Covina City Council
December 6, 2022

IN day and the have executed this Agreement onyear the hereto paties WHERE OF, ?rst above. for
th
ATTEST:

By
City Clerk
APPROVED AS TO FORM:

By
City Attorney
(SEAL)
OWNER: Inc. SoCalifomia One,
uth
ern By
Title
CITY: C
IT
Y

OFCOVIN
A
By
M
a
y
or

A notary public or other officer completing this certi?cate veri?es only th e
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of tl1eindividual who signed the document to which this certi?cate is atta che
d,
and
not the truth?ilness, accuracy, or validity of that document State of California )
County of Los Angeles )
On , 202 , before me, ,
Iand title ofthe nam oflicer)
Notary Public, personally appeared , who proved to me on the basis of satisfactory evidence to be twhose is/are per name(s) so
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subscribed to the within instrument and acknowledged to me texecuted the he/ same she
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in his/her/theirauthorized capacity(ies),and that by his/her thei r
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I certify under PENALTY OF PERJURY under the la
ws
theat oStef California
f foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)

A notary publicor other of?cer completingthis certi?cate veri?es only th e
i
of the individual who signed the document to which this certi?cate is attac hed,
and
not the truthfulness, accuracy, or validity of that document.

State of California )
County of Los Angeles )
On , 202 , before me, ,
name and officer) title ofthe
Notary Public, personally appeared , who proved to me on the basis of satisfactory evidence to be t name(s) whose is/are pe rs
on
(s)
subscribed to the within instrument and acknowledged to me the/ executed the same she
/
the
y
in his/her/their authorized capacity(ies),and that by his/her thei r
the instrument the on
person(s), or the entity upon behalf of which the person(s) acte d,
ethe instrument.
x
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c
u
te
d
I certify under PENALTY OF PERJURY under the law
s
theat oStef California
f foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)

LI
UL
oro
Exhibit “A”
Legal Description of the Property

THE LAND REFERRED TO HEREN BELOW IS N THE COUNTYOF LOS A N
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APN: 8427—0O1—006

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Exhibit “C”
Develo
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Plan for the Property of Development
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RESOLUTION NO. 2022-023 PC

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

COVINA, CALIFORNIA, RECOMMENDING THAT THE CITY
COUNCIL APPROVE CONDITIONAL USE PERMIT (CUP) 21-29 AND
SITE PLAN REVIEW (SPR) 21-160, TO ALLOW THE DEVELOPMENT OF A 141,984 SQUARE-FOOT 3-STORY PUBLIC SELF-STORAGE
BUILDING (PUBLIC STORAGE) WITHIN A 2.70-ACRE SITE, AND
OTHER ASSOCIATED SITE IMPROVEMENTS, WITHIN THE M-1
(LIGHT MANUFACTURING) ZONE, LOCATED AT 1330 E. CYPRESS
STREET — APN - 8427-001-006.

WHEREAS, PS Southern California One Inc. c/o Bryan Miranda, is the owner of the property located 1330 E. Cypress Street. The property owner has ?led a Conditional Use pennit (CUP) 21-29 and Site Plan Review (SPR) 21-160 (Project) and proposes to develop a 141,984 square-foot 3-story public selfstorage building within a 2.70-acre site, and other associated site improvements, within the M-l (Light Manufacturing) Zone, located at 1330 E. Cypress Street — APN - 8427-001-006.

WHEREAS, on November 8, 2022, the Planning Commission conducted a meeting at which time oral and written comments received prior to or at the meeting together with a written recommendation from the Planning Division was presented to the Planning Commission. The PlanningCommission concluded said meeting on that date.

WHEREAS, all legal prerequisites prior to the adoption of this Resolution have occurred.

NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF COVINA, CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. The foregoing recitals are true and correct and are incorporated herein and made an operative part of this Resolution.

SECTION 2. Based upon the entire record made available at the November 8, 2022 meeting, the staff report the oral presentation and related documents submitted to the Planning Commission prior to and at the meeting the Plarming Commission hereby finds and determines as follows:

1. Findings for Conditional Use Permit (CMC Section 17.62.1201 the use and all yards, spaces, walls and fences, parking, loading, landscaping and other features required by this title to adjust the use with land and uses in the neighborhood. Facts: A described within the ‘Project Analysis’ and illustrated on attached architectural plans dated October 21 2021 (Exhibit 3), the proposedproject complies with all required development standards (i.e size, shape, setbacks, walls, fences, parking, loading, landscaping) for a public tora e facility, and is comparable with other nearby uses in the neighborhood developed under the same criteria as the proposed project. The subject site 1 l cated within the Light Manufacturing (M-1) zone urr nded by commercial a d i ht m n facturing uses to the west, light 1 Page 43 of 1828 uses to the Project Site, and single-farnily residentialuses and Southern Paci?c Railroadto the South. The Project Site is withinan establishedarea characterizedby lightindustrialuses that conformswell to surroundingneighborhoodinfrastructureand support services.The Project Site willrequire20 new trees. The ProjectSit will also include a 6-foot high tubularsteel fence around the perimeterof the north, east, and west secureportions of the site. A 6-foot high concrete masonry unit(CMU) wall will be located adjacent to the south property line. Parking providedby the Project will include21 standard parking spaces,4 ADA accessibleparking spaces, and 3 electric vehicle/cleanair vehicle (EV/CAV) parkingspaces for a totalof 28 parkingspaces.

Three loading spaces will be providedbehindthe proposedbuilding. Therefore, as proposed,this criterionhas been met.

That the site for the proposed use relates to streets and highways adequate in width and pavement type to can-y the quantity and kind of tra?ie generated by the proposed use.

Facts: Theproposedsiteimprovementswillprovideadequateingress andegress to the subjectsiteand improvepathoftravel,facilitating adequatevehicle maneuvering on site. The site is located within an establishedarea characterizedby light industrial uses that conform well to surrounding neighborhood infrastructure and support serviceswith accessto majorstreets and freeway system. TheProjectSitewill remove two of the driveways with the most easterly driveway to remain to provide direct vehicularaccessto PublicStorage fromEast Cypress Street. Therefore, as proposed, this criterionhas been met.

The proposed use will have no adverse effects on the abutting properties or the permitted use thereof.

Facts: The proposeduse is located withinan establishedarea characterized by a lightindustrial uses that conform well to surrounding neighborhood infrastructure and support services. The proposedsite improvementssatisfy all requireddevelopment ‘ProjectAnalysis’ andillustratedon the attached
location, site access locations, building location, parking layout, on-site vehicle maneuvering, and proposed perimeter blockwalls,thereby havingno adverse e?ects to abutting properties. Therefore, as proposed,this criterion has been met. That the conditions stated in the decision are deemed necessary to protect the public health, safety and general welfare. Such conditions include the following: The operation of a public storage facility is conditionally pennitted within the M-l Light Manufacturing Zone. The Project will incorporatea 24-hour/seven-day video surveillance security system of the parking lots, entry-ways, customer lobbies and pedestriancommon areas to ensure the safety. The Project Sitwill also include a 6- foot high tubular steel fence around the perimeterof the north, east, and west secure portions of the site. A 6-foot high concrete masonry unit (CMU) wall will be located adjacent to the south property line. The access system requires customers and employees entering the secure area to enter a unique access code at both the sliding security entry gate and the telescopingentry gate. An individualaccess code is also requiredto enter the customer lobbies and send the elevatorto the ?oor of the customer’s storage unit. This security measure limits who can access parking areas and customer lobbies and allows management to review who has entered and exited these areas, if necessary. The Projectdesignwouldinclude lightingof parkinglots,

II.

I.

3. entry-ways, and pedestriancommon areas for site security purposes. Therefore, as proposed,this criterion has been met.
frSite
' C 'nl7 . 0
All provkions of 'l‘ltle of the CMC are complied with and the following are so arranged that traf?e congestion is avoided, pedestrian and vehicular safety and welfare are protected, and there will be no adverse effect to surrounding properties: buildings, structures and improvements; vehicle ingress, egress and internal circulation; setbacks; building height; location of service; walls; and landscape materials.

Fact: As describedwithinthe “Project Analysis”,the proposed projectcomplieswith all required provisions for a public storage facility use located within the Light Manufacturing (M-l) zone. The proposed site improvements follow all required developmentstandardsfor a publicstorage facility and comparablewith other nearby uses in the neighborhood due to the site located within an established area characterizedby existingstreets, sidewalks,walls,andcommercialbuildings/usesthat conform well to surrounding neighborhoodinfrastructure,circulationand support services. The proposed in?ll development, increase in landscapingalong the site perimeter, and improved defensible space planning measures on site will provide additionalpedestrianand vehicularsafety and welfareto itssurrounding environment.

The projectwould have no negative impactsto existingstreets and sidewalksin that, the proposedproject is a commercialstructure beingdemolishedto accommodatea similar/relatedcommercial use and would be minimal on existingand surrounding traf?c conditions with the proposed site improvements. With the proposed modi?cations and overall site improvements, the proposeduse will have no adverse effect to surrounding properties. Therefore, as proposed,this criterion has been met.

The project design conforms to the general plan, the design guidelines, transportation demand management regulations, and any speci?c plans or guidelinesapplicableto the project;
Fact: The proposed scope of work is consistent and conformsto the City of No. Policy No. 7, in that the
similar/relatedcommercialuse “facilitates developmentfor community economic betterment,image enhancement,will not adverselyaffect the integrityof established commercialand/orindustrialareas,encroachintoresidentialneighborhoods,or impose undue burdens on local infrastructure or services.” The proposed public storage facility conforms to the City's design guidelines for said use, as reviewed and deten-nined by planning staff. As such, the proposed scope of work satis?es all applicable guidelines to the project, as outlined under the CMC Chapter 17.54 M-l- Light Manufacturing Development Standards, the Covina Design Guidelines, and GeneralPlan therefore,this criterionhas been met. The project design is harmonious, consistent and complete within itself and functionally and visually compatible with neighboring structures and the area in which it is located; Fact: As previouslystated under “Project Analysis,” the subjectsite is located withinthe LightManufacturing(M-l) zone, whichissurroundedbycommercialand lightmanufacturingusesto thewest, lightmanufacturinguses to theeast, singlefamily residential homes and a school to the north, with an approximately60-foot wide

arterialstreet bufferbetweenthe residentialand school uses and the Project Site, and singlefamily residentialuses and SouthernPaci?c Railroadto the South. The subject site is within an establishedareacharacterizedby lightmanufacturingusesthat connect well to existing neighborhood intiastructure and support services. Proposed improvements to the site are aesthetically pleasing, functional, visually compatible with neighboringstructures and the area withinwhich it is proposedto be located,and in compliancewith the CovinaDesign Guidelines. Therefore,this criterionhas been met.

4. The developnientwill constitute an adequate environment for the intendeduse by sustaining the desirability and stability of the neighborhood and community; Fact: The proposed Project is designedand in conformancewith development standards consistent with the character, appearance, and features of public storage facility, thereby facilitating the desiredsustainabilityand stability adequate for its environment,theneighborhoodandcommunityitwillserve. Therefore,this criterion has been met.

5. Proposed lighting is so an-angerl as to reflect lighting away from adjoining properties;
Fact: Any proposedexteriorwall-mountedlightingwillbe shielded,directed,or illuminatedaway ?'om neighboringproperties. Accent lightingof buildings,trees, or other landscape features will accentuate those individualfeatures with no spillover beyond the facadeof the building or tree and be fully shieldedand mountedas close as possible to the architecturalfeature of the building or tree being illuminated. A lighting plan will be submittedfor review for compliancewith the applicable safety, security, and design relatedprovisionsof the ZoningCode and DesignGuidelines, as a conditionof approval, Therefore,as conditioned,this criterionhas been met.

6. Proposed signs will not by size, location, color or lighting, interfere with traific or limit visibility;
Fact: Any proposed signage is not a part of this review and approval. As a conditionof approval, a separate sign permit applicationand relatedplans will be requiredshowing compliancewiththe City of Covina’sSign Ordinance. Therefore, as conditioned,thisconditionhas beenmet.
1164.130. Fact: The applicant will be required to comply with utility and/or street improvementsrequiredby the Department of PublicWorks(Engineering,Traffic,and EnvironmentalServices.) Therefore,as conditioned,this criterionhas been met. SECTION3, Pursuant to and in accordancewith CEQA,the City of Covina has completed an initial Study to detennine whether the Projectmay have a signi?cant effect on the environment. The Initial Study concludes that the Project, with mitigation measures, will not have a signi?cant effect on the environment. The City has thereforeprepareda Mitigated Negative Declaration(MND), to be considered by the PlanningCommissionand City Council.Pursuantto Section15072of the CEQAguidelines,the Projectsite is not on any of the lists enumerated under Section 65962.5 of the Government Code. The MNDidenti?esthat the proposedprojectwouldresultin no impactor lessthan signi?cantimpactsin the following environmentalimpact categories:agriculturaland forestry resources, air quality, biological resources, energy, geology and soils, greenhousegas emissions, hydrologyand water quality, landuse and

1%
agriculturaland forestry resources, air quality, biological resources, energy, geolo gy
angreenhouse soils,
d gas emissions, hydrology and water quality, land use and planning, mineral res ou
rc
es,
services, public
recreation, transportation, utilities and service systems, and wild?re. With the in co
rp
or
ati
on
of mitigation
measures identi?ed in the MND, the potentiallysigni?cant impactsof the propose d
the following in
categories would be reduced below a level of signi?cance, cultural and tribal hazards and hazardous materials, and Noise. No signi?cant and unmitigable impacts have bee n
MND. the in
The Notice of Intent to adopt the MND was published in the San Gabriel Valley E x
a
m
in
er
2022, onJuly 7,
and the MND was released for a 30-day public comment period beginning on Jul y
ending o202 and 7
2, August 5, 2022. The Final MND, which consists of the Dra? MND, Commentsand the MND, Dra? Responsesto Comments, has been completedin accordance with the requirements The Planning C E
Q
A
.

Commission by Resolution No. 2022-021 has recommended that the City Counciland the MND Mitigation Monitoring and Reporting Program (“MMRP”). Said resolution bythis in co
rp
or
at
ed
reference and incorporated herein.”
SECTION4. Based upon ?ndings and conclusion set forth in Sections 1, 2 an d
Planning 3the abo
ve, Commission hereby recommendsthat the City Councilapprove the following app lica
tio
ns:

A. The Conditional Use Pennit (CUP) 21-29 and Site Plan Review tosubject 21- 160, the conditions of approval set forth in the written record the Commissio n incorporated here and attached hereto as Exhibit “A.” B. The Secretary of the PlanningCommission is directed to serve, by written amail, notice of this decision to the Applicant within ?ve (5) days.

SECTION 5. This Resolution shall become effective immediately upon its a d
o
p
ti
o
n
,
10atosubject
calendar-day appeal period
APPROVED AND ADOPTED by the members of the Planning of Covina this 8"‘day of November 2022.

SUSAN ZERMENO, CHAIR

CITY OF COVINA PLANNI
NG
CO
M
MI
SSI
O
I hereby certify that the for
eg
oin
g
Planning bythe Resolution adopted true of aicopy
Commission of the City of C
ov
in
a
8"‘ November the day of held meeting thereof onatregular a 2022, by the following vote ofCommission: Plan
ning
AYES: RICHARDSO
N

ZERMENO MCMEEKIN, CONNORS R
O
D
R
I
G
U
E
NOES: NONE
ABSENT: NONE
ABSTAIN: NONE
‘ ANNING SECRETARY

CITY OF COVINA

COMMUNITYDEVELOPMENTDEPARTMENT
“EXHIBIT A”
RESOLUTIONNO.2022-023PC
CONDITIONALUSE PERMIT (CUP) 21-029,
SITE PLANREVIEW (SPR) 21-160,AND
APN: 8427-001-006

CONDITIONSOF APPROVAL AND

MITIGATIONMONITORINGANDREPORTINGPROGRAM
Development Application(s):
l. ResolutionNo. 2022-023PC reconnnendingthatthe City CouncilapproveConditional Use Permit (CUP) 21-029,for a proposedself-storage use, a Site Plan Review (SPR) 21-160,for site developmentconsisting of demolishingan existing 55,321squarefoot 2-story commercial building to allowthe construction of a new 141,984square foot 3-story public self-storage building on an approximately2.70-acre site. The project site is within the M-1 Light Manufacturing Zone, locatedat 1330E.Cypress Street(APN: 8427-001-006).

ALL OF THE FOLLOWING CONDITIONSAPPLY TO THE PROJECT
APPLICANT SHALL CONTACT TE PLANNING DIVISION AT 626-384-5450, FOR COMPLIANCE WITH THE FOLLOWING CONDITIONS:

A. TIME LIMITS:

1. Conditional Use Permit (CUP) 21-029 and Site Plan Review (SPR) 21-160: Approvalof this applicationwillexpiretwo years fromthe date of Projectapprovalif buildingpermitsare not issuedimless otherwiseextended pursuant to applicablelaws.The applicantmay apply to extend the expiration date for a maximum period of one year upon written request to the Directorof Community Developmenta minimumof thirty (30) days prior to expiration. The Approval of ConditionalUse Permit (CUP) 21-029 and Site Plan Review (SPR) 2|-160 are contingent upon approval of the Mitigated Negative Declaration(MND) and Development Agreement (DA) 22-001, by the City Council. B. GENERALREQUIREMENTS: 1. 1|Page This approval will not be effective for any purposes untilthe Applicanthas ?led with the Planning Division an a?idavit stating that it is aware of and agrees to accept all of the conditions of this approval as set forth herein, within 10 calendar days from the date of approval. To the full extent pennitted by law, Applicantagrees to and shall fully indemnify, hold harmless,and defend, CITY and its respectiveelectedand appointedo?icials, of?cers,

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 2|-029, SPR 21-I60, DA22-00]

members, agents, employees, and representatives(each an “Agent” and collectively“Agents”) fromany andall claims,suits,causesof action,?nes, penalties,proceedings,damages, injuries or lossesof any name, kind or description,speci?cally includingattorneys’ fees(collectively, “Claim(s)”), arising in any way out of or challenging the validity of Project, or the CEQA Determination.Applicant's indemni?cationobligation shall include, but not be limited to, actionsto attack,set aside,void, or armulany approval,should it occur,relatedto theProject, or theCEQADetermination,includingactionsinvokingPlanningandZoningLaw or CEQA.

Applicant shall reimburseCITY for any court costs and attorneys’ fees that CITY may be required by a court to pay as a result of such Claim(s). CI'I'Ymay, at its sole and absolute discretion, participateinthe defenseof any suchClaim(s) undertakenby Applicant, or (b) retain separate counselwhose attorneys’ fees and costs shallbe paidby Applicant. Such participation in the defense of suchClaim(s) or the retentionof separate counselby CITY shall not relieve Applicantof its obligationsunderthese indemnityrelatedconditionsof approval.

CITY shallpromptlyprovidewrittennoticeto Applicantof any Claim(s). CITY shalltake all necessary and reasonablesteps to provide suchnotice to Applicantin a timelyfashion and in a mannerthat will not result in any substantialprejudice to Applicant's ability to defend the relevant Claim(s). Such notice shall contain a copy of any relevant pleadingstiled in connectionwith the relevantClaim(s). CITYand Applicantshall coordinateand cooperate in theirdefenseactivities,whetherCITY is participatingin defenseundertakenby Applicantor is retainingseparate counsel. As used in this Agreement, cooperationdoes not includeCITY having to take any actionor make any decisionthat CITY does not believe, in the exercise of its good faith judgment, is in its own best interest. Unless expressly providedto the contrary, nothing in this Ageement shall be construedin a manner that requires CITY to exercise its discretionin a particular manner.

Applicantmay not resolve suchClaim(s) withoutCI'I'Y's priorwritten consent. In all events, CITY shall have the right to resolve any such Claim(s) in any manner, in its discretion, provided,however, Applicant’sconsent shall be required(and may be granted or withheldin Applicant’sdiscretion) if the resolutionof the Claim(s) shall require a payment by Applicant or limitApplicant's rights underthe Project. Applicant’: obligationto paythe cost of any such Claim(s), includingjudgment, post-judgmentmotions, and any and all appeals,shall extend until any Claim is completelyconcluded,judgment is entered and completelysatis?ed. elected and appointed officials, officers, members, agents, employees, and representatives (each an “Agent” and collectively “Agents"), and shall hold and save them and each of them harmlessfrom any and all claims, damages of any kindand litigationwhich may arise from Applicant's or Applicant's agents, contractors, subcontractors, agents, or employees’, whether such operationsbe by Applicantor by any of Applicant's agens,contractors or subcontractors or by any one or more persons directly or indirectly employed by or acting as agent for Applicantor any of Applicant'sagenm,contractors or subcontractors. All indemnity provisions,as set forth above,shallsurvive terminationofthe Projectand shall continueto be the liabilityand obligationof Applicant,binding upon Applicant,untilthe ?nal resolutionof all Claims, and shall survive the completion, partial completion,or abandonment of the Project. The Applicant shall reimburse the City for all fees and costs for special review of these applicationsby both (i) the City’sretainedplanning,engineering,and related consultantsand

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 21-029.SPR 21-160,DA22-001

C.

10. ll.
(ii) theCovina City Attomey’s O?ice through an executedReimbursementAgreement. Such special review includes, but is not limitedto, review of the Project's compliancewith conditionsof approval,plan checkprocess,etc.

The Project Site and all improvementsthereon, includinglandscaping,must be maintainedin a sound, healthy, and attractiveconditionreasonably free of weeds, visible deterioration, graf?ti, debrisandlorot:herconditionsthat violatethe CovinaMunicipalCode.

The costs and expenses of any code enforcement activities, including, but not limited to, attomeys' fees, causedby Applicant'sviolationof any conditionor mitigationmeasureimposed hereunderor any provisionof the OovinaMunicipalCode must be paidby the Applicant.

Approvalof the CUP and SPR applicationsshall not waive the Applicant’sobligationfor compliancewithallotherapplicablesectionsoftheCovinaMunicipalCode,theCovinaDesign Guidelines,andall otherapplicableplans and non-City lawsandregulations.

SITE DEVELOPMENT

1. The Project Site shall be developedand maintainedin accordancewith the CovinaMunicipal Code, and the approvedplans on ?le with the Community Development Department, all representationsofrecord madeby theApplicant(s),the conditionscontainedherein,theCovina MunicipalCode, and the CovinaDesignGuidelines.

Final plans incorporatingall conditionsof approval and any plan~relatedchanges required in the approval process shall be submitted for the Director or his/her designee for review and approval, priorto submittalfor Plan Checkprocess.

A complete building materials illustration board, describing material, brands, types, and applicablereferencenumbersshallbesubmittedto thePlanningDivision.Minormodi?cations in elevation daails and/or colors may be submittedwith detaileddrawings and/orinformation to the Director or his/her dcsignee for review and approval, prior to or during the subsequent Plan Checkprocess.

All site, precise grading landscape, and irrigation, and street improvement-plansshall be coordinatedfor consistency, priorto issuanceof any building pennits. All ground mountedutility appurtenances such as transformers, etc. shall be adequately screenedusing a combinationof concrete or masonry walls, and or landscaping to the reasonablesatisfactionofthe Directoror his/herdesignee. During constructionand following Projea completion,all gradingand all exteriordrainageon the Project Site shall conformto all applicablerequirementsof the PublicWorks Department. A complete exteriorlightingplan, including photometricprintout,shall be submittedfor review and approval,prior to issuance of building pennits. The plan shall illustrate light ?xture features, locations, height, and the compliancewith applicableCity Code provisionson

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 2!-029, SPR 21-I60, DA 22-001
Page4ofl0
ll.
illumination, design, and lighting orientation/glare prevention and the minimum one-foot candle standardwhereapplicable.

