State Water Resources Control Board and Regional Water Quality Control Board Orders In California, the SWRCB and RWQCBs administer the NPDES permitting programs and are responsible for developing waste discharge requirements. Each local RWQCB is responsible for developing waste discharge requirements specific to its jurisdiction. General waste discharge requirements that may apply the Project include the SWRCB Construction General Permit and the regional MS4 Permit administered by the LARWQCB.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-2 December 2023
Exhibit D
NPDES Construction General Permit
Section 4.8
Hydrology and Water Quality
SWRCB Order No. 2009-0009-DWQ NPDES General Permit No. CAS000002 Waste Discharge Requirements for Discharges of Stormwater Runoff Associated with Construction Activity (Construction General Permit), was adopted on September 2, 2009. The permit was previously amended by Order No. 2010-0014-DWQ and then again by Order No. 2012-0006-DWQ. The Construction General Permit has been extended while a new order is in the process of being reviewed and adopted.
During the construction phase, any development project that is one acre or greater in size, or that is less than one acre in size but is part of a larger common plan of development, is subject to the requirements of the Construction General Permit, or a future SWRCB Order re -issuing the Construction General Permit. For coverage by the Construction General Permit, a project owner is required to submit to the SWRCB a Notice of Intent to comply with the Construction General Permit, and develop and implement a Stormwater Pollution Prevention Plan (SWPPP) describing Best Management Practices (BMPs) to be used during and after construction to prevent the discharge of sediment and other pollutants in stormwater runoff from the project.
County Waste Discharge Requirements
The Los Angeles County Flood Control District, the County of Los Angeles, and the City of Downey along with 83 other incorporated cities therein (Permittees) discharge pollutants from their municipal separate storm sewer (drain) systems (MS4s). Stormwater and non-stormwater enter and are conveyed through the MS4 and discharged to Los Angeles Region surface water bodies. These discharges are regulated under countywide waste discharge requirements contained in the NPDES Permit. The MS4 Permit Order provides the revised waste discharge requirements for MS4 discharges within the Los Angeles County watersheds. The MS4 Permit Order (Order R4-2012-0175), which became effective December 28, 2012, supersedes Order No. 01-182. The City also uses its Municipal Code to require that projects comply with NPDES MS4 Permit water quality requirements.
4.8.3.3 Local
Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties Each RWQCB must formulate and adopt a Water Quality Control Plan (Basin Plan) for its region in conformance with the policies set forth in the Porter -Cologne Act and established by the SWRCB in its State Water Policy. The Los Angeles Region covered by the Basin Plan encompasses all coastal watersheds and drainages flowing to the Pacific Ocean between Rincon Point (on the coast of western Ventura County) and the eastern Los Angeles County line, as well as the drainages of five coastal islands (Anacapa, San Nicolas, Santa Barbara, Santa Catalina, and San Clemente), and all coastal waters within three nautical miles off the continental and island coastlines.
The Basin Plan establishes beneficial uses for surface and groundwater in the region, and sets forth narrative and numeric water quality standards to protect those beneficial uses. Basin plans are updated every three years and provide the basis of determining waste discharge requirements, taking enforcement actions, and evaluating clean water grant proposals.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-3 December 2023
Exhibit D
City of Downey Municipal Code
Section 4.8
Hydrology and Water Quality
Article V, Sanitation, in the Downey Municipal Code contains Chapter 7, Storm Water and Urban Runoff Pollution and Conveyance Controls. This chapter outlines multiple requirements related to water quality.
Prohibited pollutants to the MS4 are addressed in Municipal Code §5702. These include pollutants such as sediments, food waste, medical waste, chemical wastes, and other pollutants identified in §5702 or by the LARWQCB. Municipal Code §5705 addresses BMP requirements for urban runoff reduction. The owner, occupant, or other person in charge of daily operation or maintenance of each parcel in the City is required to comply with BMP requirements in order to prevent or reduce the discharge of pollutants to achieve water quality standards/receiving water limitations. Municipal Code §5706 requires submittal of an Urban Runoff Mitigation Plan and §5708 requires submittal of hydrology studies for new development projects. The specifically required source controls are outlined in §5707.
Other code sections within Article V, Chapter 7 include general regulations such as conformance with NPDES, enforcement mechanisms, and establishment of inspection fees.
City of Downey General Plan
The City's General Plan is a long-range planning document that guides community development and growth throughout the City. The City adopted the General Plan 2025 in 2005. Goals and policies applicable to the proposed Project are as follows:
Conservation Element
• Goal 4.2: Prevent the contamination of groundwater.
o Policy 4.2.1: Monitor and improve groundwater quality. ■ Program 4.2.1.4: Discourage business practices and land use classes that contribute to soil contamination that degrade groundwater quality. • Goal 4.3: Reduce the contaminant level at beaches and oceans. o Policy 4.3.1: Reduce the contaminant level of stormwater and urban runoff generated within Downey.
