requires that eligible renewable energy resources and zero-carbon resources supply 100% of the retail sales of electricity to California by 2045, and that the zero-carbon electricity resources do not increase the carbon emissions elsewhere in the western grid and th at the achievement not be achieved through resource shuffling. Thus, the proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency; therefore, impacts during constructi on and operation of the proposed Project would be less than significant.

Cumulative Effects

The proposed Project and additional forecasted growth in SCE’s service area and SoCalGas’ service area would cumulatively increase the demand for electricity and natural gas supplies and infrastructure capacity. Although the proposed Project would result in the use of renewable and non-renewable resources during construction and operation, which could limit future availability of non-renewable energy sources, the use of such resources would be on a relatively small scale, would be reduced by measures making the Project more energy-efficient, and would be consistent with growth expectations for the service areas. Furthermore, as with the Project, during construction and operation, other future development projects would be expected to incorporate energy conservation features, comply with applicable regulations including CALGreen and state energy standards under Title 24, and incorporate mitigation measures, as necessary.

Furthermore, as described above, the proposed Project would be consistent with the energy efficiency policies emphasized by the 2020 RTP/SCS. Since the Project is consistent with the Connect SoCal (2020 RTP/SCS), its contribution to cumulative impacts related to wasteful, inefficient, and unnecessary use of transportation fuel would not be cumulatively considerable and, thus, would be less than significant.

As such, the Project’s contribution to cumulative impacts related to wasteful, inefficient and unnecessary use of electricity would not be cumulatively considerable and, thus, would be less than significant.

Finding
The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on energy as it relates to consumption of energy, conflict or obstruction of a plan for renewable energy, and cumulative impacts to energy, therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

2.3.7 Geology and Soils
Expose People or Structures to Fault Rupture

The Project site is not located within an Alquist-Priolo Earthquake Fault Zone and no known faults traverse the Project site (CGS 2021). According to the Geotechnical Investigation, the closest such zone is located along the Raymond Fault, located approximately 0.6 miles to the northwest of the Project site (Figure 4.5-2). Therefore, the Project site would not be subject to rupture of a known earthquake fault because no faults traverse the site.

Furthermore, the Project site would not directly or indirect ly cause or exacerbate existing fault rupture risks from the construction of new buildings and associated infrastr ucture on the Project site because no Project-related activities would occur within the Raymond Fault zone. Ther efore, no impact related to surface rupture of a known earthquake fault would occur.

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34 Expose People or Structures to Strong Seismic Ground Shaking

The Project site is located in the seismically active region of Southern California. The Raymond Fault and the Sierra Madre Fault have been mapped in the vicinity of the Project site. These faults, as well as numerous other regional faults (e.g., Puente Hills Thrust Fault, Santa Monica Faul t, Verdugo Fault, Whittier Fault, San Fernando, and San Andreas Fault), are capable of producing moderate to large earthquakes that could cause substantial ground shaking at the Project site. The severity of ground shaking would depend on the magnitude of the earthquake, the distance to the Project site, duration of shaking and on-site geologic conditions. Ground shaking could lead to substantive damage to structures and infrastructure, pers onal injury and death, utility service disruption, fire, explosion, and hazardous material spills, if not engineered appropriately.

The soils underlying the Project site fall within the characteristics of Class D (i.e., “Stiff Soil” profile), as defined in Chapter 20 of the American Society of Civil Engineers (ASCE) 7-10. This information was used to calculate the anticipated ground motions on the Project site, using the U.S. Geological Survey U.S. Seismic Design Maps tool (Appendix D-1). According to the Geotechnical Investigation, the site has the potential to experience ground accelerations of 0.939g, which is substantive and capable of causing significant damage if not designed appropriately. The Geotechnical Investigation prepared for the Project provides the seismic parameters to be used in the structural design of the Project, based on the materials encountered subsurface exploration at the site and provides for preliminary design measures that are cons istent with CBC building code requirements. The CBC provides procedures for earthquake-resistant structural design that includes considerations for on-site soil conditions, occupancy, and the configuration of the structure, including the structural system and height. Although substantial damage to structures may be unavoidable during large earthquakes, the proposed structures would be designed to resist structural collapse and thereby provid e reasonable protection from serious injury, catastrophic property damage, and loss of life.

The 2019 edition of the CBC is based on the 2018 International Building Code, and all construction must be conducted in compliance with the latest version of th e CBC. Chapters 16 and 16A of the 2019 CBC include structural design requirements governing seismically resistant construction, including factors and coefficients used to establish seismic site class and seismic occupancy category for the soil/rock at the building location and the proposed building design.

Project construction would be completed in accordance with the CBC. As with all development within the City, development within the Project site would be required to comply with the seismic safety requirements of the CBC.

The CBC provides procedures for earthquake resistant structural design that includes considerations for onsite soil conditions, occupancy, and the configuration of the structure, including the structural system and height. Standards provided in CBC Section 1803 also require preparation of a geotechnical evaluation and that all recommendations set forth in a final site-specific design-level geotechnical report – which would be based on the preliminary Geotechnical Investigation that was prepared for the Project – be incorporated into all applicable phases of Project excavation, grading and construction. Therefore, upon compliance with the CBC and City policies aimed at minimizing geologic hazards, including CBC Section 1803, requiring the incorporation of recommendations set forth in the final design-level site-specific geotechnical investigation, the Project site would not directly or indirectly cause substantial adverse effects involving strong seismic ground shaking, and impacts would be less than significant.

Expose People or Structures to Liquefaction

According to the Geotechnical Investigation, the historic al high groundwater levels for the general area have been interpreted at 100–150 feet below the ground surface in the vicinity of the Project site, and the potential

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35 for liquefaction to occur beneath the Project site is considered to be very low. The site is not located within a mapped C a l i f o r n i a G e o l o g i c S u r v e y l i q u e f a c t i o n h a z a r d z o n e (Appendix D-1, CGS 2021). As such, seismic- related ground failure due to liquefaction would not be expected to occur on the Project site and impacts would be less than significant.

Expose People or Structures to Landslides

The Project site is not located within an earthquake-induced landslide zone. Because the Project site is not located within an area identified by the California Geological Survey (CGS) as having potential for seismic slope instability, geologic hazards associated with landsliding are not anticipated at the site (Appendix D-1). Additionally, the Project would not exacerbate the potential for on- or off-site landslides. As such, implementation of the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. Impacts would be less than significant.

Soil Erosion or Loss of Topsoil

Construction

The Project site is not located in a hillside development area or agricultural zone that could be susceptible to eroding soils or the loss of topsoil due to site development. The Project site is currently fully developed and paved, with negligible amounts of soil exposed in areas of ornamental landscaping.

Project construction would entail demolition and grading of portions of the Project site as well as excavations for the subterranean parking structure, followed by construction of the foundation and proposed structures. The Project site has the potential for collapsible soils and would require removal and recompaction of any previously disturbed and/or artificial fill soils. As recommended in the Geotechnical Investigation, the fills underlying the Project site would be removed and replaced with compacted fill (Appen dix D-1). These construction activities could result in temporary, short-term impacts related to a potential for erosion and loss of topsoil during the development of the Project site.

As previously discussed, Chapter 8 of the AMC requires that all grading plans and permits must comply with the provisions of the NPDES General Construction Permit and implement erosion control BMPs before grading begins to prevent erosion and loss of topsoil from the site. Prior to the start of construction activities, the Contractor is required to file a Permit Registration Document with the State Water Resources Control Board (SWRCB) in order to obtain coverage under the NPDES General Permit for Storm Water Discharges Associated with the Construction and Land Disturbance Activities (Order No 2009-009-DWQ as amended by 2010-0014-DWQ and 2012-0006-DWQ, NPDES No. CAS000002). No grading permit would be issued unless the plans for such work include a SWPPP with details of BMPs which include erosion control measures to minimize the transport of sediment and protect public and private property from the effects of erosion. The required SWPPP would establish site-specific erosion and sediment control BMPs for all construction activities. Typical examples of erosion-related construction BMPs include the following:
x Silt fences and/or fiber rolls installed along with the limits of work and/or the Project construction site x Stockpile containment and exposed soil stabilization structures (e.g., Visqueen plastic sheeting, fiber rolls, gravel bags and/or hydroseed)
x Runoff control devices (e.g., fiber rolls, gravel bag barriers/chevrons, etc.) used during construction phases conducted during the rainy season

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36 x Wind erosion (dust) controls
x Tracking controls at the site entrance, including regular street sweeping and tire washes for equipment x Regular inspections and maintenance of BMPs

These BMPs would be refined and/or added to as nece ssary by a qualified SWPPP professional to meet the performance standards in the Construction General Permit. Compliance with the Construction General Permit would ensure that soil erosion would be minimized.

Although the Project would require excavation of soils related to construction of the subterranean parking structure and related to removal and recompaction of collapsible soils, this would not result in a substantial loss of topsoil.

The Project site is currently developed and paved and does not contain native topsoil, with the exception of minimal landscaped areas adjacent to surface parking lots and buildings. The Project site is not used, and is not zoned for, agricultural uses or other activities that require the use of topsoil. Therefore, with compliance of the NPDES General Construction Permit, potential impacts associated with soil erosion and/or loss of topsoil would be less than significant.

Operations

Long-term operation of the Project would not result in substantial soil erosion or loss of topsoil as the majority of the Project site would be covered by the structures and paving, while the remaining portions of the site would be covered with irrigated landscaping. No exposed areas subject to erosion would be created or affected by the Project.

In addition, the majority of the area surrounding the Project site is completely developed and would not be susceptible to indirect erosional processes (e.g., uncontrolled runoff) caused by the Project. With the implementation of applicable construction BMPs that also include post-construction requirements, impacts related to erosion or loss of topsoil would be less than significant.

Located on or Would Cause Unstable Soil

Landslides

As previously discussed, the Project site is relatively leve l and the topography in the site vicinity slopes slightly downward toward the south (Appendix D-1). The State of California (CGS 2018) and the City of Arcadia (2010) indicate that the site is not located within a zone of required investigation for earthquake-induced landslides. There are no known landslides near the site, nor is the site in the path of any known or potential landslides. Therefore, the potential for slope stability hazards to adversely impact the site is considered low. Because the Project site is not located within an area identified by the CGS as having potential for seismic slope instability, geologic hazards associated with landsliding are not anticipated at the site (Appendix D-1). No impacts would occur.

Liquefaction/Lateral Spreading

According to the State of California (CGS 2017) and the City of Arcadia (2010) the site is not located in an area potentially susceptible to liquefaction or lateral spreading. Potential impacts concerning liquefaction are evaluated above. Lateral spreading is the finite, lateral movement of gently sloping, saturated soil deposits caused by earthquake-induced liquefaction. Impacts associated with lateral spreading would be similar to those associated with liquefaction and would therefore be less than significant.

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37 Subsidence

According to the Geotechnical Investigation, the existing artificial fill and any unsuitable, soft alluvial soils onsite are considered suitable for reuse provided they are compacted to meet current building code requirements (Appendix D-1).

Volumetric changes in earth quantities would occur if excavated onsite soil materials were to be replaced with properly compacted fill. In accordance with the CBC Section 1804A, the compacted fill shall comply with the provisions of an approved final design level geotechnical report, which is also in accordance with CBC Section 1803, as discussed above. The proposed Project would be required to meet th e most recent building safety criteria and construction design recommendations of the site-specific final design level geotechnical report that would be prepared for the proposed Project. As such, impacts related to subsidence would be less than significant.

Collapsible Soils

As previously stated, the preliminary geotechnical investigation indicated that artificial fill soils in the upper 4 feet exhibit collapsible potential upon wetting. If such material s are left in the current condition, excessive settlement of structures and site improvements could result due to the weight of new foundations and the introduction of water from rain or irrigation. Excessive settlement from such materials could be prevented through excavation and recompacted, as recommended by the preliminary geotechnical investigation. Materials anticipated to exhibit this condition consist of the artificial fill soils and any encountered soft alluvial soils. Soils below the collapsible soil zone are anticipated to exhibit low compressibility characteristics in their current state (Appendix D-1).

The preliminary geotechnical investigation concluded that after appropriate site preparations (e.g., removal and recompaction of artificial fills) total settlement of fo undations would be less than about 1.25 inch and bearing pressure is limited to about 4,000 pounds per square foot. Associated differential settlement should be less than

0.75 inches over 20 feet. Such settlement is anticipated to be tolerable for the proposed development.

A final design-level geotechnical investigation report is required in accordance with the CBC. As previously discussed, the CBC, 2019 edition, including Appendix J, issuing grading requirements, is adopted by reference pursuant to Section 8110 of the AMC (City of Arcadia 2021a). In accordance with Section 1803 of the CBC, a geotechnical investigation is required to include soil testing, laboratory testing or engineering calculations to evaluate soil types, soil expansion, depth of groundwater, deep foundations, rock strata, excavation, compacted fill, soil strength, seismic design criteria and other soil charac teristics that need to be considered in the structural design and construction of buildings and infrastructure. Geotechnical investigations must be prepared by registered professionals (i.e., California Registered Civil Engineer or Certified Engineering Geologist). Recommendations from geotechnical investigations must be incorporated into the design and construction of the Project, as reviewed and approved by the City’s Development Services Department. As such, impacts related to collapsible soils would be less than significant.

In summary, upon Project compliance with the CBC and City policies aimed at minimizing geologic hazards, and the recommendations set forth in the final design level geotechnical report, the proposed Project would not directly or indirectly exacerbate existing conditions related to on-s ite or off-site landslide, lateral spreading, subsidence, liquefaction or collapse, and impacts would be less than significant.

Located on Expansive Soil

Expansive soils are clay-rich soils that shrink when dry and swell when wet. This change in volume can exert substantial pressure on foundations over time, resulting in structural distress and/or damage. According to the

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38 preliminary geotechnical investigation, the site is underlain by artificial fill and Holocene age alluvium comprised of alluvial channel and outwash deposits consisting of varying amounts of silt, sand, and gravel (Appendix D-1).

As previously discussed, based on depth of the proposed subterranean levels, the near surface soils have a low expansion potential. Given the low expansion potential anticipated at the site, only nominal steps will be needed to mitigate adverse effects. Typical mitigation measures de scribed in Chapter 18 of the CBC to alleviate expansive soils include the following:

x Excavation of expansive soils until such a depth that competent material is encountered x Installation of foundations designed to resist forces exerted on the foundation due by expansive soils x Stabilization of the soils by chemical, dewatering, pre-saturation, or equivalent techniques

Project construction would not increase or exacerbate the potential for expansive soils to create substantial direct or indirect risks to life or property. Additionally, the proposed Project would be constructed according to the mandatory seismic and structural design guidelines established in CBC, Chapter 16, Section 1601 et seq. As such, impacts would be less than significant.

Soils Incapable of Supporting Septic Tanks

The Project site is currently served by existing sewer infrastructure, and any new development would require connecting to the existing system. There is adequate capacity in the sewer system for the Project. There are no septic tanks or alternative wastewater disposal proposed; therefore, implementation of the Project would result in no impact.

Cumulative Effects

Potential cumulative impacts on geology and soils would result from Projects that combine to create geologic hazards, including unstable geologic conditions, or contribute substantially to erosion. The majority of impacts from geologic hazards, such as rupture of a fault line, liquefaction, landslides, expansive soils, and unstable soils, are site-specific and are therefore generally mitigated on a project-by-project basis. Each cumulative Project would be required to adhere to required building engineering design per the most recent version of the CBC in order to ensure the safety of building occupants and avoid a cumulative geologic hazard. Additionally, as needed, Projects would incorporate individual mitigation or geotechnical requirements for site-specific geologic hazards present on each individual cumulative Project site, similar to that described above for the proposed Project.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on fault rupture, strong seismic ground shaking, liquefaction, landslides, erosion, unstable soil, expansive soil, and septic tanks; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

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39 2.3.8 Greenhouse Gas Emissions
Greenhouse Gas Emissions

Construction Emissions

On-site sources of GHG emissions include off-road equipment and off-site sources including haul trucks, vendor trucks, and worker vehicles. The estimated total GHG emissions during construction of would be approximately 2,135 MT CO
2e over the construction period, which is less than the GHG significance threshold of 3,000 MT CO2e per year. Therefore, the proposed Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, and this would represent a cumulatively less than significant impact.

Operational Emissions

The estimated operational GHG emissions from Project area sources, energy consumption, mobile sources, solid waste, and water consumption and wastewater treatment associated with the proposed Project would be equal to 2,400 MT CO2e, below the SCAQMD GHG threshold of 3,000 MT CO 2e per year. Even without taking into account the removal of the existing land uses, the proposed Project’s estimated emissions would be below the SCAQMD GHG threshold of 3,000 MT CO
2e per year. Therefore, the proposed Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, and this would represent a cumulatively less than significant impact.

Conflict with an Applicable Plan, Policy, or Regulation

Consistency with the Connect SoCal (2020–2045 RTP/SCS)

SCAG’s Connect SoCal is a regional growth-management strategy that targets per capita GHG reduction from passenger vehicles and light-duty trucks in the Southern California region. The Connect SoCal incorporates local land use projections and circulation networks in city and county general plans. Typically, a project would be consistent with the RTP/SCS if the project does not exceed the underlying growth assumptions within the RTP/SCS.

The proposed Project would accommodate an expected 909 residents which would be counted within the overall population growth projections included in the Connect SoCal of 5,519 residents between 2020 and 2045.

As stated in the Connect SoCal 2020–2045 RTP/SCS, there is no obligation by a jurisdiction to change its land use policies, General Plan, or regulations to be consistent with the RTP/SCS, and lead agencies have the sole discretion in determining a local project’s consistency with the RTP/SCS (SCAG 2020a). Because there is no wholly reliable population, housing, or employment data after 2010, as the U.S. Census is conducted every ten years, all data for years prior to the 2020 Census should be viewed as projections or estimates. The proposed Project would implement the guiding principles, goals and policies of SC AG’s 2020–2045 RTP/SCS as they relate to livability, economic prosperity, and sustainability through the development of walkable, mixed use communities along major transportation corridors. The development of housing within 350 feet of transit (Metro’s L Line Arcadia Station), thereby alleviating pressure on suburban and open space areas to develop, is fully supportive of SCAG’s strategies.

Because the proposed Project would support SCAG’s goals and strategies for growth in the region and because the proposed Project would assist the development of new housing and improves the City’s job/housing balance, impacts related to population growth assumed in Connect SoCal would be less than significant.

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40 Consistency with the CALGreen

The 2019 CALGreen requirements are comprehensive and applicable to the proposed Project. The provisions of the CALGreen code apply to the planning, design, oper ation, construction, use and occupancy of every newly constructed building or structure. In mixed occupancy buil dings, such as the proposed Project, each portion of a building must comply with the specific green building measures applicable to each specific occupancy (CEC 2019).

The proposed Project must comply with all relevant measures applicable to the types of structures to be built, including live-work units and residential. Therefore, the proposed Project would be implemented consistent with the requirements of CALGreen and impacts would be less than significant.

Consistency with CARB’s Scoping Plan

The Scoping Plan provides a framework for actions to reduce California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other in itiatives to reduce GHGs. The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32 and establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. The proposed Project would comply with all regulations adopted in furtherance of the Scoping Plan to the extent required by law and to the extent that they are applicable to the proposed Project.

Consistency with EO S-3-05 and SB 32

EO S-3-05 establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80% below 1990 levels by 2050. SB 32 establishes for a statewide GHG emissions reduction target whereby CARB, in adopting rules and regulations to achieve the maximum technologically feasible and cost- effective GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40% below 1990 levels by December 31, 2030. CARB believes that the state is on a trajectory to meet the 2030 and 2050 GHG reduction targets set forth in AB 32, EO B-30-15, and EO S-3-05.

Consistency with General Plan’s Air Quality Element

The City Arcadia’s General Plan (City of Arcadia 2010) includes various policies related to reducing GHGs (both directly and indirectly) because strategies that reduce criteria air pollutant emissions may also reduce GHG emissions. Total proposed Project emissions, including operation and amortized construction, would be below the SCAQMD significant threshold of 3,000 MT CO2e per year. Furthermore, based on the considerations previously outlined, the proposed Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, and no mitigation is required. Therefore, this impact would be less than significant.

Cumulative Effect

GHG emissions inherently contribute to cumulative im pacts. The proposed Project would not result in GHG emissions in exceedance of the SCAQMD significance threshold. Therefore, cumulatively, Project GHG emissions would be less than significant.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on emissions generated, consistency with applicable regulations, and cumulative GHG effects; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

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41 2.3.9 Hazards and Hazardous Materials
Routine Transport, Use, or Disposal of Hazardous Materials/Release of Hazardous Materials and the Potential for Upset Conditions

Long-Term Operational Impacts

The operational phase of the proposed Project would not be expected to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Hazardous materials would be limited to use of commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available substances. Such chemicals are typically used in an urban environment, and when used in accordance with manufacturer’s recommendations and applicable regulations, do not result in a risk to human health or the environment. The routine transport, use, and/or disposal of these substances would be subject to applicable federal, state, and local health and safety laws and regulations, which would minimize health risk to the public associated with hazardous materials. Therefore, impacts would be less than significant and no mitigation is required.

Hazardous Materials within One-Quarter mile of an Existing or Proposed School

There are no public or private K–12 schools located within 0.25 miles of the Project site, therefore, impacts would be less than significant and no mitigation is required.

Cortese List

The Project site is not listed on or adjacent to a Cortese List site, nor has the Project site been impacted by a Cortese List site. Therefore, the Project would not create a signif icant hazard to the public or the environment due to its location of a hazardous materials site included on the list compiled under Government Code Section 65762.5, and no impact would occur.

Near an Airport or within an Airport Land Use Plan

The Project site is not located within 2 miles of a public use airport, nor is it located within an airport land use plan.

Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area, and no impact would occur.

Impair or Interfere with an Adopted Emergency Response Plan or Emergency Evacuation Plan

Short-Term Construction Impacts

Construction of the proposed Project would occur complete ly within the Project site and would not require road closures. Additionally, the Project site is not located on a designated disaster evacuation route. The City of Arcadia Safety Element Policies S-5.1, S-5.2, and S-5.11 require police and fire department personnel to be involved in the development review process, integration of new technologies for crime and fire prevention in new development and require new developments to pay for costs associated with increased public safety needs. As such, review of the proposed Project as it relates to emergency response and emergency evacuation would be an integral part of the review process within the City of Arcadia, and deficiencies would be remedied, and costs accounted for. As such, impacts would be less than significant.