All building andsite improvementsalong with landscapingand irrigation must be installedin accordance with approvedplans and infomtationon ?le with the Plarming,Building,and EngineeringDivisions,and the inigationsystems must be fully operationalupon issuanceof certi?catesof occupancy. Furthermore,duringconstruction,all on-sitelandscapedareasmust be maintainedreasonably free of weeds and debris.

The Project Site must be clean and reasonably free of trash and constructiondebris, and all constructionequipmentmust be removed from the Project Site prior to issuance of the last certi?cate of occupancy.

Grading
a. Grading of the Project Site shall be in accordance with then-current adopted California Building Code, City Grading Standards, and accepted grading practices. The Rough Grading Planand PreciseGrading andDrainage Plan(s) shallbe in substantialconformance with the approvedconceptualgradingand drainage plan.
b. A soilsreport shall be preparedby a quali?ed engineerlicensedby the State of California to performsuch work.Two copieswillbe providedat gradingand drainageplansubmittal for review. Plans shall implementdesign recommendationspersaid report. c. A geologic report shall be preparedby a quali?ed engineer or engineeringgeologistand submittedat the time of applicationfor Grading and Drainage Plan review. d. The PreciseGrading and Drainage Plan, appropriatecerti?cations and compactionreports shall be completed,submitted,and approved by the Building and Safety Official prior to the issuanceof BuildingPermits.
e. ThisProjectshallcomplywiththe applicableaccessibilityrequirementsofthe then-current adoptedCaliforniaBuildingCode.

D. LANDSCAPINGANDWATER EFFICIENT REQUIREMENTS

1. All landscape or planterareas shownon the approvedlandscapeplan shallbe constructedsuch that they can remain landscaped in perpetuity. These areas shall not be paved or used for Detailedon—siteand o?'-site landscape and irrigation plansshall be submittedto the Director of Community Development or his/herdesignee for review and approval, priorto issuance of building permits. The landscapeand planter areas shall conformto applicablestandardsand requirementsof the City's Water Bf?cient Landscape Regulationsand the July 2015 Updated Model State Water E?icient Landscape Ordinance of the State of California Water Commission. E. CONSTRUCTIONMITIGATION AND MANAGEMENT PLAN I. All constructionmust complywith the below-notedconstructionmitigationplanand theCity NoiseOrdinance. The Applicantshall preparea constructionmitigationand management plan to mitigatenoise as well as other construction-relatedimpacts. The construction-relatedactivitiesshall conform

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 21-029, SPR 2|-160, DA 22-001

to the following requirements that address potential noise and other construction-related impacts:

8. The constructionmitigationplan shalladdresstlnefollowing areas: 1) site supervision, 2) constructionaccess and schedule,3) deliverylhaul route andtraffic control,4) material storage and staging,5) constructionparking,6) workhours, 7) noisereduction,8) erosion control,9) dust and mud control, 10) debriscleanup, l 1)street sweeping,l2) pedestrian and neighborhoodsafety, 13) Project contact-relatedsignage, and 14) subcontractor educationand securitymeasures.

Providecontact infonnationforQuali?edStorm Water Practitioner(QSP) andQuali?ed StormWater Developer (QSD).

Construction-relatedactivities, including gradingactivities, shall be prohibitedbetween 6:00 pm and 7:00 am on Monday throughFriday and between 5:00 pm and 8:00 am on Saturday and all day on Sundays and Holidays(except by specialpemnit).

All constructionequipmentshallbe in properoperatingconditionand shallbe ?tted with standardfactory noise attenuation features. All equipmentshall further be properly maintainedto helpassure that no additionalsigni?cant noise,dueto worn or improperly maintainedparts, wouldbe generated.

The Applicant and/or hislher representative(s) shall frequently monitor for and, if detected, remove any and all graffiti on and/or repair damaged or vandalized construction-relatedfencing and/orrelatedelementsas quicklyas feasible.

Loud noisegeneratingactivities such as crushing concrete pavement will be restrictedto 7:00 am — 6:00 pm on Monday through Friday. Signs (multiple)shall be postedon site stating the days and hours of constructionallowed, prohibiting“drinking. loitering and music” at all times, and including phone listings for community concerns.

View-obscuring constructionfencing shall be provided around the entire Project Site.

Constructionentriesshall have gameswith view-obscuring material.

At leastthirtydays priorto the commencement of any Project-relateddemolitionandgrading, the Applicantand/or his/herrepresentative(s)shall notify the occupants of all residentialand institutionalpropertiesthat lie within500 feet ofthe ProjectSite of the general parameters of the impendinggrading and constructionactivities.

The approved constructionmitigation arndmanagement plan shall be distributedto all APPLICANT SHALL CONTACT THE BUILDING& SAFETY DIVISIONAT 626-384-5460,FOR COMPLIANCE WITH TE FOLLOWING CONDITIONS: F. HOUSING DIVISION 1. Non-residential (commercial,of?ce or industrial) developmentimpactfeesforthe Projectshall be paid, priorto the issuanceof any permitsfor the Project. Development Impact Fees apply where new squarefootage is created in commercialand industrialdevelopments. The Applicant shall contact the Director or his designee for calculation of the developmentimpact fee, prior to issuance of any permits for the Project:

« [NW VI ..m..,..)
M (~,..,.. ..M“)
(1.. )

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 2!-029, SPR 21-160.DA 22-00]

Land U ImpactFee Square Feet Square eet Total Fee
or
de o hed
credit
Commercial 5 6.253 per bldg.square X - Use foot addedor created OfficeUse 3 5.721 perbldg.square X 900 - 0 $5,148.90
foot added or created
industrial Uses S 2.173 per bldg. square X 141,084 - 55,32l $186,362.99 G.
foot added or created

BUILDINGANDSAFETY DIVISION

1. Submit4 sets of completeplans including any proposedutilitiesand earthwork/grading.The Project must complywiththe2019CalifomiaBuildingCode andStandartk.(see handoutsformin submitlalrequirementsfor constructionplan check).

Two sds each of any structuraland energy calculationsshall be submittedwith the abovementionedplans.Allcalglations mg; @ angrig? signature?gm the documeng a?rgg, This Project must complywith applicableFederal and State Accessibilityrequirementsto and throughout the buildings. include compliancemethods and structuraldetails on the plans. it is recommendedthat an independentCASpreview of the projectbe performedalthoughyour new facility may have alreadybeenapprovedand permittedby the buildingdepartment,it isimportant to obtainCASp inspectionservicesalter your move-inbecauseunintendedaccess barriersand violationscan be created,suchas placingyour ?rmitureandequipmentin areas requiredto be maintainedclearof obstructions.For plannedalterations,a CASpcan reviewyour improvement plansandprovidean access complianceevaluationofyour facility's publicaccommodationareas that may not be part ofthe alteration.

Demolitionactivitiesrequirean asbestoscontainingmaterials(ACM) survey. (SCAQMD RULE l403).TheACMreponshallbepreparedbyanaccmditedtes?nglabmatoryinaccordancewidr rulesandregulations. Proofof noti?cationto the SouthCoast AirQuality Divisionwiththe relevantpennit applicationfor all demolitionactivities.Contactthe SCAQMD at the address or numberbelow for more information.Once any demolitionactivity has adhered to the applicablenoti?cationrequirementsto the SCAQMD,a fonnal demolitionplanandpennit must beobminedfrom the Buildingand SafetyDivision. 0 SCAQMDHeadquarters; 21865 Copley Drive, Diamond Bar, CA, (909) 396- 2381 Pleaseprovidean additionaldigitalcopy (pdfprefened) of the building?oor plan,elevations, and site planto be submittedto the LA County Assessor. This copy shouldbe in su?icient detail to allowthe assessor to determinethe square footageofthe buildingsand, inthe case of residential buildings,the intendeduse of each room. For additional information, please contact the LA County Assessor’s, Public Service Desk at 88&807-2111.

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 11-029,SPR 21-160, DA 22-001

6. Constructionactivitywithin500' of a residentialzone isprohibitedbetweenthe hoursof 6:00pm and7:00amonMondaythroughFridayand between5 pmand Sarnonsatrmdayandalldayon Sunday andHolidaysunlessotherwisepermitted.

APPLICANTSHALL CONTACT THE PUBLIC WORKS DEPARTMENTAT 626-384-5490,FOR COMPLIANCEWITH THE FOLLOWINGCONDITIONS:

II. PUBLIC WORKS - ENGINEERINGDIVISION
I. Priorto issuanceof any permits,the applicantshall submita Precise Paving& DrainagePlan for the project showing building footprints,pad elevations, ?nished grades, drainage routes, retainingwalls, erosioncontrolmeasures, and other pertinentinformationin accordance with AppendixJ ofthe CaliforniaBuildingCode,latest editionforreview and approvalof the City Engineer.

The applicant shall submit a ?nal Soils and Geologic Report to the satisfactionof the City Engineer.

Prior to the issuanceof a Grading Permit, the applicantshallsubmita temporary erosioncontrol planto the satisfaction of the City Engineer. The erosioncontrolshall be installedand operable at all times.

Improvement PlansandConstruction:
a. The applicantshallremoveand replacethe existing curb& gutter and sidewalkwithin the limits ofthe developmentto the satisfactionofthe City Engineer. b. The applicantshall installstreet trees along the southside of Cypress Street withinthe limitsof the developmentto the satisfactionof the Departmentof PublicWorks. c. The applicantshallobtaina publicworkspermitfor allwork in or adjacentto the public right-of-way(ROW). All work within the public ROW shall be in accordancewith applicable standards of the City of Covina, i.e. Standard Speci?cations for Public Works Construction(Green Book), and the Work Area Traffic Control Handbook (WATCH), and further that constructionequipmentingress and egress be controlled of the Project Site development, including streets and paving, curbs and gutters, sidewalks,and street lights,as determinedby the City Engineer. e. The applicant shall reconstruct the existing pavement section ( ” Grind/2” AC Overlay) for the southerly half of Cypress Street within the limitsof the development to the satisfactionof the City Engineer. f. Pavement striping shallbe installedon the newly reconstructedpavement surface on Cypress Streetto the satisfactionof the City Engineer. The applicantshalldedicateadditionalproperty along the northside ofthe property to theCity of Covina to provide a minimum half-width of 40 feet for Cypress Street, as shown on submittedplansto the City. The Applicantshall enhance the existing storm drain inlets on the property to meet current standardsand provideotherdrainageimprovementsas necessary to carry runoffof storm water inthe area proposedto bedeveloped,andforcontributingdrainagefromadjoiningproperties

R‘ M
’
. I _=

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 21-029,SPR 21-I60, DA 22-00]

to the reasonablesatisfactionofthe City Engineerand in accordancewith all applicablefederal, state and locallaws and regulationsandCity's SubdivisionOrdinance(CMC ChapterI6). The proposeddrainage improvementsshall be basedon a detailedhydrologystudy conforming to the current Los AngelesCounty Methodology.

The applicantshallprovidedemiledhydrauliccalculationsto verify the capacityofthe existing downstreamstonn drain and verify the integrityof the existing downstreamimprovements. If the downstream improvements do not meet the requirements and standards of the City of Covina and Los Angeles County Flood Control, the applicant shall reconstruct the system to the satisfactionof the City Engineer.

The developershallundergroundall new electricalandcommunicationutilityservicespanning the distance from the proposedPublic Storage facility building to the existing overhead electricaland communicationdistributionutilitylinesthat are alignedparallel,and adjacentto, Cypress Avenue, located within the Cypress Avenue right-of-way to the satisfaction of the Community Development Director. The developer is not responsiblefor undergrounding the existing overheadelectricaland communication distributionutility lines that are aligned parallel,andadjacentto, Cypress Avenue, locatedwithinthe Cypress Avenue right-of-way.

PUBLIC WORKS - ENVIRONMENTAL SERVICES DIVISION AT 626-384-5480, FOR COMPLIANCE WITH THE FOLLOWING CONDITIONS:

1. 2.

Complywith the Low Impact Development(lid) requirements.

LID — Project quali?es as a Low Impact Development, and must incorporate storm water BMPs.

Waste Management Projectdebris may be hauledoffsiteby the City's franchisewaste hauler, or self-hauledby the Applicantto an approvedrecycling facility.

C&D — 75% of constructionand demolition debris must be recycled. Forms and a security depositwill be required.

Only and disposeof trash. APPLICANT SHALL CONTACT THE POLICE DEPARTMENT AT 626-384-5623, FOR COMPLIANCEWITH THE FOLLOWING CONDITIONS: J. POLICE DEPARTMENT When applicable,the owner or operator shall contract with a security company for security personnelor hire securitypersonnelas employees. a. If the owner or operator choosesto hire a security company,the securitycompany must be licensed to operate in both the State of California and the City of Covina. Additionally all employees who are assigned to work the premises must be licensed by

..:4 _,,.
cm! or COVINA
CONDITIONSor APPROVAL
cur 2n-029, sra 2n-nan, DA 22-001

tlneState of Californiaas securityguardsand be in good standing throughouttheir time of employment.
b. In the event the owner or operator or manager providetheir own security personnel,all personnel must be employed only as security personnel and not have other responsibilitieswhile acting in that capacity. Additionally, all employees acting as securitypersonnelmust be licensedand in good standingwith the State of California through theirtime of employment.

2. At no timewill any securitypersonnel,whetheremployed by a private company or licensedby the City or employedby the establishment,be armedwithany type of ?rearm.

3. Exteriorlightingto include: Parkinglot liglnt?xtures arndwall mountedlight?xturesshall be of LED.Detailedplansto showcomplianceshallbe submittedto PoliceDepartmentand Planning Division for review and approval, prior to issuance of permit and prior to installation.The conditionof approvalshallbe accomplishedon or beforeopening.

4. Way?nding sigrnageshall be providedand submittedto PoliceDepartment and PlanningDivision for review and approval. Way?nding signage shall have lighting as well. The condition of approvalshall be accomplishedon or beforeopening.

5. Signage statingvehiclecode is enforceablemust be postedat all entrances so thinguests/visitors are aware of what will be enforced on the property. Police Department to review signage.The conditionof approvalshallbe accomplishedon or beforeopening.

6. The pemnitteeand the operator of any businessat the premisesshall install, use, and maintain in goodworking conditiona video security system capable of viewing and recording events at the premisesas approvedby theChiefof Police. The video securitysystem shallbe on and operating at all timesby commonareas, developmentenhances and exits, and parkingareas. The video security system shall be of such to provide images of such a resolution as to clearly identify individualsfor later identi?cation. Security systems could deter and prevent public nuisances.

Installationand approvalshall occur priorto the releaseofthe occupancyor approvalof business license.
operator at employee or other person is present on the premisesduring nonnal businesshours with the necessary knowledgeand skill to operate the video security system so that he or she is able to providethe CovinaPoliceDepartmentcopiesof video recordingsimmediatelyupon request. 8. The per-mitteeand the operator of any business at the premisesshall preserve the video security system’srecordedinformationof each businessdayfora periodof not lessthanten (10) business daystherea?er fortheCovinaPolice Department'sreviewinconnectionwitha criminalor other investigation. 9. The owners, operators, or managers shall,subject to approvalof the Police Department,develop a planto monitorthearea surroundingthe locationfortrash and otherdiscardeditemsthat impact publichealth and to maintainthe cleanlinessof the parkinglots,sidewalks,and the property of adjacentbusinessowners.

CITY OF COVINA

CONDITIONSOF APPROVAL
CUP 2|-029, SPR 21-160, DA22-001

l0. The owners, operators, or managersshall,subjectto approvalof tdevelop Departme Po nt. lic
e
ll.
a planto ensurethat all exteriorlocationsare adequatelyand saf ely
hours of during ill
u
mi
na
te
d
darkness.

The owners, operators, or managersmust complywith all City c o
d
e
s
torelating ordinan and
ces policeresponseand abatementnuisanceconditions.
. All landscaping should follow the two-foot six-foot rule. All ground beshould cover, two feet or less and lower tree canopies shouldbe at s i
x
natural This increases fe
et
. surveillanceand eliminates hidingareas within landscaping. Tr ee
interfere not should c
a
n
o
p
i
e
s
with or blockthe ligrting along sidewalksor parkinglots. Thi s
of andreas shadow c
rs
e
a
t
e
s
concealment.Planterswill use plant species with limitedg r
o
w
t
h.
that ensure toThis is
maintenancedoes not becomean issue and surveillancefromthemaintaine is d.
. Any rolling gate, community access point garage, and any pe de
str
ia
n
including access, gate
slidingsecuritygate and telescoping gate, shallhave a keypad in st
al
le
d
code access current with
providedto PoliceDispatchat (626) 384-5808.

K. IDS ANGELESCOUNTY FIRE DEPARTMENT — FIRE PRE
VEN
TIO
N

DIVISION

1. Comply with Los Angeles County Fire Department Codes Re gul
ati
ons
.

MIT
IGA
TIO
N

REPO AND MONITO

PAGE RING NEXT ON

OFCONDITIONS END

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Mitigation Monitoring an
d Program
1330 E. Cypress Street (Public St
or
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The State CEQAGuidelines, Section l5074(d), requires that adopt agency responsi or l ble e
a
d
mitigation monitoring plan when approving or carrying out a identi?es anIS/MND when changes that the lead agency has required in the project or madeor tomitigate of approval c o
n
d
it
i
o
n
avoid signi?cant environmental effects. As lead agency for th e
for City responsible isthe p
r
o
je
ct
,
adoption and implementationof the mitigation monitoring and r e
(MMRP). program
The MMRPis presented in Table 4-1 below and will be in place of throughout all phases etfe ctiv
e
the project. The City will be responsible for administering the parties ensuring that allnd comply with its provisions. The City may delegate monitori ng
consultants, or tostaff, ac
tiv
iti
es
contractors. The City will also ensure that monitoring is docum ented
and thatro reports periodic
ugh deficiencies are promptly corrected.The designated environm ental
and document track will mo
nito
r
compliance with required measures, note any problemsthat ma y
action toappropriate and take r
rectify problems.
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2. 23.3:

1 RESOLUTION CC 2022-133

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COVINA,

CALIFORNIA, ADOPTING MITIGATED NEGATIVE DECLARATION
(SCH2022070107) PURSUANT TO THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT AND THE MITIGATION

MONITORING AND REPORTING PROGRAM FOR DEVELOPMENT
AGREEMENT (DA) 22-001, CONDITIONAL USE PERMIT (CUP) 21-29, AND SITE PLAN REVIEW (SPR) 21-160 FOR THE DEVELOPMENT OF A PUBLIC STORAGE FACILITY WITHIN A 2.70-ACRE SITE, FOR THE PROPERTY LOCATED AT 1330 E. CYPRESS STREET – APN - 8427-001- 006.

WHEREAS, PS Southern California One Inc. c/o Bryan Miranda, is the legal owner of the property located 1330 E. Cypress Street. The property owner proposes to develop a 141,984 square-foot 3-story public self-storage building within a 2.70-acre site, and other associated site improvements, within the M1 (Light Manufacturing) Zone, located at 1330 E. Cypress Street – APN - 8427-001-006 – referred to herein as the “Project.”
WHEREAS, the development of the Project necessitates, and the property owner has applied for, the following land use entitlements:

1.) Development Agreement (DA) 22-001, between Public Storage, Inc. and the City of Covina.

2.) Conditional Use Permit (CUP) 21-29 and Site Plan Review (SPR) 21-160, to allow the demolition of an existing 55,321 square-foot 2-story building and the development of a 141,984 square-foot 3-story public self-storage building within a 2.70-acre site, and other associated site improvements, within the M-1 (Light Manufacturing) Zone, located at 1330 E. Cypress Street – APN - 8427-001-006.

WHEREAS, the Project is considered a “project” as defined by the California Environmental Quality Act, Public Resources Code § 21000 et seq. (CEQA) and the State CEQA Guidelines (14 Cal. Code Regs. sections 15000, et seq.) (CEQA Guidelines).

WHEREAS, pursuant to CEQA, City is the lead agency for the Project.

WHEREAS, the City subsequently contracted for the independent preparation of environmental review for the Project, including all necessary technical studies and reports.

WHEREAS, the City completed an Initial Study to determine whether the Project may have a significant effect on the environment, in accordance with CEQA. The Initial Study, which reflects the independent judgment of the City, concluded that the Project, with mitigation measures, will not have a significant effect on the environment. The City therefore prepared a Mitigated Negative Declaration (MND), to be considered by the Planning Commission and City Council. Pursuant to Section 15072 of the CEQA guidelines, the Project site is not on any of the lists enumerated under Section 65962.5 of the Government Code.

WHEREAS, the Draft IS/MND identifies that the proposed project would result in no impact or less than significant impacts in the following environmental impact categories: agricultural and forestry resources, air quality, biological resources, energy, geology and soils, greenhouse gas emissions, hydrology

and water quality, land use and planning, mineral resources, public services, recreation, transportation, utilities and service systems, and wildfire. With the incorporation of mitigation measures identified in the MND, the potentially significant impacts of the proposed project in the following categories would be reduced below a level of significance, cultural and tribal resources, hazards and hazardous materials, and Noise. No significant and unmitigable impacts have been identified in the MND.

WHEREAS, a Notice of Intent to adopt the Draft IS/MND was published in the San Gabriel Valley Examiner on July 7, 2022 and the Draft IS/MND was released for a 30-day public comment period beginning on July 7, 2022 and ending on August 5, 2022. The Draft IS/MND was available at City Hall, Community Development Department, Planning Division, located at 125 E. College Street, Covina, CA, 91723, and at http://covinaca.gov/pc/page/prjects-under-review. City received no comment letters.

WHEREAS, on September 15, 2022, the notice of public hearing including the Intent to Adopt the Final IS/MND was published in the San Gabriel Valley Examiner in a one-eighth page legal advertisement.

Further, the notice of Planning Commission public hearing was sent to all property owners within 300 feet radius of the Project Site.

WHEREAS, on September 27, 2022 and continued to October 11, 2022, October 27, 2022, and November 8, 2022, at a duly noticed public hearing as prescribed by law, the Planning Commission considered the proposed Project, and any comments received prior to or at the public hearing, at which time staff presented its report, and interested persons had an opportunity to and did testify either in support or in opposition to the proposed project, Draft IS/MND and the Mitigation Monitoring and Reporting Program.

WHEREAS, following consideration of the entire record of information received at the public hearing and due consideration of the Project, the Planning Commission found that there is no substantial evidence that the Project will have a significant effect upon the environment, and the Planning Commission, adopted Resolution No. 2022-021 PC , incorporated herein by this reference, recommending that the City Council adopt the MND and the Mitigation Monitoring and Reporting Program prepared for this Project.

WHEREAS, on December 6, 2022, at a duly notice public hearing as prescribed by law, the City Council considered the Mundane the Mitigation Monitoring and Reporting Program for the Project , and any comments received prior to or at the public hearing, at which time staff presented its report, and interested persons had an opportunity to and did testify either in support or in opposition to the proposed project, MND and the Mitigation Monitoring and Reporting Program.