■ Program 4.3.1.1: Provide treatment of runoff generated by properties on -site before release into the storm drain system.
■ Program 4.3.1.2: Discourage activities that generate pollutants on parking lots, and public streets.
Program 4.3.1.4: Encourage proper storage and handling of construction materials to avoid the contact of pollutants with storm water runoff during construction.
Safety Element
• Goal 5.6: Minimize potential adverse impacts from flooding. o Policy 5.6.1: Protect life and property from flooding hazards.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-4 December 2023
Exhibit D
Section 4.8
Hydrology and Water Quality
o Policy 5.6.2: Minimize the potential for flooding due to stormwater generation.
Program 5.6.2.1: Minimize increases in the amount of stormwater generated by existing and proposed land uses.
■ Program 5.6.2.2: Maximize the amount of pervious surfaces on properties to absorb stormwater and decrease runoff volumes.
■ Program 5.6.2.3: Preserve existing naturally vegetated areas and encourage re - vegetation and soil restoration where feasible.
4.8.4 Significance Criteria and Thresholds
The significance criteria used to evaluate the Project impacts related to hydrology and water quality are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hydrology and water quality would occur if the Project would:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off -site.
Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off -site.
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional resources of polluted runoff.
iv. Impede or redirect flood flows
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundation. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
Through the analysis in the IS/NOP (see Appendix A of this EIR), it was determined that the proposed Project would result in less than significant impacts associated with groundwater supply (Threshold b), flood flows (Threshold c.iv), and inundation hazards (Threshold d). Accordingly, these issues are not analyzed further in the EIR.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-5 December 2023
Exhibit D
Section 4.8
Hydrology and Water Quality
4.8.5 Methodology and Assumptions
The proposed Project was evaluated against the above significance criteria/thresholds, as the basis for determining the level of significance concerning hydrology and water quality impacts. Information regarding pre- and post -Project hydrology and water quality has been reviewed and summarized from several public sources, including City, County and state documents, and the Project's LID Report (Appendix 1). This EIR acknowledges that issues that would be addressed by the codes and regulations would be subject to those in place at the time of permitting.
4.8.6 Impacts and Mitigation Measures
Threshold 4.8-a: Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less than Significant Impact. Construction activities such as clearing and grading would result in the exposure of soils, which creates a greater potential for erosion compared to the existing, developed conditions. The exposed soils could result in water quality impacts if runoff from the Project site is not properly controlled. Other construction -related pollutants, such as fuels and paints, would be stored in accordance with applicable regulations that would prevent these materials from entering runoff and degrading water quality.
Development of project sites exceeding one acre are required by the LARWQCB and City to obtain coverage under the NPDES Construction General Permit. The Construction General Permit requires the development of a project -specific SWPPP to list the BMPs that will be implemented to control storm water runoff. These may include the use of silt fences, sandbag barriers, and/or other ground covers.
The Project proponent would develop and submit a project -specific SWPPP to comply with the requirements of the NPDES Construction General Permit. This would also bring the Project into compliance with Municipal Code §5704. Therefore, the Project would reduce potential impacts during construction to less than significant levels with implementation of BMPs.
During operation of the Project, there would be potential for typical urban pollutants such as fuels, pesticides, and trash to enter Project runoff. To reduce the potential for these pollutants to enter groundwater or surface waters, the Project would implement measures in accordance with local and regional water quality requirements. Based on the contaminated soils on the Project site, infiltration is not feasible for this Project. The Project's LID Plan further details the proposed water quality control measures (Appendix 1). The Project would be split into two drainage management areas (DMAs), which would both collect surface runoff via a series of drop inlets. DMA 1 would encompass 14.5 acres in the western portion of the Project site and DMA 2 would encompass 14.66 acres in the eastern portion.
Within each DMA, drop inlets would route runoff to an underground detention vault prior to entering a WetlancIMOD treatment system. The WetlancIMOD treatment system would be sized for a 96-hour drawdown time and consists of a manufactured planter box with engineered soil, media, planting, and an underdrain. The system was sized to accommodate an 851" percentile storm. After treatment, flows would be pumped off -site to spill to grade at the driveway, which would mimic the existing drainage pattern. Implementation of these Project components would result in Project compliance with the MS4 permit conditions and prevent the Project from degrading surface or ground water quality. Impacts during Project operation would be less than significant.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-6 December 2023
Exhibit D
Mitigation Measures
No mitigation is required.