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The proposed Project would increase residential density at the Project site. As noted above, review of the proposed Project as it relates to emergency response and emergenc y evacuation would be an integral part of the review process within the City of Arcadia in accordance with po licies set forth in the General Plan, Safety Element, and deficiencies would be remedied, and costs accounted for. As such, impacts would be less than significant.

Wildland Fires

The proposed Project site is located in a highly urbanized area and is not located within an area of high wildfire hazard. Therefore, people and structures would not be subj ect to significant risks related to wildland fires, and impacts would be less than significant.

Cumulative Effect

There are a variety of hazardous material and public health and safety issues that are relevant and applicable to the Project. Many potential impacts related to hazardous materials and public health and safety risks would be minimized due to compliance with federal, state, and local regulatory requirements.

Because cumulative Projects would be fully regulated, thus reducing potential for public safety risks, cumulative impacts associated with exposure to hazards and hazard ous materials would be less than significant. Through mitigation and compliance with regulatory requirements, the construction or operation of the proposed Project itself would not create significant human or environmental health or safety risks that could combine with other Project impacts to create a significant and cumulatively considerable impact. For these reasons, the proposed Project would not result in cumulatively considerable impacts related to hazards and hazardous materials.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on hazards and hazardous materials as it relates to the long-term use, storage and transport of hazardous materials; proximity of an existing or proposed school; the proximity of the project to an airport or an airport land use plan; emergency response plan; Cortese list; wildland fires; and cumulative impacts to hazards and hazardous materials; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

2.3.10 Hydrology and Water Quality
Violate Water Quality Standards or Waste Discharge Requirements

Short-Term Construction Impacts

Site grading would require a combination of “cut and fill” earthwork to create a building/parking structure pad and to accommodate two levels of subterranean parking. Grading is estimated to result in approximately 57,200 cubic yards of excavation/export (or “cut”) and 200 cubic yards of import fill for site rebalancing. Final grading plans would be approved by the City Engineer before the City issues grading permits.

Grading and construction would potentially result in short-term erosion and associated siltation that could lead to adjacent storm drain infrastructure. Erosion-induced sedimentation affects water quality and interferes with photosynthesis; oxygen exchange; and the respiration, grow th, and reproduction of aquatic species. Additionally, other pollutants, such as nutrients, trace metals, and hydrocarbons, can attach to sediment and be transported to

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downstream drainages which could contribute to the degradation of water quality. Other pollutants that could affect surface-water quality during the construction phase include petroleum products (gasoline, diesel, oil, and grease), hydrocarbons from asphalt paving, construction equipment leaks, paints and solvents, detergents, fertilizers, and pesticides (including insecticides, fungicides, herbicides, and rodenticides).

In accordance with the State NPDES Construction General Permit and WDR Permit, as established by the Porter- Cologne Water Quality Act, the development of an acre or more of land must file a notice of intent with the SWRCB, followed by development of a site-specific SWPPP for cons truction activities (Section 7827, General Control of Runoff Required, Construction Activity, City of Arcadia Municipal Code). The property owner/developer must comply with the Construction General Permit applicable at the time a grading permit is issued. The SWPPP must include erosion- and sediment-control BMPs that will meet or exceed measures required by the determined risk level of the Construction General Permit, as well as BMPs that control the other potential construction-related pollutants. A Construction Site Monitoring Program that identifies monitoring and sampling requirements during construction is a required component of the SWPPP. The SWPPP is required to identify BMPs that protect stormwater runoff and ensure avoidance of substantial degradation of water quality.

Incorporation of required BMPs for temporary materials and waste storage and handling during construction, and equipment and vehicle maintenance and fueling would redu ce the potential discharge of polluted runoff from construction sites, consistent with the State NPDES Construction General Permit and the City’s Municipal Code requirements for construction activities.

As set forth in Section 7800 of the City’s Municipal Code, the Project must ensure the future health, safety, and general welfare of citizens by: (a) eliminating non-stormwater discharges to the municipal separate storm drain; (b) controlling the discharge from spills, dumping or disposal of materials other than stormwater to municipal separate storm drains; and (c) reducing pollutants in stormwater discharges to the maximum extent practicable. Section 7820 of the Municipal Code prohibits the discharge of non-stormwater into the City’s storm drain system, unless a discharge permit, which meets the City’s requirements, is obtained. Section 7827 of the Municipal Code specifically requires that all proposed development and/or redevelopment Project protect water quality by either (a) implementing an erosion and sediment control plan and all applicable BMPs to ensure discharge of pollutants are effectively prohibited or (b) preparing a SWPPP in accordance with the Construction General Permit. The proposed Project would adhere to all applicable stormwater management and discharge control regulations, and, as such, is not anticipated to violate any water quality standard or waste discharge requirement during operation.

The historical high groundwater levels in the Project vi cinity have been interpreted at 100–150 feet below the ground surface, and as such, excavation activities as sociated with the subterranean parking garage are not expected to encounter groundwater. However, perched groundwater conditions are dependent on seasonal precipitation, land use, among other factors, and may vary as a result. Additionally, the Project pro poses to install drywells to satisfy low impact development requirements (as further discussed below), which are anticipated to reach depths of 42 feet; therefore, it is possible that the construction of the drywells could encounter perched groundwater (Appendix H-1).

In the event that groundwater is encountered during excavations, the Project applicant/developer would be required by existing regulatory requirements to procure a dewatering permit from the Los Angeles RWQCB for pumping and disposal of groundwater. Groundwater dewatering would be controlled in compliance with the Waste Discharge Requirements for the Discharge of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties (Order No. R4-2018-0125, NPDES No. CAG994004). This permit requires permittees to conduct monitoring of dewa tering discharges and adhere to effluent and receiving water limitations contained within the permit so that the water quality of surface waters is protected.

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Application for the permit would involve collecting and analyzing groundwater samples to determine its constituents.

In the event that contamination is identified, the permit would include specific types of treatment requirements to ensure compliance with the discharge standards. The permit also establishes requirements for initial and continuous groundwater testing throughout the dewatering process to ensure that the water remains suitable for discharge and that the impacts of dewatering discharges do not constitute a significant and adverse impact to downstream waters.

Compliance with existing regulations would prevent violation of water quality standards and minimize the potential for contributing sources of polluted runoff. Therefore, comp liance with existing regulations would ensure that the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface quality from demolition and construction activities. Impacts would be less than significant, and no mitigation is required.

Long-Term Operational Impacts

The primary source of surface water pollution from long-term operations on the Project site would be incidental spills of vehicle oils in parking garages. Certain metals, along with nutrients and pesticides from landscape areas, could also be present in stormwater runoff, although on-site landscaping would be minimal. During storm events, pollutants from paved areas lacking proper stormwater co ntrols and BMPs could enter the municipal storm drain system. Between periods of rainfall, surface pollutants te nd to accumulate, and runoff from the first significant storm of the year (“first flush”) would likely have the largest concentration of pollutants. Such discharges would potentially violate state/federal antidegradation policies, the California Toxics Rule, and water quality objectives as established in the Los Angeles RWQCB Basin Plan.

However, Project design, construction, and operation woul d b e r e q u i r e d t o b e c o m p l e t e d c o n s i s t e n t w i t h t h e RH/SGRWQG EWMP, and in accordance with the City Stormwater Management and Discharge Control Ordinance, Municipal NPDES Permit, and the County of Los Angeles Low Impact Development Best Management Practices Handbook (LID Manual), with the goal of reducing the amount of pollutants in stormwater and urban runoff (City of Arcadia 2021b). The LID Manual requires that that post-construction stormwater runoff from new developments be infiltrated, evapotranspired, captured and reused, and/or treated through a high efficiency BMP onsite for the 85th percentile storm event, or 0.75 inches of precipitation, whichever is greater.

The LID Manual requires that BMPs be designed and implemented to manage and capture stormwater runoff.

Infiltration systems are the first priority type of BMP improvements, as such systems provide percolation and infiltration of stormwater into the ground, which not only reduces the volume of stormwater runoff entering the MS4, but also contributes to groundwater recharge in some areas. The second priority BMP is capturing and reusing stormwater onsite for either landscape irrigation or toilet flushing. Proposed drainage for the proposed Project would include stormwater treatment features, in accordance with the City and County LID requirements. According to a review of the 2011–2012 Municipal Separate Storm Sewer System (MS4) Annual Report for the Rio Hondo/San Gabriel River Water Quality Group Enhanced Watershed Management Program (RH/SGRWQG EWMP) area, at least 150 BMPs were reported within the City of Arcadia, including green infrastructure, source control, and institutional BMPS.

Based on the Geotechnical Investigation, prepared by Geocon West, Inc (see Appendix E-2), the Conceptual Hydrology and LID Report (Appendix H-1) determined that infiltration is feasible for stormwater treatment. Two drywells and one four-foot diameter primary settling chamber are proposed to be constructed on the Project site, located in the south side of the basement parking lot, which would be able to capture the required runoff volume and treat that volume as quickly as it enters the drywell system.

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The existing infiltration rate for the site is 13.83 inches/hour with a design infiltration of 6.92 inches/hour. 3 Based on this data, the Project requires a mitigation volume of 7,592 cubic feet. A drywell with a diameter of 6 feet and an infiltration depth of 42 feet would provide a disposal rate of 0.07091 cubic feet per second (cfs) and would result in a disposal volume of 24,505 cubic feet over a 96-hour period. As a result, the 96-hour infiltration volume for the combined wells would be 49,010 cubic feet. Based on the total mitigated volume of 7,592 cubic feet, after subtracting the volume infiltrated as quickly as it enters the drywell of 6,577 cubic feet, the remaining volume is 1,015 cubic feet. The storage provided in the drywell system would be 1,062 cubic feet, which is adequate to accommodate the mitigated volume.

In addition to the drywells and settling chamber, the Projec t includes street-level overflow curb drain outlets that would discharge into the Wheeler Street curb gutter and run west to the catch basin on the northeast corner of Wheeler Avenue and North Santa Anita Avenue. The existing peak flow rate value of 8.81 cubic feet per second (cfs) would decrease by 0.73 cfs under proposed conditions, resulting in a proposed or post-Project peak flow rate value of 8.08 cfs. The post-Project condition shows the conceptual location of the drywells, settling chamber, and overflow pipes to the existing storm drain system, which would contribute to the peak flow rate reduction under proposed conditions. Because the peak flow rate would be reduced in the proposed condition, it is understood that the existing City storm drains would not be negatively affected by implementation of the proposed Project.

Once the water quality volume is met through the drywells, the “higher flows” would enter overflow pipes, which would discharge stormwater to the local storm drain system . The proposed peak flow rate that would be used to design the overflow piping is the reduced peak flow rate of 8.08 cfs generated after infiltration. As presented in Appendix H-1, under the proposed infiltration system, the volume infiltrated in 96 hours is approximately six times the required mitigated volume and the volume infiltrated as it enters the drywells are nearly equal to the mitigated volume. Therefore, the drywells and settling chamber to be constructed as part of the Project would result in the treatment of the entire required volume for the Project site and the elimination of pollutant runoff up to the 50-year storm event.

The implementation of LID features would, to the maximum extent practicable, reduce the discharge of pollutants into receiving waters, including inadvertent release of pollutants (e.g., hydraulic fluids and petroleum); improper management of hazardous materials; and trash and debris during Project operations. In accordance with all applicable state and local regulations, including General Plan Policy RS-9, Project source controls to improve water quality would be provided for outdoor trash storage/waste areas and outdoor loading/unloading areas. As a result of compliance with existing regulations, the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality during the long-term Project operations. Impacts would be less than significant, and no mitigation is required.

Deplete Groundwater Supplies or Interfere with Groundwater Recharge

The amount of impervious area under proposed Project conditions would remain at 95%, which is the same as under existing conditions. The soil zones encountered on site are suitable for infiltration of stormwater, the proposed Project would incorporate drywells to facilitate infiltration in compliance with applicable LID requirements. The Project site is not currently used for groundwater infiltration, either by spreading or by groundwater injection.

3 The design infiltration rate is the corrected in-situ infiltration rate and has been calculated in accordance with the Boring Percolation Test Procedure in the County of Los Angeles Department of Public Works Geotechnical and Materials Engineering Division (GMED) Guidelines for Geotechnical Investigation and Reporting, Low Impact Development Stormwater Infiltration.

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The 96-hour infiltration volume for the combined wells would be 49,010 cubic feet. As such, upon construction and operation of the drywells, groundwater recharge at the site would increase in comparison to existing conditions.

The proposed Project is not anticipated to encounter groundwater during excavation for the subterranean parking garage. However, perched groundwater conditions may vary over time, and in the unlikely event that groundwater is encountered during excavations, the Project applican t/developer would be required by existing regulatory requirements to procure a dewatering permit from the Los Angeles RWQCB for pumping and disposal of groundwater. Groundwater dewatering would be controlled in compliance with the Waste Discharge Requirements for the Discharge of Groundwater from Construction an d Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties (Order No. R4-2018-0125, NPDES No. CAG994004). Temporary dewatering, if required, would be short-term and would not substantially interfere with groundwater supplies.

Additionally, the Project site is above the Main San Gabriel Basin (Groundwater Basin 4-013), which has been designated as Very Low Priority with respect to es tablishment of a GSA and completion of a Groundwater Sustainability Plan (SGMA 2021). Therefore, the proposed Project would not substantially decrease groundwater supplies. Impacts would be less than significant, and no mitigation is required.

Alter Existing Drainage Pattern (Erosi on, Surface Runoff, Exceed Capacity Drainage System, Impede or Redirect Flood Flows)

The proposed Project site is fully developed in the existing condition and is located in a highly urbanized portion of Arcadia, surrounded by developed properties. Implementation of the proposed Project would not alter the existing drainage patterns on the site such that downstream streams or rivers would be affected. The Project would infiltrate stormwater in accordance with all applicable LID regulations and would continue to outflow into the existing storm drain system. No naturalized drainages or creeks would be affected. According to the Conceptual Hydrology and LID Report, total impervious surface area and post-project ru noff are anticipated to be the same as under existing conditions. Therefore, the Project would not substantially al ter the existing drainage pattern of the site, including through the alteration of the course of a stream or river or through the addition of impervious surfaces. Impacts would be less than significant, and no mitigation is required.

Flood Hazard, Tsunami, or Seiche Zones

No areas within the City of Arcadia are designated 100-year flood zones (City of Arcadia 2010). According to the Federal Emergency Management Agency (FEMA), the Project si te is located within Zone X, which is an area of Minimal Flood Hazard (FEMA 2021). Therefore, the Project site is not located within an area that would be subject to flooding.

The Project is, however, located in the Santa Anita Dam floo d inundation zone. Approximately half of the City is located within the dam inundation zone. Failure of the Santa Anita Dam would lead to inundation of a large eastern section of the City. At capacity, floodwaters from the dam would travel down Santa Anita Canyon to about Orange Grove Avenue and then spread across the eastern half of the city from Arcadia Wash. To comply with state dam safety regulations, the water level behind the dam is restricted to be no higher than an elevation of 1,230 feet above mean sea level, to meet the California Division of Safety of Dams seismic safety requirements and to reduce the potential magnitude of downstream flooding (City of Arcadia 2010). According to the General Plan Safety Element, flood hazards in the City are well addressed by existing storm control infrastructure. Seismic retrofit of the Santa Anita Dam, which was built in 1927, was scheduled to begin in Spring of 2021 to improve public safety and prevent flood damage to downstream communities (LACDPW 2019a). Dam failure potential is low and the extent

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of inundation would depend on the amount of water stored at the time of failure. Seismic upgrades will further reduce already low potential for flooding due to dam failure at the Project site, and the proposed Project would not exacerbate potential risks associated with dam failure.

The Project site is not located near a body of water or close to the ocean and as a result, is not susceptible to tsunamis or seiches (DOC 2021). In the unlikely event that the site were to be flooded as a result of dam failure, the risk of release of pollutants due to inundation of the Project site is low, as the proposed sites primary uses (i.e., residential) would not include storage of hazardous materials or hazardous waste. Existing state, regional and local regulations related to emergency preparedness would be su fficient to address potential hazards associated with floods, tsunamis, or seiches, which have not been identified as hazards for the Project site. Therefore, Project impacts would be less than significant, and no mitigation is required.

Conflict with Water Quality Control Plan or Sustainable Groundwater Management Plan

The Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties is the Water Quality Control Plan (WQMP) for the Los Angeles Region, which includes the City of Arcadia. The Basin Plan: (i) identifies beneficial uses for surface waters and groundwaters, (ii) includes the narrative and numerical water quality objectives that must be attained or maintained to protect the designated bene ficial uses and conform to the state's anti-degradation policy, and (iii) describes implementation programs and other actions that are necessary to achieve the water quality objectives established in the Basin Plan (LARWQCB 2019). The existing, potential or intermittent beneficial uses for the Arcadia Wash, the Santa Anita Wash, and the Rio Hondo Channel, where stormwaters from the City are discharged and for the underlying groundwater basins in the City (Raymond and San Gabriel Valley groundwater basins) include: domestic water supply (MUN); industrial activities (IND); industrial process dependent upon water quality (PROC); agricultural supply (AGR); groundwater recharge (GWR); Water Recreation (REC-1, REC-2); warm water ecosystems (WARM); cold water ecosystems (COLD); terrestrial ecosystems (WILD); rare, threatened or endangered species (RARE); and wetland ecosystems (WET) (LARWQCB 2019).

With compliance with applicable regulations, the proposed Project does not include any facilities or land uses that could generate pollutants that could result in substantial water quality impacts. Compliance with the City’s Stormwater Management requirements would protect the water quality of watercourses in a manner pursuant to and consistent with the Federal Clean Water Act, and pursuant to the NPDES CGP No. 2009-0009-DWQ.

Restrictions in this Ordinance are applicable to both construction activities and operations. Additionally, compliance with CGP issued by the SWRCB would require implementation of BMPs during construction to address the potential for pollutants from entering downstream waters. The Project’s potential to violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water or groundwater quality would be less than significant and no mitigation is required.

The proposed Project would comply with applicable water quality regulatory requirements, including implementation of a SWPPP, stormwater BMPs, and LID design, which woul d minimize potential off-site surface water quality impacts and contribute to a reduction in water quality impacts within the Rio Hodo Watershed subarea and the overall Los Angeles River Watershed. In addition, with compliance with these regulatory requirements, the Project would reduce potential water quality impairment of surface waters such that existing and potential beneficial uses of key surface water drainages throughout the jurisdiction of the Los Angeles RWQCB Basin Plan would not be adversely impacted. As a result, the Project would not conflict with or obstruct the Los Angeles RWQCB Basin Plan.

W i t h r e s p e c t t o g r o u n d w a t e r m a n a g e m e n t , S G M A e m p o w e r s l o c a l a g e n c i e s t o f o r m G S A s t o m a n a g e b a s i n s sustainably and requires those GSAs to adopt Groundwater Sustainability Plans for crucial groundwater basins in California. A GSA has not been established for the Main San Gabriel Basin, as it is not considered a high priority

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basin. Further, the Project would not substantially depl ete groundwater supplies or interfere substantially with groundwater recharge. As a result, the Project would not co nflict with or obstruct this sustainable groundwater management plan. Impacts would be less than significant, and no mitigation is required.

Cumulative Effect

Water Quality

The geographic context for the analysis of cumulative impacts associated with water quality is the Los Angeles River Watershed and the Rio Hondo Watershed subarea, which is already largely urbanized with impervious surfaces.

Although the land surrounding the Project site is largely developed with impervious surfaces, continued redevelopment within the Project area could slightly increase the amount of impervious surfaces that could increase stormwater runoff rates and amounts, as well as changes in land use that may increase the amount of pollutants in stormwater runoff. Typical pollutants of concern would be associated with the construction phase (e.g., sediment, fuels, litter), private vehicle use (e.g., any leakage of grease/oils), landscaping/grounds work (e.g., improper/ excessive use of pesticides, herbicides, and/or fertilizers), and/or trash (e.g., due to improper waste disposal). The release of such pollutants, however, would be minimized through compliance with terms and conditions of the NPDES permit, CALGreen Code, California Building Code, AMC, and the ordinance codes of other authorities in the region—which all require implementation of a SWPPP for development and redevelopment projects. In summary, all cumulative development would be subject to existing regulatory requirements to protect water quality and minimize increases in stormwater runoff. For example, the NPDES permit requires the City to effectively prohibit non- stormwater discharges from within its boundaries and to comply with the NPDES permit and to specifically prohibit certain discharges.

Every two years, the Los Angeles RWQCB must reevaluate wa ter quality within its geographic region and identify those water bodies not meeting water quality standards. For those impaired water bodies, a TMDL must be prepared and implemented to reduce pollutant loads to levels that would not contribute to a violation of water quality standards. All development within the Los Angeles River Watershed would be subject to the water quality standards outlined in the Basin Plan and would comply with any established TMDLs. The continuing review process would ensure that cumulative development within the watershed would not substantially degrade water quality.

In addition, the Project would comply with existing and fu ture regulations to protect water quality, including the Construction General Permit. Compliance with existing regulations would prevent violation of water quality standards and minimize the potential for contributing a dditional sources of polluted runoff. Therefore, Project impacts associated with water quality standards and polluted runoff would be less than significant, and the Project would not contribute considerably to cumulative impacts.

Drainage

The Los Angeles River Watershed is already largely urbanized with impervious surfaces. Cumulative development within the City could potentially increase the amount of impervious surfaces that could cause or contribute to storm drain system capacity exceedance, alter the existing stor m drain system, and/or require construction of new or expanded facilities. However, new development within the watershed would be subject to the same requirements for LID infrastructure and BMPs to address the potential fo r increased runoff from development sites. All projects must comply with current state and local environmental regulations, such as the AMC mandates. Potential impacts to drainage associated with the Project would be less than significant, and the Project would not contribute considerably to cumulative impacts.

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Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on hydrology and water quality. Therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.

2.3.11 Land Use
Physically Divide an Established Community

The physical division of an established community typically refers to the construction of a linear feature (e.g., a major highway or railroad tracks) or removal of a means of access (e.g., a local road or bridge) that would impair mobility within an existing community or between a community and outlying area.