WHEREAS, all legal prerequisites prior to adoption of this Resolution have occurred.

NOW, THEREFORE, BE IT RESOLVED, after reviewing the Final MND and considering all oral and written information regarding the project presented before and during that hearing, the City Council hereby finds and determines as follows:

SECTION 1. The City Council hereby finds that the above recitals are true and correct and hereby incorporates as though set forth in full by this reference.

SECTION 2. The City Council hereby finds that agencies and interested members of the public have been afforded ample notice and opportunity to comment on the Final IS/MND and the Project.

SECTION 3. The City Council has independently reviewed and considered the contents of the Final IS/MND prior to rendering as decision on the Project. The City Council finds that the Final IS/MND reflects the City Council’s independent judgment and analysis. The City Council hereby finds on the basis of the whole record before it (including the initial study and any comments received), that with the imposition of mitigation measures, there is no substantial evidence that the Project will have a significant

effect on the environment .

SECTION 4. The City Council finds that the additional information provided in the staff reports, the comments on the Final IS/MND, and the evidence presented in written and oral testimony at the City Council and Planning Commission hearings, does not constitute new information requiring recirculation of the MND under CEQA. None of the information presented to the Planning Commission or City Council has deprived the public of a meaningful opportunity to comment upon an environmental impact of the Project or a feasible mitigation measure or alternative that Covina has declined to implement.

SECTION 5. The City Council finds that the comments regarding the Final IS/MND and the responses to those comments have been received by the City; that the Planning Commission and City Council received information and public testimony regarding the adequacy of the Final IS/MND; and that the City Council has reviewed and considered all such documents and testimony and the Final IS/MND prior to making its determination on the Project.

SECTION 6. The City Council, exercising its independent judgment and analysis, and after considering the administrative record, pursuant to CEQA Guidelines section 15074, hereby adopts the Final IS/MND , attached hereto as Exhibit “A” and incorporated herein by this reference.. The City Council also hereby adopts the mitigation measures set forth in the Mitigation Monitoring and Reporting Program, attached hereto as Exhibit “B” and incorporated herein by this reference, and imposes each mitigation measure as a condition of Project approval.

SECTION 7. The documents and materials that constitute the record of proceedings on which these findings and this Resolution are based are located at the City Clerk’s office or the Community Development Department, Planning Division, located at 125 E. College Street, Covina, CA 91723 or at www.covinaca.gov. The custodian of these records is the City Clerk.

SECTION 8. The City Council hereby directs the Director of Community Development to prepare and file a Notice of Determination with the County Clerk under Title 14, California Code of Regulations Section 15075.

SECTION 9. This resolution shall become effective upon adoption.

SECTION 10. The City Clerk shall certify to the passage and adoption of this Resolution and shall enter the same in the Book of Original Resolutions.

SIGNED AND APPROVED this 6th day of December, 2022.
____________________________________

PATRICIA CORTEZ, MAYOR

ATTEST:

FABIAN VELEZ, DEPUTY CITY CLERK
APPROVED AS TO FORM:

____________________________________
CANDICE K. LEE, City Attorney

CERTIFICATION
I, Fabian Velez, Deputy City Clerk of the City of Covina, do hereby certify that Resolution CC 2022-133 was duly adopted by the City Council of the City of Covina at a regular meeting held on the 6 th day of
December, 2022, by the following vote:

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:

Dated:

FABIAN VELEZ

DEPUTY CITY CLERK

EXHIBIT “A”
Initial Study / Mitigated Negative Declaration

Final

CITY OF COVINA PUBLIC STORAGE PROJECT
Initial Study/Mitigated Negative Declaration
Prepared for September 2022
City of Covina

Final

CITY OF COVINA PUBLIC STORAGE PROJECT
Initial Study/Mitigated Negative Declaration
Prepared for September 2022
City of Covina

80 South Lake Avenue
Suite 570
Pasadena, CA 91101
626.204.6170
esassoc.com

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D202100759.02

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City of Covina Public Storage Project i ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

TABLE OF CONTENTS
City of Covina Public Storage Project
Initial Study/Mitigated Negative Declaration
Page
Section 1, Introduction ...................................................................................................... 1-1

1.1 Statutory Authority and Requirements ............................................................... 1-1

1.2 Purpose ............................................................................................................. 1-2 Section 2, Project Description .......................................................................................... 2-1

2.1 Project Location................................................................................................. 2-1

2.2 Surrounding Land Uses ..................................................................................... 2-1

2.3 Existing Site Conditions ..................................................................................... 2-1

2.4 Existing General Plan/Zoning Designations....................................................... 2-4

2.5 Project Features ................................................................................................ 2-4

2.5.1 Building Heights and Elevations.............................................................. 2-4

2.5.2 Parking and Access ................................................................................ 2-9

2.5.3 Landscaping............................................................................................ 2-9

2.5.4 Signage and Lighting .............................................................................. 2-9

2.5.5 Site Security.......................................................................................... 2-11

2.5.6 Water/Solid Waste Generation.............................................................. 2-11

2.6 Construction Activities and Schedule............................................................... 2-11

2.7 Project Approvals............................................................................................. 2-12 Section 3, Initial Study/Environmental Checklist ............................................................ 3-1

3.1 Environmental Factors Potentially Affected ....................................................... 3-3

3.2 Environmental Checklist .................................................................................... 3-4 Aesthetics .......................................................................................................... 3-4 Agriculture and Forestry Resources .................................................................. 3-8 Air Quality ........................................................................................................ 3-11 Biological Resources ....................................................................................... 3-25 Cultural Resources .......................................................................................... 3-29 Energy ............................................................................................................. 3-33 Geology and Soils............................................................................................ 3-39 Greenhouse Gas Emissions ............................................................................ 3-45 Hazards and Hazardous Materials................................................................... 3-52 Hydrology and Water Quality........................................................................... 3-60 Land Use and Planning ................................................................................... 3-65 Mineral Resources........................................................................................... 3-67 Noise ............................................................................................................... 3-68 Population and Housing................................................................................... 3-90 Public Services ................................................................................................ 3-92 Recreation ....................................................................................................... 3-99 Transportation ............................................................................................... 3-101 Tribal Cultural Resources .............................................................................. 3-105

Table of Contents
Page
City of Covina Public Storage Project ii ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Utilities and Service Systems ........................................................................ 3-108 Wildfire........................................................................................................... 3-115 Mandatory Findings of Significance............................................................... 3-117 Section 4, Mitigation Monitoring and Reporting Program.............................................. 4-1

4.1 CEQA Requirements ......................................................................................... 4-1 Section 5, Preparers and Acronyms................................................................................. 5-1

5.1 Preparers........................................................................................................... 5-1

5.1.1 Lead Agency ........................................................................................... 5-1

5.1.2 Initial Study/Mitigated Negative Declaration Preparation .......................... 5-1

5.1.3 Technical Subconsultant......................................................................... 5-2

5.2 Acronyms and Abbreviations ............................................................................. 5-2 Section 6, Introduction to the Response to Comments.................................................. 6-1

6.1 CEQA Requirements ......................................................................................... 6-1

6.2 CEQA Process................................................................................................... 6-2

6.2.1 Public Participation Process.................................................................... 6-2

6.2.2 Evaluation and Response to Comments................................................. 6-2

6.2.3 Final IS/MND Approval ........................................................................... 6-2

6.2.4 Notice of Determination .......................................................................... 6-2

6.3 Summary of Response to Comments Findings ................................................. 6-2 Appendices
A. Air Quality, Energy, Greenhouse Gas Emissions Assumptions and Modeling B. Cultural Resources Assessment Report
C. Geotechnical Engineering Exploration and Analysis Report D. Paleontological Resources Assessment
E. Phase I Environmental Site Assessment
F. Preliminary Hydrology Study and LID Plan
G. Noise Measurements and Modeling Report
H. Trip Generation Analysis Memorandum
List of Figures
Figure 1 Regional Location Map................................................................................... 2-2 Figure 2 Local Vicinity Map........................................................................................... 2-3 Figure 3 Conceptual Site Plan ...................................................................................... 2-5 Figure 4 Concept Elevations......................................................................................... 2-6 Figure 5 Building/Site Elevations .................................................................................. 2-7 Figure 6 Temporary Monopole Detail ........................................................................... 2-8 Figure 7 Conceptual Landscape Plan......................................................................... 2-10 Figure 8 Conceptual Grading Plan.............................................................................. 2-13 Figure XIII-1 Onsite Noise Monitoring Locations ............................................................... 3-70 Figure XIII-2 Offsite Noise Monitoring Locations ............................................................... 3-71

Table of Contents
Page
City of Covina Public Storage Project iii ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 List of Tables
Table III-1 Maximum Daily Construction Emissions....................................................... 3-17 Table III-2 Maximum Daily Operational Emissions ........................................................ 3-18 Table III-3 Maximum Daily Localized Construction Emissions....................................... 3-20 Table III-4 Maximum Daily Localized Operational Emissions ........................................ 3-21 Table VI-1 Summary of Energy Consumption During Project Construction ...................3-34 Table VI-II Project Operational Energy Usage ............................................................... 3-36 Table VIII-1 Annual Project Greenhouse Gas Emissions................................................. 3-49 Table XIII-1 Summary of Ambient Noise Measurements ................................................. 3-69 Table XIII-2 City of Covina Sound Level Limit.................................................................. 3-74 Table XIII-3 RCNM Default Noise Emission Reference Levels and Usage Factors......... 3-77 Table XIII-4 Construction Phasinga .................................................................................. 3-78 Table XIII-5 Estimated Construction Noise Levels at Existing Off-Site Sensitive Receptors ..................................................................................................... 3-79 Table XIII-6 Vibration Damage Criteria ............................................................................ 3-84 Table XIII-7 Groundborne Vibration and Groundborne Noise Impact Criteria for General Assessment .................................................................................... 3-85 Table XIII-8 Vibration Source Amplitudes for Construction Equipment ............................ 3-86 Table XIII-9 Summary of Construction Equipment and Activity Vibration......................... 3-87 Table 4-1 Mitigation Monitoring and Reporting Program for the City of Covina Public Storage Project .................................................................................... 4-2

Table of Contents
City of Covina Public Storage Project iv ESA / D202100759.02 Initial Study/Mitigated Negative Declaration
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September 2022

City of Covina Public Storage Project 1-1 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 SECTION 1
Introduction
The City of Covina (City) has determined the Public Storage Project (the Project or Public Storage or Public Storage Project) is subject to the guidelines and regulations of the California Environmental Quality Act (CEQA). This Initial Study/Mitigated Negative Declaration (IS/MND) addresses the indirect, direct, and cumulative environmental impacts associated with the Project. The Project would include the demolition of the existing 55,321 square-foot (SF) 2- story commercial building (i.e., electronic manufacturing) and the development of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) within a 2.70-acre site.

Project features would include a partial basement, a rental office, a temporary monopole cell tower, associated secured surface parking areas, pedestrian walkways, and landscaping.

1.1 Statutory Authority and Requirements
In accordance with the CEQA (Public Resources Code Sections 2100–21177) and pursuant to California Code of Regulations (CCR) Title 14, Section 15063, the City, acting in the capacity of Lead Agency, is required to undertake the preparation of an Initial Study to determine if the Project would have a significant environmental impact. If the Lead Agency finds that there is no evidence that the Project, either as proposed or as modified to include the mitigation measures identified in the Initial Study, may cause a significant effect on the environment, the Lead Agency must find that the Project would not have a significant effect on the environment and must prepare a Negative Declaration (ND) or Mitigated Negative Declaration (MND) for that Project. Such determination can be made only if, “there is no substantial evidence in light of the whole record before the Lead Agency” that such impacts may occur (Public Resources Code Section 21080(c)).

The environmental documentation is intended as a document undertaken to provide an environmental basis for discretionary actions required to implement the Project. The environmental documentation and supporting analysis is subject to a public review period. During this review, public agency comments on the document should be addressed to the City. Following review of any comments received, the City will consider these comments as part of the Project’s environmental review and include them with the Initial Study documentation for consideration by the Planning Commission and City Council of the City.

The preliminary determination by the City is that the preparation of an MND could be adequate to address the potential environmental issues associated with construction and operation of the Project. Therefore, this document is an IS/MND. If the evaluation determines that a significant

1. Introduction
City of Covina Public Storage Project 1-2 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 impact cannot be reduce to a less than significant level, then an environmental impact report would be required.

1.2 Purpose
The City has prepared this Draft IS/MND to provide the public and responsible agencies with information about the potential environmental impacts associated with implementation of the Public Storage Project. This Draft IS/MND includes project-level analysis of the potential effects associated with the Project.

This Draft IS/MND was prepared in compliance with the content requirements in Section 15071 of the CEQA Guidelines of 1970 (as amended) and CCR Title 14, Division 6, Chapter 3. In accordance with Section 15071, this Draft IS/MND includes a description of the Project, the location of the Project, a proposed finding that the Project will not have a significant effect on the environment, an Initial Study that documents reasons to support the finding, and mitigation measures to avoid potentially significant impacts.

City of Covina Public Storage Project 2-1 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 SECTION 2
Project Description

2.1 Project Location
Regionally, the Public Storage Project is located in the City within the San Gabriel Valley of Los Angeles County (County); refer to Figure 1, Regional Location Map. The surrounding jurisdictions include the cities of Duarte, Azusa, and Glendora to the north, San Dimas to the east, West Covina to the south, and Irwindale and Baldwin Park to the west and pockets of Los Angeles County Unincorporated Areas adjacent and within City limits. Locally, the Project is located at 1330 East Cypress Street (Assessor’s Parcel Number [APN]: 8427-001-006) (Project Site) within the northeastern portion of the City; refer to Figure 2, Local Vicinity Map. Regional access to the Project Site is via Interstate 210 (I-210) to the north, Interstate 10 (I-10) to the south, and South Azusa Avenue/California State Route 39 (SR-39) to the east. Local access to the Project Site is from East Cypress Street immediately to the north and Glendora Avenue to the west.

2.2 Surrounding Land Uses
Land uses immediately adjacent to the Project consist of the following:
• North: East Cypress Street, single-family residences, and Charter Oak High School. • East: Commercial uses (Ultra High End Audio, Sunny Components Inc., Grey Wash Gallery Tattoo, Cypress Animal Hospital) with residential uses beyond. • South: Southern Pacific Railroad and single-family residences. • West: Covina Auto Repair & Smog Services, HG Covina Market, Senor Baja Mexican Food, Domino’s Pizza, El Fino Mexican Food, Fire Bird Liquor Store, and Glendora Avenue.

2.3 Existing Site Conditions
The Project Site is currently improved with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas at the front of the Site along East Cypress Street, the eastern portion of the Site, and the western portion of the Site. Existing ingress/egress to the Project Site is available via three driveways located along the eastern, central, and western portions of the Project Site along East Cypress Street.

E Covina Blvd Charter Oak N Damato Dr
N Jenifer Ave
E Wingate St
N Ivescrest Ave
N Bender Ave
E Colver Pl
E Edna Pl
N Glendora Ave
E Cypress St
Kahler Russell
Park
E Covina Blvd
St. Louise D
Marillac
Elementar
School
Charter Oak
High School
Charter Oak Creek
Southern Pacific RR
E Retford St
E Farland St
N Rimhurst Ave
E Colver Pl
N Banna Ave
N Mangrove Ave
E Cypress St
Sonrise
Christian
Charter Oak
High School
Path: U:\GIS\GIS\Projects\2021xxx\D202100759_02_Covina_Public_Self_Storage\03_MXDs_Projects\PD.aprx, sgeissler 1/27/2022 N
SOURCE: Mapbox, 2021 City of Covina Public Storage Project Figure 2
Local Vicinity Map
0 500
Feet
Project Site

2. Project Description
City of Covina Public Storage Project 2-4 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

2.4 Existing General Plan/Zoning Designations
The existing general plan designation for the Project Site is General Industrial (GI). Permitted uses in the General Industrial (GI) land use designation include manufacturing, processing, assembly, warehousing, and related activities plus ancillary administrative offices that comply with applicable use, operation, and other provisions of the City’s Zoning Ordinance, Building Code, Fire Code, and other related City codes. Additionally, permitted uses include, but are not limited to, animal hospitals, automotive repair shops, very limited retail functions, gas stations, self-storage outlets, and parking lots.

The zoning designation for the Project Site is M-1 (Light Manufacturing). The M-1 zoning designation is intended to provide for the development of industrial uses which include fabrication, manufacturing, assembly or processing of materials that are in already processed form.

2.5 Project Features
The Project would include the demolition of the existing 55,321 SF 2-story commercial building (i.e., electronic manufacturing) and the development of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) within a 2.70-acre site. Project features would include a partial basement, a rental office, a temporary monopole cell tower, associated secured surface parking areas, pedestrian walkways, and landscaping; refer to Figure 3, Conceptual Site Plan. Level one (1st floor) would include up to 47,328 SF of storage space, circulation corridors, staircases, and elevators with an associated elevator lobby. Level two (2nd floor) would include up to 46,428 SF of storage space, 900 SF of rental office use including the 148 SF employee break room, circulation corridors, staircases, and elevators with an associated elevator lobby. The employee break room includes a sink, microwave, under counter refrigerator, and a closet for technology equipment. Level three (3rd floor) would include up to 47,328 SF of storage space, circulation corridors, staircases, and elevators with an associated elevator lobby. The temporary monopole cell tower positioned on wheels is situated at the temporary location during construction in place of the monopole cell tower that is currently located on the existing building roof. Upon completion of building construction, the temporary monopole cell tower will be removed and a new, permanent cell tower will be located on the roof. The new, permanent cell tower is not part of this entitlement and will be obtained by T-Mobile.

2.5.1 Building Heights and Elevations
The Project is comprised of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) and would not exceed the maximum allowed height of 75 feet for the Site; refer to Figure 4, Concept Elevations and Figure 5, Building/Site Elevations. The temporary monopole cell tower up to approximately 55 feet would be located within the southwestern portion of the Project Site; refer to Figure 6, Temporary Monopole Detail. Materials and finishes for the proposed building include exterior plaster with a combination of moth gray, winter mood, roller coaster, and tornado paints, precision and split face concrete masonry units (CMU), decorative stone, clear glazing, spandrel glazing, foam trim, decorative metal kickers and shutters, and metal louvers awnings; refer to Figures 4 and 5.

N Not to scale
0 2000
Feet N
Project Boundary
Sensitive Uses
Heading
City of Covina Public Storage Project
Figure 3
Conceptual Site Plan
SOURCE: KSP Studio, 2022
D202100759.02 - Covina Public Self Storage\05 Graphics
0 80
Feet N

City of Covina Public Storage Project
Figure 4
Concept Elevations
SOURCE: KPS Studio, 2022
D202100759.02 - Covina Public Self Storage\05 Graphics

City of Covina Public Storage Project
Figure 5
Building/Site Elevations
SOURCE: KPS Studio, 2021
D202100759.02 - Covina Public Self Storage\05 Graphics

SHE
City of Covina Public Storage Project
Figure 6
Temporary Monopole Detail
SOURCE: KPS Studio, 2022
D202100759.02 - Covina Public Self Storage\05 Graphics

2. Project Description
City of Covina Public Storage Project 2-9 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

2.5.2 Parking and Access
The number of parking spaces required per the City’s Zoning Ordinance is one vehicular space for the rental office and two vehicular spaces for the estimated two employees of Public Storage for a total of three vehicular spaces. Parking provided by the Project would include 21 standard vehicular spaces, 2 Americans with Disabilities Act (ADA) accessible vehicular spaces, and 3 electric vehicle/clean air vehicle (EV/CAV) vehicular spaces for a total of 26 vehicular spaces; refer to Figure 4. Three loading spaces are required and three loading spaces would be provided behind the proposed building. One short term bicycle parking space and one long term bicycle parking space would be provided.

Existing ingress/egress to the Project Site is available via three driveways located along East Cypress Street. Two of the driveways would be removed with the most easterly driveway to remain and provide direct vehicular access to Public Storage from East Cypress Street. Six parking spaces are located adjacent to the rental office outside the secured area. Public Storage would use an access system that requires customers and employees entering the secured area of the Project Site to enter a unique access code at both the sliding security entry gate and the telescoping entry gate. A private driveway and fire lane would be located on both sides of building along the eastern and western site boundaries. Pedestrian access would be provided from at-grade sidewalks along East Cypress Street. Refer to Figure 4 for locations of the Project driveway and security gates.

2.5.3 Landscaping
Project implementation would require the removal of 16 trees (9 Weeping Figs, 6 Southern Magnolias, and 1 Fan Palm). No oak trees are located within the Project Site. Per the City’s Design Guidelines, one tree per 500 SF of landscaped area is required, resulting in 20 required trees. One 24-inch box tree per 60 linear feet of street frontage is required resulting in 6 required trees. The Project would provide 20 trees in total, which would include 11 trees to be located within the street frontage. Overall, the Project would provide 4 Golden Rain Trees, 8 Cherokee Crape Myrtle Trees, and 8 Sweet Bay Trees. Refer to Figure 7, Conceptual Landscape Plan for the proposed plant legend and location of the proposed trees, planter areas, and landscaping.

2.5.4 Signage and Lighting
Site signage would be used for Project identity, building identification, rental office identification, pedestrian wayfinding, loading/unloading signage, and security markings. Signage would be designed and located to be compatible with the architecture and landscaping of the Project. No off-site signage would be proposed. All signage would be provided consistent with the City’s Zoning Ordinance.

Parking lots, entry-ways, and pedestrian common areas would be well lit for security. Lensed light-emitting diode (LED) linear lights would be integrated into the architectural canopies to provide appropriate light levels. Fixtures would be designed to prevent light trespass on adjacent properties. Surface mounted lights on the building and lot lights will project down and meet all codes related to light pollution.

COMMERCIAL ZONE

COMMERCIAL ZONE
City of Covina Public Storage Project
Figure 7
Conceptual Landscape Plan
SOURCE: KPS Studio, 2021
D202100759.02 - Covina Public Self Storage\05 Graphics 080 Feet N

2. Project Description
City of Covina Public Storage Project 2-11 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

2.5.5 Site Security
The Project would incorporate a 24-hour/seven-day video surveillance security system of the parking lots, entry-ways, customer lobbies and pedestrian common areas to ensure the safety of its customers and their belongings. If motion is detected when the facility is closed, an off-site security company will check the video for security issues prior to calling the police or setting off an alarm. If an employee or office manager is present at Public Storage during normal business hours, they will have the necessary knowledge and skill to operate the video surveillance security system to provide the Covina Police Department (CPD) copies of video recordings immediately upon request, if needed. If an employee is not present, a phone number will be displayed to contact personnel that have the necessary knowledge and skill to operate the video surveillance security system to provide the Covina Police Department copies of video recordings upon request.

The Project Site would include a 6-foot high tubular steel fence around the perimeter of the north, east, and west secure portions of the site. A 6-foot high concrete masonry unit (CMU) wall will be located adjacent to the south property line. The access system requires customers and employees entering the secure area to enter a unique access code at both the sliding security entry gate and the telescoping entry gate. An individual access code is also required to enter the customer lobbies and send the elevator to the floor of the customer’s storage unit. This security measure limits who can access parking areas and customer lobbies and allows management to review who has entered and exited these areas, if necessary. The Project design would include lighting of parking lots, entry-ways, and pedestrian common areas for site security purposes.