Section 4.8
Hydrology and Water Quality
Threshold 4.8-c: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on -or off -site; substantially increase the rate or amount of surface runoff in a manner which could result in flooding on- or off - site; or create or contribute runoff water which could exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Less than Significant Impact. As discussed further above under Threshold 4.8-a, the Project would be required to prepare a SWPPP prior to construction activity on the Project site. Implementation of BMPs as identified in the SWPPP would reduce potential impacts related to erosion and siltation during construction to less than significant levels.
During Project operation there would be limited potential for erosion due to the installation of impervious surfaces. Runoff from impervious surfaces would be treated by the WetlandlVIOD systems for pollutants and solids before outletting to the storm drain system, which would prevent runoff from resulting in siltation. The Project would not result in substantial erosion or siltation on- or off- site and impacts would be less than significant.
With implementation of the Project, impervious areas would decrease from 28.73 acres to 27.6 acres, for a total decrease of 1.13 acres. This would equate to impervious surfaces covering 94.5 percent of the site under Project conditions. Based on the decrease in impervious surface, slightly less surface runoff would be generated under Project conditions. As described above, the Project would include a treatment system for runoff that would pump treated flows to the driveway. The outflow of Project runoff to the driveway would be similar to existing conditions and would not represent a substantial change in the drainage pattern for the area. The installation of the on -site stormwater system would alter on -site drainage patterns compared to existing conditions; however, these changes would not result in changes to release points or other off -site changes that would result in flooding either on- or off- site. Impacts would be less than significant.
As the amount of runoff would decrease compared to existing conditions, the Project would not result in runoff which would exceed the capacity of the existing stormwater system. The release of on -site runoff to the off -site stormwater system would remain the same as the existing Project site. The treatment system outlined in the LID Plan would collect on -site runoff and treat it prior to releasing flows to the stormwater system. Therefore, runoff from the Project would not provide substantial sources of polluted runoff and impacts would be less than significant.
Mitigation Measures
No mitigation is required.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-7 December 2023
Exhibit D
Section 4.8
Hydrology and Water Quality
Threshold 4.8-e: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Less than Significant Impact. The Project site is located within the Central Groundwater Basin, which is very low priority under the Sustainable Groundwater Management Act and is not required to create a Groundwater Sustainability Plan (DWR 2020). Therefore, the Project would not conflict with a sustainable groundwater management plan.
The Basin Plan is the water quality control plan applicable to the Project. As discussed under the previous thresholds, the Project would be required to comply with the requirements of the Basin Plan through permitting requirements for construction activities such as BMP implementation and SWPPP preparation. With implementation of the design elements in the LID Plan and conformance with NPDES and City requirements during operation, the Project would not conflict with the Basin Plan and impacts would be less than significant.
Mitigation Measures
No mitigation is required.
4.8.7 Cumulative Impacts
The cumulative impact analysis considers construction and operation of the proposed Project in conjunction with other development projects in the vicinity of the Project site and resulting from full buildout of the City's General Plan and the general plans of local jurisdictions that are located within the San Gabriel River watershed. Cumulative impacts associated with hydrology and water quality typically occur as a result of development within a watershed that increases impervious surfaces and the presence of potential pollutants. Since the Project would redevelop an existing industrial land use and result in a decrease of impervious areas on the Project site, it would not contribute to increases in impervious surfaces typically associated with urban development. Runoff from the Project site would follow patterns of the existing condition and would not result in impairment of the region's stormwater system. The Project would not substantially increase the presence of pollutants within the watershed and would treat runoff in accordance with the LID Plan and regulatory requirements. The Project is not anticipated to cause a substantial increase in runoff or pollutants within the watershed and would have less than significant impacts related to hydrology and water quality. Therefore, cumulative impacts related to hydrology and water quality would be less than significant and not cumulatively considerable.
4.8.8 Significant Unavoidable Impacts
No significant unavoidable impacts related to hydrology and water quality have been identified.
4.8.9 References
California Department of Water Resources (DWR). 2020. Statewide Map of Current SGMA Prioritization.
April 28.
California State Water Resources Control Board (SWRCB). 2022. 2020-2022 Integrated Report for Clean Water Act 303(d) List and 305(b) Report. March 23.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-8 December 2023
Exhibit D
Section 4.8
Hydrology and Water Quality
Kimley-Horn & Associates. 2021. Low Impact Development Plan. June.
Los Angeles Regional Water Quality Control Board (LARWQCB). 2014. Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. September 11.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.8-9 December 2023
Exhibit D
Section 4.8
Hydrology and Water Quality
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Exhibit D
4.9.1 Introduction
Section 4.9
Land Use and Planning
This section of the EIR analyzes the potential land use and planning effects that would result from implementation of the proposed Project. This section evaluates consistency with the City of Downey Vision 2025 General Plan (DGP), Downey Municipal Code (DMC), and Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTC/SCS).