The Project site currently consists of a 2-story office building, two 1-story commercial buildings, an 8-story office building, a 1-story bank drive-through and surface parking. Access to the Project site is provided on Santa Clara Street to the north, Wheeler Avenue to the south, an alleyway to the east, and Santa Anita Avenue to the west.

The proposed Project involves construction of a multi-family residential development and the demolition of some of the existing structures on the site, including the 2-story office building, the two 1-story commercial buildings, and surface parking. The Project includes a Tentative Parcel Map which would merge lots on site as well as a portion of the alley would be vacated to accommodate the Project.

Under the existing condition, the Project site is develope d land and is not used as a connection or thoroughfare between established communities. Instead, connectivity within the area surrounding the Project site is facilitated via local roadways. The proposed Project would not result in the construction of new driveways; rather, the Project would allow for access via existing driveways on Santa Anita Avenue, Santa Clara Street, Wheeler Avenue, and an alleyway.

Further, the alleyway adjacent to the eastern boundary of the Project site would be partially converted into a pedestrian paseo through the installation of removeable bollards, which would facilitate the Project’s objectives of connectivity to the City’s Downtown. Therefore, the Project does not include the construction of a new roadway that would impair mobility within the existing Project site or the surrounding area. Rather, the Project would increase access at existing driveways and pedestrian/transit connectivity. As such, the Project would not impede movement within the Project site, within an established community, or from one established community to another.

Therefore, impacts associated with the division of an established community would be less than significant. No mitigation is required.

Conflict with an Applicable Land Use Plan, Policy, or Regulation

Consistency with the Connect SoCal (SCAG 2020–2045 RTP/SCS)

SCAG’s Connect SoCal is a regional growth-management strategy that targets per capita GHG reduction from passenger vehicles and light-duty trucks in the Southern California region. The Connect SoCal incorporates local land use projections and circulation networks in city and county general plans. Typically, a project would be consistent with the RTP/SCS if the project does not exceed the underlying growth assumptions within the RTP/SCS.

The proposed Project would result in approximately 909 residents, which would estimate approximately 1.5% of the 2045 SCAG estimate for the City’s projected total population. Additionally, it is likely that the proposed residential

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units would accommodate a combination of existing residents and new residents that either currently work within the City and/or new residents that would be hired as a result of projected employment generation within the City.

Furthermore, the proposed Project is estimated to generate a net loss of 20 employees as compared to existing conditions. This indicates that the proposed Project would not outpace regional infrastructure, since the SCAG RTP/SCS is used for local and regional planning purposes. Furthermore, the proposed Project would implement the guiding principles, goals, and policies of SCAG’s 2020 –2045 RTP/SCS as they relate to livability, economic prosperity, and sustainability through the development of a mixed-use residential development. The development of the proposed Project within proximity to transit would thereby alleviating pressure on suburban and open space areas to develop, is fully supportive of SCAG’s strategies. the proposed Project would not conflict with any of the goals within SCAG’s Connect SoCal. The Project would develop the Project site, producing an estimated 909 residents and a net loss of 20 employees as compared to existing conditions. The Project site’s vicinity is served by existing public transit such as the Metro L Line and vari ous bus routes provided by Metro and Foothill Transit. For these reasons, the Project would not conflict with the applicable goals in the RTP/SCS adopted for the purpose of avoiding or mitigating an environmental effect.

City of Arcadia General Plan Consistency

The proposed Project would result in the construction of a new multi-family residential building on a total lot area of 128,517 square feet (sf), or 2.95 acres. As described in the General Plan, the DMU land use only accounts for commercial square footage in calculation of FAR. The total non-residential area of the proposed Project consists of 83,253 square feet (consisting of a Bank of America building, an 8-story office building, and a 1-story office building). Additionally, the Project includes 8 live/work units with a total of 15,145 square feet in size. Of the total live/work areas proposed, 9,281 square feet would be designated for “work” or commercial uses. Therefore, the total non-residential area, including the existing office an d “work” areas is 92,534 square feet. In summary, the proposed Project’s FAR would result in 0.72, which is consistent with the General Plan’s maximum of 1.0. Applicable policies identified in each element of the General Pl an (Land Use and Community Design Element, Economic Development Element, Circulation and Infrastructure Element, Housing Element, Resource Sustainability Element, Parks, Recreation, and Community Resources Element, Safety Element, and Noise Element) were reviewed and it was determined the Project would be consistent with applicable goals and policies of the General Plan. The proposed Project does not require a General Plan Amendment for implementation to occur and would be consistent with the General Plan for the purposes of avoiding or mitigating environmental effect.

City of Arcadia Municipal Code

The City of Arcadia Development Code, in conformance with the General Plan, regulates land use development in the City. In each zone, the zoning regulations specify the permitted and prohibited uses, and the development standards, including setbacks, height, parking, and design standards, among others. The proposed Project would not require a Zone Change for implementation. The Project requests the following discretionary approvals for Project implementation: Certification of Demolition; Minor Use Perm it with Density Bonus; Site Plan and Design Review; Street Vacation for the Alley; and a Tentative Parcel Map.

Compliance with applicable zoning regulations would reduce potential impacts associated with the avoidance or mitigation of an environmental effect. With the City’s approval, demolition activities would be permitted and review of the proposed site plan for design consistency would occur. The Project proposes a unit mix consisting of 64 studios, 168 one-bedroom units, 79 two-bedroom units, and 8 live-work units. The need for the issuance of a Minor Use Permit is required for the development of multifamily dwellings and live-work units. Additionally, consistent with the General

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51 Plan, the Project site has a base density of 80 du/ac, allowing for a total of 236 dwelling units on the 2.95-acre site.

The Project applicant proposes to utilize a 35% density bonus under SB 1818, which would increase the allowable dwelling unit count to 319 total units. In order to comply with SB 1818, the Project would include 26 affordable dwelling units. Thus, the final unit mix would consist of 293 market rate units, and 26 affordable units, totaling 319 dwelling units. Utilization of the State Density Bonus is further codified in Section 9103.15 of the City’s Development Code. Finally, the approval of a Street Vacation for the Alley on the Project site’s eastern edge and approval of a Tentative Parcel Map is required for Project implementation. The Tentative Parcel Map would merge four of the lots into two legal lots and a portion of the alley would be vacated to accommodate the Project’s design objectives for pedestrian connectivity. Therefore, with the approval of these items, less than significant impacts would occur related to land use regulations adopted for the purposes of avoiding or mitigating an environmental effect.

Cumulative Effects

Cumulative land use impacts could occur if any of the related projects would result in incompatible land uses, or result in land uses that are inconsistent with adopted land use plans when combined with the impacts of the Project.

Given the built-out conditions of the greater Los Angeles Metropolitan region, including the Project site, cumulative development would likely convert existing underutilized prop erties in the Project site’s area to revitalized higher- density developments to respond to the need for housing, sources of employment, and associated retail land uses.

The Project would benefit the surrounding community by replacing underutilized properties; add residential uses to a job-rich community; and improve local and regional access to the regional transportation network. Furthermore, by providing additional housing and employment in close proximity to transit, the Project would assist the City and region in achieving short- and long-term planning goals and objectives related to reducing urban sprawl, efficiently using existing infrastructure, reducing regional congestion, and improving air quality through the reduction of vehicle m i l e s t r a v e l e d . T h i s i s c o n s i s t e n t w i t h S C A G a n d o t h e r regional policies for promoting more intense land uses adjacent to transit stations and job centers.

Generally, land use conflicts would be related to noise, traffic, air quality, and hazards/human health and safety issues. Land use conflicts are also typically site-specific and not cumulative in nature; in other words, despite the number of cumulative projects in a given area, they would not necessarily compound to create cumulative land use conflicts. Cumulative incompatibility issues associated with surrounding developments or projects are anticipated to be addressed and mitigated for on a project-by-project basis. Further, all related projects in the City would be subject to the same local development standards, such as those identified in the City’s Development Code, as the proposed Project. Therefore, cumulative impacts related to land use and planning would be less than significant.

No mitigation is required.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant i m p a c t o n l a n d u s e a n d p l a n n i n g ; t h e r e f o r e , n o m i t i g a t i o n i s r e q u i r e d , a n d n o s i g n i f i c a n t , u n a v o i d a b l e a d v e r s e impacts would occur.

2.3.12 Mineral Resources
There are no oil wells or oil/mineral ex traction activities on the Project site (CalGEM 2020). Current on-site land uses do not allow for oil/mineral extraction. According to the City’s General Plan, Resource Sustainability Element, Figure RS-1 (Mineral Resource Zones), the Project site is within the Mineral Resources Zone-4 (MRZ-4), which is characterized as areas where there are insufficient data to assign any other Mineral Resource Zone designation.7

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52 The MRZ-4 classification does not imply that there is little likelihood for the presence of mineral resources, but rather there is a lack of knowledge regarding mineral occurrence. However, given that the Project site is located within an urban setting, does not currently allow for oi l/mineral extraction, and is not designated for mineral extraction, the Project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on the local general plan or other land use plan. Thus, impacts associated with mineral resources would not occur and will not require further evaluation in the Draft EIR.

Finding

Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to mineral resources; therefore, mineral resources were not addressed in the Draft EIR. No mitigation would be required and no significant, unavoidable adverse impacts would occur.

2.3.13 Noise
Generation of a Substantial Temporary or Permanent Increase in Ambient Noise Levels

Construction Noise (Short-Term Impacts)

Construction noise and vibration are temporary phenomena. Construction noise and vibration levels vary from hour to hour and day to day, depending on the equipment in use, the operations performed, and the distance between the source and receptor.

Construction of the proposed Project would include demolition, site preparation, grading, building construction, paving, and application of architectural coatings and landscaping. No rock blasting, on-site rock crushing or pile driving is anticipated to be necessary as part of this Project.

Equipment that would be in use during construction would include, in part, graders, backhoes, excavators, loaders, cranes, dozers, cement pump trucks, pavers, rollers, welders, concrete saws, and air compressors. Usually, construction equipment operates in alternating cycles of full power and low power, producing average noise levels over time that are less than the listed maximum noise level. The average sound level of construction activity also depends on the amount of time that the equipment operates and the intensity of construction activities during that time.

The Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM) (FHWA 2008) was used to estimate construction noise levels at the nearest occupied noise-sensitive land use (although the model was funded and promulgated by the FHWA, the RCNM is often used for non-roadway projects, because the same types of construction equipment used for roadway projects are often used for other types of construction). Input variables for the RCNM consist of the receiver/land use types, the equipment type and number of each (e.g., two graders, a loader, a tractor), the duty cycle for each piece of equipment (e.g., percentage of hours the equipment typically works per day), and the distance from the noise-sensitive receiver. Although some noise reduction from intervening structures is likely for most of the modeled locations because of the relatively large distances, barrier shielding was conservatively neglected for this analysis. The RCNM ha s default duty-cycle values for the various pieces of equipment, which were derived from an extensive study of typical construction activity patterns. Those default duty- cycle values were used for this noise analysis.

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53 The highest noise levels are predicted to occur during demolition, site preparation, and grading activities. At the nearest noise-sensitive land use (a private school located to the northwest of the Project site), construction noise levels would be as high as 64 dBA L
eq at the school when Project construction occurs near the Project boundary, approximately 630 feet away. At the typical construction activity/receiver distance from the school of approximately 765 feet, construction noise would range from approximately 50 to 63 dBA Leq. At the nearest existing residences and at Arcadia County Park, each located approximately 650 feet from the nearest construction work, noise from construction activities is estimated to range from approximately 51 to 63 dBA L eq.

At the adjacent medical office building, noise levels from construction activities would be as high as 88 dBA L eq when Project construction occurs at the nearest Project boundary, approximately 30 feet away. At the typical construction activity/receiver distance from the medical office building of approximately 165 feet, construction noise would range from approximately 63 to 76 dBA L eq. According to the FHWA (FHWA 2011), the typical noise reduction provided by buildings varies from 20 to 25 dBA for buildings of light frame construction with the windows closed. Buildings constructed using masonry provide approximately 25 to 30 dB noise reduction with windows closed. Conservatively assuming a noise reduction factor of 20 dB, the interior noise level at the medical office building would be as high as 68 dBA L
eq when Project construction occurs at the nearest Project boundary, approximately 30 feet away. At the typical construction activity/receiver distance from the medical office building of approximately 165 feet, the interior noise levels would range from approximately 43 to 56 dBA L eq.

According to the City’s Municipal Code, construction work is prohibited between the hours of 6:00 p.m. and 7:00 a.m. Monday – Friday, 5:00 p.m. and 8:00 a.m. on Saturday, and any time on Sunday and holidays. Although nearby off-site receivers would be exposed to elevated construction noise levels, the noise levels would not be high enough to pose a hazard to human health based on the Division of Occupational Safety and Health (DOSH) standards.

Within the State of California, the DOSH, better known as Cal/OSHA, aims to protect and improve occupational health and safety.

As noted above, at noise sensitive receptor locations, construction noise will reach up to 64 dBA Leq, which is below Cal/OSHA’s AL and PEL. Therefore, construction would not pose human health risks and would not generate a substantial temporary increase in ambient noise levels in excess of standards.

Furthermore, the exposure would be short-term and would cease upon completion of construction. In compliance with the City’s Municipal Code, construction activities associated with the proposed Project would not take place between 6:00 a.m. and 7:00 a.m. on weekdays, 5:00 p.m. and 8:00 a.m. on Saturday, or at any time on Sunday or holidays. Therefore, the proposed Project construction would be in compliance with applicable noise regulations, and therefore construction noise would be less than significant, and no mitigation is required.

Operational Noise (Long-Term Impacts)
Off-Site Traffic Noise
The proposed Project would generate traffic along adjacent arterial roadways (primarily Santa Anita Avenue, Santa Clara Street, Wheeler Avenue, and Huntington Drive). The City does not have a specific criterion for evaluating the significance of Project-related increases in off-site traffic noise levels at residences or noise-sensitive areas. For the purposes of this analysis, Project-generated traffic noise level increases are considered significant if they cause an increase of 3 dBA CNEL (a barely perceptible difference) compared to existing traffic noise levels, or cause noise levels to exceed 65 dBA CNEL at residential land uses or other applicable thresholds based upon the City’s General Plan. If existing traffic noise levels exceed 65 dBA CNEL under existing conditions, impacts are considered significant if the Project increases traffic noise above existing traffic noise levels.

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54 The noise levels associated with roadway traffic were determined based on the Project’s Transportation Technical Memorandum (Appendix K-2) and using the FHWA TNM 2.5 Traffic Noise Model version 2.5 (FHWA 2004). The results of the traffic modeling at the nearby off-site receivers show Project-related traffic would result in a noise level increase of zero (0) dB CNEL (when rounded to whole numbers) along the studied roadways in the vicinity of the Project site. The proposed Project would not result in an exceedance of the City’s 65 dBA CNEL noise threshold for residences or other applicable thresholds, and Project-related traffic would not substantially increase the existing noise levels in the Project vicinity. Therefore, op erational traffic-related noise impacts would be less than significant. No mitigation is required.

Stationary Operations Noise

The incorporation of new multi-family homes and a mix of commercial uses attributed to development of the proposed Project would add a variety of noise-producing mechanical equipment.

Residential Unit Heating, Ventilation, and Air Conditioning Noise: HVAC equipment would be located on the rooftop of the proposed building and would be screened from di rect view by nearby receivers by parapet walls and/or mechanical equipment screen walls. Based upon information provided by the applicant, a total of 327 roof-mounted Carrier air conditioner units would be used for heating, ventilation and air conditioning (HVAC), each with a cooling capacity of 2 tons. From the HVAC manufacturers’ equipment specifications for representative models (details of which are provided in Appendix I-3), the dimensionless sound power levels were found to range from approximately 55 dBA to 73 dBA. Conservatively assuming a sound power level of 73 dBA per HVAC unit, a Microsoft Excel–based outdoor sound propagation prediction model was used to calculate the combined noise level from all 319 units at nearby sensitive receptors

Using the aforementioned noise prediction model, and without consideration of noise reduction due to acoustical shielding from structures other than the proposed Project, the noise levels from the combination of all operating condenser units at the nearby receivers was estimated and noise levels at the nearest receivers would range from approximately 24 to 40 dBA L
eq, which would be well below the applicable noise standards and would also be well below measured ambient noise levels. Therefore, on-site stationary noise would be less than significant. No mitigation is required.

Excessive Groundborne Vibration or Groundborne Noise Levels

Construction activities can expose persons to excessive groundborne vibration or groundborne noise under certain circumstances. Caltrans has collected groundborne vibration information related to construction activities (Caltrans 2020). Information from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips is considered annoying. For context, heavier pieces of constr uction equipment, such as a large bulldozer or similar equipment that may be expected on the Project site, have peak particle velocities of approximately 0.089 ips or less at a reference distance of 25 feet (FTA 2018).

Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions found in FTA and Caltrans guidance. A large bulldozer or similar type of heavy equipment operating on site would generate an estimated vibration level of approximately 0.001 ips at the nearest residences located approximately 650 feet from the Project site. Therefore, because these predicted vibration levels are less than the Caltrans guidance-based annoyance threshold of 0.2 ips PPV, the impact of vibration-induced annoyance to occupants of nearby existing homes would be less than significant. No mitigation is required.

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55 Construction vibration, at sufficiently high levels, can also present a building damage risk. At the nearest office building approximately 30 feet from the Project site, vibration is predicted at approximately 0.067 ips PPV, which is be well below the guidance limit of 0.3 ips PPV for preventing structural damage (Caltrans 2020). Because the predicted vibration levels are less than both the annoyance and building damage risk thresholds, vibration from construction activities would be less than significant. No mitigation is required.

Once operational, the Project would not be expected to feature major onsite producers of groundborne vibration.

Anticipated onsite mechanical systems like pumps, com pressors, and fans are designed and manufactured to feature rotating or reciprocating components (e.g., impellers, rotors, and pistons) that are well-balanced with isolated vibration within or external to the equipment ca sings. On this basis, potential vibration impacts due to Project operation would be less than significant. No mitigation is required.

Expose People Residing or Working in Airport Land Use Plan to Excessive Noise Levels

The Project is not located within the vicinity of a private airstrip, and the nearest airport (San Gabriel Valley Airport, formerly known as El Monte Airport) is located approximately 3.5 miles south of the Project site. The Project is not located within the planning area for this airport, nor is it located within two miles of this airport or any other airport (Airnav.com 2021; County of Los Angeles 2014). Therefore, the Project would not expose people residing or working in the Project area to excessive noise related to public airports. No impact would occur.

Cumulative Effects

Temporary/Periodic Increases in Ambient Noise Levels

The Project would result in temporary noise increases during construction activities, as discussed under 4.10.4(a) above. The construction period of the Project has the potential to overlap with the construction of other development projects in the City. Due to the decrease in noise levels with distance and the presence of physical barriers (i.e., intervening buildings and topography), noise due to construction of other projects would not meaningfully combine with future development under the Proposed Project to produce a cumulative noise effect during construction. By way of illustration, if there are two concurrent constructi on projects of comparable sound emission intensity, and the activity nearest to the studied noise-sensitive receptor is compliant with the City’s applicable noise threshold, the other activity could be no closer than three times the distance of the receptor to the nearest activity and not make a cumulatively measurable contribution to the total and still City-compliant noise exposure level. Cumulative construction noise is likely to be dominated by the closest or loudest activity to the receptor, and the combination will be no more than a barely perceptible difference (i.e., up to a 3 dB change). Based on the cumulative project list provided by the City for the Project, there are no construction projects that would potentially contribute construction noise that would, in combination with the Project, result in cumulat ive impacts. Thus, cumulative impacts associated with temporary increases in ambient noise levels would be less than significant.

Vibration

Construction-related vibration from future development under the Project was addressed under Threshold 4.10.4(b) above. Other foreseeable projects within the vicinity of the Project site would not be close enough to create a combined excessive generation of groundborne vibration; therefore, cumulative impacts associated with excessive groundborne vibration would be less than significant.

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56 Permanent Increase in Ambient Noise Levels
Off-Site Traffic
Future development from implementation of the Project along with other unrelated projects would generate off- site traffic noise. When calculating future traffic impacts, the traffic study included traffic attributed to both the Project and unrelated projects. Thus, future traffic noise prediction results with and without the Project already account for the cumulative impacts from unrelated projects contributing to traffic increases. Since the noise impacts are generated directly from the traffic analysis results, the Existing and Year 2024 traffic with and without Project predicted increases in traffic noise levels described herein already reflect cumulative impacts. As described herein, the noise level increases associated with both of these scenarios would not exceed applicable standards. As such, anticipated increases would be below the significance thresholds; hence, the incremental effect of the Project on off-site traffic noise is not cumulatively considerable. Cumu lative off-site traffic noise impacts would be less than significant.

Stationary Sources

Noise from operation of stationary mechanical equipment added to the outdoor ambient sound environment as a result of Project implementation would include permanent on-site noise sources (e.g., rooftop HVAC equipment) as addressed under Section 4.10.4, Impacts Analysis, under Threshold 4.10a. A cumulative impact could occur if noise produced from such sources due to implementation of the Project were to combine with noise produced from the operation of other unrelated projects in the vicinity to create a cumulatively significant permanent increase in ambient noise levels. However, noise emission from HVAC equipment attenuates with distance and can be occluded by structures and terrain. Additionally, the operation of the Project, along with the operation of other unrelated projects, would be subject to applicable requirements from the City’s noise ordinance, which limits the exterior noise levels at residences. Hence, for these two reasons, cumulative impacts to outdoor ambient noise levels resulting from Project stationary sources would be less than significant.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on noise as it relates to groundborne vibration, exposing people residing or working within an airport land use plan to excessive noise levels, and cumulative noise impacts; therefore, no mitigation is required and no significant, unavoidable adverse impacts would occur.

2.3.14 Population and Housing
Induce Substantial Population Growth

Short-Term Construction Impacts

Construction activities at the Project site would lead to the temporary need for construction workers, which may come from the City, other areas of Los Angeles County, or elsewhere within the SCAG region. The proposed Project involves fairly common construction requirements that would not require a highly specialized labor force to permanently relocate from other regions. Construction of the Project is anticipated to start in June 2023, in which construction would last approximately 26 months, ending in August 2025. The different construction activities require specific skill sets for a much shorter duration than the overall construction schedule. Because

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57 construction workers would not be needed continuously and only for varying portions of the Project phases, it is reasonable to assume that workers/crews would work at the Project site on a temporary basis only, and thus, are not likely to relocate their households as a consequence of the construction job opportunities presented by the Project. Because the demand for construction workers would be short-term, and because the Project site within an urban metropolitan region with a high diversity of skille d labor, a permanent need for new workers to relocate in order to accommodate the proposed Project’s temporary construction workforce is not anticipated. Any changes in the City or regional population, housing, or employment due to short-term construction activities would be less than significant.