2.5.6 Water/Solid Waste Generation
The negligible estimated water use resulting from Project implementation would be generated from the two single occupancy restrooms, the janitor’s closet, the sink included in the employee break room, fire sprinklers, and the drought tolerant landscaping. All landscape areas would be irrigated with an automatic smart irrigation control system with a dedicated water meter. The Project’s estimated solid waste would result from the 900 SF of office use. Customers of Public Storage are required to dispose of their own waste off-site and the trash enclosure to be located in the rear of the proposed building in the southeastern portion of the Project Site would be locked.

2.6 Construction Activities and Schedule
Project construction would take place for approximately 12 months, from approximately November 2022 to November 2023. In general, construction activities would occur between 7:00 A.M. and 5:00 P.M., Monday through Friday, except on Sundays and federal holidays.

Construction on Saturdays would require pre-approval by the City Engineer. Construction of the Project would involve the use of a variety of heavy construction equipment onsite. Large construction equipment would include aerial lifts, backhoes, concrete/industrial saws, excavators, forklifts, graders, haul trucks, pavers, paving equipment, and rough terrain forklifts.

Approximately 80 personnel would be used for construction of the Project. Construction phases would include demolition, site preparation, grading/excavation, drainage/utilities/trenching, foundations/concrete pour, building construction, paving, and architectural coatings. Demolition

2. Project Description
City of Covina Public Storage Project 2-12 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 of the Project would include removal of 55,321 SF of the existing 2-story commercial building and the existing pavement and base materials in the parking lot. The Project would include approximately 11,500 cubic yards of cut and approximately 3,500 cubic yards of fill, resulting in approximately 8,000 cubic yards of soil export; refer to Figure 8, Conceptual Grading Plan.

2.7 Project Approvals
The City of Covina, as Lead Agency for the Project, has discretionary authority over the Project.

In order to implement this Project, the Project would require a grading permit for grading in excess of 5,000 cubic yards and grading that would support a structure is designated as engineering grading. Demolition permits to remove the 55,321 SF of the existing 2-story commercial building and the existing pavement and base materials in the parking lot would be required, as well as a building permit. In addition, the issuance of a Site Plan Review (SPR) 21- 160 for site development and a CUP 21-29 would be required for the proposed use of selfstorage. Further, implementation of the Project would require Ordinance No. XXXXX for Development Agreement (DA) 22-001, approving and adopting a DA between Public Storage, Inc. and the City of Covina related to a proposed development consisting of an approximate 141,984 SF 3-story public self-storage building on approximately 2.70 acres and the conveyance of $315,000 for City-wide infrastructure improvements.

City of Covina Public Storage Project
Figure 8
Conceptual Grading Plan
SOURCE: DRC Engineering, Inc., 2021
D202100759.02 - Covina Public Self Storage\05 Graphics 0120 Feet N

2. Project Description
City of Covina Public Storage Project 2-14 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 This page intentionally left blank

City of Covina Public Storage Project 3-1 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 SECTION 3
Initial Study/Environmental Checklist

1. Project Title: City of Covina Public Storage Project

2. Lead Agency Name and Address: City of Covina, Community Development Department, 125 E. College Street, Covina, CA
91723

3. Contact Person and Phone Number: Mercenia Lugo, Senior Planner, (626) 384-5450

4. Project Location: Regionally, the Public Storage Project is located in the City of Covina within the San
Gabriel Valley of Los Angeles County. The
surrounding jurisdictions include the cities of
Duarte, Azusa, and Glendora to the north, San
Dimas to the east, West Covina to the south,
and Irwindale and Baldwin Park to the west and
pockets of Los Angeles County Unincorporated
Areas adjacent and within City limits. Locally,
the Project is located at 1330 East Cypress
Street (APN: 8427-001-006) within the
northeastern portion of the City.

5. Project Sponsor’s Name and Address: City of Covina, Community Development Department, 125 E. College Street, Covina, CA
91723

6. General Plan Designation(s): General Industrial (GI)

7. Zoning: M-1 (Light Manufacturing)

8. Description of Project:

The Project would include the demolition of the existing 55,321 SF 2-story commercial building (i.e., electronic manufacturing) and the development of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) within a 2.70-acre site. Project features would include a partial basement, a rental office, a temporary monopole cell tower, associated secured surface parking areas, pedestrian walkways, and landscaping.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-2 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

9. Surrounding Land Uses and Setting.

Land uses immediately adjacent to the Project consist of East Cypress Street, single-family residences, and Charter Oak High School to the north; commercial uses (Ultra High End Audio, Sunny Components Inc., Grey Wash Gallery Tattoo, Cypress Animal Hospital) to the east; and Southern Pacific Railroad and single-family residences to the south; and Covina Auto Repair & Smog Services, HG Covina Market, Senor Baja Mexican Food, Domino’s Pizza, El Fino Mexican Food, Fire Bird Liquor Store, and Glendora Avenue to west.

10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement.)
Not applicable.

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Yes, the City conducted consultation with California Native American tribes pursuant to Assembly Bill (AB) 52 to identify tribal cultural resources in or near the Project Site. The City, sent consultation notification letters via certified mail to Native American groups geographically and culturally affiliated with the Project Site on October 5, 2021. To date, the City has received one response from the Native American groups regarding consultation, the details of which are provided below.

The Gabrieleno Band of Mission Indians-Kizh Nation has corresponded with City staff between October 7 and December 10, 2021. The Gabrieleno Band of Mission Indians-Kizh Nation stated that the Project Site is located within the tribe’s traditional ancestral territory and requested formal government-to-government consultation. The Gabrieleno Band of Mission Indians-Kizh Nation provided a map of the Kizh Nation Ancestral Tribal Territory. On November 30, 2022, representatives from the City and the Gabrieleno Band of Mission Indians-Kizh Nation met via a telephone conference. During the call, the Gabrieleno Band of Mission Indians-Kizh Nation provided their knowledge of the Project Site and the nearby village of Weniinga, and their concerns about the sensitivity of the Project. The Gabrieleno Band of Mission Indians-Kizh Nation indicated that the Project Site is archaeologically sensitive, but did not identify any known tribal cultural resources (as defined in Public Resources Code Section 21074) within the Project Site. The Tribe recommended monitoring during construction. For further information, please refer to Section XVIII, Tribal Cultural Resources.

3. Initial Study/Environmental Checklist

3.1 Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and Forestry Resources □ Air Quality □ Biological Resources � Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse Gas Emissions � Hazards & Hazardous Materials □ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources � Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation � Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire □ Mandatory Findings of Significance DETERMINATION: (To be completed by the Lead Agency)
On the basis of this initial study:

D I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
� I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

D I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

D I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect l) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

D I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, 1 g further is required.

Signature
Date
Date
City of Covina Public Storage Project 3-3 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-4 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

3.2 Environmental Checklist
Aesthetics
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporated
Less Than
Significant
Impact No Impact
I. AESTHETICS — Except as provided in Public
Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista? ☐ ☐ ☒ ☐ b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
☐ ☐ ☒ ☐
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are
those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and
other regulations governing scenic quality?
☐ ☐ ☒ ☐
d) Create a new source of substantial light or glare
which would adversely affect daytime or nighttime
views in the area?
☐ ☐ ☒ ☐
Discussion
Would the Project:
a) Have a substantial adverse effect on a scenic vista? Less than Significant Impact. Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual features that are seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting. A scenic vista can be impacted in two ways: a development project can have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view corridors or “vista” of the scenic resource. Important factors in determining whether a proposed project would block scenic vistas include the project’s proposed height, mass, and location relative to surrounding land uses and travel corridors.

The City’s General Plan Natural Resources and Open Space Element does not designate any scenic vistas within the City (Covina, 2000). However, the City is located near the foot of the San Gabriel Mountains, which are considered a prominent visual resource. The Project Site is located within a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project Site is currently developed with an approximately 55,321SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. Intermittent long-range views of the San Gabriel Mountains can be seen from the Project Site in between existing buildings, fencing, and trees from East

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-5 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Cypress Street, but the majority of these views are obstructed due to the existing structures, trees, and the relatively flat topography of the Project area.

The Project would include the demolition of the existing 55,321 SF 2-story commercial building (i.e., electronic manufacturing) and the development of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) within a 2.70-acre site. The ridgeline of the San Gabriel Mountains is visible when looking north along East Cypress Street. This view is primarily experienced by east and westbound travelers on East Cypress Street; views of the San Gabriel Mountains’ ridgeline are not visible when looking through the Project Site under existing conditions. Upon development of the proposed 3-story public self-storage building on the Project Site, the partial view of the San Gabriel Mountains looking north along East Cypress Street would not be affected, as the view is generally limited to the roadway corridor.

The Project would replace an existing building of similar type and massing, thereby not substantially altering the current view along East Cypress Street. Compliance with the City’s Municipal Code and restrictions restricting height would ensure that views of scenic resources, including views of the San Gabriel Mountains, would be preserved. As such, the Project would not result in a substantial adverse effect on a scenic vista, and impacts would be less than significant. No mitigation is required.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Less than Significant Impact. The Project Site is located in a highly urbanized area of the City predominantly developed with residential, commercial, and school uses. The Project Site is currently developed with a 2-story commercial building, asphalt surface parking lots, and ornamental landscaping and trees. The Project Site is not located in the vicinity of a City or statedesignated scenic highway. The nearest officially designated state scenic highway, State Route 2 (SR-2), is located in the San Gabriel Mountains and would not be visible to motorists (Caltrans, 2020). The proposed 3-story public self-storage building would be constructed within the boundaries of the Project Site, which is surrounded by existing development and would not be visible from SR-2 due to intervening urban development, distance, and topography. The Project Site does not contain any rock outcroppings or historical buildings. As the Project is not located in the vicinity of a state scenic highway, no historical buildings would be substantially damaged with implementation of the Project. Vegetation on the Project Site consists of a mix of ornamental landscaping and trees. The Project would require the removal of 16 trees; however, these trees would be replaced and the Project would provide 20 trees in total. The Project would comply with applicable provisions pertaining to the removal and replacement of trees per Chapter 17.83, Tree Preservation, of the City’s Municipal Code (Covina, 2022). Overall, based on the above, the Project would not substantially damage scenic resources located within the vicinity of a scenic highway and a less than significant impact would occur. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-6 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?
Less than Significant Impact. The Project Site is located in a highly urbanized areas of the City predominantly developed with residential commercial, and school uses. The Project Site is currently developed with a 2-story commercial building, asphalt surface parking lots, and ornamental landscaping and trees. Construction activities associated with the Project would require the use of construction equipment and storage of materials on-site, thus introducing contrasting features into the visual landscape that affect the visual quality of the Project Site and immediate vicinity. Contrasting features could include demolition materials, excavated areas, stockpiles, and other materials generated and stored on-site during construction. However, adverse effects to visual character associated with Project construction would be temporary.

The Project would include the demolition of the existing 55,321 SF 2-story commercial building (i.e., electronic manufacturing) and the development of a 141,984 SF 3-story public self-storage building (up to 30 feet and 7 inches in height) within a 2.70-acre site. The existing zoning designation for the Project Site is M-1 (Light Manufacturing) which would require the issuance of a CUP for the proposed use of self-storage. The existing general plan designation for the Project Site is General Industrial (GI). Permitted uses in the General Industrial (GI) land use designation include, but are not limited to, very limited retail functions, self-storage outlets, and parking lots.

As such, compared to the existing aesthetic conditions and surrounding land uses, including single-family residences, commercial uses, industrial uses, and school uses, the land use density and development intensity on the Project Site would be consistent with the existing visual character. Furthermore, the Project would be subject to review by the City to ensure that design of the Project is consistent will all applicable design requirements, standards, and regulations set forth in the City’s Municipal Code. Therefore, impacts related to degradation of existing visual character and quality would be less than significant. No mitigation is required. d) Create a new source of substantial light or glare which would adversely affect daytime or nighttime views in the area?
Less than Significant Impact. The Project Site is located in a highly urbanized area of the City predominantly developed with residential, commercial, and school uses. The Project Site is currently developed with a 2-story commercial building with exterior lighting. The Project area exhibits considerable ambient nighttime illumination levels due to the densely developed nature of the Project area and adjacent properties. Artificial light sources from surrounding properties include interior and exterior lighting for security, parking lot lighting, sports field lighting at Charter Oak High School, and incidental landscape lighting. Automobile headings, streetlights, and stoplights for visibility and safety purposes along adjacent roadways contribute to overall ambient lighting levels as well. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-7 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Construction of the Project would not occur during evening hours. Outdoor project construction activities would occur only during permitted daytime hours (from 7 a.m. to 5 p.m.), in accordance with the City’s Municipal Code. As such, construction of the Project would not introduce any new sources of substantial nighttime lighting or glare, and potential impacts associated with construction would be minor and temporary.

Security lighting used during operation of the Project could introduce new sources of light to the Project Site and the immediate vicinities. Lensed light-emitting diode (LED) linear lights would be integrated into the architectural canopies to provide appropriate light levels. Fixtures would be designed to prevent light trespass on adjacent properties. Surface mounted lights on the building and lot lights will project down and meet all codes related to light pollution. Compliance with these regulations would ensure that operational impacts regarding Project lighting would be less than significant.

Glare within the Project Site and the surrounding areas occur from sunlight reflected from reflective materials utilized in existing buildings along adjacent roadways and from vehicle windows and surfaces. Glare-sensitive receptors include motorists on the roadways surrounding the Project Site. As glare is a temporary phenomenon that changes with the movement of the sun, receptors other than motorists are generally less sensitive to glare impacts than to light impacts.

The City’s Municipal Code Section 9.42.020 (applicable to disturbances imposed on residential uses only) requires that “no operation, activity, sign, or lighting fixture shall create illumination that exceeds five foot-candles on any adjacent property, whether the illumination is direct or indirect light from the source. Glare levels shall be measured with a photoelectric photometer following the standard spectral luminous efficiency curve adopted by the International Commission on Illumination.” Compliance with City’s Municipal Code Section 9.42.020 would ensure that adverse nighttime lighting and glare effects do not occur at nearby residential uses as a result of the Project. As such, a less than significant impact would occur in this regard. No mitigation is required.

References
Caltrans, 2020. California Department of Transportation, List of Eligible and Officially Designated State Scenic Highways. Available at https://dot.ca.gov/programs/design/laplandscape-architecture-and-community-livability/lap-liv-i-scenic-highways, accessed May, 2022.

Covina, 2000. City of Covina’s General Plan, Natural Resources and Open Space Element, adopted April 18, 2000.

Covina, 2022. City of Covina Municipal Code, passed January 18, 2022, https://www.codepublishing.com/CA/Covina/, accessed May 2022.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-8 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Agriculture and Forestry Resources
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporated
Less Than
Significant
Impact No Impact
II. AGRICULTURE AND FORESTRY RESOURCES —
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use?
☐ ☐ ☐ ☒
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
☐ ☐ ☐ ☒
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
☐ ☐ ☐ ☒
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
☐ ☐ ☐ ☒
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒
Discussion
Would the Project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
No Impact. The Project Site is located in a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. According to the City’s General Plan Natural Resources and Open Space Element, the City is approximately 99 percent built out and does not contain usable agricultural soils or important agricultural areas (Covina, 2000). Further, the Project Site does not contain agricultural uses or related operations and is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (DOC,

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-9 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 2020). Therefore, the Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses. No impact would occur in this regard. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. The Project Site is currently zoned M-1 (Light Manufacturing).

No portion of the Project Site or surrounding land uses are zoned for agriculture and no nearby lands are enrolled under the Williamson Act. As discussed above, the City is approximately 99 percent built out and does not contain usable agricultural soils or important agricultural areas (Covina, 2000). As such, the Project would not conflict with existing zoning for agricultural uses or a Williamson Act Contract and no impact would occur in this regard. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. The Project Site is currently zoned M-1 (Light Manufacturing). The Project Site is located in a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. No forest land or land zoned for timberland is present on the Project Site or in the surrounding area. According to the City’s Natural Resources and Open Space Element, the City is approximately 99 percent built out and does not contain any forests (City of Covina, 2000). As such, the Project would not conflict with existing zoning for forest land or timberland and no impact would occur in this regard. d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. No forest land exists on the Project Site or in the surrounding area. As discussed above in Response II.c, the City is approximately 99 percent built out and does not contain any forests (City of Covina, 2000). As such, the Project would not result in the loss of forestland or the conversion of forestland to non-forest use. No impact would occur in this regard.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-10 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
No Impact. As discussed above in Responses II.a through II.d, there are no agricultural or forest uses or related operations on or near the Project Site. Therefore, the Project would not involve the conversion of farmland forest land to other uses. No impacts to agricultural or forest land or uses would occur in this regard.

References
City of Covina, 2000. General Plan, Natural Resources and Open Space Element, page D-9.

Adopted April 18, 2000.

DOC, 2020. California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/dlrp/ciff/, accessed May 2022.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-11 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Air Quality
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
III. AIR QUALITY —
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
☐ ☐ ☒ ☐
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state
ambient air quality standard?
☐ ☐ ☒ ☐
c) Expose sensitive receptors to substantial pollutant
concentrations?
☐ ☐ ☒ ☐
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
☐ ☐ ☒ ☐
Discussion
Would the Project:
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The Project Site is located within the 6,745-square-mile South Coast Air Basin (Basin). Air quality planning for the Basin is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The SCAQMD has adopted a series of Air Quality Management Plans (AQMPs) to meet the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS) for criteria air pollutants. The SCAQMD is required, pursuant to the Clean Air Act, to reduce emissions of criteria pollutants for which the Basin is in non-attainment of the NAAQS (e.g., ozone [O3], and particulate matter 2.5 microns in diameter or less [PM2.5]). The SCAQMD, California Air Resources Board (CARB), and United States Environmental Protection Agency (USEPA) have adopted the 2016 AQMP which incorporates scientific and technological information and planning assumptions, regarding air quality, including the Southern California Association of Governments (SCAG) 2016 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), and emission inventory methodologies for various source categories (SCAG 2016a; SCAQMD 2017). The AQMP builds upon other agencies’ plans to achieve federal standards for air quality in the Air Basin and incorporates a comprehensive strategy aimed at controlling pollution from all sources, including stationary sources, and on-road and off-road mobile sources. In addition, it highlights the significant amount of emission reductions needed and the urgent need to identify additional strategies, especially for mobile sources, to meet all federal criteria pollutant standards in accordance with the Clean Air Act. The 2016 AQMP is used in these analyses since it has been adopted by both SCAQMD and CARB.

The AQMP contains a comprehensive list of pollution control strategies directed at reducing emissions and achieving the NAAQS. These strategies are developed, in part, based on regional growth projections prepared by the SCAG. As part of its air quality planning, SCAG has prepared

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-12 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 the Regional Comprehensive Plan (RCP) and Guide and the RTP/SCS, which provide the basis for the land use and transportation components of the AQMP and are used in the preparation of the air quality forecasts and the consistency analysis included in the AQMP. Both the RCP and AQMP are based, in part, on projections originating with county and city general plans.

The 2016 AQMP was prepared to accommodate growth, reduce the high levels of pollutants within the areas under the jurisdiction of SCAQMD, return clean air to the region, and minimize the impact on the economy. Projects that are consistent with the assumptions used in the AQMP do not interfere with attainment because the growth is included in the projections utilized in the formulation of the AQMP. Thus, projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the AQMP would not jeopardize attainment of the air quality levels identified in the AQMP, even if it would individually exceed the SCAQMD’s regional significant thresholds. The SCAQMD’s 2016 AQMP contains a comprehensive list of pollution control strategies directed at reducing emissions and achieving the NAAQS and includes transportation control strategies designed to reduce vehicle miles traveled (VMT). SCAQMD’s 2016 AQMP control strategies were developed, in part, based on regional growth projections prepared by SCAG through 2040. While SCAG’s Regional Council adopted the 2020–2045 RTP/SCS on September 3, 2020, SCAQMD’s 2016 AQMP is based on growth projections and control strategies from the 2016–2040 RTP/SCS.

For this reason, consistency with the 2016–2040 SCAG RTP/SCS remains the appropriate version when discussing a project’s consistency with the SCAQMD’s 2016 AQMP.

The Project’s consistency with applicable air quality plans is provided below. There are no applicable numerical thresholds of significance for this consistency analysis. In accordance with the SCAQMD’s CEQA Air Quality Handbook, the following criteria were used to evaluate the Project’s consistency with the SCAQMD’s 2016 AQMP:
• Criterion 1: Will the project result in any of the following:
– An increase in the frequency or severity of existing air quality violations; or – Cause or contribute to new air quality violations; or – Delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.
• Criterion 2: Will the project exceed the assumptions utilized in preparing the AQMP? The Project’s potential impacts with respect to these criteria are discussed to assess the consistency with the SCAQMD’s 2016 AQMP.

Criterion 1
Consistent with the first criterion, the Project would not conflict with the ability of federal, State, and local agencies to implement fair-share emissions strategies or achieve compliance with criteria pollutant standards or other federal requirements. Specifically, the Project’s volatile organic compound (VOC), nitrogen oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2), respirable particulate matter (10 microns or smaller in diameter, PM10), and fine particulate matter (2.5 microns or smaller in diameter, PM2.5) emissions resulting from construction and

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-13 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 operation were analyzed to ascertain any potential effects on localized concentrations and determine the potential for such emissions to cause or contribute to a violation of the ambient air quality standards. As discussed under response to Section III (b) and response to Section III (c), the Project’s construction and operational emissions would not exceed the SCAQMD’s regional mass emissions thresholds for VOC, NOX, CO, SO2, PM10 or PM2.5 or the localized significance thresholds (LSTs) for NOX, CO, PM10 or PM2.5, or generate roadway traffic congestion at an intersection that would result in a CO hotspot in excess of the ambient air quality standards as a result of project motor vehicle operations. The Project’s emissions would therefore not increase concentrations of criteria pollutants or their precursors in a manner that would conflict with or obstruct SCAQMD’s efforts to achieve attainment of ambient air quality standards for any criteria pollutant for which it is currently not in attainment or jeopardize the current attainment status of the Basin for other criteria pollutants. Therefore, in response to Criterion 1, the Project would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new air quality violations, or delay timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.

Criterion 2
With respect to the second criterion for determining consistency with AQMP growth assumptions, the projections in the AQMP for achieving air quality goals are based on assumptions in SCAG’s 2016–2040 RTP/SCS regarding population, housing, and growth trends.

Determining whether or not a project exceeds the assumptions reflected in the AQMP involves the evaluation of consistency with applicable population, housing, and employment growth projections and appropriate incorporation of AQMP control measures. The following discussion provides an analysis with respect to these criteria.

Air Quality Management Plan Consistency
The Project would not obstruct implementation of the 2016 AQMP for, as discussed below, its construction and operational emissions would be less than significant. The Project would comply with applicable required fleet rules and control strategies to reduce on-road truck emissions (i.e., 13 CCR, section 2025 [CARB Truck and Bus regulation]), and other applicable SCAQMD rules specified and incorporated in the 2016 AQMP. As discussed above, projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the AQMP would not jeopardize attainment of the air quality levels identified in the AQMP. As discussed below, compliance with the applicable required fleet rules and control strategies and requirements would render it consistent with, and meet or exceed, the AQMP requirements for control strategies intended to reduce emissions from construction equipment and activities. Thus, the Project’s criteria pollutant emissions would not cause the Basin’s criteria pollutant emissions to worsen so as to impede the SCAQMD’s efforts to achieve attainment with respect to any criteria pollutant for which it is currently not in attainment of the NAAQS and CAAQS (i.e., ozone, PM10, and PM2.5), or to cause the Basin to deteriorate from its current attainment status with respect to any other criteria pollutant emissions.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-14 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 As further discussed below, the Project is also consistent with the 2016 AQMP. The Project incorporates into its design appropriate control strategies set forth in the 2016 AQMP for achieving its emission reduction goals and would be consistent with the demographic and economic assumptions upon which the plan is based.