4.9.2 Environmental Setting
4.9.2.1 Existing Project Site and Surrounding Land Uses The Project site is completely developed with existing industrial buildings. Figure 2-3, Existing Land Uses, in Chapter 2, Project Description, of this Draft EIR, illustrates the existing land uses currently occupying the Project site. The existing industrial buildings and related improvements were likely developed in the mid-1970s. The Project site currently has four driveway entrances off Stewart and Gray Road and three driveway entrances off Hall Road that lead to private internal roads, which provide vehicular access around the separate buildings. These internal roads and paved areas provide parking for employees, parking for trailers and containers, recycling equipment and storage of heavy operation equipment.
The Project site is surrounded by the following land uses:
• North: Hall Road and Union Pacific Railroad corridor, beyond which are commercial and industrial uses.
• South: Stewart and Gray Road, beyond which are industrial and public utility uses; multi -family and single-family residential uses are located further to the southwest. • East: Adjacent commercial and industrial uses, Woodruff Avenue, additional commercial and industrial uses further east; multi -family residential uses are located further to the northeast beyond the rail corridor.
• West: Industrial uses, beyond which are single-family and multi -family residential uses.
4.9.2.2 Existing General Plan Land Use
Figure 2-4, Project Site Land Use Designations, in Chapter 2, Project Description, of this EIR, depicts land use designations at the Project site and surrounding area. The Project site is designated General Manufacturing (GM), which is intended for manufacturing, wholesaling, and other industrial land uses.
Since uses consistent with the GM designation have potential for creating traffic, noise, odor, vibration and other impacts, areas designated Manufacturing should be separated from other land uses by a major natural or physical barrier and screen. The intensity of the GM designation should not exceed a floor area ratio of 0.6:1.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-1 December 2023
Exhibit D
4.9.2.3 Existing Zoning
Section 4.9
Land Use and Planning
Figure 2-5, Project Site Zoning Designations, in Chapter 2, Project Description, of this EIR, depicts the zoning designations for the Project site and surrounding area. The Project site is zoned M-2 (General Manufacturing Zone), consistent with the current General Plan Land Use designation of GM.
4.9.3 Regulatory Framework
4.9.3.1 State
Sustainable Communities and Climate Protection Act of 2008 The Sustainable Communities Act of 2008 (Senate Bill [SB] 375, Chapter 728, Statutes of 2008) provides a means for achieving greenhouse gas (GHG) emissions goals through the reduction in greenhouse gas emissions of cars and light -duty trucks. SB 375 built on the foundation of the California Global Warming Solutions Act of 2006, also known as Assembly Bill (AB) 32, signed into law by then -Governor Arnold Schwarzenegger. AB 32 focused on reducing GHG emissions in California and requires the California Air Resources Board (CARB) to adopt rules and regulations that would achieve GHG emissions equivalent to statewide levels in 1990 by 2020. SB 375 seeks to coordinate land use decisions made at the local (city and county) level with regional transportation planning. By coordinating these efforts, it is envisioned that vehicle congestion and travel can be reduced resulting in a corresponding reduction in emissions.
SB 375 directed CARB to set regional targets to reduce emissions and regional plans are required to identify in their regional transportation plan/sustainable communities' strategy how they will meet these targets.
SB 375 has three major components:
• Using the regional transportation planning process to achieve reductions in emissions consistent with AB 32's goals.
Offering California Environmental Quality Act (CEQA) incentives to encourage projects that are consistent with a regional plan that achieves emissions reductions. • Coordinating the Regional Housing Needs Allocation Assessment (RHNA) process with the regional transportation process while maintaining local authority over land use decisions.
An SCS is a required component of the RTP. The SCS is an emissions reduction strategy for the region which, in combination with transportation policies and programs, strives to reduce emissions and, if feasible, helps meet CARB's targets for the region. An alternative planning strategy (APS) must be prepared if the SCS is unable to reduce emissions and achieve the emissions reduction targets established by CARB. Certain transportation planning and programming activities must be consistent with the SCS; however, SB 375 expressly provides that the SCS does not regulate the use of land, and further provides that local land use plans and policies (e.g., general plan) are not required to be consistent with either the RTP or SCS. CARB set the following reduction targets for SCAG: reduce per capita emissions 8 percent below 2005 levels by 2020 and 13 percent below 2005 levels by 2035.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-2 December 2023
Exhibit D
Section 4.9
Land Use and Planning
4.9.3.2 Regional and Local
Southern California Association of Governments
The Southern California Association of Governments (SCAG) is a council of governments representing Riverside, Orange, Los Angeles, Orange, San Bernardino, and Imperial counties. SCAG is the federally recognized Metropolitan Planning Organization (MPO) for this region. SCAG is a regional planning agency and a forum for addressing regional issues concerning transportation, the economy, community development, and the environment. SCAG is also the regional clearinghouse for projects requiring environmental documentation under federal and state law. In this role, SCAG reviews proposed development and infrastructure projects to analyze their impacts on regional planning programs. As the Southern California region's MPO, SCAG cooperates with the South Coast Air Quality Management District (SCAQMD), California Department of Transportation (Caltrans), and other agencies in preparing regional planning documents.