Long-Term Operational Impacts

The proposed Project would demolish some of the existing structures on the Project site, including a 2-story office building, two 1-story commercial buildings, and surface parking. The Project site also contains an existing 8-story office building and 1-story bank drive-through, which woul d remain in place. The Project would redevelop the site with the construction of a 7-story multi-family residentia l building, consisting of 319 dwelling units with various residential amenities throughout the building and Project site. An outdoor plaza would be constructed between the 8-story office tower and the proposed residential building. In addition, approximately 750 square feet of lobby space within the existing 8-story building would be converted into a café, while the alleyway adjacent to the eastern boundary of the site would be converted into a pedestrian paseo. The Project would also include a total of 576 parking spaces, contained within two above-ground parking areas, within Levels 1 and 2 of the proposed building, and two subterranean parking levels. Implementation of the proposed Project would not require a General Plan Amendment or Zone Change. Therefore, the proposed Project would directly result in building new housing where housing currently does not exist.

Population Projections

SCAG estimated that Los Angeles County had 10,407,000 residents in 2020 and estimates the county would have 11,647,000 residents by 2045. The U.S. Census Bureau determined the City had a total of 56,681 residents in 2020 and SCAG estimates 62,200 residents by 2045. As such, the forecasted population growth for the City of Arcadia is 5,519 persons between 2020 and 2045.

Using population and housing estimates from the California Department of Finance, the City has an occupancy rate of 2.85 persons per household (DOF 2021). Assuming 2.85 persons per household, the proposed Project’s residential units would accommodate 909 individuals. Addition ally, it is likely that the proposed residential units would accommodate a combination of existing residents an d new residents that either currently work within the C i t y a n d / o r n e w r e s i d e n t s t h a t w o u l d b e h i r e d a s a r e s u l t o f p r o j e c t e d e m p l o y m e n t g e n e r a t i o n w i t h i n t h e C i t y .

Additionally, the City’s 2021 housing vacancy rate of 6.3% is slightly less than Los Angeles County’s housing vacancy rate 6.4% (DOF 2021).

The U.S. Census Bureau determined, based on the 2020 Census results, there were 56,364 residents in the City in 2010 (U.S. Census 2021). The City’s General Plan estimated a buildout population of 61,994 residents by 2035 (see Table 4.11-5). SCAG’s Connect SoCal projections of 62,200 persons by 2045 represents an expectation that
the City will meet the population growth set forth in th e General Plan. When considering the 2035 buildout of the General Plan, it can be interpreted that the proposed Pr oject’s anticipated population of 909 residents would be fulfilling a 2035 population projection that was anticipated at the time of the preparation of the City’s General Plan.

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58 The proposed Project would accommodate an expected 909 residents which would be counted within the overall population growth projections included in the Connect SoCal of 5,519 residents between 2020 and 2045.

The proposed Project would be considered growth-accommodating rather than growth-inducing in that the proposed Project’s 319 new residential units would accommodate 909 residents, which are anticipated to be a mix of current and future residents to the City. If all 909 residents would be new to the City, the Project would be within the overall population growth projections included in the Connect SoCal.

Because the proposed Project would support SCAG’s goals and strategies for growth in the region and because the proposed Project would assist the development of new housing and improves the City’s job/housing balance, impacts related to population growth would be less than significant.

Employment Projections

The Project would develop a new residential building, which would require staffing to support on-site services. In addition, the proposed Project would include 8 live/work units. As further detailed in Appendix K-2 of this Draft EIR, approximately 9,281 square feet of the live/work units would be considered a commercial/retail land use. The Project also includes the interior renovation of the existing 8-story office tower in order to convert the space into a new 750 square foot café. Given that the existing office and commercial land uses on site would be demolished, the Project would result in a loss of approximately 50 potential jo bs and the proposed Project is anticipated to generate approximately 30 jobs. Therefore, the proposed Project is estimated to generate a net loss of approximately 20 jobs as compared to existing conditions.

Although the proposed Project would result in a loss of 20 employment opportunities at the Project site, the proposed Project would not result in a significant effect to the City or region. According to the California Employment Development Department, preliminary results find approx imately 10.4% (529,700 persons) of the Los Angeles County’s 5,108,400 person-labor force were unemployed as of July 2021, and approximately 7.8% (2,300 persons) of the City’s 29,300 person-labor force were unemployed in July 2021 (EDD 2021). Given the fact that unemployment rates during COVID-19 may be skewed when compared to previous years, the 2019 rates were also evaluated. According to the California Employment Development Department, approximately 4.6% (234,400 persons) of the Los Angeles County’s 5,090,800 person-labor force were unemployed as of July 2019, and approximately 3.7% (1,100 persons) of the City’s 29,800 person -labor force were unemployed in July 2019 (EDD 2021). As such, it can be assumed that many of the 30 new jobs would be filled by individuals that live within the City.

As previously discussed above, the number of jobs in the City would decrease by approximately 20 positions as a result of the Project. Therefore, the proposed Project would not contribute to SCAG’s employment growth projections in Los Angeles County, nor would the Project contribute to SCAG’s employment growth projections for the City.

Instead, the estimated loss of 20 jobs at the Project site resulting from the proposed Project would represent a nominal change to the City’s jobs-rich community, as further described below.

Housing Projections Analysis

SCAG projects that Los Angeles County will have an increase of 647,000 housing units between 2020 and 2045, and that the City will have an increase of 1,111 units during this same period. The proposed Project’s 319 residential units would represent 0.05% of SCAG’s projected housing for Los Angeles County and 28.7% of the projected housing for the City. Therefore, the proposed Project’s housing units would not exceed the projections for housing within the City, as set forth in the 2020–2045 RTP/SCS.

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California’s housing element law requires that each city and county develop local housing programs designed to me et its fair s h are of exist ing and fu tur e h ou sing ne eds for all inc o me gr ou ps. This eff ort is co ordin at ed w he n preparing the state-mandated Housing Element of the City’s General Plan. This fair share allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of, not only its resident population, but for all households that might reasonably be expected to reside within the jurisdiction, particularly lower income households. This assumes the availability of a variety and choice of housing accommodations appropriate to their needs, as well as certain mobility among households within the regional market.

Because the proposed Project will be occupied within the timeframe of the 6th Cycle, it is most relevant to the analysis.

The City’s fair share allocation for the planning period is 3,214 units. This indicates that between the years 2021 to 2029, the City needs to accommodate at least 3,214 housin g units, consisting of a variety of housing types to accommodate extremely low, very low, low, moderate, and above moderate-income households to keep pace with housing demand. The proposed Project would create new housing and would include affordable housing in accordance with SB 1818. The specific allocation between the types of low-income housing has yet to be determined; however, the proposed low-income units would satisfy a portion of the City’s mandated 6 th Cycle RHNA allocation.

As such, the proposed Project’s 319 new residential unit s would assist the City in meeting the mandated RHNA allocation and would be consistent with and supportive of the City’s Housing Element projections for new residential units within the City.

Jobs/Housing Balance

The City is considered to be a jobs-rich community. The proposed Project would generate additional housing available for the community, as the jobs-housing balance of the proposed Project would be 0.09:14, which is a housing-rich project.

As such, the proposed Project would be contributing additional housing to the City’s jobs-rich community and would assist in meeting the mandated RHNA allocation of housing units. In conclusion, the proposed Project would facilitate a more balanced jobs-housing profile for the City by adding more housing to a city with an approximately 1.6:1 jobs to housing ratio (SCAG 2020b).

Displace Substantial Numbers of Existing Housing or People

The Project site, under existing conditions, consists of surface parking as well as the commercial and office space.

No housing units are located on the Project site. Thus, Project implementation would not require demolition of existing housing or displace people or housing. The proposed Project would include the construction of a mixed-use development that would add approximately 319 housing units to the City. Impacts would be less than significant.

Cumulative Effect

Assuming 2.85 persons per household, the proposed Project’s residential units would accommodate 909 residents.

Additionally, the Project is estimated to result in a net loss of 20 employees as compared to the existing conditions.

The remaining cumulative projects would primarily be increasing employment in the City and potentially further exacerbating the jobs-rich profile of the City, which could increase the vehicle miles traveled between employment centers and residential land uses. While the proposed Project would provide employment opportunities to the local and regional area, the net loss of employment opportunities on site would not contribute to current projections for employment growth in the City or Los Angeles County. The planned growth of cumulative projects within the City includes over 73,795 square feet of additional commerc ial development. With the addition of the 319 housing units, the proposed Project is anticipated to facilitate a more balanced jobs-housing profile for the City of Arcadia.

4 30 jobs and 319 housing units = 30/319 = 0.09
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A total of 486 units are proposed within one mile of the Project site, all of which are within the City limits. In addition to the proposed 319 units of housing growth by the Project, the cumulative total would be estimated at 805 new units. Given that the City’s Housing Element is currently undergoing an update in accordance with State law and at the time of this Draft EIR’s production, state and regional projections are used for analysis comparison. The California Department of Finance estimates 21,289 units exist within the City. Moreover, SCAG estimates a total of 22,400 units would be built by 2045. As such, the addition of 805 units would result in 22,094 new units in the City once the proposed Project is operational in 2024. Therefore, the estimated household growth is within the state and regional growth projections. Furthermore, the proposed housing growth generated by the Project would further the goals and strategies of SCAG and the City’s General Plan by providing housing in an urban setting in close proximity to transit, while contributing to a more balanced jobs-housing community. Although, the proposed Project’s residential population would not exceed SCAG’s population projections, it can also be assumed that many of the residential units would accommodate workers within the City and could reduce vehicle miles traveled by providing housing in proximity to employment centers.

Cumulative population growth could be assumed using the previously identified 2.85 persons per household. Thus, the related projects could result in approximately 1,385 persons. In addition to proposed population growth generated by the Project (909 residents), a total of 2,294 persons is anticipated. As such, 58,975 persons are estimated at build out of both the related projects and the proposed Project, which is within SCAG’s projected population growth of 62,200 persons for the City by 2045. Thus, it is not anticipated that the proposed Project, in combination with other future foreseeable projects, would create a cumulatively considerable impact to population, housing or employment.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on population and housing related to inducing growth during construction and displacing a substantial number of people or housing; therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.

2.3.15 Public Services and Recreation
Fire Protection

Construction

Construction activities associated with the proposed Project may temporarily result in a slight increase demand for fire protection and emergency medical services. Construction activities may involve the operation of construction equipment and machinery, storage, handling, and disposal of combustible materials, and the use of flammable or toxic materials.

To comply with California Department of Industrial Relations, Division of Occupational Safety and Health and Fire and Building Code requirements, constr uction managers and personnel would be trained in fire prevention and emergency response, and fire suppression equipment specific to construction would be maintained on site. Project construction would comply with all applicable codes and ordinances related to the maintenance of mechanical equipment, handling and storage of flammable materials, and cleanup of spills of flammable materials. City and state regulations and code requirements would, in part, require personnel to be trained in fire prevention and emergency response, maintenance for fire suppression equipment, and implementation of proper procedures for storage and handling of flammable materials. Thus, compliance with regulatory requirements would reduce the potential for construction activities to expose people to the risk of fire explosion related to hazardous materials.

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Section 21806 of the California Vehicle Code allows drivers of emergency vehicles to have a variety of options for avoiding traffic, such as using sirens to clear a path of travel and driving in the lanes of opposing traffic. Based on these considerations, construction of the proposed Project would not be considered a high-risk activity, and the AFD is equipped and prepared to deal with construction-related traffic and fires, should they occur. Due to compliance with applicable codes and fire safety standards, Project construction would not adversely impact firefighting and emergency services in their ability to maintain acceptable service ratios, response times or other performance objectives for fire protection. Therefore, impacts are less than significant, and no mitigation is required.

Operation

The Arcadia Fire Department (AFD) currently serves the Project site and the surrounding area. Each additional development that provides net new square footage creates a greater demand on existing resources. The increased use of the Project site resulting from the Project would be expected to increase the frequency of emergency response calls relative to existing conditions. However, for the reasons enumerated below, the proposed increase in development intensity at the Project site would not result in substantial adverse physical impacts associated with the need for new or expanded fire protection facilities.

The need for new or expanded public services (such as fire protection facilities/structures/buildings) is associated with a substantial population increase, a substantial increase in developed structures, and/or a substantial increase in fire activity, such as wildfire hazards. Project employment and new residential uses would result in a net loss of approximately 20 employees (as compared to exis ting conditions) and 909 new residents on the Project site. The proposed Project would support SCAG’s goals and strategies for growth in the region.

The Project site is currently served by three existing fire stations (Stations 105, 106, and 107). The AFD stated that as the City continues to develop high density projects, call volume for fire services will continue to increase, which will result in longer response times. With the addition of the proposed Project, services would be incrementally impacted. However, the AFD has indicated that the proposed Project would not directly result in the need for new facilities and/or physically altered facilities in order to maintain acceptable service ratios, response times, or other performance objectives of the AFD. No expansion of fire department facilities is currently contemplated or required to serve the proposed Project, and no new fire stations are required to serve the proposed Project (Appendix J-1).

Therefore, impacts would be less than significant and no mitigation is required.

Furthermore, the proposed Project would be designed and constructed in accordance with all applicable provisions of the fire code, which includes requirements for adequate fire flows, width of emergency access routes, turning radii, automatic sprinkler systems, fire alarms, and floor to sky height limits along emergency access routes.

Compliance with the fire code standards would be ensured through the plan check process and fire review prior to the issuance of building permits for the Project. More specifically, the proposed Project would be designed to include the following fire protection features, which would help pr event fire hazards: appropriate roadway access for fire lines, AFD connections and fire sprinkler system control valves, and a fire alarm system. The building would also be equipped with fire pumps and alarms consisting of smoke detection, voice alarm capability, and visual alarms.

These fire safety features and compliance with fire co de standards would reduce th e potential demand for fire services by decreasing the likelihood and/or severity of a fire emergency at the site.

The operational phase of the proposed Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Hazardous materials would be limited to use of commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available substances typically used at office and residential establishments. Although the Project would introduce

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62 commercially available potentially hazardous materials, such as cleaning supplies and landscaping products, to future residents, employees, and visitors of the Project site, the use of these substances would be subject to applicable federal, state, and local health and safety laws and regulations that are intended to minimize health risk to the public associated with hazardous materials. The use of commercially available hazardous materials would not significantly impact AFD services.

According to the Engineering Due Diligence Report (Appendix G of this Draft EIR) there are three mains located on the Project site available for domestic water and/or fire services connections. The specific location of new connections required for Project implementation and pipe sizing would be based upon the City’s requirements and subject to City approval. The system must provide adequa te water supply for operation of the building’s domestic requirements, automatic sprinkler systems and fire hydr ants. Fire flows for the proposed development must be based on the requirements listed in the California Fire Code that is in effect at the time of plan submission, as amended by the City.

The Project site is located within an urbanized area and is not located within a Very High Fire Hazard Severity Zone (CAL FIRE 2021). The Project is surrounded by roadways and developed properties on all sides and is entirely developed, so it is not susceptible to exacerbating wildfire risks. Further, the Project site does not contain extensive amounts of vegetation or wildland fuel. Therefore, the Project would not result in increased potential for wildland fire hazards that could affect AFD services.

Given the reasons described above, the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities. Impacts would be less than significant and no mitigation is required.

Police Protection

Construction

There is the potential for Project construction activities t o c r e a t e a n i n c r e a s e i n d e m a n d f o r p o l i c e p r o t e c t i o n services, as construction sites can be sources of attractive nuisances, can provide hazards, and can invite theft and vandalism when not properly secured. This could result in an increase in the demand for police protection services.

During construction, the Project Applicant/developer or its construction contractor would implement temporary security features including security fencing, lighting, and locked entry. These features would reduce the need for police protection services during the Project’s constructi on phase. Potential short-term construction impacts to police services would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, and impact s would be less than significant and no mitigation is required.

Operation

As with fire protection services, the increased use of the Project site attributable to the proposed Project would be expected to increase the frequency of emergency and non-emergency calls to the Arcadia Police Department (APD).

While the Project site currently places some demand on the APD due to the occupied commercial and office buildings, the proposed Project would increase demands re lative to existing conditions. The APD has stated that the existing police station facilities are sufficient to provide service to the proposed Project and that the development of the proposed Project would not result in the need for new facilities and/or physically altered facilities to maintain acceptable service ratios, response times, or other performance objectives (Appendix J-2).

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63 The Project site is currently served by the APD at 250 West Huntington Drive. No expansion of this facility is currently contemplated or required for the proposed Project (Appe ndix J-2). Payment of development fees by the Project Applicant/developer would be used to offset the costs of increased personnel or equipment that could be required to maintain acceptable service ratios, response times, and other performance objectives. The proposed Project would incorporate operational practices and design elements to increase safety and to reduce the potential for crime to occur, including constructing buildings equipped with alarm systems and access controls, and clear visibility of public spaces and pedestrian corridors. Signage and lighting would be used to facilitate wayfinding and safe pedestrian movement throughout the site and within the proposed buildings.

The APD has reported the current APD established performance standards are being achieved and the existing police station is sufficient to provide service to the proposed Project (Appendix J-2). For these reasons, the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities and potential impacts would be less than significant and not mitigation is required.

Schools

The proposed Project’s approximately 909 residents would generate students that would attend AUSD schools.

Using the student generation rates from AUSD, at 319 dwelling units, the Project could generate approximately 137 new students (Appendix J-3). Communication with Arcadia Unified School District (AUSD) indicates the existing schools are sufficient to support the proposed Project, and that all schools are below their capacity, even when including the projected increases due to the Project (Appendix J-3). Education Code Section 17620 allows school districts to assess fees on new residential and commer cial construction within their respective boundaries.

Pursuant to California Government Code Section 65995, the payment of these fees by a developer serves to fully mitigate all potential project impacts on school facilities from implementation of a project to less-than-significant levels. Sections 65996(a) and (b) state that such fees collected by school districts provide full and complete school facilities mitigation under CEQA. These fees can be collected without special city or county approval, to fund the construction of school facilities necessitated by the impact of residential and commercial development activity.

The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required to pay to mitigate a project’s impacts on school facilities. The maximum fees authorized under SB 50 apply to zone changes, general plan amendments, zoning permits and subdivisions. Pursuant to SB 50, the applicant would be required to pay development fees for schools to AUSD prior to the issuance of the Project’s building permit. The provisions of SB 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other state or local la w. Therefore, with the payment of the applicable school fees, the operation of the Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered schools, or the need for new or physically altered schools, the construction of which could cause significant environmental impacts to maintain acceptable service ratios, or other performance objectives for schools. As such, impacts on schools would be less than significant and no mitigation is required.

Parks

The Project would include 909 new residents. At least a portion of these residents are anticipated to patronize the various public parks and recreation facilities located in proximity to the Project site. The Project would redevelop the space between the existing office building and the proposed residential building with a new paseo and outdoor plaza. This community open space area would include on-site wayfinding features, minimized vehicular access, flexible pedestrian space, seating, trees and enhanced plantings, lighting, bicycle parking. The proposed Project

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64 would provide approximately 23,957 square feet of private open space and 17,398 square feet of public open space, which exceeds the City’s requirement for 31,900 square feet of open space.

The CDPR minimum standard of park space is approximately 3 acres per 1,000 residents. The Los Angeles County average is 3.3 acres per 1,000 residents, and the City’s strives to provide a minimum of 2.43 acres per 1,000 residents. The City and the County currently differ on where the City stands regarding the acreage per 1,000 resident ratio because they each use different methodologies for determining the available park acreage. According to the LACDPR, under existing conditions the City currently provides 1.32 acres of parkland per 1,000 residents (Appendix J-4), and according to the ARCSD, the City provides 2.38 acres per 1,000 residents (Appendix J-4). According to both agencies, the City is not currently meeting the acre per resident goal of 3.3 acres (County) and

2.43 acres (City) per 1,000 residents, respectively. When the projected population increase related to the Project is incorporated, the City would continue to underperform when compared to the standards provided by both the City and the County.

The state utilizes a slightly different model for calculating park service ratios. As previously discussed, the CDPR FactFinder tool calculates parks acreage per 1,000 residents within a half-mile radius of a given center point (i.e. 150 North Santa Anita Avenue). According the CDPR, under existing conditions, the Project site is in a location with an abundance of park space (19.68 acres per 1,000 residents), which significantly exceeds the minimum standards provided by the CDPR, LACDPR and ARCSD. Under projected Project conditions, the City would continue to exceed the minimum acreage standards by at least a factor of five (CDPR 2021). The City does not consider the Special Parks, Joint-Use Parks and Facilities, County Parks and Faci lities as municipal assets for recreation and does not take credit for these facilities in the calculation of acres of parkland per residents. However, these additional 545 acres of parks and recreation facilities within the City do provide an important asset for the City residents and towards the overall available open space and recreation amenities within the City.

Nevertheless, the City does not currently provide the 2.43 acres per 1,000 residents, as required by the City’s General Plan. In order to address the additional demand on recreational facilities within the City, the proposed Project would be subject to the City’s Council Resolution 6602, Park Facilities Impact Fee (Section 9105.15.040 of the City’s Development Code), which requires new development projects to pay impact fees, which would support park improvements as well as fund capital costs for new and existing recreational infrastructure. Pursuant to the Park Facilities Impact Fee resolution, the Project Applicant/developer would pay its fair share of impact fees based on the fee category and adopted impact fee rates. While the ARCSD indicates that new park facilities would be required under both existing and Project conditions to meet the City’s performance standards, the mitigation fees paid to the City as part of the proposed Project would fairly compensate for the Project associated increase in demand or use of park facilities. Fees for the proposed Project are currently set at $3.73 per square foot, which applies to all multifamily housing developments (City of Arcadia 2021a). Further, the Project would include common open space areas, including an outdoor pool area, fire pit, barbeque dining area, game lounge, and a lawn/grassy area, as well as an outdoor passive court. These on-site amenities would provide an alternative to off-site public parks and recreational facilities, allowing the Project’s residents to recreate on the Project site while incrementally reducing impacts to off-site public parks and recreational facilities. Therefore, with required payment of fees as mandated by the City’s Development Code, impacts associated with the need for new or expanded park facilities would be less than significant and no mitigation is required.