Construction
Control Strategies
Construction activities associated with the Project have the potential to generate temporary criteria pollutant emissions through the use of heavy-duty construction equipment, such as excavators and backhoes, and through vehicle trips generated from worker trips and haul trucks traveling to and from the Project area. In addition, fugitive dust emissions would result from demolition and various soil-handling activities. During its construction phase, the Project would ensure compliance with CARB’s requirements to minimize short-term emissions from on-road and off-road diesel equipment, and with SCAQMD’s regulations such as Rule 403 for controlling fugitive dust and Rule 1113 for controlling VOC emissions from architectural coatings.

Compliance with these regulatory measures and requirements would be consistent with and meet or exceed the AQMP requirements for control strategies intended to reduce emissions from construction equipment and activities.

Growth Projections
The Project would generate short-term construction jobs, but these jobs would not necessarily bring new construction workers or their families into the region, since construction workers are typically drawn from an existing regional pool who travel among construction sites within the region. Construction workers are not typically brought from other regions to work on developments such as the Project. Moreover, these jobs would be relatively small in number and temporary in nature. Therefore, the Project’s construction jobs would not conflict with the longterm employment or population projections upon which the 2016 AQMP is based.

Operations
Control Strategies and Policy Consistency
The 2016 AQMP was prepared to accommodate growth, reduce the levels of pollutants within the areas under the jurisdiction of SCAQMD, return clean air to the region, and minimize the impact on the economy. The Project would include the development of a Public Storage facility that would require two employees to operate. The Project would have no effect on long-term population and employment growth. Projects that are considered consistent with the AQMP would not interfere with attainment because this growth is included in the projections used in the formulation of the AQMP.

Growth Projections
The Project would require approximately two new employees, which is well within SCAG’s employment growth assumptions for the City. SCAG predicted City’s employment growth between 2012 and 2040 to be 4,200 jobs (SCAG, 2016b). As discussed in the Trip Generation Memo (Appendix H, of this Draft IS/MND), during each operation day, the Project has a maximum of 214 daily vehicle trips, which would include up to 14 AM peak hour trips, and 24 PM peak hour trips from employees and visitors to and from the Project Site. As such, the Project

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-15 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 would generate 3 fewer daily vehicle trips, 20 fewer AM peak hour vehicle trips, and 13 fewer PM peak hour vehicle trips as compared to the existing use (LSA, 2021). In other words, the trip generation characteristics of the Project are less intense than those of the existing use. Further, the Project does not have a significant impact on transportation and would not require a Traffic Impact Analysis (LSA, 2021). Mobile source emissions associated with the Project Site were calculated and are discussed in Threshold b, below.

Projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the AQMP would not jeopardize attainment of the air quality reductions identified in the AQMP. Based on the above, the Project would not conflict with growth projections in the 2016 AQMP and impacts would be less than significant. No mitigation is required.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant Impact. The Basin is currently designated as extreme nonattainment for ozone (O3) (federal and State standards), non-attainment for respirable particulate matter 10 microns in diameter or less (PM10) (State standards) and PM2.5 (federal and State standards).

The SCAQMD’s approach for assessing cumulative impacts related to operations is based on attainment of ambient air quality standards in accordance with the requirements of the federal and State Clean Air Acts. As discussed above, the SCAQMD has developed a comprehensive plan, the 2016 AQMP, which addresses the region’s cumulative air quality condition.

A significant impact may occur if a project were to add a cumulatively considerable contribution of a federal or State non-attainment pollutant. Because the SCAB is currently in nonattainment for ozone, PM10 and PM2.5, related projects could cause ambient concentrations to exceed an air quality standard or contribute to an existing or projected air quality exceedance. Cumulative impacts to air quality are evaluated under two sets of thresholds for CEQA and the SCAQMD. In particular, CEQA Guidelines Sections 15064(h)(3) provides guidance in determining the significance of cumulative impacts. Specifically, Section 15064(h)(3) states in part that:
“A lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program which provides specific requirements that will avoid or substantially lessen the cumulative problem (e.g., water quality control plan, air quality plan, integrated waste management plan) within the geographic area in which the project is located. Such plans or programs must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency…”
For purposes of the cumulative air quality analysis with respect to CEQA Guidelines Section 15064(h)(3), the Project’s incremental contribution to cumulative air quality impacts is determined based on compliance with the SCAQMD adopted 2016 AQMP. The 2016 AQMP

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-16 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 includes demographic growth forecasts for various socioeconomic categories (e.g., population, housing, employment), developed by SCAG for their 2016 Regional Transportation Plan (RTP).

As discussed above in Response III.a, the Project would not conflict with the 2016 AQMP.

The Project would contribute to local and regional air pollutant emissions during construction (short-term or temporary). However, based on the following analysis, construction and operation of the Project would result in less than significant impacts relative to the daily significance thresholds for criteria air pollutant emissions established by the SCAQMD for construction and operational phases (SCAQMD, 2015).

Daily regional and annual construction and operational source Project criteria pollutant emissions (NOX, volatile organic compounds [VOC], PM10, PM2.5, sulfur oxides [SOX], and carbon monoxide [CO]) are estimated using the California Emissions Estimator Model (CalEEMod) (Version 2020.4.0) software, an emissions inventory software program recommended by the SCAQMD. The model also calculates emissions from direct and indirect sources and quantifies applicable emissions reductions achieved from emissions control strategies and mitigation measures. CalEEMod is based on outputs from off-road vehicle model (OFFROAD) and emission factors model (EMFAC), which are emissions estimation models developed by CARB and used to calculate emissions from construction activities, including on- and off-road vehicles and statewide and regional emissions inventories from all motor vehicles, including passenger cars to heavy-duty trucks, operating on highways, freeways, and local roads in California.

CalEEMod was used to estimate emissions from off-road equipment, while mobile source emissions were calculated separately using client-provided trip generation, trip lengths from CalEEMod, and applying emission factors from EMFAC2021. Within CalEEMod, fugitive dust emissions include the application of water as a control measure consistent with SCAQMD Rule 403, which applies to the Project’s construction activities. Fugitive dust control measures are not mitigation under CEQA because they are regulatory compliance. The input values used in the CalEEMod modeling analysis were adjusted based on Project-specific information. Assumptions and modeling output are included in Appendix A, of this Draft IS/MND.

Construction Emissions
Construction activities associated with the Project would result in emissions of CO, VOCs, NOX, SOX, PM10, and PM2.5. Construction related emissions are expected from all phases of construction: demolition, site preparation, grading/excavation, drainage/utilities/trenching, foundations/concrete pour, building construction, paving, and architectural coating. Construction is expected to commence in the November 2022 to November 2023, as described previously in Section 2.6, Construction Activities and Grading, of the Project Description. The analysis utilized construction fleet information and a construction schedule provided by the client and represents a “worst-case” scenario. It is assumed that all construction equipment would be Tier 3. If construction commences later than the anticipated start date, air quality impacts would be less than those analyzed herein, because a more energy-efficient and cleaner burning construction equipment fleet mix would be expected in the future, pursuant to State regulations that require construction equipment fleet operators to phase-in less polluting heavy-duty equipment. The duration of construction activity and associated equipment represents a reasonable approximation of the expected construction fleet as required per CEQA guidelines. Site specific construction

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-17 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 fleet may vary due to Project specific needs at the time of construction. A detailed summary of construction assumptions is provided in Section 2.6, Construction Activities and Grading, of the Project Description.

The estimated maximum daily construction emissions are summarized in Table III-1, Maximum Daily Construction Emissions. Building construction and paving as well as building construction and architectural coating may occur simultaneously; thus, emissions are summed and presented as overlapping phases below. Emissions from the construction would not exceed any criteria pollutant thresholds established by the SCAQMD. Therefore, impacts would be less than significant. No mitigation is required.

TABLE III-1
MAXIMUM DAILY CONSTRUCTION EMISSIONSa,b
Year
Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Construction Phases
Demolition - 2022 0.3 14.2 12.7 0.1 1.5 0.6
Demolition - 2023 0.3 12.4 12.6 0.0 1.5 0.6
Site Preparation - 2023 0.3 6.0 9.4 0.0 0.5 0.4
Grading/Excavation - 2023 0.5 14.6 17.6 0.0 1.2 0.7
Drainage/Utilities/Trenching - 2023 0.3 5.2 8.7 0.0 0.6 0.4 Foundations/Concrete Pour - 2023 0.4 12.3 15.2 0.1 1.2 0.6 Building Construction - 2023 0.2 3.3 10.0 0.0 0.9 0.3
Paving - 2023 0.4 4.4 8.0 0.0 0.4 0.2
Architectural Coating - 2023 66.8 2.0 3.0 0.0 0.2 0.1
Overlapping Phases
Building Construction + Paving – 2023 0.6 7.8 18.0 0.0 1.3 0.6 Building Construction + Architectural
Coating – 2023 67.0 5.3 13.0 0.0 1.1 0.5
Maximum Daily Regional Emissions 67.0 14.6 18.0 0.1 1.5 0.7 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
NOTES:
a Totals may not add up exactly due to rounding in the modeling calculations. b Emissions include fugitive dust control measures consistent with SCAQMD Rule 403.

VOC = volatile organic compounds; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter, aerodynamic diameter of 10 micrometers or less; PM2.5 = particulate matter, aerodynamic diameter of 2.5 micrometers or less.

SOURCE: Appendix A, of this Draft IS/MND. ESA 2022.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-18 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Operational Emissions
During operation of the Project, there would only be periodic maintenance and two employees for the Public Storage facility working on-site. As such, the Project would result in fewer employees compared to the existing manufacturing building. Emissions from mobile sources would actually decrease compared to existing conditions. The existing operational emissions were estimated using CalEEMod and were counted as credit for the Project. The estimated maximum daily construction emissions are summarized in Table III-2, Maximum Daily Operational Emissions.

Emissions from operation would not exceed any criteria pollutant thresholds established by the SCAQMD. The Project would also include a landscaping plan that provides 20 trees and removes 16 trees (see Section 2.5.3, Landscaping, of the Project Description). Of the 26 vehicle parking spaces, three spaces would be set aside for electric vehicles or clean air vehicles. Two bicycle parking spaces would be provided. Therefore, impacts would be less than significant. No mitigation is required.

TABLE III-2
MAXIMUM DAILY OPERATIONAL EMISSIONSa
Year
Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Sources
Area 3 <1 <1 <1 <1 <1
Energy <1 <1 <1 <1 <1 <1
Motor Vehicles 1 1 6 <1 1 <1
Maximum Daily Regional Emissions 4 1 6 <1 1 <1
Existing Operations 2 1 7 <1 1 <1
Net Daily Regional Emissions 2 <1 -1 <1 <1 <1
SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
NOTES:
a Totals may not add up exactly due to rounding in the modeling calculations.

VOC = volatile organic compounds; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter, aerodynamic diameter of 10 micrometers or less; PM2.5 = particulate matter, aerodynamic diameter of 2.5 micrometers or less.

SOURCE: Appendix A, of this Draft IS/MND. ESA 2022.

By applying SCAQMD’s cumulative air quality impact methodology, implementation of the Project would not result in an addition of criteria pollutants such that cumulative impacts would occur, in conjunction with related projects in the region. In addition, construction and operation of the Project is not expected to result in a cumulatively considerable net increase of any criteria pollutant for which the SCAQMD is in non-attainment (ozone, PM10, PM2.5). Therefore, impacts would be less than significant. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-19 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact. According to the SCAQMD CEQA Air Quality Handbook, sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. The localized effects from the on-site portion of the emissions are evaluated at nearby sensitive receptor locations potentially impacted by the Project according to the SCAQMD’s Localized Significance Threshold Methodology (June 2003, revised July 2008), which relies on on-site mass emission rate screening tables and project-specific dispersion modeling typically for sites greater than five acres, as appropriate (SCAQMD, 2008). The localized significance thresholds are applicable to NOX, CO, PM10, and PM2.5. For NOX and CO, the thresholds are based on the ambient air quality standards. For PM10 and PM2.5, the thresholds are based on requirements in SCAQMD Rule 403 (Fugitive Dust) for construction and Rule 1303 (New Source Review Requirements) for operations. The SCAQMD has established screening criteria that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance thresholds and therefore not cause or contribute to an exceedance of the applicable ambient air quality standards without Project-specific dispersion modeling. The screening criteria depend on: (1) the area in which the Project is located, (2) the size of the Project Site, and (3) the distance between the Project Site and the nearest sensitive receptor (e.g., residences, schools, hospitals). The screening criteria were utilized in this assessment. For the Project, the appropriate Source Receptor Area (SRA) for the localized significant threshold (LST) is the East San Gabriel Valley monitoring station (SRA 9). Since the total acreage disturbed is less than five acres per day, SCAQMD’s screening look-up tables were used to determine localized significance thresholds. The nearest sensitive receptors to the Project Site are the residential uses located adjacent to the Project Site to the north and south and Charter Oak High School to the north, as described in Section 2.2, Surrounding Land Uses, of the Project Description. Receptors adjacent to the Project Site may be exposed to localized emissions on short-term and temporary basis.

While the total construction site area is approximately 2.7 acres, a worst-case construction day would disturb up to 2 acres.

SCAQMD’s Methodology clearly states that “off-site mobile emissions from the Project should not be included in the emissions compared to LSTs.” Therefore, for purposes of the LST analysis only emissions included in the CalEEMod “on-site” emissions outputs were considered. The significance thresholds determined conservatively assume LST screening levels for a 2-acre site that is 25 meters away from the nearest sensitive receptor.

Localized Construction Emissions
Table III-3, Maximum Daily Localized Construction Emissions, identifies the localized impacts at the nearest receptor location in the vicinity of the Project Site. The localized emissions during construction activities would not exceed any of the SCAQMD’s localized significance thresholds.

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

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-20 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 TABLE III-3

MAXIMUM DAILY LOCALIZED CONSTRUCTION EMISSIONS
Year
Emissions (pounds per day)
NOX CO PM10 PM2.5
Construction Phases
Demolition - 2022 5 7 1 <1
Demolition - 2023 5 7 1 <1
Site Preparation - 2023 6 8 <1 <1
Grading/Excavation - 2023 10 14 1 1
Drainage/Utilities/Trenching - 2023 5 7 <1 <1
Foundations/Concrete Pour - 2023 6 8 <1 <1
Building Construction - 2023 3 4 <1 <1
Paving - 2023 4 7 <1 <1
Architectural Coating - 2023 2 3 <1 <1
Overlapping Phases
Building Construction + Paving - 2023 7 10 <1 <1
Building Construction + Architectural Coating -
2023 5 6 <1 <1
Maximum Daily Localized Emissions 11 14 1 1
SCAQMD Regional Threshold 128 953 7.0 5.0
Threshold Exceeded? No No No No
NOTES:

NOx = oxides of nitrogen; CO = carbon monoxide; PM10 = particulate matter, aerodynamic diameter of 10 micrometers or less; PM2.5 = particulate matter, aerodynamic diameter of 2.5 micrometers or less.

SOURCE: Appendix A, of this Draft IS/MND. ESA 2022.

Localized Operational Emissions
According to SCAQMD LST methodology, LSTs would apply to the operational phase of a Project, if the Project includes stationary sources, or attracts mobile sources that may queue and idle at the site (e.g., warehouse or transfer facilities). With regard to on-site sources of emissions, the Project would generate emissions from area sources located on-site such as landscaping equipment, and use of consumer products. The Project would not use natural gas or be connected to the natural gas system. Table III-4, Maximum Daily Localized Operational Emissions, identifies the localized impacts at the nearest receptor location in the vicinity of the Project Site.

The localized emissions during operation would not exceed any of the SCAQMD’s localized significance thresholds. Therefore, impacts would be less than significant. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-21 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 TABLE III-4

MAXIMUM DAILY LOCALIZED OPERATIONAL EMISSIONS
Year
Emissions (pounds per day)
NOX CO PM10 PM2.5
Sources
Area <1 <1 <1 <1
Energy <1 <1 <1 <1
Total Project On-Site Emissions <1 <1 <1 <1
Existing Operations <1 <1 <1 <1
Net Daily Regional Emissions <1 <1 <1 <1
SCAQMD Regional Threshold 128 953 2.0 2.0
Threshold Exceeded? No No No No
NOTES:

NOx = oxides of nitrogen; CO = carbon monoxide; PM10 = particulate matter, aerodynamic diameter of 10 micrometers or less; PM2.5 = particulate matter, aerodynamic diameter of 2.5 micrometers or less.

SOURCE: Appendix A, of this Draft IS/MND. ESA 2022.

CO “Hot Spot” Analysis
According to SCAQMD ambient air quality monitoring data, existing CO concentrations within the Project Site (Source Receptor Area 9, East San Gabriel Valley 1 (Azusa)) for 2018, 2019, and 2020 were approximately 1.4, 1.6, 2.4 parts per million (ppm), respectively, for the maximum 1- hour average and 1.0, 1.1, 2.0 ppm, respectively, for the maximum 8-hour average (SCAQMD 2018, 2019, 2020). These measured values are substantially below the most stringent ambient air quality standard of 20 ppm for the 1-hour average and 9.0 ppm for the 8-hour average.

A CO hotspot is an area of localized CO pollution that is caused by severe vehicle congestion on major roadways, typically near intersections. Projects may worsen air quality if they increase the percentage of vehicles in cold start modes by two percent or more; significantly increase traffic volumes (by five percent or more) over existing volumes; or worsen traffic flow, defined for signalized intersections as increasing average delay at intersections operating at Level of Service (LOS) E or F or causing an intersection that would operate at LOS D or better without the Project, to operate at LOS E or F. While construction-related traffic on the local roadways would occur during construction, the net increase of construction worker vehicle trips to the existing daily traffic volumes on the local roadways would be relatively small (no more than 95 construction workers at a time) and would not result in CO hotspots in excess of the 1-hour or 8- hour ambient air quality standard. Additionally, the construction-related vehicle trips would only occur in the short-term and intermittently to the Project Site.

During operation, only minimal emissions would be generated from vehicle trips by the two employees, customers of the Public Storage facility, and periodic maintenance workers. The Project would not produce the volume of traffic required to generate a CO hotspot. Therefore, impacts would be less than significant. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-22 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Toxic Air Contaminants
Concentrations of toxic air contaminants (TACs) are also used as indicators of ambient air quality conditions. A TAC is defined as an air pollutant that may cause or contribute to an increase in mortality or in serious illness, or that may pose a hazard to human health. TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk may pose a threat to public health even at low concentrations.

Construction
Intermittent construction activities associated with the Project would result in short-term emissions of diesel particulate matter, which the State has identified as a TAC. During construction, the exhaust of off-road heavy-duty diesel equipment would emit diesel particulate matter during general construction activities, such as demolition, site preparation, grading/excavation, and foundations/concrete pour.

Intermittent construction activities associated with the Project would result in short-term emissions of diesel particulate matter, which the State has identified as a TAC. During construction, the exhaust of off-road heavy-duty diesel equipment would emit diesel particulate matter during general construction activities, such as demolition, grading/excavation, and building construction. Diesel particulate matter poses a carcinogenic health risk that is generally measured using an exposure period of 30 years for sensitive residential receptors, according to the California Environmental Protection Agency (CalEPA), Office of Environmental Health Hazard Assessment (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (OEHHA Guidance), which was updated in 2015 with new exposure parameters including age sensitivity factors (OEHHA, 2015). Sensitive receptors (residences) would be located adjacent to the Project Site; however, localized diesel particulate matter emissions (strongly correlated with PM2.5 emissions) would be minimal and would be below localized thresholds as presented in Table III-3. Although the localized analysis does not directly measure health risk impacts, it does provide data that can be used to evaluate the potential to cause health risk impacts. The low level of PM2.5 emissions coupled with the short-term duration of construction activity and the relatively small-scale of the Project would result in overall low level of diesel particulate matter concentrations in the Project area. Furthermore, compliance with the CARB airborne toxic control measures (ATCM) anti-idling measure, which limits idling to no more than five minutes at any location for diesel-fueled commercial vehicles, would further minimize diesel particulate matter emissions in the Project Site. The Project would utilize a Construction Contractor(s) that complies with required and applicable Best Available Control Technology (BACT) and the In-Use Off-Road Diesel Vehicle Regulation. Thus, it is expected that sensitive receptors would be exposed to emissions below thresholds and construction TAC impacts would be less than significant. No mitigation is required.

Operations
The Project would replace an electronics manufacturing facility with a Public Storage facility.

Typical sources of hazardous TACs include industrial manufacturing processes and automotive repair facilities which require extensive use of commercial or household cleaning products. The Project would not include any of these uses although, minimal emissions may result from the use of consumer products (e.g., aerosol sprays). Operation of the Project would only result in minimal

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-23 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 emissions of toxic air contaminants from the use of architectural coatings and other products. As presented in Table III-4, the localized emissions during operation would be minimal and below localized thresholds. Therefore, the Project would not expose surrounding sensitive receptors to TAC emissions. Impacts would be considered less than significant. No mitigation is required. d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact. As shown in Table III-1 and Table III-2, the Project would not exceed any criteria pollutant thresholds for which the SCAQMD is in attainment (CO, SOX). As mentioned previously, the CARB ATCM anti-idling measure would limit idling to no more than five minutes at any location (e.g. unloading or loading for the Public Storage facility) for dieselfueled commercial vehicles. Therefore, impacts would be less than significant. No mitigation is required.

Odors
Potential sources that may emit odors during construction activities include construction equipment exhaust and the application of asphalt for the parking lot and other asphalt surfaces surrounding the facility. According to the SCAQMD CEQA Air Quality Handbook, construction equipment is not a typical source of odors. While there is no specific architectural coating construction phase, SCAQMD Rule 1113 would limit the amount of VOCs from architectural coatings and solvents used during construction. Further, construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of construction. Through adherence with mandatory compliance with SCAQMD Rules, no construction activities or materials are proposed which would create objectionable odors affecting a substantial number of people. It is assumed that this would be the worst case scenario as the residences (sensitive receptor) are adjacent to the Project.

According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. Since the Project would construct a Public Storage facility, it is not anticipated to generate fugitive or evaporative odor emissions. Further, as shown in Table III-1 and Table III2, construction and operation of the Project would not generate emissions of other pollutants (pollutants for which the region is attainment or maintenance, which includes CO and SOX) in substantial quantities and emissions of such pollutants would be below the applicable SCAQMD significance thresholds. Therefore, the Project would not generate odors affecting a substantial number of people and impacts would be considered less than significant. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-24 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 References
LSA, 2021, Public Storage Covina, California – Trip Generation Analysis. July 30, 2021.

SCAQMD, 2008. South Coast Air Quality Management District (SCAQMD), 2008. Final Localized Significance Threshold Methodology. Available at:
http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysishandbook/localized-significance-thresholds, accessed November 2020.