Connect SoCal: 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy SCAG's Connect SoCal 2020-2045 Regional Comprehensive Plan/Sustainable Communities Strategy (RTP/SCS) provides the long-range vision of the SCAG region. Connect SoCal expands land use and transportation strategies established from previous cycles to increase mobility options and achieve a more sustainable growth pattern. It contains plans and projections for the region's future, from 2020 through the horizon year of 2045. Like other RTP/SCS publications, Connect SoCal provides a policy framework for preparing local plans and handling issues of regional significance, such as land use and housing, open space and biological habitats, water, energy, air quality, solid waste, transportation, security and emergency preparedness, economy, and education. Specifically, Connect SoCal also strives to achieve broader regional objectives, such as the preservation of natural lands, improvement of public health, increased roadway safety, support for the region's vital goods movement industries and more efficient use of resources.
The RTP/SCS advances regional planning by incorporating an integrated approach between SCAG, state and local governments, transportation commissions, resources agencies and conservation groups, the private sector, and the general public.
City of Downey Vision 2025 General Plan
The City of Downey Vision 2025 General Plan (DGP) is a legal document, in the form of a map and accompanying text adopted by the City Council. It serves as a guide to the long-term physical development and growth of the community. In addition, the DGP prepares long-range programs to address further changes in the City. The City's first general plan was adopted in 1963. Downey Vision 2025 is the fourth general plan that was adopted in January 25, 2005. As mandated by state law, cities must update their general plans to ensure all land use decisions are to be consistent with the current zoning regulations and to reflect the needs of the community. The City of Downey General Plan Vision 2025 outlines goals and policies that are applicable to the proposed Project as follows:
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-3 December 2023
iti_ifftw
Section 4.9
Land Use and Planning
Land Use Element
• Goal 1.1. Provide sufficient land areas for uses that serve the needs of residents, visitors, and businesses.
o Policy 1.1.1. Maintain a balance of land uses.
o Policy 1.1.3. Provide an appropriate amount of land area for business and employment. • Goal 1.2. Advance livable community concepts.
o Policy 1.2.1. Promote livable communities concepts that allow added flexibility in addressing land use needs.
Circulation Element
• Goal 2.1. Increase the capacity of the existing street system. o Policy 2.1.2. Promote improvements in the street system through the development process.
• Goal 2.2. Promote the use of alternative modes of travel, other than single -occupant vehicles, to relieve traffic congestion.
o Policy 2.2.1. Promote walking as an attractive alternative to vehicular transportation. o Policy 2.2.2. Promote bicycling as an attractive alternative to vehicular transportation. • Goal 2.3. Reduce adverse impacts from truck traffic.
o Policy 2.3.1. Promote the safe and efficient movement of truck traffic through the City. o Policy 2.3.2. Minimize negative impacts associated with truck traffic. o Policy 2.3.3. Discourage land uses that generating high amounts of truck traffic. • Goal 2.5. Minimize the impacts from the lack of parking. o Policy 2.5.1 Provide for adequate parking supply to meet parking demands.
Conservation Element
• Goal 4.1. Provide an adequate water supply for the needs of residents, workers, and visitors to the City.
o Policy 4.1.1. Promote conservation of water resources. • Goal 4.2. Prevent the contamination of groundwater.
o Policy 4.2.1. Monitor and improve groundwater quality. • Goal 4.3. Reduce the contaminant level at beaches and oceans. o Policy 4.3.1. Reduce the contaminant level of stormwater and urban runoff generated within Downey.
• Goal 4.4. Preserve trees wherever possible.
o Policy 4.4.1. Preserve trees on private and public property.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-4 December 2023
Exhibit D
Section 4.9
Land Use and Planning
• Goal 4.5. Encourage activities that improve air quality. o Policy 4.5.1. Pursue every available means and opportunities to reduce air particulate and pollutants within the city and region.
• Goal 4.6. Conserve energy resources.
o Policy 4.6.1. Promote the conservation of energy by residents and businesses to conserve energy.
• Goal 4. 7. Provide efficient and low-cost solid waste disposal. o Policy 4.7.1. Reduce the amount of solid waste generated within the City.