Other Public Facilities

Other public facilities and services provided within the City include library services. Library services are provided at the APL located at 20 West Duarte Road, approximately 0.9-mile south of the Project site. The APL indicated that

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although library staffing is currently not meeting their goal of a 0.9-ratio of staff per 1,000 residents, this existing staffing deficit would not result in the need to provide any new library facilities and/or physically altered facilities to maintain performance objectives of the Arcadia Public Library (Appendix J-5).

Another library located within the City boundaries is the Live Oak Library, which is managed by the County and located 2.8 miles south of the Project site at the far southern end of Arcadia. The County levies a developer fee for new residential projects within the unincorporated County and levies a special tax on parcels within 10 incorporated cities, excluding Arcadia. As such, the proposed Project is outside of the Live Oak Library service area and is not subject to any fees. The County’s library is 2.8 miles away from the Project site and is not anticipated to be utilized frequently by proposed Project residents, as the APL is located almost two miles closer to the site.

The proposed Project is a mixed-use development project th at would contribute to the tax revenues for the City, thereby contributing to potential funding sources for librar y services. As stated above, the APL has indicated that no new library facilities are required to serve the proposed Project. Therefore, impacts to other public facilities in the area resulting from the proposed Project would be less than significant and no mitigation is required.

Increase in the Use of an Existing Neighborhood, Regional Park, or Recreational Facility

The Project would include 909 new residents. As previously discussed, the ARCSD is responsible for developed park land that provides a wide variety of attractions and amenities. The City also offers a wide variety of recreational programs and activities for residents, which have transitioned to become entirely virtual, for the time being. Virtual offerings include soccer drills and yoga classes for kids an d seminars for adults and seniors. At least a portion of the potential future residents are anticipated to patronize the various public parks and recreation facilities located in proximity to the Project site. Pursuant to the Section 9105.15.040 of the Development Code, the Project Applicant/developer would pay its fair share of impact fees based on the fee category and adopted fee rates, currently set at $3.73 per square foot for multifamily developments. While the ARCSD indicates that new park facilities would be required under both existing and Proj ect conditions to meet the City’s performance standards, the mitigation fees paid to the City as part of the proposed Project would fairly compensate for the Project associated increase in demand or use of park facilities. Fees for the proposed Project are currently set at $3.73 per square foot, which applies to all multifamily housing developments (Appendix J-4). Further, the Project would include common open space areas, including an outdoor pool area , fire pit, barbeque dining area, game lounge, and a lawn/grassy area, as well as an outdoor passive court. These on-site amenities would provide an alternative to off- site public parks and recreational facilities, allowing the Project’s residents to recreate on the Project site while incrementally reducing impacts to off-site public parks and recreational facilities.

As such, with payment of the required development impact fees related to parks and recreation in combination with provision of on-site recreational facilities, the Project would meet the anticipated demand for neighborhood and regional parks or other recreational facilities. Project residents and, to a certain extent, the public utilizing the improved pedestrian corridor and/or café, would have access to adequate on-site recreational facilities, which would offset increased use of existing parks and recreational facilities in the City. Therefore, implementation of the Project would not result in a substantial increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur. Impacts to neighborhood and regional parks would be less than significant and no mitigation is required.

Inclusion of or Requirement for Construction/Expansion of Recreational Facilities

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area, there is an abundance of park space under both existing and projected Project conditions. The Project would also include common open space areas, as well as landscaped areas around the Project site, including an outdoor pool area, fire pit, barbeque dining area, game lounge, and a lawn/grassy area, as well as an outdoor passive court.

The construction of these common open space areas and associated recreational amenities is analyzed under this EIR. As demonstrated throughout this Draft EIR, any environmental impacts as a result of Project implementation would be reduced to a less-than-significant level through the incorporation of the mitigation measures described throughout. Additionally, the Project would be subject to th e Park Facilities Impact Fee resolution, which requires new development projects to pay impact fees, which would support park improvements as well as fund capital costs for other new and existing infrastructures. Pursuant to th e Impact Fee, the Applicant/developer would pay its fair share of impact fees based on the fee category and adopted fee rates, currently set at $3.73 per square foot. As such, Project implementation would not require the construction or expansion of recreational facilities, and impacts would be less than significant.

Cumulative Effects

The cumulative study area used to assess potential cumulative population and housing impacts includes the City of Arcadia, AFD and APD service areas, and the AUSD. Cumulative impacts on public services including fire and police protection, parks, and schools would result when projects collectively increase demand on services such that additional facilities or services must be constructed or provided.

Fire Protection

A cumulatively significant impact related to fire protec tion and emergency services could occur as a result of population growth and development within the AFD service area due to the Project and cumulative projects. The Project, along with cumulative projects, could result in increased calls and demands for fire protection and emergency services. The AFD stated that as the City continues to see higher density projects, call volume will continue to see an increase, which will result in longer response times. Additionally, response times would inevitably increase due to the increased burden of access asso ciated with responding to incidents in multi-story developments—such as the proposed Project—including the need to traverse up and/or across through stairwells, elevators, and/or use of the aerial ladder. In addition, in downtown Arcadia there are a number of new mixed-use buildings of similar density to the proposed Project being contemplated.

As such, the AFD is currently conducting analysis of the call response times and staffing resources that may be necessary to keep response times within the City's guidelines. This analysis may result in a AFD Program or Impact Fee and may result in a fair share contribution from this Project, as described under “Conditions of Approval” above, as well as subsequent projects in the downtown area. This AFD Program or Impact Fee would fund solutions to address the densification and multi-story development within the City and the downtown area specifically. An anticipated solution to be funded by the AFD Program or Impact Fee to help decrease response times and increase emergency response safety would be the implementation of an alerting or pre-emption system that is integrated with the City's traffic light system.

An example of such a system is HAAS ALERT. Such a system would not result in physical impacts to the environment, as such technologies generally consist of a software program that would be mounted to the existing traffic lighting system on existing streets. The AFD is currently working on a study that will apply to the downtown area.

The AFD has not identified the need for any new or altered fire stations or governmental facilities that would have the potential to result in substantial adverse physical impacts, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services. Therefore, potential cumulative impacts would be less than significant, and no mitigation is required.

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Additionally, both the Project and cumulative projects wo uld be subject to the requirements of the fire code standards. This would be ensured through the plan check process and fire review prior to the issuance of building permits for the Project and cumulative projects. Furthermore, the Project and cumulative projects would coordinate with the Arcadia Fire Department Fire Prevention Division to ensure fire flow requirements are met and any required upgrades to the existing water distribution system are addressed for each individual project. As determined by AFD, existing fire protection facilities are sufficient to m eet the proposed Project (Appendix J-1). Based on the above considerations, the Project’s contribution to cumulative im p a c t s t o f i r e p r o t e c t i o n s e r v i c e s w o u l d b e l e s s t h a n significant.

Police Protection

A cumulatively significant impact related to police protection services could occur as a result of population growth within the APD service area due to the Project and cumulative projects. The APD has stated that the existing police station facilities are sufficient to provide service to the proposed Project and that the development of the proposed Project would not result in the need for new facilities and/or physically altered facilities to maintain acceptable service ratios, response times, or other performance objectives (Appendix J-2). As with the proposed Project, the applicants of the cumulative projects would be required to incorporate appropriate safety features into the design and construction of their respective projects to minimize the potential for crime and to maximize safety, ultimately minimizing the need for police protection services. In addition, the cumulative projects would contribute to funding police protection services or new facilities through development impact fees. Based on the above considerations, the Project’s contribution to cumulative impacts to police protection services would be less than significant.

Schools

The increase in student population as a result of the pr oposed Project and cumulative residential projects could require the construction or expansion of school facilities. The proposed Project itself, as determined by AUSD would not result in significant impacts on service demand (Appendix J-3). While most cumulative projects require discretionary actions, they would incrementally increase the need for school facilities. However, Education Code Section 17620 allows school districts to assess fees on new residential and commercial construction within their respective boundaries. Pursuant to California Government Code Section 65995, the payment of these fees by a developer serves to fully mitigate all potential project impacts on school facilities from implementation of a project to less-than-significant levels. Sections 65996(a) and (b) state that such fees collected by school districts provide full and complete school facilities mitigation under CEQA. Therefore, the increase in the demand for school facilities and services due to cumulative development would be less than significant level by the payment of development impact fees.

Parks and Recreational Facilities

Buildout of the Project along with cumulative projects would increase use of existing local and regional parks and could result in the accelerated deterioration of park and recreation facilities. As discussed, the Project itself would result in less than significant impacts to park and recreation facilities. The deterioration that would occur to local parks and recreational facilities from regional population growth may be offset with funding from new development through Park Facilities Impact Fees. Cumulative projects would be required to demonstrate compliance with CEQA prior to Project approval, and existing federal, state, and local regulations related to parks and recreational facilities would mitigate potential adverse impacts to the environment that may result from the expansion of such facilities.

Therefore, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact to park facilities.

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Other Public Facilities (Libraries)

Future cumulative development would generate new tax revenues and would be subject to the City’s development impact fees, which act as funding sources for City libraries. The proposed Project itself, as determined by the APL, would not result in new physical facilities (Appendix J-6). The Project and cumulative projects would be required to fund their fair share of an established fee program designed to alleviate the cumulative impact. These revenues would help offset the increase in demand for library services as a result of the Project. Therefore, cumulative impacts to library services would be less than significant.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on police and fire protection services, parks, schools, and other public facilities as well as impacts related to recreation; therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.

2.3.16 Transportation
Conflict with Circulation System Plan, Ordinance, or Policy

RTP/SCS Consistency Analysis

The Project would facilitate a more balanced jobs-housing profile and once constructed, would continue to support regional economic development. In addition, the Project site’s vicinity is served by existing public transit including Metro Routes 79, 187, and 287 and the Metro L Line; Foothill Transit Line 187; and Arcadia Transit’s Green and Red Lines. Project development would increase transit accessibility of jobs and services within the Project site’s vicinity and would bring residential development the City’s Downtown, which contains a mix of office and commercial development uses, thereby reducing travel demands for people. Further, the Project includes objectives to support walkability and increased pedestrian access to support connectivity with the nearby Arcadia Metro L Line Station. For these reasons, the proposed Project would not conflict with the applicable goals in the RTP/SCS.

City of Arcadia General Plan Consistency

The Project would be consistent with the applicable goals and policies of the City’s General Plan. The project would not hinder the City’s ability to provide an efficient roadway system that serves all transportation modes and balances the roadway system with planned land uses. The project would support the City’s goals to provide a connected, balanced, and integrated bicycle and pedestrian network by developing a mixed-use project that promotes pedestrian connectivity with the City’s Downtown and includes on-site improvements to facilitate circulation and community cohesion within the existing environment.

Transit, Bicycle, and Pedestrian Facilities

The proposed Project would support transit, bicycle, and pedestrian circulation throughout the Project site and the surrounding environment and would not conflict with any plan s or policies regarding existing or proposed transit, bicycle, and pedestrian facilities in the study area.

The Project would include bicycle parking as well as on-site improvements to support pedestrian connectivity with the City’s Downtown and nearby Arcadia Metro L Line Station. Site improvements include redeveloping the space between the existing office building and the proposed residential building with a new paseo and outdoor plaza. This community open space area would include on-site wayfinding features, minimized vehicular access, flexible

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pedestrian space, trees and enhanced plantings, lighting, and bicycle parking. Additionally, the alleyway adjacent to the eastern boundary of the Project site would be partially converted into a pedestrian and bicycle paseo and would facilitate connectivity between the Arcadia Metro L Line Station and the City’s downtown amenities. Stairs and a ramp would be installed on the Project site’s sout hwest side between the residential building and existing office tower, which would create an entrance to the paseo to the north from Wheeler Avenue. Pedestrian access is also proposed to provide access to the paseo from the garage. The northern lobby would be accessible via the alley and Santa Clara Street, and the southern lobby would be accessible via the alley and Wheeler Avenue. Sidewalks and other designated pathways would follow direct and safe routes from the external pedestrian circulation system to each building on the Project site. All pedestrian areas within the Project site would meet American Disability Act (ADA) requirements and adhere to City design guidelines. Bicyclist and pedestrian safety would be maintained at existing levels in the area. Additionally, the Project would not conflict with or result in the change of bus routes in the study area; therefore, the Project would not severely delay, impact, or reduce the service level of transit in the area. Therefore, the Project would not adversely affect, in a manner that conflicts with, an applicable program, plan, ordinance, or policy, addressing the performance of the circulation system, including public transit, roadway, bicycle or pedestrian facilities. Impacts would be less than significant.

Conflict with CEQA Guidelines Section 15064.3 (b)

State CEQA Guidelines Section 15064.3(b) focuses on newly adopted criteria (VMT) adopted pursuant to SB 743 for determining the significance of transportation impacts. The following VMT analysis is based on the City of Arcadia Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (City of Arcadia 2020) and OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018). As shown in the analysis below, the Project would be screened from a project-level analysis and no impacts due to conflicts or inconsistencies with Section 15064.3(b) are presumed, and impacts would be less than significant.

Screening Criteria

The City’s Guidelines provide three types of VMT screening that can be applied to the proposed Project to screen from a project-level VMT assessment. The screening criteria are consistent with the recommendations provided in OPR’s Technical Advisory.

Transit Priority Area (TPA) Screening

Projects located within a TPA may be presumed to have a less than significant impact absent substantial evidence to the contrary. This presumption may not be appropriate if the project:

1. Has a Floor Area Ratio (FAR) of less than 0.75;

2. Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking);

3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization)

4. Replaces affordable residential units with a smaller number of moderate- or high-income residential units

As shown in Appendix K-1, the proposed Project is located within a TPA. The Arcadia Metro L Line Station (East Los Angeles to Azusa) is located approximately 400 feet north of the Project site, with a weekday peak service frequency of five minutes. Additionally, the nearest bus service is provided by LA Metro Routes 79 and 287, along with Foothill Alexan Mixed-Use Development Project Final EIR 11663.03

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70 Transit Route 187, with stops along 1st Avenue, Huntington Drive, and Santa Anita Avenue surrounding the Project site. Peak frequencies range between 10 minutes (78/79 within the downtown Los Angeles area) and 40 minutes (LA Metro Routes 79 and 287 within Arcadia). As previously noted, Route 79 operates in conjunction with Route 78 within the downtown Los Angeles area, upon which the route splits into two separate lines in the City of Alhambra, with Route 79 traveling along Huntington Drive. Foothill Transit Route 187 operates with peak service frequencies of 20 minutes. Although the nearby bus transit services do not operate with peak service frequencies of 15 minutes or less, the Project site is located within one-half mile of a TPA as the Arcadia Metro L Line Station serves a Major Transit Stop, operating with a weekday peak service frequency of 5 minutes. Therefore, the Project can be screened out using this criterium.

Low VMT Area Screening

Residential and office projects located within a low VMT- generating area may be presumed to have a less than significant impact absent substantial evidence to the co ntrary. In addition, other employment-related and mixed- use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area.

This presumption may not be appropriate if the Project land uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips.

For this screening, the SCAG travel forecasting model was used to measure VMT performance for individual traffic analysis zones (TAZs). TAZs are geographic polygons similar to Census block groups used to represent areas of homogenous travel behavior. Total daily VMT per service population (population plus employment) was estimated for each TAZ.

The SGVCOG screening tool (available at https://www.sgvcog.org/vmt-analysis-tool) was used to determine whether or not the proposed Project would be located in a low VMT- generating area. Per the City’s guidelines, a low VMT- generating area is determined as 15% below the subarea baseline home-based VMT per capita and VMT per employee. The VMT per Capita for the project TAZ is 11.78, and the subarea jurisdiction’s average is 15.61. Further, the VMT per Worker for the project TAZ is 15.45, and the subarea jurisdiction’s average is 19.17. Therefore, the TAZ would be 27.97% and 21.49% below the subarea threshold for VMT per Capita and per Worker, respectively, which would meet the required baseline screening criteria established in the City’s guidelines. As such, the proposed Project can be screened out using this criterium.

Project Type Screening

The City’s guidelines list local serving land uses that have been identified as having the presumption of a less than significant impact. The land uses include land uses such as local serving schools, parks, day care centers, and local serving retail of less than 50,000 square feet. The uses are those which should be able to demonstrate that its users (employees, customers, visitors) would be existing within the community. The screening criterion also identifies projects that would generate less than 110 da ily vehicle trips and having a presumption of less than significant. The proposed residential component of the Pr oject would not fall under a local serving land use and would also generate greater than 110 daily vehicle trip s; therefore, this component of the Project cannot be screened out from further VMT analysis using this criter ium. However, the 750 square-foot proposed café would serve as a local serving land use and can be screened out using this criterium.

In conclusion, while the residential component of the Project would not be screened out from VMT analysis using the Project Type Screening, based on SB 743 and the revised CEQA guidelines, the City’s Transportation Study

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71 Guidelines for Vehicle Miles Traveled and Level of Service Assessment, and the San Gabriel Valley Council of Governments (SGVCOG) VMT Assessment tool, the entire Project would be screened from a project-level VMT analysis because the Project is in a Low VMT generating area within a TPA. Therefore, a VMT analysis is not required and impacts to VMT would be less than significant.

Hazards Due to Geometric Design Feature

Project Access

The existing Project site is currently co nfigured w it h sev en acc es s poi nts. Proposed vehicular circulation to the Project site and parking structure would remove or reconfigure four access points to provide full access drive aisles as well as entrance-only and exit-only locations to and from the proposed parking garage, as follows:

x Project Driveway (Northwest)/Santa Clara Street: ATM driveway; exit only x Alley Project Driveway (Northeast)/Santa Clara Street: Full access x Santa Anita Avenue/Project Driveway (West): Right-out; exit only (currently right-in; inbound only) x Project Driveway (Southwest)/Wheeler Avenue: Full access x Existing Driveway (North)/Santa Clara Street: To be removed x Existing Driveway (South)/Wheeler Avenue: To be removed x Alley Project Driveway (Southeast)/Wheeler Avenue: To be closed to non-emergency vehicular traffic x As noted above, vehicular access to the Project site would be available from the alley on the eastern edge of the Project site from Santa Clara Street. An entrance and exit point to the parking structure is proposed along the alleyway on the east side of the Project site from Santa Clara Street. Two sets of approximately 10 removable bollards are proposed within the eastern alley’s right-of-way, closing off the alleyway south of the parking garage entrance to Wheeler Drive from vehicular traffic to facilitate pedestrian and bicycle movement between the L Line Station and Downtown Arcadia. The other parking garage access point is located at the southwest corner of the garage, and can be accessed from Wheeler Avenue, which provides full access to the site. Additionally, an exit-only drive aisle would also provide direct egress to Santa Anita Avenue, south of the existing office building. It must be noted that this drive aisle currently exists and is proposed to remain; however, it is currently designat ed as an ingress only drive aisle and would be converted to an egress only drive aisle with the development of the proposed Project. Finally, an egress point is provided through the existing ATM exit-only drive-thru at the northwestern corner of the site. x All reconfigured driveways and internal access poin ts would be designed and constructed to ensure appropriate line of sight and appropriate turning radi i. The reconfigured driveways are also proposed to better facilitate the internal site circulation pattern to meet the needs of both the existing and proposed uses. No impacts are anticipated with the reconfigured driveways. The following design features would facilitate access to the drive-thru and maintain flow through the parking garage:
x Wayfinding signage would be provided at all parking garage ingress points for customers prior to entering the garage
x Wayfinding signage would be provided within the parking garage such that customers are directed to the ATM drive-thru, and other users of the site are channeled to parking spaces and garage exits. x Northbound left-turning movements onto Santa Clara Street would be restricted.

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72 On and Off-site Queuing Analysis

x To ensure the Project would not result in driveway queueing onto Santa Clara street, Santa Anita Street, or Wheeler Avenue, which could create hazards to oncoming traffic, a queuing analysis was conducted at the project driveways and for specific turning movements at adjacent intersections (see Appendix K-2). The queuing analysis was prepared for all project driveways to assess the adequacy of any off-site storage lanes into the Project site, as well as the adequacy of driveway throat lengths and space on-site for vehicles to queue without impacting the internal circulation on the Project site. Queuing was analyzed utilizing the SimTraffic software, which calculates the 95th percentile (design) queue. All queuing analysis data and SimTraffic queuing worksheets are provided in Appendix K2. x None of the calculated 95th percentile (design) queues exceed storage capacities within the existing left- turn pockets on Santa Clara Street, Santa Anita Avenue, or the two-way-left-turn-lane along Santa Clara Street. None of the queues would conflict with turning movements into or out of the Project site, within the internal access drive aisles, or along eastbound Wheeler Avenue with the addition of Project traffic during the Existing and Opening Year (2024) conditions.
x The longest 95th percentile queue is shown for the westbound, stop-controlled turning movement at the Santa Anita Avenue/Wheeler Avenue intersection, reaching 94 feet in the PM peak hour under Existing plus Project conditions and 96 feet in the PM peak hour under the Opening Year (2024) plus Project conditions.

Twenty-five (25) feet is equivalent to approximately one (1) car waiting to exit from the Project driveway onto the adjacent street during the peak hour. Based on this assumption, approximately four (4) vehicles would queue up to the intersection and would not overlap into the Project driveway.

Additionally, the 95
th percentile queue for the westbound left-turn lane extends approximately 10 to 15 feet past the striped left-turn pocket, but does not extend past the available stacking distance (as measured from the intersection stop bar to the ATM driveway exit). This is an acceptable queue and would not impede operations at the ATM driveway. In addition, the Project would restrict northbound left-turning movements onto Santa Clara Street given the proximity of the intersection as noted above. As queueing would not exceed available stacking distances, the addition of Project traffic would not create increased hazards due to a geometric design feature or incompatible uses. Impacts would be less than significant and no mitigation is required.

Inadequate Emergency Access

Operation

x All areas of the Project site would be accessible to emergency responders for the long-term operation of the proposed Project. Local access to the Project site would be provided via Santa Anita Avenue, Santa Clara Street, Wheeler Avenue, and 1st Avenue. All the Project access points would be designed according to the City’s applicable design standards. The proposed Project would provide adequate access to the Project site, including access for emergency vehicles. The internal drive aisles and loading and parking areas would be designed to comply with City’s width, clearance, and turning radius requirements of the Fire Department, which were established to ensure safe and efficient vehicular circulation. Because the project would comply with all applicable local requirements related to emergency vehicle access and circulation, the project would not result in inadequate emergency access. Therefore, operational impacts associated with inadequate emergency access would be less than significant.