SCAQMD, 2015. Air Quality Significance Thresholds. Available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significancethresholds.pdf, accessed February 2022.

SCAQMD, 2016. Final 2016 Air Quality Management Plan. Available:
https://www.aqmd.gov/home/air-quality/clean-air-plans/air-quality-mgt-plan/final-2016- aqmp, accessed February 2022.

SCAG, 2016b, 2016-2040 RTP/SCS Demographics and Growth Forecast Appendix, accessed February 2022.

SCAQMD, 2017, 2016 Air Quality Management Plan, http://www.aqmd.gov/home/airquality/clean-air-plans/air-quality-mgt-plan. Accessed February 2022.

SCAQMD, 2018, 2019, 2020. Historical Data by Year (2018, 2019, and 2020). Available:
http://www.aqmd.gov/home/air-quality/historical-air-quality-data/historical-data-by-year, accessed February 2022.

Southern California Association of Governments (SCAG), 2016a, 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy (2016-2040 RTP/SCS).

OEHHA, 2015. Office of Health Hazard Assessment (OEHHA), 2015. Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Available at:
http://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots-program-guidancemanual-preparation-health-risk-0, accessed November 2020.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-25 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Biological Resources
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IV. BIOLOGICAL RESOURCES — Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or
other means?
☐ ☐ ☐ ☒
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
☐ ☐ ☐ ☒
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☐ ☒
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state
habitat conservation plan?
☐ ☐ ☐ ☒
Discussion
Would the Project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
No Impact. The Project Site is located in a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. No native or natural vegetation occurs on the Project Site or within approximately 800 feet of the Project Site.

In the absence of any potential habitat areas, no special-status species of wildlife or plants would be expected to occur on the property or would be directly or indirectly affected by the Project.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-26 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Therefore, no impact would occur related to a substantial adverse effect on any plant or animal species identified as candidate, sensitive, or special-status in local or regional plans, policies, or regulations by the California Department of Fish and Wildlife (CDFW) or the U.S. Fish and Wildlife Service (USFWS).
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? No Impact. No riparian habitat or sensitive natural communities occur on or adjacent to the Project Site. A segment of Charter Oak Creek, consisting of a barren flood control channel conveying nuisance flow and storm runoff, is located approximately 680 feet to the south of the Project Site with residential housing occupying the area between the Project Site and the Creek.

The nearest section of Charter Oak Creek contains little or no vegetation until it flows downstream under Glendora Avenue approximately 800 feet to the southwest of the Project Site.

At that point Charter Oak Creek flows through Wingate Park where the drainage is still channelized but where it flows through the Park, it is surrounded by a patch of trees, including native coast live oak (Quercus agrifolia) and other natural and non-native vegetation, that may derive some support from the flood control drainage feature. The Charter Oak Creek segment may be considered to constitute a “semi-natural” riparian habitat area, since the Creek is channelized. In any event, as compared with the existing condition of the Project Site, the Project will not alter the existing drainage feature or the quality of nuisance flows or stormwater runoff that may enter Charter Oak Creek for the local area (including the Project Site) and then flow downstream through Wingate Park. The Project will replace the existing approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions”, which is used for electronics manufacturing, with a new public self-storage building of similar size to the existing commercial use. Implementation of the Project will not increase or decrease runoff quantity or pollutant loads in the storm drain system that may flow into Charter Oak Creek. Therefore, no impact would occur to any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or USFWS. c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No Impact. No wetlands or “waters” subject to state or federal regulatory jurisdiction, such as waters of the United States, pursuant to CWA Section 404, or streams or lakes, pursuant to California Fish and Game Code Section 1600 et al., occur on the Project Site. The Project Site does not contain any resources that would be regulated under the Clean Water Act (CWA) or California Fish and Game Code Section 1600 et al. Further, there are no potential offsite impacts that could be regulated under the CWA or California Fish and Game Code Section 1600.

Therefore, no impact would occur with respect to a substantial adverse effect on state or federally protected wetlands (including but not limited to marsh, vernal pool coastal) through direct removal, filling, hydrological interruption, or other means for on-site resources.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-27 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? No Impact. The Project site does not contribute to or function as part of a travel or migration route for terrestrial or avian wildlife species. The Project Site is not part of a regionally important or vital wildlife movement corridor. No native wildlife nursery sites occur in the Project vicinity and no such resources would be affected by the Project. Therefore, the Project would have no impact that would impede wildlife movement or the use of native wildlife nursery sites. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No Impact. The City’s General Plan includes a Natural Resources and Open Space Element that serves to identify, protect, and conserve local natural resources and to establish a framework for preserving, managing, and enhancing the community’s open space areas (Covina, 2000). Natural resources include water, soils, water bodies, vegetation, wildlife, and air; open space lands pertain to parks and related recreational facilities and trails. However, as noted above, the Project Site does not coincide with any existing natural areas or biological resources, and does not overlap or occur adjacent to areas zoned as open space. Nevertheless, there are existing trees on the Project Site and certain Goals and Policies in the Natural Resources and Open Space Element (Section IV) may apply to trees and landscaping design as follows:

Policy Area 2 - Vegetation and Wildlife
c. In new construction or redevelopment proposals, preserve existing mature trees, whenever feasible, particularly those located within forty feet of any public right-of-way or within any existing or proposed parking lot.
g. Require that new and significantly expanded/remodeled private, quasi-public, and public developments, including parking lots, incorporate adequate landscaping, in accordance with City Zoning, Design Guidelines, and general landscape installation provisions, for both aesthetic and ecological reasons.
h. Provide for landscape improvements to the City’s sidewalks, streets, civic properties, and related public spaces and facilities, in accordance with all applicable standards and provisions, for aesthetic and ecological reasons, to the greatest extent possible.

As noted above in Section 2.5.3, Landscaping, of the Project Description, a tree report was prepared that indicated no native oak trees are located within the Project Site but implementation of the Project would require the removal of 16 ornamental trees (9 Weeping Figs, 6 Southern Magnolias, and 1 Fan Palm). It is not practical or feasible to protect these trees in place as the entire site must be demolished for implementation of the Project. However, the Project includes a Landscape Plan which includes planting more trees than what current exists on the Site; refer to Figure 7. Moreover, the Landscape Plan fully conforms to the City of Covina Design Guidelines which require 20 trees overall (minimum 1 tree / 500 SF of landscape area) for a total of 9,781 SF

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-28 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 and at least 1 tree for each 60 feet of street frontage (6 trees required, 11 trees provided). The Landscape plan also prescribes planting a variety of shrubs along with the ornamental trees around sections of the perimeter of the property and in front of the storage structures. The ornamental tree specimens proposed to be planted that will replace the existing trees would include 8 sweet bay (Laurus nobilis), 8 Cherokee crape myrtle (Lagerstroemia indica “Cherokee”) and 4 golden rain tree (Koelreutaria paniculata), all of which are relatively drought tolerant and will not require excessive irrigation.

The City’s Municipal Code, Title 17 – Zoning, includes a Tree Preservation Ordinance (Ch.

17.83). The purpose of this ordinance is “to assure that new development addresses the preservation of significant healthy and mature trees to the greatest extent which is reasonable and that activities on properties with existing development are conducted in a manner that minimizes harm and destruction of such trees.” The ordinance does not apply to street trees or to repair and maintenance of existing parkways, highways and streets and/or other public facilities. Tree protection is limited to requiring a permit for any damage to designated “Heritage Trees.” Heritage Trees include all Quercus (oak) species 10 inches in diameter at breast height (DBH) or greater and trees or groups of trees designated as heritage tree(s) by the City Council. The ornamental tree species on the Project Site are no subject to this ordinance and there are no Heritage Trees within or adjacent to the Site.

Therefore, implementation of the Project will have no impact with respect to potential conflicts with the City’s Tree Preservation Ordinance or with regard to local policies protecting biological resources, such as the established City’s General Plan policies to preserve trees, provide for adequate landscaping, and assure adherence to landscape design guidelines. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The Project Site is located in a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. The Project will not directly or indirectly affect any natural area or habitat subject to any conservation planning instruments such as a Habitat Conservation Plan (HCP) or other local, regional, or state habitat conservation plan. As such, no impact would occur in this regard.

References
Covina, 2000. General Plan, Natural Resources and Open Space Element, adopted April 18, 2000.

Covina, 2022. City of Covina Municipal Code, passed January 18, 2022, https://www.codepublishing.com/CA/Covina/, accessed April 2022.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-29 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Cultural Resources
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
V. CULTURAL RESOURCES — Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
☐ ☒ ☐ ☐
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant to
§15064.5?
☐ ☒ ☐ ☐
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
☐ ☒ ☐ ☐
Discussion
The following analysis is based, in part, on the City of Covina Public Storage Project, City of Covina, California – Cultural Resources Assessment Report (Cultural Resources Assessment Report) (ESA, 2022), located in Appendix B, of this Draft IS/MND. The report summarizes the methods and results of a records search conducted through the California Historical Resources Information System (CHRIS) South Central Coastal Information Center (SCCIC); review of historic topographic maps and aerial photographs; and a desktop archaeological sensitivity assessment. Given the paved and developed nature of the Project Site, an archaeological resources survey was not conducted.

Would the Project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Less Than Significant Impact with Mitigation Incorporated. No cultural resources were identified within or immediately adjacent to the Project Site as a result of the SCCIC records research conducted for the Site. The historic map and aerial review indicates a structure and orchards were present within the Project Site from 1927 through the early 1960s. Starting in the early 1960s, the maps show the Project Site and its vicinity were subject to suburban development which began to replace the orchards. It is during this time that the structure and orchards depicted within the Project Site are no longer present. By the late 1980s the current buildings and parking lot within the Project Site are depicted.

Based on geotechnical testing conducted for the Project Site, artificial fill is known to extend from the Project Site’s surface to a depth of 6 feet below ground surface, and the fill is underlain by Quaternary alluvium. As such, the archaeological sensitivity assessment indicates Projectrelated ground disturbing activities from the Project Site’s surface to a depth 6 feet below ground surface (bgs) have no potential for encountering intact archaeological deposits (based on the previous disturbances in the Project Site), and the likelihood for encountering intact archaeological deposits below 6 feet bgs within the Quaternary alluvium is low to moderate. The Project’s proposed ground disturbance would extend to a maximum depth of 10 feet bgs,

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-30 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 intruding into the Quaternary alluvium. Therefore, there is some potential, albeit low to moderate, for Project-related ground disturbance to encounter intact subsurface archaeological deposits underlying the artificial fill below depths of 6 feet bgs. Should subsurface archaeological deposits be encountered during Project implementation, they may qualify as historical resources pursuant to CEQA and could be subject to significant impacts. With the incorporation of Mitigation Measures CUL-1 through CUL-3, potential impacts to subsurface archaeological deposits that qualify as historical resources would be less than significant.

Mitigation Measures
CUL-1: Prior to the start of ground-disturbing activities, the Project Applicant shall retain a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for archaeology (U.S. Department of the Interior, 2012) to carry out Mitigation Measures CUL-2 and CUL-3.

CUL-2: Prior to the start of ground-disturbing activities, construction personnel shall be trained in the identification of cultural resources. Prior to earth moving activities, the qualified archaeologist shall conduct cultural resources sensitivity training for all construction personnel. Construction personnel shall be informed of the types of archaeological resources that may be encountered, and of the proper procedures be to enacted in the event of an inadvertent discovery of archaeological resources or human remains. The Project Applicant shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance CUL-3: In the event of the unanticipated discovery of archaeological materials, the Project Contractor(s) shall immediately cease all work activities in the area (within approximately 100 feet) of the discovery until it can be evaluated by a qualified archaeologist. Prehistoric archaeological materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or tool-making debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; and stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones. Historic-period materials might include stone or concrete footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. Construction shall not resume until the qualified archaeologist has conferred with the City on the significance of the resource.

If it is determined that the discovered archaeological resource constitutes a historical resource under CEQA, avoidance and preservation in place is the preferred manner of mitigation. Preservation in place maintains the important relationship between artifacts and their archaeological context and also serves to avoid conflict with traditional and religious values of groups who may ascribe meaning to the resource. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. In the event that preservation in place is demonstrated to be infeasible and data recovery through excavation is the only feasible mitigation available, an Archaeological Resources Data Recovery and Treatment Plan shall be prepared and implemented by a

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-31 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 qualified archaeologist in consultation with the City and the Project Applicant that provides for the adequate recovery of the scientifically consequential information contained in the archaeological resource. The City shall consult with appropriate Native American representatives in determining treatment for prehistoric or Native American resources to ensure cultural values ascribed to the resource, beyond that which is scientifically important, are considered.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less Than Significant Impact with Mitigation Incorporated. As detailed above, there is some potential, albeit low to moderate, for Project-related ground disturbance to encounter intact subsurface archaeological deposits below depths of 6 feet bgs. Should subsurface archaeological deposits be encountered during Project implementation, they may qualify as unique archaeological resources pursuant to CEQA and could be subject to significant impacts. With the incorporation of Mitigation Measures CUL-1 through CUL-3, potential impacts to subsurface archaeological deposits that qualify as unique archaeological resources would be less than significant.

Mitigation Measures
Implement Mitigation Measures CUL-1 through CUL-3.
c) Disturb any human remains, including those interred outside of dedicated cemeteries?
Less Than Significant Impact with Mitigation Incorporated. No known formal or informal cemeteries or other burial places are known to exist within the Project Site and the Project is unlikely to disturb human remains. However, because the Project would involve earthmoving activities, there is the possibility, albeit low, that such actions could unearth, expose, or disturb previously unknown human remains. With the incorporation of Mitigation Measure CUL-4, which requires compliance with State Health and Safety Code Section 7050.5 and PRC Section 5097.98, potential impacts to human remains would be less than significant.

Mitigation Measures
CUL-4: If human remains are encountered, the Project Contractor(s) shall halt work in the vicinity (within 100 feet) of the find and contact the Los Angeles County Coroner in accordance with PRC Section 5097.98 and Health and Safety Code Section 7050.5. If the County Coroner determines that the remains are Native American, the California Native American Heritage Commission (NAHC) will be notified in accordance with Health and Safety Code Section 7050.5, subdivision (c), and PRC Section 5097.98 (as amended by Assembly Bill 2641). The NAHC will designate a Most Likely Descendent (MLD) for the remains per PRC Section 5097.98. Until the landowner has conferred with the MLD, the Project Contractor(s) shall ensure that the immediate vicinity where the discovery occurred is not disturbed by further activity, is adequately protected according to generally accepted cultural or archaeological standards or practices, and that further activities take into account the possibility of multiple burials.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-32 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 References
ESA. 2022. City of Covina Public Storage Project, City of Covina, California – Cultural Resources Assessment Report. Prepared for the City of Covina Community Development Department by Environmental Science Associates.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-33 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Energy
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VI. ENERGY — Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☒ ☐
Discussion
Would the Project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation?
Less Than Significant Impact. The Project would consume energy during construction activities primarily from on- and off-road vehicle fuel consumption in the form of diesel, gasoline, and electricity from water conveyance for dust control. Operation of the Project would consume energy from energy use from general building operations, including building heating, ventilation and air conditioning (HVAC) systems and lighting, and from mobile sources. The analysis below includes the Project’s energy requirements and energy use efficiencies by energy type for each stage of the Project (construction and operations).

Construction
Construction of the Project would result in energy demand primarily from off-road equipment and on-road vehicle fuel consumption (diesel and gasoline) and secondarily from electricity for conveying water used for dust suppression and for a temporary on-site construction office/trailer.

The analysis below includes the Project’s energy requirements and energy use efficiencies by energy type for each stage of the Project.

The estimated fuel usage for off-road equipment is based on the number and type of equipment that would be used during construction activities, hour usage estimates, the total duration of construction activities, and hourly equipment fuel consumption factors from the California Air Resources Board (CARB) OFFROAD model, which was used in the Project’s air quality analysis. On-road vehicles would include trucks to haul material to and from the Project Site, vendor trucks to deliver supplies necessary for Project construction, water trucks for dust control, and fuel used for employee commute trips. The estimated fuel usage for on-road vehicles is based on the number of trucks and employee commute trips that would occur during construction activities and per mile fuel consumption factors from the CARB on-road vehicle emissions factor (EMFAC) model, which was used in the Project’s air quality analysis. Electricity used for a portable construction office was calculated using energy intensity factors from CalEEMod and electricity from water conveyance for dust control was calculated using assumptions for gallons

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-34 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 used per acre per day and CalEEMod water conveyance intensity factors applied to calculate total construction electricity consumption. Construction activities typically do not involve the consumption of natural gas. Table VI-1, Summary of Energy Consumption During Project Construction, summarizes the Project’s total and annual fuel and electricity consumption from construction activities.

TABLE VI-1

SUMMARY OF ENERGY CONSUMPTION DURING PROJECT CONSTRUCTION Fuel Type Quantity
Gasoline gallons
On-Road Construction (Workers) 13,705
Total Gasoline (12 months) 13,705
Diesel gallons
On-Road Construction Equipment 14,964
Off-Road Construction Equipment 13,263
Total Diesel (12 months) 28,226
Electricity MWh
Construction Office 13
Water Conveyance for Dust Control 0.60
Total Electricity (12 months) 13.6
NOTES:
gal = gallons; MWh = megawatt-hours.

SOURCE: ESA, 2022.

As shown in Table VI-1, total construction electricity usage would be approximately 13.6 megawatt-hours (MWh) and would be within the supply and infrastructure capabilities of Southern California Edison (SCE), the electricity provider for the Project Site, which had a net energy load of 85,399 gigawatt-hours (GWh) in 2020 (SCE, 2021).1 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. Electricity use from construction would be short-term, limited to working hours, used for necessary constructionrelated activities, and represent a small fraction of the Project’s annual operational electricity (the Project’s annualized construction electricity would be approximately 6.1 percent of the Project’s annual operational electricity). When not in use, electric equipment would be powered off so as to avoid unnecessary energy consumption. Furthermore, the electricity used for off-road light construction equipment would have the co-benefit of reducing construction-related air pollutant and greenhouse gas (GHG) emissions from more traditional construction-related energy in the form of diesel fuel. Therefore, impacts from construction electrical demand would be less than significant and would not result in the wasteful, inefficient, and unnecessary consumption of energy. No mitigation is required.
1 The most recent year that SCE data was available.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-35 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 The energy use summary provided above in Table VI-1 represents the amount of energy that could potentially be consumed during Project construction based on a conservative set of assumptions, provided in Appendix A, of this Draft IS/MND. As shown, on- and off-road vehicles would consume approximately 13,705 gallons of gasoline and 28,226 gallons of diesel fuel throughout the Project’s construction. For comparison purposes, the fuel usage during construction of the Project would represent approximately 0.0005 percent of the 2020 annual onroad gasoline-related energy consumption and 0.005 percent of the 2020 annual diesel fuelrelated energy consumption in California (CEC, 2021).

Operation
During operation of the Project, energy would be consumed for multiple purposes, including, but not limited to HVAC equipment, lighting, and the use of electronics. Energy would also be consumed during operation of the Project related to water usage, solid waste disposal, and vehicle trips. Table VI-II, Project Operational Energy Usage, summarizes the Project’s operational energy consumption. As shown in Table VI-II, the Project would result in a net annual consumption of electricity of approximately 263 MWh per year, which would represent approximately 0.0003 percent of SCE’s total sales of 85,399,000 MWh in 2020 (SCE, 2021).

The Project would install lighting and a ventilation system that conforms to the CALGreen Code and 2019 Title 24 Standards. In addition, the Project would include electric vehicle parking in accordance with the 2019 Title 24 Standards.

Additionally, the Project would decrease the demand for natural gas resources because the Project will not use natural gas or be connected to the natural gas system. As shown in Table VI-II, the Project would decrease natural gas demand by 0.96 million cubic feet as compared to existing land uses. As would be the case with electricity, the Project would comply with the applicable provisions of Title 24, and the CALGreen Code in effect at the time of building occupancy to minimize natural gas demand. As such, the Project would minimize energy demand. Therefore, with the incorporation of these features, operation of the Project would not result in the wasteful, inefficient, and unnecessary consumption of natural gas, and impacts would be less than significant. No mitigation is required.

The Project would decrease demand for transportation fuels relative to existing site conditions for gasoline, diesel, and natural gas. During daily operations, the Project would have a maximum of 214 vehicle trips. The Project would decrease fuel use relative to existing site conditions by 1,685 gallons of gasoline, 37 gallons of diesel, and 3 gasoline gallon equivalent (GGE) of natural gas.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-36 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022

TABLE VI-II

PROJECT OPERATIONAL ENERGY USAGE
Energy Typea Annual Quantityb
Electricity
Existing:

Building Energy 601 MWh
Water Conveyance 167 MWh
Existing Total Electricity 767 MWh
Project:

Building Energy 594 MWh
Water Conveyance 432 MWh
EV Charging 5 MWh
Project Total Electricity 1,030 MWh
Net Total Electricity 263 MWh
Natural Gas
Existing:

Building Energy 0.96 million cf
Existing Total Natural Gas 0.96 million cf
Project:

Building Energy 0.0 million cf
Project Total Natural Gas 0.0 million cf
Net Total Natural Gas (0.96 million cf)
Transportation
Existing:

Gasoline 27,216 gallons
Diesel 4,054 gallons
Natural Gas 69 GGE
Project:

Gasoline 25,530 gallons
Diesel 4,016 gallons
Natural Gas 66 GGE
Total Transportation – Gasoline (1,685 gallons)
Total Transportation – Diesel (37 gallons)
Total Transportation – Natural Gas (3 GGE)
NOTES:

MWh = megawatt-hours; million cf = million cubic feet; GGE = gasoline gallon equivalent.

Detailed calculations are provided in Appendix A, of this Draft IS/MND. a Project electricity and natural gas estimates assume compliance with applicable 2019 Title 24 and CALGreen requirements
b Totals may not add up due to rounding of decimals.

SOURCE: ESA, 2022.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-37 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact. The Project would utilize a Construction Contractor(s) who demonstrate compliance with applicable regulations. Construction equipment would comply with federal, State, and regional requirements where applicable. With respect to truck fleet operators, the USEPA and National Highway Traffic Safety Administration (NHSTA) have adopted fuel efficiency standards for medium- and heavy-duty trucks. The Phase 1 heavy-duty truck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through 2018 and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline, depending on the vehicle type (USEPA, 2011). USEPA and NHTSA also adopted the Phase 2 heavy-duty truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25 percent reduction in fuel consumption over the 2017 baseline depending on the compliance year and vehicle type (USEPA, 2016). The energy modeling for trucks does not take into account specific fuel reductions from these regulations, since they would apply to fleets as they incorporate newer trucks meeting the regulatory standards; however, these regulations would have an overall beneficial effect on reducing fuel consumption from trucks over time as older trucks are replaced with newer models that meet the standards.

In addition, construction equipment and trucks are required to comply with CARB regulations regarding heavy-duty truck idling limits of five minutes at a location and the phase-in of off-road emission standards that result in an increase in energy savings in the form of reduced fuel consumption from more fuel-efficient engines. Although these regulations are intended to reduce criteria pollutant emissions, compliance with the anti-idling and emissions regulations would also result in the efficient use of construction-related energy.

The State of California and the City have implemented energy policies relevant to the Project.