Safety Element
• Goal 5.2. Protect the health, safety, and welfare of residents, workers, and visitors from the improper use, storage, handling, and disposal of hazardous materials. o Policy 5.2.1. Monitor the generation, storage, and disposal of hazardous materials. • Goal 5.3. Maintain and improve fire protection services. o Policy 5.3.1. Provide adequate response to fire emergencies. • Goal 5.5. Address the potential hazards associated with seismic activity. o Policy 5.5.1. Minimize damage in the event of a major earthquake. • Goal 5.6. Minimize potential adverse impacts from flooding. o Policy 5.6.2. Minimize the potential for flooding due to stormwater generation. • Goal 5. 7. Reduce the likelihood of traffic accidents. o Policy 5. 7.1. Promote traffic safety along streets.
o Policy 5.7.2. Promote the installation of sidewalks and walkways to improve traffic safety.
Noise Element
• Goal 6.1. Protect persons from exposure to excessive noise. o Policy 6.1.1. Minimize noise impacts onto noise -sensitive uses. • Goal 6.2. Protect persons from exposure to excessive noise generated by various modes of transportation.
o Policy 6.2.1. Reduce noise generated by vehicular traffic. • Goal 6.3. Minimize noise impacts on noise -sensitive land uses. o Policy 6.3.1. Minimize the amount of noise generated by land uses.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-5 December 2023
Exhibit D
Design Element
Section 4.9
Land Use and Planning
• Goal 8.1. Promote quality design for new, expanded, and remodeled construction. o Policy 8.1.1. Promote architectural design of the highest quality. • Goal 8.3. Promote the enhancement of the streetscape. o Policy 8.3.1. Enhance the views of property from public streets to exhibit a positive image.
o Policy 8.3.3. Promote the installation of new trees.
• Goal 8.4. Enhance Downey's cultural resources.
o Policy 8.4.1. Identify the city's cultural resources.
Economic Development
• Goal 9.1. Attract and retain businesses.
o Policy 9.1.1. Develop programs to attract and retain businesses. • Goal 9.2. Promote Downey as an employment center.
o Policy 9.2.1. Promote job -generating land uses.
o Policy 9.2.2. Promote employment in various economic sectors to shield against business cycles.
• Goal 9.3. Ensure the continued fiscal balance of the community. o Policy 9.3.1. Balance the maximization of revenue generation with costs for providing services.
4.9.4 Significance Criteria and Thresholds
The significance criteria used to evaluate the Project impacts related to land use and planning are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to land use and planning would occur if the Project would:
a) Physically divide an established community, or
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
Through the analysis in the IS/NOP (see Appendix A of this EIR), it was determined that the proposed Project would result in no impacts associated with physical division of an established community (Threshold a). Accordingly, that issue is not further analyzed in the EIR.
4.9.5 Methodology and Assumptions
The analysis of land use and planning consists of a summary of the regulatory framework that guides the decision -making process, a description of the existing conditions in the Project area, thresholds for Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-6 December 2023
Exhibit D
Section 4.9
Land Use and Planning
determining if the proposed Project would result in significant impacts, anticipated impacts (direct, indirect, and cumulative), mitigation measures, and level of significance after mitigation.
4.9.6 Impacts and Mitigation Measures
Threshold 4.9-b: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant with Mitigation Incorporated. The Project's consistency with the applicable portions of the 2020 RTP/SCS, Downey General Plan Vision 2025, and the Downey Municipal Code are NINUMT-MI11.7sm- re In,
Consistency with SCAG Regional Transportation Plan/Sustainable Communities Strategy The 2020 RTP/SCS forecasts the number of people, households, and jobs expected in the SCAG region at the jurisdictional level through the plan horizon year of 2045. This forecast helps determine where expected growth might occur and is prepared with participation and input from local jurisdictions. The forecast uses several major data sources, including land use and General Plan data from local jurisdictions. The 2020 RTP/SCS Jurisdiction -Level Growth Forecast identifies a projected population of 92,800 for the City in 2045. The Project would be developed consistent with the existing General Plan and zoning land use designations, and thus, is included in the growth projections for the City identified in the 2020 RTP/SCS.