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73 Cumulative Effects

Plan, Program, Ordinance, or Policy Addressing Circulation

The proposed Project is consistent with the following plans addressing the circulation system SCAG 2020–20405 RTP/SCS; City of Arcadia General Plan; and the Metro Long Range Transportation Plan. The Project and would not conflict with adopted policies, plans, or programs regardin g public transit, bicycle, or pedestrian facilities under cumulative conditions. Therefore, cumulative impacts relate d to a program, plan, ordinance, or policy related to addressing the circulation system would be less than significant.

CEQA Guidelines Section 15064.3(b)

The Project is located within a low VMT generating area and within a TPA. The Project would be screened from a project-level VMT analysis. Cumulative impacts can be presumed to be less than significant.

Hazardous Design Features

As discussed above, the Project’s reconfiguration of th e existing site access would not result in hazardous conditions into or out of the Project site. The proposed Project has a completed circulation analysis using LOS methodology provided in Appendix K-2, along with a 95th percentile queueing analysis provided in Appendix K-2 and detailed in the section above, that indicates that the trips generated by the proposed Project would not result in adverse circulation conditions. Because the impacts related to Project access points and circulation are site specific, and would be less than significant, the Project would not contribute to cumulative impacts with respect to hazardous design features.

Emergency Access

The Project would not result in inadequate emergency access and Project impacts to emergency access would be less than significant. As with the proposed Project, driveways and/or circulation modifications proposed in the surrounding area would comply with applicable local, regional, state, and/or federal requirements related to emergency access and evacuation plans. Further, since modification to access are largely confined to the Project site and the immediately surrounding area, Project-specific emergency access impacts would likely not impact other cumulative projects. Therefore, the Project’s contributions to cumulative impacts would be less than significant.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on transportation as it relates to conflict with circulation system plan, ordinance, or policy; conflict with CEQA Guidelines Section 15064.3 (b); inadequate emergency access; and cumulative impacts. Therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.

2.3.17 Tribal Cultural Resources
Change in a State listed or Eligible Tribal Cultural Resource

A CHRIS records search and pedestrian survey were conducted for the Project site. The CHRIS records search, archival research, and the pedestrian survey did not identify any previously recorded archaeological resources of Native American origin within or surrounding the Project site that are listed or eligible to be listed in the CRHR or in

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a local register. Further, no specific TCRs have been identified by California Native American tribes as part of the City’s AB 52 notification and consultation process (Appendix L) that could be eligible for listing in the CRHR or in a local register as a historical resource as defined in Public Resources Code section 5020.1(k). Therefore, the Project would not adversely affect TCRs that are listed or eligible for listing in the state or local register. Impacts would therefore be less than significant.

Finding

The City finds that, based upon substantial evidence in th e record, the Project would have a less than significant impact on tribal cultural resources as it relates to impacts to any listed resource or a resource eligible for listing.

Therefore, no mitigation is required, and no significant, unavoidable adverse impacts would occur.

2.3.18 Utilities and Service Systems
Require or Result in the Relocation or Construction of New or Expanded Water, Wastewater Treatment, Stormwater Drainage, Electric Power, Natural Gas, or Telecommunications Facilities

Water Conveyance

The City of Arcadia is its own water supplier, approximately 96% of the population living within the City’s sphere of influence is served by the Arcadia water system, which supports approximately 13,400 service connections (City of Arcadia 2013). The City primarily sources its water from the San Gabriel Valley and Raymond Groundwater Basins, as well as from water imported from the Upper District.

The City’s water distribution infrastructure comprises 164.6 miles of water lines (City of Arcadia 2013). According to the Report of Existing Infrastructure contained in Appe ndix G, the water lines closest to the Project site include an 8-inch cast iron water main with 50 psi static pressure on Santa Clara Street, an 8-inch cast iron water main with 54 psi static pressure on Wheeler Street and a 30-inch welded steel water main with 55 psi static pressure on Santa Anita Avenue. These three mains are available for domestic water and/or fire services. The water service connection for domestic water and fire protection within the proposed Project site would be made to one or more of the existing City water lines the development area. The specific location of these connections and pipe sizing would be based upon the City’s approval.

The proposed Project would increase water demand on the Pr oject site relative to existing conditions, due to the proposed increase in land use intensity. As such, the Project would place additional demands on the existing water infrastructure that serves the area. To determine the potential constraints on the existing water infrastructure that could be caused by the proposed Project, water flow requirements were measured against the available water flow from the existing infrastructure.

Through flow assessment, it was determined that the existing system would provide adequate water supply for operation of the Project’s domestic requirements, automatic sprinkler systems and off-site fire hydrants, if required by the state or City Fire Marshal. Fire flows for the proposed Project would be based on the requirements listed in the version of the California Fire Code that is in effect at the time of plan submission, as amended by the City.

While it was determined that adequate water supply exists to serve the proposed Project, results of the flow test demonstrated that the static and dynamic pressure on the public water system around the Project area is relatively low. As demonstrated in the fire flow test provided by the City (Appendix G) fire and domestic water booster pumps

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75 would be required to ensure adequate pressure. The required booster pumps are included as a design feature of the Project. The booster pumps would be located on-site in a dedicated room within the ground level parking garage.

Access would be provided via the alleyway along the southwest corner of the proposed residential development.

The Project’s anticipated water demand falls within the future supply projections for the City of Arcadia. (These projections take into account treatment of the water supply in accordance with regulatory standards.) As such, the proposed Project would not require or result in the need for new or expanded water treatment facilities.

Water infrastructure required for the proposed Project would thus be limited to on-site infrastructure, consisting of a booster pump, new water meters and connections to the existing water system to provide domestic water, fire water, and irrigation water to the proposed Project. Connections may also be required to provide water conveyance to additional fire hydrants. The minimum number of fire hydrants required would be calculated using Table C102.1 from the California Fire Code and the minimum number of fire hydrants would be installed pursuant to the California Fire Code. Installation of new water connections would cons ist of either trenching to the depth of pipe placement or using trenchless technology, which causes less ground disturbance. Trenching would result in temporary stockpiling of soil along the length of the trench, pending backfilling, which could result in potential short-term erosion and siltation. Trenchless technology requires temporary stockpiling of soil adjacent to excavations on both ends of a pipe section. Environmental effects associated with soil disturbance and the potential for erosion and siltation during this process would be addressed through construction best management practices for water quality protection, including sandbag barriers, dust controls, perimeter controls, drain inlet protection, and proper construction site housekeeping practices. Construction of water infrastructure for the Project would be limited to the Project site boundaries and its immediate street fron tages and would occur during the Project’s construction phase. As such, impacts associated with installation of water infrastructure necessary for the Project have been analyzed in the EIR. No additional impacts outside of those analyzed and disclosed throughout this EIR would occur as a result of construction of water infrastructure. For all of the foregoing reasons, the Project’s water conveyance and treatment impacts would be less than significant.

Sanitary Sewer Conveyance and Treatment

The existing buildings on the Project site proposed for demolition are currently served by an existing City owned and maintained 8” diameter vitrified clay pipe (VCP) sewer line that runs laterally through the Project site’s centerline, south along the off-site alley way, and then east along Wheeler Avenue, where it intersects with the LACSD’s Arcadia- Sierra Madre Sections 2 and 5 Trunk Sewers. The 15-inch diameter trunk sewer line runs north-south along North First Avenue and has a capacity of 4.5 million gallons per day (mgd) and conveyed a peak flow of 2.3 mgd when l a s t m e a s u r e d i n 2 0 1 3 ( L A C S D 2 0 2 1 ) . A s e w e r a n a l y s i s w a s p e r f o r m e d b y P s o m a s ( A p p e n d i x M ) t o d e t e r m i n e whether existing sewers have sufficient capacity to accommodate anticipated wastewater flows associated with the project. The existing sewer pipes were analyzed using th e County of Los Angeles Department of Public Works (LACDPW) Sewer Manual S-C4 chart which requires a maximum design capacity at half full for pipes less than 15- inches and at three quarters full for pipes 15-inches and greater. Based on the analysis, the sewer system serving the Project site would remain under 50% capacity with the addition of the project’s anticipated average and peak flows (Appendix M). As such, the existing sewer system would have adequate capacity to serve the proposed Project, and no new or upgraded sewer lines would be necessary as a result of the project.

According to the General Plan EIR, 1% of the City’s ex isting sewer infrastructure needs to be upgraded to accommodate anticipated growth through 2026 (City of Arcadia 2010), however, the sections identified as requiring improvements are not located on or adjacent to the Project site and the Project itself would not necessitate the upgrades. As such, any sewer infrastructure improvements or expansions would be carried out by the City; however,

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76 the Project’s development fees contribute towards any needed future capital improvements, as required through the City’s regulatory requirements: Article VII, Chapter 4 of the Arcadia Municipal Code regulates sewer line design, connection to the City’s sewer system, fees, and permits. Article VII, Chapter 5 of the Arcadia Municipal Code regulates water system connection and fees, with Part 5 addressing water use and the City’s Water Conservation Ordinance and Water Efficient Landscaping Ordinance.

Wastewater generated by the proposed Project would be treated at the San Jose Creek Water Reclamation Plant (SJCWRP) located adjacent to the City of Industry, whic h has a capacity of 100 mgd and currently processes an average flow of 61.2 mg (LACSD 2021). The remaining capacity at SJCWRP is approximately 38.8 mgd, or approximately 39% of its total capacity. The existing uses on the project site generate an average flow of 0.03 CFS (Appendix M). Implementation of the project would increase the average and peak daily wastewater flows from the project site by 0.01 CFS, which is equivalent to an average flow of 0.0065 mgd (Appendix M). This increase in wastewater generation represents approximately 0.02% of the remaining capacity of the SJCWRP. As such, the project would not exceed the available treatment capaci ty of SJCWRP and would not, therefore, require the construction of additional wastewater treatment infrastructure.

As with water infrastructure, the on-site sewer infrastructure necessary to serve the Project would consist of meters and lateral connections to existing sewer lines. The constr uction processes required to install such infrastructure would be similar to those described above for the on-site water infrastructure. Similarly, construction of sewer infrastructure for the Project would be limited to the Project site boundaries and its immediate street frontages and would occur during the Project’s construction phase. As such, impacts associated with installation of sewer infrastructure have been analyzed in the EIR as part of the project. No additional impacts outside of those analyzed and disclosed throughout this EIR would occur as a result of construction of wastewater infrastructure. For all of the foregoing reasons, the Project’s wastewater conveyance impacts would be less than significant.

Stormwater Drainage

The proposed Project would not generate increased stormwater runoff. As described under Section 4,8, Hydrology and Water Quality of this Draft EIR, the drainage patterns of the Project site would not substantially change relative to existing conditions. .Project design, construction, and operation would be completed consistent with the Rio Hondo/San Gabriel River Water Quality Group Enhanced Watershed Management Program, and in accordance with the City Stormwater Management and Discharge Control Ordinance, and the County of Los Angeles Low Impact Development Best Management Practices Handbook (LID Manual), with the goal of capturing stormwater runoff for i n f i l t r a t i o n a n d r e d u c i n g t h e a m o u n t o f p o l l u t a n t s i n s t o r m w a t e r a n d u r b a n r u n o f f ( C i t y o f A r c a d i a 2 0 2 1 c ) . T h e proposed Project would incorporate two drywells and one four-foot diameter primary settling chamber are proposed to be constructed on the Project site, located in the south side of the basement parking lot, which would be able to capture the required runoff volume and treat that volume as quickly as it enters the drywell system.

After installation of the infiltration drywells, the peak flow rate on the Project site would decrease by 0.73 cubic feet per second, resulting in a proposed or post-Project peak flow rate value of 8.08 cubic feet per second. Because the peak flow rate would be reduced in the proposed condition, it is understood that the existing City storm drains would not be negatively affected by implementation of the proposed Project. As such, the proposed Project would not require the construction or expansion of off-site stormwater drainage facilities, as the Project would not contribute a substantial amount of new stormwater runoff relative to existing conditions. Impacts would be less than significant.

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Sempra Utilities provides natural gas to the City via dist ribution lines and laterals within the City streets and easements. A high-pressure gas line lies approximately 42 inches belowground and crosses the City along Duarte Road, from Holly Avenue to Mountain Avenue in Monrovia (City of Arcadia 2010). These gas lines would not be affected by the Project’s construction-related activities. There is an existing 2-inch Gas Company gas line in Wheeler Avenue and Santa Clara Street as well as an 8” gas main along Santa Anita Avenue. It is considered that these lines will be adequate to provide gas service to the proposed development (Appendix G). No off-site improvements for natural gas infrastructure are anticipated with the implementation of the proposed Project.

SCE provides electricity to the City and operates four substations within the City’s SOI. Both underground and overhead electrical distribution lines are present within the City streets and yard easements, and high -voltage transmission lines exist along the I-605 freeway (City of Arcadia 2010). Pole mounted transformer units currently service the existing buildings on the east side of the Project site. The portion of overhead power along the alley that is to be vacated would be demolished and a new power service feed would be established to accommodate the Project. As part of the Project, a new transfer location would be provided onsite to service the new building (Appendix G). In compliance with the City’s General Plan, all utilities in the Downtown area must be placed underground. No off-site improvements for electric po wer infrastructure are anticipated with the implementation of the proposed Project.

If unanticipated upgrades were to be required, they would be limited the lateral connections to the Project site and not any centralized facilities. Any unforeseen upgrades would be coordinated with appropriate service providers to minimize disruptions on service and would be completed by either trenchless technology or open trenching to the depth of the underground utilities. Additionally, the Proj ect would be required to comply with all regulatory requirements and mitigation measures outlined within this Draft EIR for the purposes of mitigating impacts associated with construction activities. No adverse physical effects beyond those already disclosed in this Draft EIR would occur as a result of implementation of the Project’s proposed utility system connections. Therefore, impacts to dry utilities would be less than significant.

Sufficient Water Supplies

According to the General Plan EIR, the City of Arcadia is its own water supplier, and provides water to approximately 96% of the population living within the City’s SOI. The City sources its water from the San Gabriel (Main) Valley and Raymond Groundwater Basins and from water imported from the Upper San Gabriel Valley Municipal Water District.

The City’s water distribution infrastructure comprises 164.6 miles of water lines (City of Arcadia 2010).

The proposed Project does not involve enough new development to require evaluation pursuant to SB 221 or SB 610 (i.e., does not generate a water demand equal to or greater than that required by a 500-dwelling unit project), thus, no Water Supply Assessment is required. The proposed Project is consistent with the General Plan and does not require a General Plan Amendment; therefore, the Project would be consistent with the City’s growth projections anticipated in local and regional planning documents, including the City’s 2020 Urban Water Management Plan (UWMP). As stated in the UWMP, the projected populations used in the UWMP for the City’s service area were based on projections obtained from the SCAG. The SCAG data incorporates demographic trends, existing land use, general plan land use policies, and input and projections from the Department of Finance and the U.S. Census Bureau.

The proposed Project is anticipated to generate an average demand of approximately 43,620 gallons per day (gpd) of potable water (Appendix M). The City’s UWMP determines the City’s water demand based on projected populations in the City’s service area using data provided by SCAG 2020-2045 RTP/SCS (Connect SoCal), and

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incorporates demographic trends, existing land use, general plan land use policies, and input and projections through the year 2045 from the Department of Finance (DOF) and the US Census Bureau for counties, cities and unincorporated areas within Southern California (City of Arcadia 2021a). The proposed Project falls within the growth projections of all applicable planning documents, including SCAG’s Connect SoCal.

As stated in the UWMP, the Main Basin and Raymond Basin have been well managed for the full period of their respective adjudications, resulting in a stable and reliable water supply for the City during average, single-dry, and multiple-dry water years (City of Arcadia 2021a) . Additionally, imported water from MWD can be utilized as a supplemental source of supplies.

The Main Basin Judgment does not restrict the quantity of water, which parties may extract from the Main Basin.

Rather, it provides a means for replacing all annual extractions in excess of a Party's annual right to extract water with Supplemental Water. The Main Basin Watermaster annually establishes an Operating Safe Yield for the Main Basin which is then used to allocate to each Party its portion of the Operating Safe Yield which can be produced free of a Replacement Water Assessment. If a producer extracts water in excess of its right under the annual Operating Safe Yield, it must pay an assessment for Replacement Water, which is sufficient to purchase one acre- f o o t o f S u p p l e m e n t a l W a t e r t o b e s p r e a d i n t h e M a i n B a s i n f o r e a c h a c r e - f o o t o f e x c e s s p r o d u c t i o n . A l l w a t e r production is metered and is reported quarterly to the Main Basin Watermaster (City of Arcadia 2021b).

Historical prolonged droughts have caused groundwater levels to decrease resulting in the Raymond Basin Management Board to temporarily reduce the amount of groundwater which may be produced. The decreased production is designed to promote recovery of groundwa ter levels. At such time the groundwater levels have recovered the program may be suspended but can be reinstated as needed in the event groundwater levels decrease in the future. Recognizing allowed pumping is limited, the City along with other Raymond Basin producers have taken steps to reduce water demands to address the potential gap between supply and demand in the event demands cannot be entirely reduced. The City has production facilities in the Main Basin and has the ability to shift production, if needed. In addition, the City has a treated water connection and has access to MWD water as an additional source of supply (City of Arcadia 2021b).

The Project would be required to include all drought-tolerant landscaping requirements included in local regulations.

AMC Section 7554.4, Plan Check Requirements, requires that, as part of the broader general permitting process, a Landscape Design Plan, and a Landscape Documentation Package be prepared by a licensed landscape architect that incorporates efficient use of water and BMPs into landscape project design. The proposed Project would not include any wells that would directly deplete groundwater supplies, and the City’s UWMP anticipates adequate supply through 2045. City water conservation efforts will continue into the future to reduce water demands within the City due to the recently implemented tiered water rate and Water Smart program, which are intended to encourage conservation, thereby making local supplies more reliable.

Additionally, Arcadia operates in accordance with Phase I Mandatory Water Conservation Prohibitions, which are codified by the City’s Water Conservation Plan. Section 7553, Water Conservation Plan, of the City’s Municipal Code sets forth the water conservation measures that are applicable to all customers and properties served by the Water Division. Restrictions include but are not limited to prohibitions on outdoor watering of sidewalks, limits on scheduling of outdoor landscape irrigation, and restrictions on provision of water to guests at restaurants, hotels, cafes, unless expressly requested by the customer, among other restrictions.

The proposed Project would adhere to the water conservation methods established in Title 24 of the California Building Code. The Project would also adhere to the City’s Water Conservation Plan and Water Efficient Landscaping Ordinance, per Article VII, Chapter 5, Part 5, Division 3 and 4 of the City’s Municipal Code. Additionally, the proposed Alexan Mixed-Use Development Project Final EIR 11663.03

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Project would be subject to a development impact/connection fee, which would serve as the Project’s fair share contribution to water infrastructure improvements in the City. As such, the proposed Project would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years. Impacts would be less than significant, and no mitigation is required.

Adequate Capacity for Wastewater Treatment

The proposed Project would be connected to the existing 8” vitrified clay pipe (VCP) sewer line that runs laterally through the Project site’s centerline, south along the off-site alley way, and then east along Wheeler Avenue, where it intersects with LACSD’s 15-inch Trunk Sewer line running north-south along North First Avenue. Wastewater generated by the proposed Project would be treated at the San Jose Creek Water Reclamation Plant (SJCWRP) located adjacent to the City of Industry, which has a capacity of 100 mgd and currently processes an average flow of 61.2 mg (LACSD 2021). The remaining capacity at SJCWRP is approximately 38.8 mgd, or approximately 39% of its total capacity. The existing uses on the project site generate an average flow of 0.03 CFS (Appendix M).

Implementation of the Project would increase the average and peak daily wastewater flows from the project site by 0 . 0 1 C F S , w h i c h i s e q u i v a l e n t t o a n a v e r a g e f l o w o f 0 . 0 0 6 5 m g d ( A p p e n d i x M ) . T h i s i n c r e a s e i n w a s t e w a t e r generation represents approximately 0.02% of the remaining capacity of the SJCWRP.

Based on the capacity of the SJWRP, the wastewater generated by the proposed Project would be nominal of capacity. As such, the proposed Project would not exceed current capacities of the wastewater treatment system and would not significantly impact existing wastewater treatment systems such that new facilities would be required.

Finally, water conservation measures as established at the local and state level would be implemented and would help reduce the amount of wastewater generated by the Project. Therefore, impacts would be less than significant.

Generation of Solid Waste

Construction

The City’s non-residential solid waste is disposed of through contracts with Republic Services, Waste Management Inc., and Valley Vista Services (City of Arcadia 2019b). These waste management services offer waste and recycling collection, green waste recycling programs, organics waste composting, special waste transportation, and transfer and materials recovery services to the City as well as many other areas in Southern California. These waste management services offer waste and recycling collection, green waste recycling programs, organics waste composting, special waste transportation, and transfer and materials recovery services to the City as well as many other areas in Southern California.

The proposed Project would involve redevelopment of the existing surface parking lot and three existing commercial buildings. Demolition and construction activities associated with the proposed Project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, plastics, and soils. Per CALGreen standards, 65% of construction and demolition waste must be diverted from landfills (CalRecycle 2020). As such, at least 65% of all construction and demolition debris from the site would be diverted. Additionally, any hazardous wastes that are generated during demolition and construction activities would be managed and disposed of in compliance with all applicable federal, state, and local laws. The remaining 35% of construction and demolition material that is not required to be recycled would either be disposed of in a regional landfill or voluntarily recycled at a solid waste facility with available capacity. As described in Section 4.15.1, Existing Conditions, the inert landfill in the County (Azusa Land Reclamation landfill) has a remaining capacity of 51,512,201 tons and is expected to remain open for approximately 25 years, as of 2021. Due to the temporary nature of construction and required compliance with the City’s Municipal Code regulations applicable to garbage, refuse and recycling (Article V, Chapter 1), construction would not generate waste in excess of standards or in excess of the capacity of local infrastructure and would not otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant.