The California Renewables Portfolio Standard (RPS) was established in 2002 and required retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2013. California Senate Bill 350 (Chapter 547, Statues of 2015) is the most recent update to the state’s RPS requirements. The RPS requires publicly owned utilities and retail sellers of electricity in California to procure 33 percent of their electricity sales from eligible renewable sources by 2020 and 50 percent by the end of 2030. The Project could potentially generate an increase in electricity demand during operation. However, the demand would be negligible with respect to SCE supplies and no additional power generation facilities would be required. The Project would not conflict with SCE or the State’s ability to achieve the RPS goals.

The City’s 2019 Energy Action Plan Update and 2012 Energy Action Plan were prepared by the San Gabriel Valley Council of Governments (SGVCOG) for the City. The plans’ goals are to reduce energy consumption and decrease GHG emissions in accordance with AB 32 and Senate Bill (SB) 32 emission reduction targets. (Covina 2012; Covina 2019). The City’s strategy to achieve these goals is structured around four key strategy topics: electricity, natural gas, and water efficiency; municipal operations; employee & department engagement; and partnership and

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-38 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 regional engagement. These strategies will reduce energy usage at the City’s municipal facilities (Covina, 2019). The Project would result in a minimal water demand for two single occupancy restrooms, a janitor’s closet, the sink included in the employee break room, fire sprinklers, and the drought tolerant landscaping. All landscape areas would be irrigated with an automatic smart irrigation control system with a dedicated water meter. Energy demand from the Project would result in less natural gas and fuel consumption compared to the existing use (Appendix A, of this Draft IS/MND). Therefore, the Project would have a less than significant impact to conflicting with or obstructing a state or local plan for renewable energy or energy efficiency. No mitigation is required.

References
CARB, 2004. California Air Resources Board, 2004. Proposed Regulation Order: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling, Appendix A, 2004. Available at https://www.arb.ca.gov/regact/idling/isorappf.pdf, accessed September 2019.

CEC, 2021. California Energy Commission. 2021. California Annual Retail Fuel Outlet Report Results (CEC-A15) Spreadsheets. https://www.energy.ca.gov/sites/default/files/2021- 09/2010-2020%20CEC-A15%20Results%20and%20Analysis.xlsx, accessed February, 2022.

California Gas and Electric Utilities, 2020. 2020 California Gas Report. https://www.socalgas.com/sites/default/files/2020-
10/2020_California_Gas_Report_Joint_Utility_Biennial_Comprehensive_Filing.pdf, accessed December 15, 2021.

Covina, 2012. City of Covina, 2012. 2012 Energy Action Plan. Available:
https://covinaca.gov/sites/default/files/fileattachments/public_works/page/584/covina-eapdecember-2012_final.pdf, accessed November 2020.

Covina, 2019. City of Covina 2019 Energy Action Plan Update. Available:
https://covinaca.gov/sites/default/files/fileattachments/public_works/page/584/eap_- _final.pdf, accessed November 2020.

SCE, 2021. Edison International and Southern California Edison 2020 Annual Report. https://docs.cpuc.ca.gov/PublishedDocs/SupDoc/A1908013/2880/342189211.pdf, accessed February, 2022.

USEPA, 2011. Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, August 2011.

USEPA, 2016. Federal Register/Vol. 81, No. 206/Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, October 25, 2016.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-39 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Geology and Soils
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VII. GEOLOGY AND SOILS — Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
☐ ☐ ☒ ☐
ii) Strong seismic ground shaking? ☐ ☐ ☒ ☐
iii) Seismic-related ground failure, including
liquefaction?
☐ ☐ ☒ ☐
iv) Landslides? ☐ ☐ ☒ ☐
b) Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐ c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☒ ☐
d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property?
☐ ☐ ☒ ☐
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal
systems where sewers are not available for the
disposal of waste water?
☐ ☐ ☐ ☒
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
☐ ☐ ☐ ☒
Discussion
The following analysis is based, in part, on the Geotechnical Engineering Exploration and Analysis, Proposed 3-Story Public Storage Building, 1330 East Cypress Street, Covina, California (Geotechnical Report) (Giles, 2021), located in Appendix C, of this Draft IS/MND, and the City of Covina Public Storage Project, City of Covina, California, Paleontological Resources Assessment (Paleontological Resources Assessment) (ESA, 2022), located in Appendix D, of this Draft IS/MND. The Paleontological Resources Assessment summarizes the methods and results of a paleontological resources database review conducted by the Los Angeles County Natural History Museum, and a review of relevant geologic maps and geotechnical reports.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-40 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Would the Project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42? Less Than Significant Impact. Fault rupture is the displacement that occurs along the surface of a fault during an earthquake. Based on criteria established by the California Geological Survey (CGS), faults may be categorized as active, potentially active, or inactive. Active faults are those which show evidence of surface displacement within the last 11,000 years (Holocene-age).

Potentially active faults are those that show evidence of most recent surface displacement within the last 1.6 million years (Quaternary-age). Faults showing no evidence of surface displacement within the last 1.6 million years are considered inactive. In addition, there are buried thrust faults, which are low angle reverse faults with no surface exposure. Due to their buried nature, the existence of buried thrust faults is usually not known until they produce an earthquake.

The CGS has established earthquake fault zones known as Alquist-Priolo Earthquake Fault Zones around the surface traces of active faults to assist cities and counties in planning, zoning, and building regulation functions. These zones, which extend from 200 to 500 feet on each side of a known active fault, identify areas where potential surface rupture along an active fault could prove hazardous and identify where special studies are required to characterize hazards to habitable structures.

The Project Site is located in the highly seismic Southern California region within the influence of several fault systems and could be subject to moderate to strong ground shaking in the event of an earthquake on one of the many active Southern California faults. However, the Project Site does not lie within the boundaries of an Earthquake Fault Zone as defined by the State of California in the Alquist-Priolo Earthquake Fault Zoning Act. According to the Geotechnical Report, there are no known active faults traversing the Project Site (Giles, 2021. The nearest active faults to the Project Site are the San Jose Fault and the Sierra Madre Fault, located approximately 2.8 miles and 3.6 miles from the Site, respectively (Giles, 2021). As such, the Project would result in a less than significant impact related to the rupture of a known earthquake fault. No mitigation is required.
ii) Strong seismic ground shaking?
Less Than Significant Impact. Seismicity is the geographic and historical distribution of earthquakes, including their frequency, intensity, and distribution. The level of ground shaking at a given location depends on many factors, including the size and type of earthquake, distance from the earthquake, and subsurface geologic conditions. The type of construction also affects how particular structures and improvements perform during ground shaking.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-41 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Strong seismic ground shaking could result in general types of ground failure; however, based on the Geotechnical Report, ground failure and associated effects of seismic activity are considered unlikely at the Project Site (Giles, 2021). The City requires that all new construction meet or exceed Title 14, Buildings and Construction, of the City’s Municipal Code, and the latest standards of the 2019 California Building Code (CBC) for construction which requires structural design that can accommodate maximum ground accelerations expected from known faults. The Project would comply with the CGS Special Publications 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California, which provides guidance for evaluation and mitigation of earthquake-related hazards. Therefore, the Project would result in a less than significant impact related to strong seismic ground shaking. No mitigation is required. iii) Seismic-related ground failure, including liquefaction? Less Than Significant Impact. Liquefaction is a phenomenon in which loosely deposited, granular soils and fine-grained soils located below the water table undergo rapid loss of shear strength when subjected to strong earthquake-induced ground shaking. Ground shaking of sufficient duration can result in a loss of grain-to-grain contact due to a rapid rise in pore water pressure causing the soul to behave as a fluid for a short period. Liquefaction is known generally to occur in saturated or near-saturated cohesionless soils at depths shallower than 50 feet below the ground surface. Factors known to influence liquefaction potential include composition and thickness of soil layers, grain size, relative density, degree of saturation, groundwater level, and both duration and intensity of ground shaking.

According to the City’s General Plan, liquefaction typically occurs in areas where the groundwater is less than 30 feet from the ground surface and where the soils are composed of predominantly poorly consolidated fine sand. The Seismic Hazard Evaluation Report for the San Dimas Quadrangle, where the Project is located, indicates that the Project Site does not lie within a designated Liquefaction Hazards Zone. In addition, the depth to historic high groundwater is reported to be approximately 180 feet below grade (Giles, 2021). Based on these conditions, liquefaction is not expected to occur. Further, compliance with the 2019 CBC and the CGS Special Publications 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California, would reduce impacts from liquefaction within the Project Site to maximum extent possible under currently accepted engineering practices. These engineering practices could include densification of soils, soil reinforcement, and drainage/dewatering to reduce pore water pressure within the soil. Therefore, the Project would result in a less than significant impact related to liquefaction. No mitigation is required.
iv) Landslides?
Less Than Significant Impact. Earthquake-induced landslides often occur in areas where previous landslides have moved and in areas where the topographic, geologic, geotechnical and subsurface groundwater conditions are conducive to permanent ground displacements. Based on a review of the soil conditions, site plan and building setbacks, landslides are not anticipated to occur (Giles, 2021). As such, a less than significant impact would occur in this regard. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-42 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 b) Result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Soil erosion refers to the process by which soil or earth material is loosened or dissolved and removed from its original location. Erosion can occur by varying processes and may occur in a project area where bare soil is exposed to wind or moving water (both rainfall and surface runoff). The processes of erosion are generally a function of material type, terrain steepness, rainfall or irrigation levels, surface drainage conditions, and general land uses. Topsoil is used to cover surface areas for the establishment and maintenance of vegetation due to its high concentrations of organic matter and microorganisms.

Construction activities associated with the Project would result in ground surface disruption during excavation, grading, and trenching that would create the potential for erosion to occur. The Project would include approximately 11,500 cubic yards of cut and approximately 3,500 cubic yards of fill, resulting in approximately 8,000 cubic yards of soil export. Wind erosion would be minimized through soil stabilization measures required by the SCAQMD Rule 403 (Fugitive Dust), such as daily watering. Potential for water erosion would be reduced by implementation of standard erosion control measures imposed during site preparation and grading activities. As discussed in more detail in Section X, Hydrology and Water Quality, the Project would be subject to all existing regulations associated with the protection of water quality. Construction activities would be carried out in accordance with applicable City standard erosion control practices required pursuant to the 2019 CBC and the requirements of the National Pollutant Discharge Elimination Systems (NPDES) General Construction Permit issued by the LARWQCB, as applicable. Consistent with these requirements, a Stormwater Pollution Prevention Plan (SWPPP) would be prepared that incorporates best management practices (BMPs) to control water erosion during the construction phase of the Project. Therefore, with compliance with applicable regulatory requirements, impacts regarding soil erosion or the loss of topsoil would be less than significant. No mitigation is required.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Less than Significant Impact. As previously discussed under Responses VII.a.iii and VII.a.iv above, liquefaction and landslide hazards were concluded to be less than significant. Lateral spreading is the downslope movement of surface sediment due to liquefaction in a subsurface layer. The downslope movement is due to the combination of gravity and earthquake shaking.

Such movement can occur on slope gradients of as little as one degree. Lateral spreading typically damages pipelines, utilities, bridges, and structures. Lateral spreading of the ground surface during a seismic activity usually occurs along the weak shear zones within a liquefiable soil layer and has been observed to generally take place toward a free face (i.e., retaining wall, slope, or channel) and to a lesser extent on ground surfaces with a very gentle slope. As stated under Response VII.a.iii, the Project Site does not lie within a designated Liquefaction Hazards Zone and the depth to historic high groundwater is reported to be approximately 180 feet below grade (Giles, 2021). Further, due to the absence of any channel, slope, or river within the Project Site, the potential for lateral spreading occurring on or off the Project Site is considered to be low.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-43 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Subsidence occurs when a void is located or created underneath a surface, causing the surface to collapse. Common causes of subsidence include withdrawal of groundwater or oil resources or wells beneath a surface. As no oil wells are located within the Project Site, subsidence associated with extraction activities is not anticipated.

Conformance to the 2019 CBC and the CGS Special Publications 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California would reduce impacts from stability hazards within the Project Site to the maximum extent possible under currently accepted engineering practices.

These engineering practices could include densification of soils, soil reinforcement, and drainage/dewatering to reduce pore water pressure within the soil. As such, implementation of the Project would result in less than significant impacts related to geological stability hazards. No mitigation is required.
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Less than Significant Impact. Soils with shrink-swell or expansive properties typically occur in fine-grained sediments and cause damage through volume changes as a result of a wetting and drying process. Structural damage may occur over a long period of time, usually the result of inadequate soil. Near surface soils on the Project Site have a very low expansion potential (Giles, 2021). Although not anticipated, expansive soils, if encountered within the Project Site, would be removed and/or replaced as part of standard construction practices pursuant to the City and the 2019 CBC building requirements. Therefore, implementation of the Project would result in less than significant impacts associated with expansive soils and substantial risks to life or property would not occur. No mitigation is required.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. The Project Site is located in an urbanized area where municipal wastewater infrastructure currently exists. The Project would connect to existing infrastructure and would not use septic tanks or alternative waste water disposal systems. Therefore, no impact would occur in this regard.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
No Impact. The Paleontological Resources Assessment did not identify the presence of paleontological resources or paleontologically sensitivity geologic units within the Project Site.

Based on the Geotechnical Report, a layer of artificial fill was identified as extending from the Project Site’s surface to a depth of 6 feet bgs (Giles, 2021). Artificial fill has no paleontological potential. Therefore, excavations within the fill would not impact paleontological resources. The fill is underlain to a depth of 36 feet by Holocene-age Quaternary alluvium, which has low potential to contain paleontological resources. Project-related ground disturbance would extend to a depth of only 4 feet within the Quaternary alluvium. Given the low potential of the Quaternary

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-44 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 alluvium and the relatively shallow excavations within intact sediments, Project-related ground disturbance is not likely to encounter and impact unique paleontological resources or unique geologic features. As such, no impact would occur in this regard.

References
ESA, 2022. City of Covina Public Storage Project, City of Covina, California – Paleontological Resources Assessment. Prepared for the City of Covina Community Development Department by Environmental Science Associates.

Giles, 2021. Giles Engineering Associates, Inc., 2021. Geotechnical Engineering Exploration and Analysis, Proposed 3-Story Public Storage Building 1330 East Cypress Street, Covina, California.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-45 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Greenhouse Gas Emissions
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VIII. GREENHOUSE GAS EMISSIONS —
Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
☐ ☐ ☒ ☐
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
☐ ☐ ☒ ☐
Discussion
Would the Project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact. Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). The major concern with GHGs is that increases in their concentrations are causing global climate change. Global climate change is a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation, and temperature. Although there is disagreement as to the rate of global climate change and the extent of the impacts attributable to human activities, most in the scientific community agree that there is a direct link between increased emissions of GHGs and long term global temperature increases.

The State defines GHGs as carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different global warming potentials (GWPs) and CO2 is the most common reference gas for climate change, GHG emissions are often quantified and reported as CO2 equivalents (CO2e). For example, CH4 has a GWP of 25 (over a 100-year period); therefore, one metric ton (MT) of CH4 is equivalent to 25 MT of CO2 equivalents (MTCO2e). The GWP ratios are available from the United Nations Intergovernmental Panel on Climate Change (IPCC) and are published in the Fourth Assessment Report (AR4). By applying the GWP ratios, project-related CO2e emissions can be tabulated in metric tons (MT) per year. Large emission sources are reported in million metric tons (MMT) of CO2e.2
Some of the potential effects in California of global warming may include loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more forest fires, and more drought years (CARB, 2008). Globally, climate change has the potential to impact numerous environmental resources through potential, though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects of global warming on weather and 2 A metric ton is 1,000 kilograms; it is equal to approximately 1.1 U.S. tons and approximately 2,204.6 pounds.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-46 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 climate are likely to vary regionally, but are expected to include the following direct effects (IPCC, 2001):
• Higher maximum temperatures and more hot days over nearly all land areas; • Higher minimum temperatures, fewer cold days and frost days over nearly all land areas; • Reduced diurnal temperature range over most land areas; • Increase of heat index over land areas; and
• More intense precipitation events.

Also, there are many secondary effects that are projected to result from global warming, including global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity. While the possible outcomes and the feedback mechanisms involved are not fully understood and much research remains to be done, the potential for substantial environmental, social, and economic consequences over the long term may be great. In the most recent IPCC Sixth Assessment Report, Summary for Policy Makers, it states “It is unequivocal that human influence has warmed the atmosphere, ocean, and land” (IPCC, 2021).

California produced 418.2 MMTCO2e in 2019, the latest year for which data are available from CARB. Combustion of fossil fuel in the transportation sector was the single largest source of California’s GHG emissions in 2019, accounting for approximately 40 percent of total GHG emissions in the state. This sector was followed by the industrial sector (21 percent) and the electric power sector (including both in-state and out-of-state sources) (14 percent) (CARB, 2021).

Impacts of GHGs are borne globally, as opposed to localized air quality effects of criteria air pollutants and toxic air contaminants. The quantity of GHGs that it takes to ultimately result in climate change is not precisely known; however, it is clear that the quantity is enormous, and no single project would measurably contribute to a noticeable incremental change in the global average temperature, or to global, local, or micro climates. From the standpoint of CEQA, GHG impacts to global climate change are inherently cumulative.

The City has not adopted a threshold of significance for GHG emissions that would be applicable to the Project. In December 2008, the SCAQMD adopted a 10,000 MTCO2e per year significance threshold for industrial facilities for projects in which the SCAQMD is the lead agency. Although SCAQMD has not formally adopted a significance threshold for GHG emissions generated by a project for which SCAQMD is not the lead agency, or a uniform methodology for analyzing impacts related to GHG emissions on global climate change, in the absence of any industry-wide accepted standards, the SCAQMD’s significance threshold of 10,000 MTCO2e per year for projects is the most relevant air district-adopted GHG significance threshold and is used as a benchmark for the Project. It should be noted that the SCAQMD’s significance threshold of 10,000 MTCO2e per year for industrial projects is intended for long-term operational GHG emissions. The SCAQMD has developed guidance for the determination of the significance of GHG construction emissions that recommends that total emissions from construction be

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-47 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 amortized over an assumed project lifetime of 30 years and added to operational emissions and then compared to the threshold (SCAQMD, 2008).

The justification for the threshold is provided in SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (“SCAQMD Interim GHG Threshold”). The SCAQMD Interim GHG Threshold identifies a screening threshold to determine whether additional analysis is required. As stated by the SCAQMD:
“…the…screening level for stationary sources is based on an emission capture rate of 90 percent for all new or modified projects…the policy objective of [SCAQMD’s] recommended interim GHG significance threshold proposal is to achieve an emission capture rate of 90 percent of all new or modified stationary source projects. A GHG significance threshold based on a 90 percent emission capture rate may be more appropriate to address the long-term adverse impacts associated with global climate change because most projects will be required to implement GHG reduction measures. Further, a 90 percent emission capture rate sets the emission threshold low enough to capture a substantial fraction of future stationary source projects that will be constructed to accommodate future statewide population and economic growth, while setting the emission threshold high enough to exclude small projects that will in aggregate contribute a relatively small fraction of the cumulative statewide GHG emissions. This assertion is based on the fact that [SCAQMD] staff estimates that these GHG emissions would account for slightly less than one percent of future 2050 statewide GHG emissions target (85 [MMTCO2e per year]). In addition, these small projects may be subject to future applicable GHG control regulations that would further reduce their overall future contribution to the statewide GHG inventory. Finally, these small sources are already subject to [Best Available Control Technology (BACT)] for criteria pollutants and are more likely to be single-permit facilities, so they are more likely to have few opportunities readily available to reduce GHG emissions from other parts of their facility.” The SCAQMD has applied its 10,000 MTCO2e per year significance threshold in such a way that GHG emissions covered by the Cap-and-Trade Program do not constitute emissions that must be measured against the threshold.3 However, for purposes of analysis in this Draft IS/MND, the GHG emissions from all of the Project’s GHG emissions sources are included in the GHG emissions and are measured against the 10,000 MTCO2e per year significance threshold. Thus, as explained above, based on guidance from the SCAQMD, if an industrial project would emit GHGs less than 10,000 MTCO2e per year, the project would not be considered a substantial GHG emitter and GHG emission impact would be less than significant, requiring no additional analysis and no mitigation.
3 For example, the SJVAPCD “determined that GHG emissions increases that are covered under CARB’s Cap-andTrade regulation cannot constitute significant increases under CEQA …” (SJVAPCD 2014). Furthermore, the SCAQMD has taken this position in CEQA documents it has produced as a lead agency. The SCAQMD has prepared three Negative Declarations and one Draft EIR that demonstrate the SCAQMD has applied its 10,000 MTCO2e/year significance threshold in such a way that GHG emissions covered by the Cap-and-Trade Program do not constitute emissions that must be measured against the threshold (SCAQMD 2014a, 2014b, 2014c, 2015).

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-48 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 CEQA Guidelines 15064.4 (b)(1) states that a lead agency may use a model or methodology to quantify GHGs associated with a project. In May 2021, the SCAQMD in conjunction with California Air Pollution Control Officers Association (CAPCOA) released the latest version of the CalEEMod (Version 2020.4.0). The purpose of this model is to estimate construction-source and operational-source emissions from direct and indirect sources. Accordingly, the latest version of CalEEMod has been used for the Project to estimate the Project’s emission impacts (Appendix A, of this Draft IS/MND).

Construction Emissions
Construction activities associated with the Project would result in emissions of CO2 and to a lesser extent CH4 and N2O. Construction-period GHG emissions were quantified based on the same construction schedule, activities, and equipment list as described in Appendix A, of this Draft IS/MND. It is assumed that all construction equipment would be Tier 3. To amortize the emissions over the life of the Project, the SCAQMD recommends calculating the total GHG emissions attributable to construction activities, dividing it by the 30-year project life, and then adding that number to a project’s annual operational-phase GHG emissions. As such, construction emissions were amortized over a 30-year period, and impacts would be less than significant during construction. No mitigation is required.

Operational Emissions
As described above in Section III, Air Quality, during operation of the Project, there would only be an estimated two full time employees to operate the Public Storage facility. It is anticipated that operational activities would be limited to periodic landscaping and maintenance and trips by customers of the Public Storage. As such, the Project’s facilities would not require a substantial increase in the number of employees. Energy usage, water usage, and waste would be minimal as the Project would use LED lighting outdoors for security purposes, result in negligible estimated water use from two single occupancy restrooms, the janitor’s closet, the sink in the employee break room, fire sprinklers, and the drought tolerant landscaping, and require customers of the Public Storage to dispose of their own waste off-site (see Sections 2.5.4 Signage and Lighting;

2.5.6 Water/Solid Waste Generation). It is assumed that there would be only waste from the office space so waste emissions from the warehouse land use is excluded from Table VIII-1.

Therefore, impacts to GHG emissions during operation would be considered less than significant.

No mitigation is required.

Existing Emissions
The Project would replace an existing electronics manufacturing building. Existing emissions were estimated to be approximately 579 MTCO2e per year as summarized in Table VIII-1, Annual Project Greenhouse Gas Emissions (Appendix A, of this Draft IS/MND).

Emissions Summary
The annual GHG emissions for the Project were estimated to be approximately 551 MTCO2e per year as summarized in Table VIII-1. The net Project emissions (direct and indirect emissions) are compared with the SCAQMD proposed screening level for industrial/stationary source projects,

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-49 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 which is 10,000 MTCO2e. As shown in Table VIII-1, the Project would result in a less than significant impact with respect to GHG emissions. No mitigation is required.