The 2020 RTP/SCS contains ten goals to support the RTP/SCS focus of integrating land use with the transportation system. While not all of the ten goals would be applicable to the Project, the Project would not result in inconsistencies or conflicts with the applicable goals of the 2020 RTP/SCS, as outlined in Table J-1, Project Consistency with SCAG Connect SoCal 2020-2045 RTP/SCS Goals, in Appendix J, Land Use Consistency Analysis Tables. The 2020 RTP/SCS' overarching strategy is to integrate land use and transportation with policies that are directed towards the development of regional land use patterns that contribute to reductions in vehicle miles traveled and improvements to transportation systems. As the Project is proposed on an already developed site within a developed industrial area, the opportunity for integrating land use in a manner that improves mobility and enhances the regional transportation system and the movement of persons and goods within the system is limited. Due to the constraints of a proposed warehouse use on an already developed site within an existing industrial area, the Project does not directly implement the vision of the 2020 RTP/SCS and its goals; however, the Project does not directly conflict or result in inconsistencies with the identified goals. The Project and associated truck traffic would utilize truck routes designated by the City for accessing nearby freeways, minimizing impacts to the local and regional transportation system by utilizing routes intended for such uses. The Project would not result in inconsistencies with the 2020 RTP/SCS.
Consistency with Downey General Plan Vision 2025
The Project site is designated General Manufacturing (GM) in the DGP Vision 2025, which is intended for manufacturing, wholesaling, and other industrial land uses. Since uses consistent with the Manufacturing designation have potential for creating traffic, noise, odor, vibration and other impacts, areas designated Manufacturing should be separated from other land uses by a major natural or Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-7 December 2023
Exhibit D
Section 4.9
Land Use and Planning
physical barrier and screen. The Project site currently contains an industrial use, and Project implementation would be a continuation of industrial uses at the Project site, specifically, warehouse uses. Adjacent land uses include commercial and industrial uses to the east and industrial uses to the west. The Project site is bounded by Stewart and Gray Road to the south, with industrial and public utility uses beyond the adjacent roadway. Uses to the north consist of Hall Road and the UPRR rail corridor to the north beyond Hall Road. These adjacent land uses are not considered sensitive and the Project would be consistent with the separation of lands zoned for GM from other land uses. As specified in the Downey General Plan Vision 2025, the intensity of the Manufacturing designation should not exceed a floor area ratio of 0.6:1. The Project would have a floor area ratio of 0.42:1, and as such, would be consistent with the General Plan floor area ratio requirement.
The Project would be consistent with applicable environmental goals, policies, and programs contained in the General Plan as described below and outlined in Table J-2, Project Consistency with Downey General Plan Vision 2025 Goals, Policies, and Programs, in Appendix J, Land Use Consistency Analysis Tables. As demonstrated in Table J-2, the Project would be consistent with the applicable goals, policies, and programs of the Land Use, Conservation, Safety, Noise, Design, and Economic Development Elements. The Housing and Open Space Elements do not contain goals, policies, and programs that would be applicable to the Project.
The Project would be consistent with the applicable goals, policies, and programs of the Circulation Element as well. One policy to note is Policy 2.3.3, which discourages land uses that generate high amounts of truck traffic. While the Project would replace a similar industrial use, it would result in increased traffic trips. As discussed in Section 4.11, Transportation, the Project would result in an increase in traffic in the Project vicinity. However, the supporting Programs identified in the Circulation Element under Policy 2.3.3 further specify to discourage land uses that attract high amounts of truck traffic without corresponding benefits to the community (Program 2.3.3.1). The Project would provide additional industrial sector uses that provide goods movement services and employment opportunities for the community and region. Program 2.3.3.2 requires discretionary approvals for land uses generating high amounts of truck traffic, including general warehouses, truck parking, truck company headquarters, and distribution centers. The Project is subject to the City's discretionary approval process to identify and minimize potential impacts. With regard to transportation, the Project would implement a Transportation Demand Management (TDM) Program, as required by Project mitigation measure TR-1 (refer to Section 4.11, Transportation), to reduce significant transportation impacts associated with the Project. As discussed in Section 4.11, the implementation of the TDM Program, as required by mitigation measure TR-1, would reduce significant transportation impacts to a less than significant level.
In addition to the goals, programs, and policies described above and analyzed in Table J-2 in Appendix J, the Circulation Element identifies acceptable level of service (LOS) as A, B, C, or D: "...the general plan advances programs to reduce congestion to provide acceptable LOS, defined as A, B, C, or D." While LOS is no longer a measure of transportation impacts under CEQA, it is discussed here in the context of General Plan consistency. Based on the Project's Transportation Impact Study (LLG 2023), analyzed intersections in the Project vicinity that are part of the City's Circulation Element roadway network would operate at a LOS D or higher during the a.m. and p.m. peak hours. As such, the Project would be consistent with the Circulation Element requirement for acceptable LOS.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-8 December 2023
Exhibit D
Section 4.9
Land Use and Planning
Consistency with the Downey Municipal Code
The Project site is zoned M-2 (General Manufacturing Zone). Warehouse and truck uses are permitted in the M-2 zone, pursuant to DMC Section 9318.04. Section 9318.06 of the DMC contains the property development standards for manufacturing zones, including the M-2 zone. The M-2 zone requires the following minimum setbacks: 10 feet in the front, 20 feet in the rear, and 10 feet along the street. The Project would meet the setback requirements identified in the DMC §9318.06. Maximum permitted building height withing the M-2 zone is 45 feet or three stories, whichever is less. The Project as currently proposed would have a maximum height of 55 feet and would conflict with this zoning regulation. The excess height of the proposed Project would not be substantially greater than the surrounding structures that include commercial and industrial uses. This deviation from the zoning regulation would require a variation of standards for building height as part of Project approvals. The DMC (Section 9826) allows for variances related to building height provided that the City can make certain findings contained in DMC Section 9826.08. These findings and a brief summary of how the Project would meet the variance findings are provided below.