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Operation

Once operational, the proposed Project would produce solid waste on a regular basis, in association with operation and maintenance activities. Based on the CalEEMod solid waste generation rates, the proposed Project would generate approximately 248 tons of solid waste per year (Appendix C-1, CalEEMod Outputs). This amount assumes compliance with AB 939 requirements for 50% waste diversion from landfills. Solid waste generated by the proposed Project would be collected and transported to a local or regional landfill. There is only one landfill within approximately 25 miles of the Project site: the Azusa Land Reclamation landfill (Azusa landfill), located approximately 6-miles east.

The Azusa landfill has a remaining capacity of 51,512,201 tons and is expected to remain open for approximately 25 years, as of 2021. As such, the annual solid waste that is anticipated to be produced by the proposed Project would equate to approximately .00048% of the available capacity of the landfill through the estimated closure date. This number would be further reduced in order to comply with CALGreen requirements for 65% waste diversion, which would require the Project Applicant/Developer to either submit a construction waste management plan to the City that identifies the C&D waste materials to be diverted from the landfills or use a waste management company that can provide verifiable documentation that the percentage of C&D waste material diverted from the landfill meets CALGreen’s 65% requirement.

Furthermore, according to the latest annual report for the Countywide Integrated Waste Management Plan, there are landfills used by the County with up to 100 years of remaining life (LACDPW 2019b). For example, the Prima D e s h e c h a S a n i t a r y L a n d f i l l i n O r a n g e C o u n t y i s e x p e c t e d t o r e m a i n o p e n f o r a n o t h e r 8 5 y e a r s , t h e M e s q u i t e Regional Landfill in Imperial County is expected to remain open for another 100 years, and the Simi Valley Landfill in Ventura County is expected to remain open for another 67 years (CalRecycle 2021). As such, other landfills in the region would also be able to accommodate solid waste from the proposed Project, and regional planning efforts would ensure continued landfill capacity into the foreseeable future.

For the reasons described above, Project operations would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastr ucture, or otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant. No mitigation is required.

Solid Waste Statutes and Regulations

The proposed Project would be required to comply with all applicable local and state regulations related to solid waste. The solid waste facility in proximity to the Azusa landfill is regulated under federal, state, and local laws.

Additionally, the City is required to comply with the solid waste reduction and diversion requirements set for in AB 939, AB 341, AB 1327, and AB 1826. Per AB 1826, businesses that generate 2 cubic yards or more of commercial solid waste per week are required to arrange for organic waste recycling services. Any hazardous wastes that are generated during construction activities would be managed and disposed of in compliance with all applicable federal, state, and local laws.

In addition to the City’s requirements for recycling construction and demolition waste, the state has set a goal of 75% recycling, composting, and source reduction of solid waste by 2020. To help reach this goal, the state has adopted AB 341 and AB 1826. AB 341 is a mandatory commercial recycling bill, and AB 1826 is mandatory organics recycling. Waste generated by the proposed Project would enter the City’s waste stream but would not adversely affect the City’s ability to meet AB 341 or AB 1826 , because the proposed Project’s waste generation would represent a nominal percentage of the waste created within the City and because the businesses and residents at the Project site would be subject to recycling and diversion requirements. In addition, waste diversion and reduction during Project construction and operations would be completed in accordance with CALGreen standards,

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CalRecycle standards, City requirements, and the County Integrated Waste Management Plan. Republic Services, Waste Management Inc., and Valley Vista Services all adhere to AB 341. As a result, the Project would comply with federal, state, and local management and reduction statues and regulations related to solid waste. Impacts would be less than significant.

Cumulative Effects

Water

Implementation of the Project, in conjunction with cumulative projects would increase demand for water services provided in the City’s water supply system. The Project area and each cumulative project would incrementally increase the amount of water that is required in the area. However, as previously described, the existing water lines that serve the Project site have the capacity to convey the estimated peak flow generated from the Project. Similar to the Project, the capacity of water lines associated with cumulative project development would be determined on a project-specific basis. In the event that water line upgrades are required due to cumulative projects, all construction work within the City public rights-of-way would be subject to local municipal code and applicable agency requirements and would be subject to CEQA review accordingly. Based on the analysis presented in the Report of Existing Infrastructure, (Appendix G), the proposed Project is not anticipated to contribute to a cumulative impact related to water infrastructure.

The City (through its UWMP) anticipates its projected water supplies will meet demand through the year 2045. In terms of the City’s overall water supply condition, any cumulative project that is consistent with the City’s General Plan has been taken into account in the planned growth of the water system.

For projects that meet the requirements established pursuant to SB 610, SB 221, and Sections 10910–10915 of the State Water Code, a Water Supply Assessment demonstrating sufficient water availability is required on a project-by-project basis. Similar to the Project, each cumulative project would be required to comply with City and State Water Code and conservation programs for both wa ter supply and infrastructure to partially offset the cumulative demand for water. As a result, no significan t cumulative water supply impacts are anticipated from development of the Project and cumulative projects, and the Project’s incremental effect would not be cumulatively considerable. No mitigation is required.

Wastewater

The Project area and each cumulative project would incrementally increase the amount of wastewater that is being generated in the area. Based on the analysis provided in Appendix M of this Draft EIR, the existing sewer lines that serve the Project site have the capacity to convey the estimated peak flow generated from the Project. All construction work within the City public rights-of-way would be subject to local municipal code and applicable agency requirements and would be subject to CEQA review accordingly.

Similarly, the proposed Project is estimated to generate an average 52,272 gpd of wastewater, with a peak generation of 156,816 gpd. For even the treatment site servicing the City with the smallest capacity (Whittier Narrows), this would result in an average increase of less than 0.3%, and peak increase of approximately 1%. As cumulative increases in wastewater treatment demand within the service area require facility upgrades, the City w o u l d c o n t i n u e t o r e g u l a t e p u b l i c s e w e r f a c i l i t i e s i n a s o u t l i n e d i n t h e 2 0 1 4 C i t y o f A r c a d i a S e w e r S y s t e m Management Plan, and any affected treatment plants woul d continue to assess potential expansions to their treatment facilities in accordance with regulatory permit requirements. As such, impacts to wastewater services would not be cumulatively considerable. No mitigation is required.

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The City of Arcadia is built-out and upgrades in electrical power, natural gas, and telecommunication capabilities are anticipated primarily due to development in the form of th e revitalization of outdated or underserved areas, and redevelopment of specific properties that will increase density and require more sophisticated technology, such as the proposed Project. However, such upgrades would generally be confined to the lateral connections to the individual project sites and not any centralized facilities. Upgrades to centralized power, natural gas, and telecommunication facilities would be determined by each of the power, gas, and telecommunications providers, as build-out continues within the region. Individual projects would be required to provide for specific project needs. As a result, cumulative impacts associated with upgrades of electric, natural gas, and telecommunication facilities would not be significant. As such, impacts to electric power, natural gas, and telecommunication services would not be cumulatively considerable.

Solid Waste

Development of the Project in combination with cumulative projects would increase land-use intensities in the area, resulting in increased solid waste generation in the service area for Azusa landfill. However, due to the built-out nature of the City, the Project and cumulative projects are considered urban infill and/or redevelopment projects.

As such, solid waste is already being generated at the Project site and the majority, if not all, of the cumulative project sites. Further, AB 939, or the Integrated Waste Management Act of 1989, mandates that cities divert from landfills 50% of the total solid waste generated to recycling facilities. In order to satisfy CALGreen requirements of diverting 65% of solid waste and to offset impacts asso ciated with solid waste, the proposed Project and all cumulative projects would be required to implement waste reduction, diversion, and recycling during both demolition/construction and operation.

Through compliance with City and state solid waste dive rsion requirements, together with the City’s Source Reduction and Recycling Element and applicable regulations outlined in Article V, Chapter 1, of the City’s Municipal Code, impacts to solid waste services would not be cu mulatively considerable. Impacts would be less than significant, and no mitigation is required.

Finding

The City finds that, based upon substantial evidence in the record, the Project would have a less than significant impact on utility and service systems; therefore, no mitigation is required.

2.3.19 Wildfire
The Project site is in a highly urbanized area and is not within a Very High Fire Hazard Severity Zone and would not exacerbate or expose people or structures to wildfire risks or substantially impair an adopted emergency response plan. The nearest wildland areas are located at the bottom of the San Gabriel Mountains, approximately 1 mile north of the Project site. Based on the CAL FIRE’s Fire Hazard Severity Zones maps, the Project site is not located in or near state responsibility areas or lands classified as Very High Fire Hazard Severity Zones. The closest designated Very High Fire Hazard Severity Zone is located approximately 0.75-mile north of the Project site. Therefore, impacts associated with wildland fire would not occur and will not require further evaluation in the EIR.

Finding

Appendix B of the Notice of Preparation for the Project found no potential for significant impacts to wildfire; therefore, wildfire was not addressed in the Draft EIR. No mitigation would be required and no significant, unavoidable adverse impacts would occur.

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83 3 Findings on Project Alternatives

CEQA requires that an EIR describe a range of reasonable alternatives to the project, or to the location of the project, that could feasibly attain the basic objectives of the project, and to evaluate the comparative merits of the alternatives (14 CCR 15126.6[a]). The CEQA Guidelines direct that the selection of alternatives be governed by “a rule of reason” (14 CCR 15126.6[a], [f]). As defined by the CEQA Guidelines, “The range of alternatives required in an EIR is governed by a ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR needs to examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the project” (14 CCR 15126.6[f]).

Additionally, CEQA Guidelines section 15091(a)(3) requires findings to be made as to why project alternatives were rejected. While an alternative may be potentially feasible under Guidelines section 15126.6 for inclusion in an EIR, the ultimate determination of feasibility is to be made by the decision-making body under section 15091(a)(3). As stated above, alternatives may be rejected when specific economic, legal, social, technological or other considerations make the Project infeasible. In making these findings, the City Council finds that there are six objectives for the Project, which are primarily dependent upon developing an under-utilized site consistent with the underlying land use designation and zoning. However, the primary objectives of the Project are (1) addressing the regional housing shortage by providing additional housing opportunities, including affordable housing, that support the goals of the Housing Element of the General Plana and the City’s Regional Housing Needs Allocation (RHNA) requirements; and (2) developing an under-utilized property within a Transit Priority Area consistent with the City’s land use designation and zoning.

3.1 Alternatives Carried Forward for Consideration
This section discusses a reasonable range of alternatives to the Project, including a no project alternative, in compliance with CEQA Guidelines Section 15126.6(e). These alternatives include the following:
x Alternative A: No Project/Existing Development
x Alternative B: Increased Commercial-Use Alternative: Conversion of Live/Work Units to Commercial

These alternatives are evaluated for their ability to avoid or substantially lessen the impacts of the Project identified in the EIR, as well as consideration of their ability to meet the basic objectives of the proposed Project as described in the Final EIR.

3.1.1 Alternative A - No Project/Existing Development
Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate and analyze the impacts of a no project alternative. The “purpose of describing and analyzing a no project alternative is to allow decision makers to compare the impacts of approving the proposed Project with the impacts of not approving the proposed Project” (14 CCR 15126.6[e][1]). When defining the no project alternative, the analysis shall be informed by “what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services” (14 CCR 15126.6[e][2]).

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Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate the specific alternative of “no project” along with its impact. As stated in this section of the CEQA Guidelines, the purpose of describing and analyzing a no project alternative is to allow decision makers to compare the impacts of approving a proposed Project with the impacts of not approving a proposed Project. As stated in Section 15126.6(e)(3)(A), when a project is the revision of an existing land use or regulatory plan or policy or an ongoing operation, the no project alternative will be the continuation of the plan, policy, or operation into the future. Section 15126.6(e)(3)(B) further states that “in certain instances, the no project alternative means ‘no build’ wherein the existing environmental setting is maintained.” The proposed Project does not include a General Plan Amendment or a Zone Change. Accordingly, Alternative A assumes the proposed Project would not proceed, no new permanent development or land uses would be introduced within the Project site, and the existing environment would be maintained. The existing uses would continue to operate as they do currently. The existing office and commercial uses would remain in place and operational, the existing surface parking lots would be retained, no new buildings or subterranean parking would be constructed, and no on-site landscaping improvements or pedestrian connections would occur. Additionally, all 36 onsite trees, including six (6) protected species un der Section 9110.01 of the City’s Tree Preservation Ordinance, would be preserved under this alternative, and none of the nine (9) Project adjacent street-trees would be encroached upon.

Analysis

Under this alternative, impacts would be slightly greater than under the proposed Project. Specifically, hydrology and water quality impacts would be greater because the continued operation of the site does not currently contain any low-impact development features potentially creating impacts to water quality, Further, the No Project Alternative would not provide additional housing units that could help meet the City’s RHNA goals and growth projections. Also,due to the underutilization of the site, the No Project Alternative would not contribute to a reduction in citywide VMT and associated GHG emissions attributed to increased development in a Transit Priority Area.

Finding

For the reasons stated below, and each of them independently of the others, the City finds that the No Project Alternative is not feasible, and rejects that alternative. The No Project/Existing Development fails to satisfy the Project’s underlying purpose and to meet any of the Project objectives, and because specific economic, legal, social, technological or other considerations make the alternative infeasible.

Rationale

No Project/Existing Development would have fewer impact s compared to the Project in terms of aesthetics, air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality (short-term impacts), noise, public services, recreation, transportation, tribal cultural resources, and utilities and service systems. The No Project/Existing Alternative would not achieve the Project objectives, with the exception of Objective No. 4, To propose development that is consistent with the existing Downtown Mixed-Use (DMU) zoning and land use designation, which assumes existing land uses and surface parking would remain. Although no new development would be proposed, Alternative A would be consistent with the existing zoning and General Plan designation.

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Conversion of Live/Work Units to Commercial
Description

Alternative B considers an alternative design that would not substantively alter the environmental impacts of the proposed Project, but would potentially improve the Project’s consistency with local policies related to increasing density near transit, and provide more employment-generating uses.

The underlying Downtown Mixed Use (DMU) land use designation permits service and retail uses, commercial businesses, professional offices, and residential uses within the City’s downtown, at a maximum floor area ratio (FAR) of 1.0 (in which only commercial square footage is counted in calculation of FAR) and a maximum unit density of up to 80 dwelling units per acre (City of Arcadia 2010). The proposed Project satisfies the allowable 80 dwelling units per acre (i.e., 236 units on the 2.95-acre site), and with addition of the 35% density bonus under Density Bonus Law, the Project proposes a dwelling unit count of 319 total units, which would include 293 market-rate and 26 affordable dwelling units. Alternative B proposes a slight adjustment to this unit count by converting the 8 live- work units to all-commercial, without altering the 26 affordable units, resulting in a total of 311 units, a slight reduction from the Project.

The purpose of converting these live-work units to all-commercial would be to increase the amount of employment- generating commercial uses on the Project site. Under the proposed Project, with the existing 83,253 square feet of commercial uses and the additional 9,281 square feet of “work” uses from the proposed live-work units, the total non-residential square footage on site would be 92,534 square feet, resulting in a FAR of 0.72. Under Alternative B, the conversion of 5,864 square feet from residential to commercial would increase the FAR to 0.77.

Alternative B would generate residents associated with the 311 units and employment associated with construction of the 15,145 square feet of commercial use, which is 5,864 square feet more than the proposed Project and would generate an additional approximately 14 employees. Under Alternative B, due to the increased commercial square footage, the number of potential employees would increase from 30 under the proposed Project (a net deficit of 20 employees when compared to the existing conditions) to 44 under Alternative B (a net deficit of 6 employees when compared to the existing conditions).

Analysis

All impacts under Alternative B would be the same as the Project and would require all of the mitigation measures identified for the Project. The following impacts would be slightly greater under this alternative. Alternative B would generate slightly more vehicle trips from commercial activities; therefore, operational impacts on regional air quality and contribution to GHG emissions under Alternative B would be slightly greater than those anticipated from the proposed Project but would not exceed the thresholds.

I n o n l y o n e i n s t a n c e w o u l d a n i m p a c t b e l e s s t h a n t h e P r o j e c t . B e c a u s e e m p l o y m e n t w o u l d i n c r e a s e u n d e r Alternative B when compared to the proposed Project, impacts to population and housing under Alternative B would be slightly less than those anticipated from the proposed Project.

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For the reasons stated below, and each of them independently of the others, the City finds that Alternative B is not feasible, and rejects that alternative. While Alternative B satisfies all of the Project Objectives, it does so to a lesser degree. Alternative B is rejected because specific economic, legal, social, technological or other considerations make the alternative infeasible.

Rationale

While the Alternative B would still achieve all of the Project objectives, the objectives would not be achieved to the same extent as the Project. Primarily, Alternative B woul d lose 8 residential units which would not help the City provide new multifamily residential housing, which is required to meet the City’s Regional Housing Needs Allocation (RHNA) requirements (Objective 2). Maximizing housing near established transit is a priority for the City and the SCAG region as a whole, and new housing is necessary to address the unprecedented shortage of housing opportunities in Los Angeles County. Further, Alternative B would not result in a reduction of a significant environmental impact. Neither the Project nor Alternative B would result in a significant environmental impact.

3.2.2 Environmentally Superior Alternative
An EIR must identify an “environmentally superior” alternative; and, where the no project alternative is environmentally superior, the EIR is then required to identify an alternative from among the others evaluated as environmentally superior (14 CCR 15126.6[e][2]).

Alternative A would result in reduced impacts to all environmental topics in the short-term because construction activity would not occur. Alternative A would therefore eliminate all mitigation requirements for short-term construction activities. Similarly, Alternative A would result in reduced environmental impacts to most environmental topics in the long-term because no operational changes would occur. However, increased environmental impacts would occur for the following topics: (1) Hydrology/Water Quality, due to the continued operation of the site that does not currently contain any low-impact development features; (2) Population and Housing, due to the lack of additional housing units th at could help meet the City’s RHNA goals and growth projections; and (3) Transportation, due to the underutilization of the site that would not contribute to a reduction in cityside VMT and associated GHG attributed to increased development in a TPA. The proposed Project would redevelop existing surface parking lots and construct a mix of land uses including residential and commercial, within a TPA and the established Downtown Arcadia focus area, which would help the City to achieve its goals and policies related to land use, circulation, economic development, and housing, which would not occur under Alternative A.

Nevertheless, the elimination of all construction and operational impacts associated with the proposed Project would result in an environmentally superior alternative when compared to the proposed Project or Alternative B.

As required under CEQA Guidelines Section 15126.6(e)(2), if the environmentally superior alternative is the “no project” alternative, the EIR must also identify an environmentally superior alternative among the other alternatives.

The proposed Project has no significant unavoidable impacts that could be addressed by the adoption of any alternative. Alternative B would have similar environmen tal impacts when compared to the proposed Project for almost all environmental topics and would not eliminate the need for any proposed mitigation measures. Alternative B would result in slightly increased impacts associated with Air Quality and Greenhouse Gas Emissions, and result in a slight decrease in impacts associated with Population and Housing. Therefore, because Alternative B would not reduce or eliminate any of the significant impacts of the proposed Project, the proposed Project would be the environmentally superior alternative.

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87 4 General CEQA Findings

Based on the information contained in the administrative record and based on the facts stated below, the City makes the Findings set forth in Sections 4.1 and 4.2.

1. The plans for the proposed Project have been prepared and analyzed so as to provide for public involvement in the planning and the CEQA processes.

2. To the degree that any impacts described in the Draft EIR are perceived to have a significant effect on the environment, or such impacts appear ambiguous as to their effect on the environment, any significant effect of such impacts has been substantially lessened or avoided by the mitigation measures set forth in the Draft and Final EIR.

3. Comments regarding the Draft EIR received during the public review period have been adequately addressed in Chapter 2, Responses to Comments Received, in the Final EIR. Any significant effects described in such comments were avoided or substantially lessened by the mitigation measures described in the Draft and Final EIR.

4.1 Findings Regarding Recirculation
The City finds that the Draft EIR does not require recirculation under CEQA (CEQA Section 21092.1, CEQA Guidelines Section 15088.5). CEQA Guidelines Sect ion 15088.5 requires recirculation of an EIR prior to certification of the Final EIR when “significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review.” As described in CEQA Guidelines Section 15088.5:

New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation includes, for example, a disclosure showing that:

1. A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;

2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;

3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen th e significant environmental impacts of the project, but the project’s proponents decline to adopt it;

4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

In addition, CEQA Guidelines Section 15088.5(b) provides that “recirculation is not required where the new information added to the EIR merely cl arifies and amplifies or makes insignificant modifications in an adequate EIR.” Recirculation also is not required simply because new information is added to the EIR — indeed, new information is oftentimes added given CEQA’s public/a gency comment and response process and CEQA’s post- Draft EIR circulation requirement of proposed responses to comments submitted by public agencies. In short, Alexan Mixed-Use Development Project Final EIR
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recirculation is “intended to be an exception rather than the general rule.” (Laurel Heights Improvement Assn. v.

Regents of University of California (1993) 6 Cal.4th 1112, 1132.)

As such, the City makes the following Findings:

1. None of the public comments submitted to the Ci ty regarding the Draft EIR present any significant new information that would require the Draft EIR to be recirculated for public review.

2. No new or modified mitigation measures are proposed that would have the potential to create new significant environmental impacts.

3. The Draft EIR adequately analyzed project alternatives and there are no feasible project alternatives or mitigation measures considerably different from others previously analyzed that would clearly lessen the significant environmental impacts of the project.

4. The Draft EIR was not fundamentally and basically inadequate and conclusory in nature and did not preclude meaningful public review and comment.

In this legal context, the City finds that recirculation of the Draft EIR prior to certification is not required. In addition to providing responses to comments, the Final EIR includes revisions to expand upon information presented in the Draft EIR (Chapter 3, Changes to the EIR); explain or enhance the evidentiary basis for the Draft EIR’s findings; update information; and to make clarifications, amplifications, updates, or helpful revisions to the Draft EIR. These revisions, clarifications and/or updates do not result in any new significant impacts or increase the severity of a previously identified significant impact. These changes are not substantial, do not deprive the public of a meaningful opportunity to comment on a substantial adverse environmental effect, a feasible way to mitigate or avoid such an effect or a feasible project alternative.

In summary, the Final EIR demonstrates that the proposed Project would not result in any new significant impacts or increase the severity of a significant impact, as compared to the analysis presented in the Draft EIR. The changes reflected in the Final EIR also do not indicate that meaningful public review of the Draft EIR was precluded in the first instance. Accordingly, recirculation of the EIR is not required as revisions to the EIR are not significant as defined in Section 15088.5 of the CEQA Guidelines.