TABLE VIII-1

ANNUAL PROJECT GREENHOUSE GAS EMISSIONS
Emission Source Total MTCO2e/year
Amortized construction emissions 10
Mobile 269
Energy (Electricity) 131
Area <1
Water Conveyance 140
Solid Waste <1
Project Subtotal 551
Existing 579
Project Net Total GHG Emissions (28)
Significance Threshold 10,000
Threshold Exceeded? No
SOURCE: Appendix A, of this Draft IS/MND. ESA 2022.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant Impact. A significant impact would occur if the Project would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment by conflicting with applicable regulatory plans and policies to reduce GHG emissions as discussed within CARB’s Climate Change Scoping Plan and City’s Energy Action Plan.

The CARB Scoping Plan Update focused on establishing a greenhouse gas reduction target of 40 percent below 1990 levels by 2030. The Project would construct a Public Storage facility and replace an electronics manufacturing building. As shown in Table VIII-1, the Project would result in fewer GHG emissions compared to the existing use and would be well below the 10,000 MTCO2e per year threshold. The Project would result in a minimal water demand for two single occupancy restrooms, a janitor’s closet, the sink included in the employee break room, fire sprinklers, and the drought tolerant landscaping. All landscape areas would be irrigated with an automatic smart irrigation control system with a dedicated water meter. Energy demand from the Project would result in less GHG emissions compared to the existing use (Appendix A, of this Draft IS/MND). Because the CARB Scoping Plan requires a suite of strategies across multiple sectors to achieve the GHG reduction targets, the Project would be consistent with the CARB Scoping Plan for water efficiency and energy use.

The City’s Energy Action Plan Update aims to reduce greenhouse gas emissions consistent with the State’s emission reduction targets for 2020 and 2030. The City’s strategy to achieve these goals is structured around four key strategy topics: electricity, natural gas, and water efficiency; municipal operations; employee & department engagement; and partnership and regional

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-50 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 engagement. These strategies will reduce energy usage at the City’s municipal facilities, which will in turn decrease GHG emissions in the City (Covina, 2019). As stated above, the Project would result in minimal water demand for the two single occupancy restrooms, the janitor’s closet, the sink included in the employee break room, fire sprinklers, and the drought tolerant landscaping. All landscape areas would be irrigated with an automatic smart irrigation control system with a dedicated water meter. Additionally, the Project would decrease the demand for natural gas resources because the Project would not use natural gas or be connected to the natural gas system. As the Project would be a less energy intensive use than the existing electronics manufacturing building, the energy demand for the Project would result in less GHG emissions compared to the existing conditions (Appendix A, of this Draft IS/MND). Therefore, the Project would be consistent with the City’s Energy Action Plan Update for water efficiency and energy use.

Overall, as the Project would be consistent with CARB’s Climate Change Scoping Plan and City’s Energy Action Plan Update, the Project would not conflict with an applicable plan, policy, or regulation to reduce GHG emissions. As such, impacts would be considered less than significant. No mitigation is required.

References
CARB, 2008. California Air Resources Board (CARB), 2008. Climate Change Scoping Plan.

December 2008. Available:
https://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf, accessed April 2017.

CARB, 2017. The 2017 Climate Change Scoping Plan Update – The Proposed Strategy for Achieving California’s 2030 Greenhouse Gas Target. January 2017. Available:
https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf, accessed April 2017.

CARB, 2021. California Greenhouse Gas Emissions for 2000-2019. https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-

19.pdf. Accessed August 2021.

Covina, 2019. City of Covina 2019 Energy Action Plan Update. Available:
https://covinaca.gov/sites/default/files/fileattachments/public_works/page/584/eap_- _final.pdf, accessed November 2020.

Intergovernmental Panel on Climate Change, Sixth Assessment Report, Summary for Policy Makers, (2021).

IPCC, 2001. Intergovernmental Panel on Climate Change (IPCC), 2001. Climate Change 2001:

Working Group I: The Scientific Basis. Available:
http://www.ipcc.ch/ipccreports/tar/wg1/index.php?idp=0, accessed April 2017.

SCAQMD, 2008. South Coast Air Quality Management District (SCAQMD). 2008. Draft Guidance Document—Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-51 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 SCAQMD, 2014a. Final Mitigated Negative Declaration for Toxic Air Contaminant Reduction for Compliance with SCAQMD Rules 1420.1 and 1402 at the Exide Technologies Facility in Vernon, CA. State Clearinghouse No. 2014101040, December.

SCAQMD, 2014b. Final Negative Declaration for Phillips 99 Los Angeles Refinery Carson Plant—Crude Oil Storage Capacity Project. State Clearinghouse No. 2013091029, December.

SCAQMD, 2014c. Final Negative Declaration for Ultramar Inc. Wilmington Refinery Cogeneration Project. State Clearinghouse No. 2012041014, October.

SCAQMD, 2015. Final Environmental Impact Report for the Breitburn Santa Fe Springs Blocks 400/700 Upgrade Project. State Clearinghouse No. 2014121014, August.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-52 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Hazards and Hazardous Materials
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IX. HAZARDS AND HAZARDOUS MATERIALS —
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☒ ☐
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
☐ ☐ ☒ ☐
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
☐ ☐ ☒ ☐
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
☐ ☒ ☐ ☐
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project result in a safety hazard or
excessive noise for people residing or working in the
project area?
☐ ☐ ☐ ☒
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☒ ☐
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
☐ ☐ ☒ ☐
Discussion
The following analysis is based, in part, on the Phase I Environmental Site Assessment, conducted on CA21222, 1330 East Cypress Street, Covina, California (Phase I) (Apex, 2021), located in Appendix E, of this Draft IS/MND.

Would the Project:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant Impact (a-b).

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-53 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Construction
During the construction of the Project, construction equipment and materials would include fuels, oils and lubricants, solvents and cleaners, cements and adhesives, paints and thinners, degreasers, cement and concrete, and asphalt mixtures, which are all commonly used in construction. Routine uses of any of these substances could pose a hazard to people or the environment and would be considered potentially significant unless mitigated.

Construction activities would be required to comply with numerous hazardous materials regulations designed to ensure that hazardous materials are transported, used, stored, and disposed of in a safe manner to protect worker safety, and to reduce the potential for a release of construction-related fuels or other hazardous materials into the environment, including stormwater and downstream receiving water bodies. The Project Contractor(s) would be required to prepare and implement Hazardous Materials Business Plan (HMBP) that would require that hazardous materials used for construction would be used properly and stored in appropriate containers with secondary containment to contain a potential release. In the County, HMBPs are submitted to the local Certified Unified Program Agency (CUPA), which in this case would be the Los Angeles County Fire Department Health Hazardous Materials Divisions (LACFD HHMD), for their review for compliance with hazardous materials regulations. The California Fire Code (CFC) would also require measures for the safe storage and handling of hazardous materials, which are included in the CUPA review of HMBPs.

The Project Contractor(s) would be required to prepare a SWPPP for construction activities according to the NPDES General Construction Permit requirements. The SWPPP would list the hazardous materials (including petroleum products) proposed for use during construction; describe spill prevention measures, equipment inspections, equipment and fuel storage; protocols for responding immediately to spills; and describe BMPs for controlling site runoff. The SWPPP would be submitted to the Los Angeles Regional Water Quality Control Board (LARWQCB), which would review both the SWPPP and the required inspection reports for compliance with the Construction General Permit.

In addition, the transportation of hazardous materials would be regulated by the U.S. Department of Transportation (USDOT), Caltrans, and the California Highway Patrol (CHP). Together, federal and state agencies determine driver-training requirements, load labeling procedures, and container specifications designed to minimize the risk of accidental release. In the event of a spill that releases hazardous materials at the Project Site, a coordinated response would occur at the federal, State, and local levels. The LACFD HHMD is the local hazardous materials response team. In the event of a hazardous materials spill, the LACFD and Covina Police Department (CPD) would be simultaneously notified and sent to the scene to respond and assess the situation.

Finally, demolition of the Project would include removal of 55,321 SF of the existing 2-story commercial building and the existing pavement and base materials in the parking lot. The existing building may include hazardous building materials, such as asbestos-containing material (ACM), lead-based paint (LBP), Polychlorinated byphenyls (PCBs), mercury, and Freon. If improperly managed, the demolition activities could result in exposures to construction workers, the public, and the environment.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-54 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Numerous existing regulations require that demolition and renovation activities that may disturb or require the removal of materials that consist of, contain, or are coated with ACM, LBP, PCBs, mercury, Freon, and other hazardous materials must be inspected and/or tested for the presence of hazardous materials. If present, the hazardous materials must be managed and disposed of in accordance with applicable laws and regulations. Compliance with existing regulations is a condition of demolition and construction permits.

In the case of ACM and LBP, all work must be conducted by a State-certified professional, which would ensure compliance with all applicable regulations. If ACM and/or LBP are determined to exist onsite, a site-specific hazard control plan must be prepared detailing removal methods and specific instructions for providing protective clothing and equipment for abatement personnel. A State-certified LBP and/or an ACM removal contractor would be retained to conduct the appropriate abatement measures as required by the plan. Wastes from abatement and demolition activities would be disposed of at a landfill permitted to accept such waste. Once all abatement measures have been implemented, the Project Contractor(s) would conduct a clearance examination and provide written documentation to the appropriate regulatory agency documenting that testing and abatement have been completed in accordance with all federal, State, and local laws and regulations.

Equipment and materials with PCBs, mercury, and Freon, are managed thru the Universal Waste Rule. In the case of PCBs, electrical transformers and older fluorescent light ballasts not previously tested and verified to not contain PCBs must be tested. If PCBs are detected above action levels, the materials must be disposed of at a licensed facility permitted to accept the materials. In the case of mercury in fluorescent light tubes and switches, the identification, removal, and disposal of the materials must be removed without breakage and disposed of at a licensed facility permitted to accept the materials. In the case of Freon or other refrigerants, the refrigerants must be directed to licensed recycling and reuse facilities permitted to handle the refrigerants.

Compliance with the numerous laws and regulations discussed above that govern the transportation, use, handling, and disposal of hazardous building materials would limit the potential for impacts due to the transportation, use, handling, disposal, or accidental release of hazardous building materials. As such, impacts would be less than significant in this regard. No mitigation is required.

Operation
Lessees of the mini-warehouse units enter into an agreement with Public Storage that specifies hazardous materials are not permitted to be stored on the premises and that the premisesshall not be used in any manner that will constitute a hazard, waste, nuisance or unreasonable annoyance to others.

The types and amounts of hazardous materials that would be used in connection with operation of the Project would include typical housekeeping and janitorial products (e.g., cleaning solutions, solvents, pesticides for landscaping, painting supplies, and petroleum products). The routine use and disposal of normal household products is not considered to create a significant hazard to the

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-55 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 public or the environment. These substances are not stored or utilized in high concentrations and would be handled in accordance with their proper use and all applicable federal, State, and local regulations.

Compliance with the numerous laws and regulations discussed above that govern the transportation, use, handling, and disposal of hazardous materials would limit the potential for impacts due to the transportation, use, handling, disposal, or accidental release of hazardous materials. As such, impacts would be less than significant in this regard. No mitigation is required.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less Than Significant Impact. There is one school within .25 miles of the Project Site; the Charter Oak High School (located at 1430 East Covina Boulevard) is immediately adjacent to the Project Site, across East Cypress Street to the northwest.

Construction activities associated with the Project would include the handling of hazardous materials, as discussed above. The route to the construction site would pass by the Charter Oak High School. The accidental release or spill of hazardous materials transported near the Charter Oak High School could expose school children, school staff, and workers to hazardous materials.

Further, the prolonged use of construction equipment could produce hazardous emissions as the construction site is near the Charter Oak High School. Although the Project Site is within .25 miles of the school, as discussed above, there are numerous regulations covering the transportation, use, storage, and disposal of hazardous materials during construction activities.

The required compliance with these regulations would ensure that nearby schools would not be exposed to hazardous materials, and the impacts would be less than significant. No mitigation is required.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less than Significant Impact with Mitigation Incorporated. A review of the State Water Resources Control Board (SWRCB) GeoTracker online database and the Department of Toxic Substances Control (DTSC) EnviroStor online database revealed that the Project Site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (SWRCB, 2022; DTSC, 2022). Apex Companies (Apex) performed a Phase I Environmental Site Assessment (ESA) at the Project Site in June 2021, and while the Project Site itself is not included on a list of hazardous materials sites, the west adjoining 76 Products Station #5012/Union Oil Service Station/Covina Auto Repair & Service (located at 856 Glendora Avenue) is the site of a former Leaking Underground Storage Tank (LUST). The site formerly operated as a gas station with two gasoline and one waste oil USTs with an industrial waste permit. All USTs were installed in 1963 and were of single-walled carbon steel construction. A release was discovered during the removal of the USTs on March 16, 1990 and affected soil only.

The incident received closure as of June 18, 1991. No further information was identified

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-56 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 regarding the UST incident (APEX, 2021). As this site has been remediated and closed, it is considered a historic recognized environmental condition.

The Phase I ESA further determined that there are three recognized environmental conditions at the Project Site. One such condition includes the historic use of chlorinated solvents between the late 1970s and early 1990s (Apex, 2021). Additionally, Speedy Drycleaners (located on the west adjoining property) could have and/or are currently utilizing chlorinated solvents onsite (Apex, 2021). Lastly, a Tier 1 Vapor Encroachment Screen (in accordance with ASTM Standard E2600- 15) was conducted by Apex due to the on and off-site conditions; based on the screening, Apex determined that a vapor encroachment condition does exist at the Project Site (Apex, 2021).

Construction
The construction activities within the Project Site would include the excavation of soil or removal of groundwater (dewatering). Construction of the Project involve the excavation of soils or extraction of groundwater from a site with existing contamination, and the contaminated materials are improperly handled, it could expose construction workers, the public, and the environment to hazardous materials. This would be a potentially significant impact.

As discussed above, there are numerous regulations covering the transportation, use, storage, and disposal of hazardous materials during construction activities. The required compliance with these regulations would reduce the exposure to hazardous materials. However, in order to ensure Project excavation would not encounter existing contamination and inadvertently expose construction personnel, the public, or the environment, the Project Applicant shall implement Mitigation Measures HAZ-1 through HAZ-3, as described below.

Mitigation Measures:

HAZ-1: Soil Vapor Sampling: Prior to start of ground-disturbing activities, including grading, trenching, or excavation, or structure demolition, soil vapor sampling shall be performed to determine the extent of the vapor encroachment condition that exists at the Project Site. The results of the soil vapor sampling shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction.

HAZ-2: Health and Safety Plan: Prior to the start of ground-disturbing activities, including grading, trenching, or excavation, or structure demolition, the Project Applicant shall require that the Project Contractor(s) retain a qualified professional to prepare a sitespecific health and safety plan (HASP) in accordance with federal Occupational Safety and Health Administration regulations (29 CFR 1910.120) and California Occupational Safety and Health Administration regulations (8 CCR Section 5192).

The HASP shall be implemented by the Project Contractor(s) to protect construction workers, the public, and the environment during all ground-disturbing and structure demolition activities. The HASP shall include designation of a site health and safety officer, a summary of the anticipated risks, a description of personal protective equipment

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-57 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 and decontamination procedures, and procedures to follow if evidence of potential soil or groundwater contamination is encountered.

HAZ-3: Soil Management Plan: In support of the HASP described in HAZ-2, the Project Applicant shall require that the Project Contractor(s) develop and implement a Soil Management Plan (SMP) for the management of potentially contaminated soil before any ground-disturbing activity. The SGMP shall describe the hazardous materials that may be encountered, the roles and responsibilities of on-site workers and supervisors, training for site workers focused on the recognition of and response to encountering hazardous materials, and protocols for the materials (soil) testing, handling, removing, transporting, and disposing of all excavated materials in a safe, appropriate, and lawful manner.

Operation
Once constructed, contaminated materials associated with implementation of PMAs would have been removed and/or treated, people and the environment would not be exposed to hazardous materials, and this impact would be less than significant. No mitigation is required. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project result in a safety hazard or excessive noise for people residing or working in the Project area?
No Impact. There are no airports within two miles of the Project Site. As such, the Project Site is not within any delineated safety or noise hazard zones. The Project would not result in a safety hazard or excessive noise. No impact would occur in this regard. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact.

Construction
The Hazard Mitigation Plan for Covina does not specifically delineate evacuation routes to be utilized during an emergency (Covina, 2019).

The Project Site is located in an established urban area that is well served by the surrounding roadway network. While it is expected that the majority of construction activities associated with the Project would be mostly confined on-site, construction activities may involve temporary lane closures along roadways adjacent to the Project Site while curbside improvements are being made (e.g., sidewalks, driveways, underground facilities and infrastructure). However, through-access for drivers, including emergency personnel, along all roadways will still be provided. In these instances, the Project Contractor(s) would implement traffic control measures (e.g., construction flagmen, signage, etc.) consistent with required City encroachment permit(s) to maintain flow and access. Furthermore, in accordance with the City’s Public Works Department, the Project

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-58 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Contractor(s) would develop a Construction Management Plan, subject to City review and approval, that includes designation of a haul routes to ensure that adequate emergency access is maintained during construction. Therefore, Project construction is not expected to impair or interfere with an established emergency response or evacuation plan, and the construction impacts would be less than significant. No mitigation is required.

Operation
With respect to operation of the Project, the LACFD, which provides fire and paramedic services for the City, and other relevant City departments would review the final design and on-site circulation of the Project, to ensure that there is no interference with an emergency response or evacuation plan. Therefore, operation of the Project is not expected to interfere or impair an emergency response or evacuation plan, and the operational impact would be less than significant. No mitigation is required.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Less Than Significant Impact. The California Department of Forestry and Fire Protection (CAL FIRE) Fire and Resource Assessment Program (FRAP) published Fire Hazard Severity Zone (FHSZ) maps. According to the map of Very Fire Hazard Severity Zones (VHFHSZ) in Local Responsibility Area (LRA) for the City, the Project Site is not within a VHFHSZ (CAL FIRE, 2011).

The Project would require construction during development, which, if unregulated, could lead to fire ignition. Nevertheless, all construction activities would be required to comply with all applicable fire protection and prevention regulations specified in the CFC, Hazardous Materials Transportation regulations, and Cal/OSHA regulations. These requirements include various measures such as accessibility of firefighting equipment, proper storage of combustible liquids, no smoking in service and refueling areas, and worker training for firefighter extinguisher use.

Compliance with all applicable laws and regulations would further minimize the potential for construction activities to cause a wildland fire.

In addition, facilities that use or store hazardous and flammable materials would be required to comply with all applicable fire codes and fire protection requirements established by the CFC, Hazardous Materials Transportation regulations, and Cal/OSHA requirements. As such, operation of the Project would not substantially increase the risk of wildland fires within the Project Site.

For these reasons, the Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires, and thus this impact is considered less than significant. No mitigation is required.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-59 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 References
Apex Companies, LLC (Apex), 2021. Phase I Environmental Site Assessment (conducted on CA21222, 1330 East Cypress Street, Covina, California. Apex Project No. 25021- 021079.00. June 9, 2021.

California Department of Forestry and Fire Protection (CAL FIRE), 2011. Very High Fire Hazard Severity Zones in LRA for the City of Covina. Map. Scale 1:12,000.

Covina, 2019. City of Covina, Hazard Mitigation Plan, November 26, 2019.

DTSC, 2022. Department of Toxic Substances Control, 2022. EnviroStor online database, records for sites in proximity to 1330 Cypress Street, Covina, CA.

SWRCB, 2022. State Water Resources Control Board, 2022. GeoTracker online database, records for sites in proximity to 1330 Cypress Street, Covina, CA.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-60 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 Hydrology and Water Quality
Issues (and Supporting Information Sources):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
X. HYDROLOGY AND WATER QUALITY —
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
☐ ☐ ☒ ☐
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
☐ ☐ ☒ ☐
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on- or offsite; ☐ ☐ ☒ ☐
ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or offsite;
☐ ☐ ☐ ☒
iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted runoff;
or
☐ ☐ ☐ ☒
iv) impede or redirect flood flows? ☐ ☐ ☒ ☐
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
☐ ☐ ☒ ☐
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
☐ ☐ ☒ ☐
Discussion
The Project Site is located in the San Gabriel River Watershed in the eastern portion of LARWQCB Water Quality Control Plan [Basin Plan] 2014. The Project Site is located in a highly urbanized area of the City predominately developed with residential, commercial, and school uses. The Project area is also located within the Wingate Park Regional Enhanced Watershed Management Plan (EWMP) upstream area, located approximately 0.10 miles southwest of the Project Site. As such, potential runoff could be collected downstream, treated and infiltrated, or released to Charter Oak Creek at Wingate Park. The Project Site is currently developed with an approximately 55,321 SF 2-story commercial building occupied by “TT Electronics Power Solutions” which is used for electronics manufacturing. The remainder of the Project Site consists of asphalt-paved surface parking lots and ornamental landscaped areas. A segment of Charter Oak Creek, consisting of a barren flood control channel conveying nuisance flow and storm runoff, is located approximately 680 feet to the south of the Project Site with residential housing occupying the area between the Project Site and the Creek.

3. Initial Study/Environmental Checklist
City of Covina Public Storage Project 3-61 ESA / D202100759.02 Initial Study/Mitigated Negative Declaration September 2022 The CWA authorizes the USEPA to regulate point sources that discharge pollutants into the waters of the United States under the NPDES permitting program. The EPA delegates the responsibility for the protection of surface water and groundwater quality to the State Water Resources Control Board and Regional Water Quality Control Boards. The Project is located within the jurisdiction of the LARWQCB which administer and enforces the Basin Plan policies and other water quality programs within the coastal watersheds of Los Angeles County. The City is currently covered by the following NPDES permits (Covina, 2022):
• Order No. R4-2021-0105 NPDES Permit No. CAS004004 Waste Discharge Requirements and NPDES Permit for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles and Ventura Counties. • Order No. 2014-0057-DWQ: NPDES General Permit No. CAS000001 for Storm Water Discharges Associated with Industrial Activities.
• Order No. 2009-0009-DWQ (As amended by 2010-0014-DWQ and 2012-006-DWQ):

NPDES General Permit No. CAS000002 for Storm Water Discharges Associated with Construction and Land Disturbance Activities.

Would the Project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less Than Significant Impact. The Project is the redevelopment of an existing industrial electronics manufacturing facility. The Project Site comprises of approximately 2.62 acres; approximately 94.8 percent of which are impervious surfaces. Construction of the Project could increase stormwater pollutants that could impair surface and groundwater through typical construction activities such as demolition, site preparation, grading and excavation, paving and landscaping. An increase in pollutants such as trash, fertilizers, cleaning agents, sediments, and spilled or leaked petroleum products on surface parking lots could violate water quality standards and waste discharge requirements set by the LARWQCB.

The Project would be constructed to match the existing drainage conditions (DRC Engineering, 2021). The City would design and construct any new facility upgrades to capture and convey stormwater runoff and pollution in accordance with the existing LA County NPDES permits.

Consistent with these requirements, a SWPPP would be prepared that incorporates BMPs to control water erosion during the construction and operation of the Project.

Therefore, adherence to applicable local, state and federal water quality control plans and permits would reduce impacts to surface and groundwater quality. As such, impacts would be less than significant. No mitigation is required.