4.2 Legal Effects of Findings
To the extent that these Findings conclude that the proposed mitigation measures outlined herein are feasible and have not been modified, superseded, or withdrawn, the City hereby commits to implementing these measures.

These Findings, in other words, are not merely informational, but rather constitute a binding set of obligations that will come into effect when the City approves the proposed Project.

The mitigation measures that are referenced herein and adopted concurrently with these Findings will be effectuated through the process of construction and implementation of the proposed Project.

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89 5 Conclusion

The mitigation measures listed in conjunction with each of the findings set forth above, as implemented through the MMRP, will eliminate or reduce to a less-than-significant level most of the adverse environmental impacts of the Project.

Taken together, the EIR which consists of the Draft EIR, Final EIR, and the MMRP provide an adequate basis for approval of the Project.

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91 6 References Cited

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CAL FIRE (California Department of Forestry and Fire Services). 2021. “Fire Hazard Severity Zone Viewer.” Accessed April 21, 2021. http://egis.fire.ca.gov/FHSZ/.

Caltrans (California Department of Transportation). 2019. List of Eligible and Officially Designated State Scenic Highways (XLSX). Accessed April 22, 2021. https://dot.ca.gov/programs/design/ lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways.

Caltrans. 2020. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office. Sacramento, CA. April 2020.

CalRecycle (California Department of Resources Recycling and Recovery). 2020. “CALGreen Construction Waste Management Requirements”. Accessed August 19, 2021. https://www.calrecycle.ca.gov/LGCentral/ Library/CandDModel/Instruction/NewStructures/.

CalRecycle. 2021. “Solid Waste Information System (SWIS) Home”. Accessed August 17, 2021. https://www2.calrecycle.ca.gov/SolidWaste/Site/Search.

CARB (California Air Resources Board). 2011. “Facts About the Advanced Clean Cars Program.” Revised November 9, 2011. Accessed May 2019. https://www.arb.ca.gov/msprog/zevprog/factsheets/ advanced_clean_cars_eng.pdf.

CDPR (California Department of Parks and Recreation). 2021. Community Fact Finder, 2020 Edition. Office of Grants and Local Services. Accessed September 15, 2021. https://www.parksforcalifornia.org/ communities/?address=arcadia%2C%20ca&lat=34.12735748&lng=-118.04586792&overlays=parks.

CEC (California Energy Commission). 2018. Forecast Commission Final Report, California Energy Demand 2018- 2030 Revised. February 2018. Accessed July 2020.

CEC. 2019. 2019 California Green Building Standards Code. July 2019. https://calgreenenergyservices.com/wp/ wp-content/uploads/2019_california_green_code.pdf.

CGS (California Geologic Survey). 2018. Earthquake Fault Zones, A Guide for Government Agencies, Property Owners/Developers, and Geoscience Practitioners For Assessing Fault Rupture Hazards in California.

Revised 2018. Accessed August 10, 2021. https://www.conservation.ca.gov/cgs/Documents/ Publications/Special-Publications/SP_042.pdf.

CGS. 2021. Earthquake Zones of Required Investigation. Accessed August 8. 2021 https://maps.conservation.ca.gov/ cgs/EQZApp/app/.

City of Arcadia. 2010. City of Arcadia General Plan. Updated 2013. Accessed August 8, 2021. https://www.arcadiaca.gov/shape/development_services_department/ planning _zoning/general_plan.php.

FINDINGS OF FACT
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92 City of Arcadia. 2013. Arcadia General Plan Update, Draft Program EIR. Accessed on August 17. 2021. https://www.arcadiaca.gov/government/city-departments/development-services/general-plan/ general-plan-eir.

City of Arcadia. 2020. City of Arcadia Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment. August.

City of Arcadia. 2021a. City of Arcadia Municipal Code. Updated February 2021. Accessed August 8, 2021. https://library.municode.com/ca/arcadia/codes/code_of_ordinances?nodeId=ARCAMUCO.

City of Arcadia. 2021b. 2020 Urban Water Management Plan. Accessed September 23, 2021.

City of Arcadia. 2021c. “Water Efficient Landscaping & Low Impact Development”. Accessed October 5, 2021. https://www.arcadiaca.gov/shape/development_services_department/neighborhood_services/welo_lid.php.

County of Los Angeles. 2014. Los Angeles County General Plan Updated Draft Environmental Impact Report SCH No. 2011081042. June 2014. Accessed August 13, 2021. https://planning.lacounty.gov/ generalplan/ceqa.

DOC (California Department of Conservation). 2018. Williamson Act contracts.

DOC. 2020. California Important Farmland Finder.

DOC. 2021. California Tsunami Maps and Data. Accesses September 2, 2021. https://www.conservation.ca.gov/ cgs/tsunami/maps.

DOF (California Department of Finance). 2021. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2020 with 2010 Census Benchmark. Table 2: E-5 City/County Population and Housing Estimates, 1/1/2021. Accessed August 23, 2021. http://www.dof.ca.gov/Forecasting/ Demographics/Estimates/E-5/.

EDD (Employment Development Department). 2021. Labor Force and Unemployment Rate for Cities and Census Designated Places. July 2021. Accessed August 23, 2021. https://data.edd.ca.gov/Labor-Force-and- Unemployment-Rates/Labor-Force-and-Unemployment-Rate-for-California-S/8z4h-2ak6/data.

EIA (U.S. Energy Information Administration). 2021c. “California State Profile and Energy Estimates – Table F16:

Total Petroleum Consumption Estimates, 2019.” Accessed August 2021. https://www.eia.gov/state/ seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_use_pa.html&sid=US&sid=CA.

FEMA (Federal Emergency Management Agency). 2021. Flood Zone Determination (Map). Accessed September 2, 2021. https://apps.gis.lacounty.gov/dpw/m/?viewer=floodzone.

FHWA (Federal Highway Administration). 2004. FHWA Traffic Noise Model Version 2.5.

FHWA. 2008. Roadway Construction Noise Model (RCNM), Software Version 1.1. U.S. Department of Transportation, Research and Innovative Technology Administration, John A. Volpe National Transportation Systems Center, Environmental Measurement and Modeling Division.

Washington, D.C. December 8, 2008.

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93 FHWA. 2011. Highway Traffic Noise: Analysis and Abatement Guidance. FHWA HEP 10-025. December.

FTA (U.S. Department of Transportation, Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment Manual. September 2018.

LACDPW (County of Los Angeles Department of Public Works). 2019a. Santa Anita Stormwater Flood Management and Seismic Strengthening Project. Accessed September 2, 2021. http://www.dpw.lacounty.gov/wrd/projects/SantaAnita/php#outer-708.

LACDPW. 2019b. Countywide Integrated Management Plan. December 2019. https://dpw.lacounty.gov/ epd/swims/ShowDoc.aspx?id=14372&hp=yes&type=PDF.

LACSD (Los Angeles County Sanitation Districts). 2021. LACSD Facilities (Map). Accessed August 18, 2021, https://www.lacsd.org/facilities/?tab=2&number=3.

OPR (California Governor’s Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Accessed June 2020. http://opr.ca.gov/ docs/20190122-743_Technical_Advisory.pdf.

SCAG (Southern California Association of Governments). 2016. 2016–2040 Regional Transportation Plan/Sustainable Communities Strategy. Adopted April 2016, http://scagrtpscs.net/ Pages/FINAL2016RTPSCS.aspx.

SCAG. 2020a. The 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments, Connect SoCal. Accessed September 9, 2021. https://www.connectsocal.org/Documents/Adopted/fConnectSoCal-Plan.pdf.

SCAG. 2020b. Connect SoCal: Current Context Demographics and Growth Forecast Technical Report. Adopted September 3, 2020. https://scag.ca.gov/sites/main/files/file-attachments/ 0903fconnectsocal_demographics-and-growth-forecast.pdf?1606001579.

SCAQMD (South Coast Air Quality Management District). 1993. CEQA Air Quality Handbook.

SCAQMD. 2017. 2016 Final Air Quality Management Plan.

SGMA (Sustainable Groundwater Management Act). 2021. Groundwater Basin Prioritizations, SGMA Data Viewer.

Accessed September 1, 2021. https://sgma.water.ca.gov/webgis/?appid=SGMADataViewer#boundaries.

The Climate Registry. 2020. Default Emission Factors. May 1. Accessed April 2020. https://www.theclimateregistry.org/ wp-content/uploads/2020/04/The-Climate-Registry-2020-Default-Emission-Factor-Document.pdf.

U.S. Census. 2021. U.S. Census Bureau, QuickFacts: Arcadia City. Accessed August 20, 2021. https://www.census.gov/ quickfacts/fact/table/arcadiacitycalifornia/PST045219.

USFWS (U.S. Fish and Wildlife Service). 2020. Jurisdictional Wetlands search.

FINDINGS OF FACT
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Exhibit B
Mitigation Monitoring and Reporting
Program (MMRP)

44 – Mitigation Monitoring and Reporting Program
Sand Canyon Resort Draft Final EIR 11285
May 2021 4-2

4 Mitigation Monitoring and
Reporting Program

California Public Resources Code Section 21081.6 requires that, upon certification of an EIR, “the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation.” This chapter contains the mitigation monitoring and reporting program (MMRP) that has been developed for the Alexan Mixed-Use Development Project (Project). This MMRP has been developed in compliance with Public Resources Code Section 21081.6 and Section 15097 of the CEQA Guidelines. The mitigation measures in the table are coded by alphanumeric identi fication consistent with the EIR. The following items are identified for each mitigation measure:
x
Mitigation Monitoring. This section of the MMRP lists the stage of the proposed project during which the mitigation measure would be implemented and the st age during which proper implementation would be monitored and verified. It also lists the agency that is responsible for ensuring that the mitigation measure is implemented and that it is implemented properly.
x Verification of Compliance. This section of the MMRP provides a location for the implementing party and/or enforcing agency to make notes and to record their initials and the compliance date for each mitigation measure.

The City of Arcadia (City) must adopt this MMRP, or an equally effective program, if it approves the proposed project with the mitigation measures that were adopted or made conditions of project approval.

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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Cultural Resources
MM--CUL--1
Prior to commencement of construction activities, an
inadvertent discovery clause, written by an archaeologist, shall be added to all construction plans associated with ground disturbing activities and the Project applicant shall retain a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, to prepare a Worker Environmental Awareness Program (WEAP). The WEAP shall be submitted to the City of Arcadia Development Services Department (City) for review and approval. All construction personnel and monitors shall be presented the WEAP training prior to the start of construction activities. The WEAP shall be prepared to inform all personnel working on the proposed Project about the archaeological sensitivity of the area, to provide specific details on the kinds of archaeological materials that may be identified during construction, to explain the importance of and legal basis for the protection of significant archaeological resources, and to outline the actions to be taken in the event of a discovery of cultural resources. Each worker shall also learn the proper procedures to follow in the event that cultural resources or human remains are uncovered during ground-disturbing activities. These procedures include work curtailment or redirection, and the immediate contact of the site supervisor and archaeological monitor.

The WEAP shall require that a qualified archaeologist be retained and on-call to respond to and address any inadvertent
discoveries identified during initial excavation in native soils, which underly the 2-4 feet below ground surface (bgs) of artificial fill soils. As it pertains to archaeological monitoring, this definition excludes movement of sediments after they have been Prior to
commencement of
construction activities;
During construction
activities
Project applicant; Project
archaeologist for preparation
of a Worker Environmental
Awareness Program (WEAP)
City of Arcadia Planning
Division
44 – Mitigation Monitoring and Reporting Program
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
initially disturbed or displaced by project-related construction. If potential archaeological resources (i.e., sites, features, or artifacts) are exposed during construction activities for the proposed Project, the City shall be notified and all construction work occurring within 50 feet of the find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology, can evaluate the significance of the find and determine whether or not additional study is warranted. The archaeologist shall be empowered to temporarily stop or redirect grading activities to allow removal of abundant or large artifacts. Depending upon the significance of the find under the California Environmental Quality Act (CEQA) (14 CCR 15064.5[f]; PRC, Section 21082), the archaeologist may simply record the find and allow work to continue. If the discovery proves significant under CEQA, additional work, such as preparation of an archaeological treatment plan and data recovery, may be warranted. The archaeologist shall also be required to curate any discovered specimens in a repository with permanent retrievable storage and submit a written report to the City of Arcadia for review and approval prior to occupancy of the first building on the site. Once approved, the final report shall be filed with the South Central Coastal Information Center (SCCIC).

Geology and Soils
MM--GEO--1
Prior to commencement of any grading activity on-site, the Applicant shall retain a qualified paleontologist per the Society of Vertebrate Paleontology (SVP) (2010) guidelines. The paleontologist shall prepare a Paleontological Resources Impact Mitigation Program (PRIMP) for the Project. The PRIMP shall be consistent with the SVP (2010) guidelines and shall outline requirements for preconstruction meeting attendance and Prior to any grading
activity; During
grading activities

Project applicant; Project
paleontologist for preparation
of a Paleontological
Resources Impact Mitigation
Program (PRIMP) and
preconstruction meeting
City of Arcadia Planning
Division
44 – Mitigation Monitoring and Reporting Program
Alexan Mixed-Use Development Project Final EIR 11663.03 June 2022 4-5
Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
worker environmental awareness training, where monitoring is required within the Project area based on construction plans and/or geotechnical reports, procedures for adequate
paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections
management. The qualified paleontologist shall attend the preconstruction meeting and a paleontological monitor shall be on-site during all rough grading and other significant ground- disturbing activities in previously undisturbed, Pleistocene alluvial deposits. These deposits may be encountered at depths as shallow as 5-10 feet below ground surface. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontological monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot radius buffer. Once documentation and collection of the find is completed, the monitor will remove the rope and allow grading to recommence in the area of the find.

Hazards and Hazardous Materials
MM--HAZ--1
Prior to the issuance of a demolition permit, the Project applicant/developer or their designated contractor shall ensure that the demolition contractor’s contract incorporate abatement procedures for the removal of materials containing asbestos, as identified in previous surveys, and identification and removal of polychlorinated biphenyls, hazardous material, hazardous wastes, and universal waste items. All abatement work shall be done in accordance with federal, state, and local regulations, including those of the U.S. Environmental Protection Agency (which regulates disposal), Occupational Safety and Health Prior to the issuance
of a demolition permit

Project applicant; Project
contractor
City of Arcadia Planning and
Building Divisions
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Administration, U.S. Department of Housing and Urban
Development, California Occupational Safety and Health
Administration (which regulates employee exposure), and the South Coast Air Quality Management District. Confirmation of adequate removal of such materials shall be provided to the City prior to the issuance of a building permit.

MM--HAZ--2
Prior to the issuance of a grading permit, the Project
applicant/developer or their designated contractor shall prepare a soil management plan (SMP) that outlines the proper screening, handling, characterization, transportation, and disposal procedures for contaminated soils on site. The SMP shall include health and safety and training procedures for workers who may come in contact with contaminated soils. The health and safety procedures shall also include periodic breathing zone monitoring and monitoring for VOCs using a handheld organic vapor analyzer and include required actions to be taken if concentrations of VOCs exceed applicable screening levels for health and safety of onsite workers. The SMP will be based on the findings of the Soil and Soil Vapor Investigation prepared for the Project, will outline areas of known or suspected soil contamination, and will be
implemented by the applicant or their designated contractor for all confirmed and suspected contaminated soils which require excavation and offsite disposal. Contaminated soil shall be managed and disposed of in accordance with applicable
federal, state, and local regulations.

Prior to the issuance
of a grading permit
Project applicant; Project
contractor for preparation of a
Soil Management Plan (SMP)
City of Arcadia Planning and
Building Divisions
MM--HAZ--3
Prior to the issuance of a grading permit, vapor mitigation design features shall be implemented in accordance with the Department of Toxic Substances Control (DTSC) Vapor Intrusion Mitigation Advisory for all future residential buildings and Prior to issuance of a
grading permit; Prior
to construction and
prior to issuance of
certificate of
Project applicant; Construction
contractor
City of Arcadia Planning and
Building Divisions; County of
Los Angeles Department of
Public Works
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
enclosed structures. Draft Supplemental Guidance issued by DTSC indicates long term mitigation may include subslab venting or depressurization systems with or without vapor barriers (subslab liners), and sewer VI mitigation such as venting, check valves, and sewer pipe linings. The construction contractor shall incorporate vapor mitigation design features into building plans that reduce potential vapor intrusion in buildings and enclosed structures on the Project site below DTSC Screening Levels. Vapor mitigation systems may be
passive or active in nature, so long as they are designed to prevent vapor contamination on the Project site in accordance with applicable DTSC regulations at the time the systems are designed. Vapor mitigation systems shall be designed, built, installed, operated, and maintained in conformance with standard geologic, engineering, and construction principles and practices by appropriately licensed professionals and shall be reviewed and approved by the permitting agency(ies) (City of Arcadia, County of Los Angeles) prior to construction and prior to issuance of certificate of occupancy. Operation of the Project shall maintain functionality of these features as required to continue protection from vapor intrusion. Following completion of construction and occupancy of the buildings, indoor air monitoring will occur semiannually for one year to verify implemented measures are functioning properly and adequately mitigating vapor intrusion to below residential DTSC Screening Levels. Results shall be submitted to the City of Arcadia for confirmation of the adequacy of the designed systems. If indoor air samples reveal vapor intrusion occurring at levels above applicable DTSC Screening Levels, modifications shall be made, as necessary, to the designed system to improve the efficacy in reducing vapor intrusion to below applicable screening levels. occupancy with
respect to vapor
mitigation systems
44 – Mitigation Monitoring and Reporting Program
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
Transportation
MM--TRA--1
Prior to the issuance of demolition or grading permits, the Project applicant/developer shall develop and implement a City- approved Construction Traffic Control Plan. The Plan shall be prepared in accordance with applicable City guidelines and shall address the potential for construction-related vehicular traffic, as well as pedestrian and bicycle circulation disruption in the public right-of-way. The Plan shall describe safe detours and shall include protocols for implementing the following:
temporary traffic controls (e.g., a flag person during heavy truck traffic for soil export) to maintain smooth pedestrian and traffic flow; dedicated on-site turn lanes for construction trucks and equipment leaving the site; scheduling of peak construction truck traffic that affects traffic flow on the arterial system to off- peak hours; consolidation of truck deliveries; and/or rerouting of construction trucks away from congested streets or sensitive receptors.

Prior to the issuance
of demolition or
grading permits
Project Applicant for the
preparation of a Construction
Traffic Control Plan
City of Arcadia Planning and
Engineering Divisions
Tribal Cultural Resources
MM--TCR--1.

The project applicant shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation (“Tribe” or “Kizh”). The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. “Ground- Prior to the
commencement of
any “ground-
disturbing activity” for
the subject project at
all project locations,
or prior to issuance of
any permit necessary
to commence a
ground-disturbing
activity; During
Construction contractor; Native
American Monitor from or
approved by the Gabrieleño
Band of Mission Indians – Kizh
Nation
City of Arcadia Planning
Division
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
disturbing activity” refers to ground disturbance occurring from 1 foot above native soils and below, and it does not include movement of sediments after they have been initially disturbed or displaced by current Project-related construction.

A copy of the executed monitoring agreement shall be
submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the
issuance of any permit necessary to commence a ground-
disturbing activity.

The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground- disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

On-site tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant or lead agency that all ground-disturbing activities as defined above and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant or lead agency that no future, planned construction activity and/or ground-disturbing
activity
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
development/construction phase at the project site possesses the potential to impact Kizh TCRs.

Upon discovery of any Kizh TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the Kizh recovers and retains all discovered Kizh TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. The Tribe shall have up to 48 hours to recover and retain any discovered Kizh TCRs, after which time construction activities in the immediate vicinity of the discovery may continue.

MM--TCR--2
Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code
Section 5097.98, are also to be treated according to this statute.

In accordance with Health and Safety Code Section 7050.5, any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

Consistent with California Public Resources Code
section 5097.98(d)(2), any items associated with the human During ground-
disturbing activities
Construction contractor County Coroner; NAHC; City
of Arcadia Development
Services Department
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
remains that are placed or buried with the Native American human remains are to be treated in the same manner as the remains, but do not by themselves constitute human remains.

Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

MM--TCR--3
If the Tribe is designated by the Native American Heritage Commission (“NAHC”) as the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than
human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

Accordingly, if the Tribe is designated as the MLD for discovered human remains, the prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: If the discovery of human remains includes During ground-
disturbing activities
Construction contractor NAHC’s “Most Likely
Descendant” Tribe; City of
Arcadia Development
Services Department
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: In the event preservation in place is not possible despite good faith efforts by the project
applicant/developer and/or landowner, before ground-
disturbing activities may resume on the project site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects. If the Tribe is designated by the NAHC as the MLD, the following condition will apply: Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. Where the Tribe is designated as the MLD, the site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the 44 – Mitigation Monitoring and Reporting Program
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Table 4--1. Mitigation Monitoring and Reporting Program Mitigation Measure
Mitigation Monitoring
Implementation
Timing
Party Responsible for
Implementation
Agency Responsible for
Monitoring Implementation
landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

If the Tribe is designated by the NAHC as the MLD, the following condition will apply: The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery and data recovery-related forms of
documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

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Table of Contents
SSECTION PAGE NO.
4 Mitigation Monitoring and Reporting Program 2
Tables
Table 4-1. Mitigation Monitoring and Reporting Program .............................................................................................. 3

Attachment No. 3
Resolution No. 7435

Attachment No. 4
Aerial Photo and Zoning Information and
Photos of the Subject Property
Overlays
Selected parcel highlighted
Parcel location within City of Arcadia
Yes
Property Owner(s):

Lot Area (sq ft):

Year Built:

Main Structure / Unit (sq. ft.):

DMU
Number of Units:

DMU
Property Characteristics
1972
46,200
0 Property Owner
Site Address: 150 N SANTA ANITA AVE
Parcel Number: 5773-006-036
N/A
Zoning:

General Plan:

Yes
Downtown Overlay:

Downtown Parking Overlay:

Architectural Design Overlay: N/A
Yes, N/A
N/A
N/A
Residential Flex Overlay:

H-8
N/A
N/A
N/A
Special Height Overlay:

Yes, 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 26-Apr-2022