1. That exceptional or extraordinary conditions or circumstances exist which are peculiar to the land, structure, or building involved and which are not generally applicable to other lands, structures, or buildings in the same vicinity and zone.
2. That the literal interpretation of the provisions of this article would deprive the applicant of rights under the terms of this article commonly enjoyed by other properties in the same vicinity and zone in which the property is located.
3. That exceptional or extraordinary conditions or circumstances do not result from the actions of the applicant.
4. That granting the variance requested will not confer on the applicant any special privilege that is denied by this chapter to other lands, structures, or buildings in the same vicinity and zone in which the property is located.
5. That the granting of such variance will be in harmony and not adversely affect the General Plan of the City.
6. That the reasons set forth in the application justify the granting of the variance and that the variance is the minimum variance that will make possible the reasonable use of the land, building, or structure.
The Project would conform with other applicable zoning regulations and would request a variance for the increase in building height. The most recent development standards for manufacturing zones were established in 2008 and did not take into account the increasing demand for high cube fulfillment centers and last mile distribution centers as a result of increasing online sales. The proposed Project would be subject to exceptional circumstance as a result of existing zoning restrictions, because the standards would place an undue burden on the applicant's ability to produce a "Class A" industry standard state-of-the-art facility. The exceptional circumstances are a result of industry demands and the need to modify zoning standards for the particular proposed uses of high cube fulfillment or large distribution and are not a result of the applicant's action. Other identical uses, high cube fulfillment or large distribution, would make the same request in order to construct a structure that can be identified Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-9 December 2023
Exhibit D
Section 4.9
Land Use and Planning
as "Class A" state-of-the-art such that no special privilege would be granted to the Project applicant. The additional height of the proposed Project is necessary due to newly emerging demands and industry standards and is indicative of the need to modify zoning standards for the proposed uses of high cube fulfillment or large distribution. The requested height deviation is the minimum height to provide an adequate "Class A" state-of-the-art facility. As discussed elsewhere in this section, the proposed Project would be in harmony with the General Plan. The granting of the variance would allow for a land use that is consistent with surrounding land uses.
Drought tolerant landscaping would be installed around the building and at the site's perimeter, and would cover approximately 10.2 percent of the Project site area, in excess of the 10 percent coverage required. The Project would comply with the landscaping requirements contains in DMC §9520.04. As specified in DMC 9520.04, a landscaping plan for the Project would require approval by the Planning Commission as part of the Site Plan Review process and shall demonstrate consistency with the requirements of §9520.04.
Lighting at the Project site would include black painted metal fixtures to be wall -mounted around the building's exterior and pole -mounted throughout the parking areas surrounding the warehouse building.
Lighting is required to be shielded away from other properties and public rights -of -way, per DMC §9520.06. The final lighting plan would be subject to approval by the City Planner. Signage and lighting for the Project would be constructed consistent with the requirements for the M-2 zone identified in DMC §§9618.02 and 9624.
As demonstrated above, the Project would be consistent with the DMC, with the exception of maximum building height. A variation of standards for building height would be required as part of Project approvals. Although the Project is not consistent with this component of the DMC, the deviation would not result in significant environmental impacts related to this variation.
Conclusion
The Project would not conflict with applicable portions of the 2020 RTP/SCS. Although a deviation from the DMC is proposed for building height, the deviation would not result in significant environmental impacts. The Project overall is consistent with applicable policies in the DGP Vision 2025. As such, impacts related to consistency with environmental policies of adopted land use plans would be less than significant, with incorporation of mitigation measures TR-1, identified in Section 4.11, Transportation, to reduce significant transportation impacts to a less than significant level.
Mitigation Measures
As detailed in Section 4.11, Transportation, the Project transportation impacts would be potentially significant, but would be reduced to a less than significant level with implementation of mitigation requiring a TDM program. Implementation of the required transportation mitigation measure (TR-1) would reduce transportation impacts to a less than significant level. No additional mitigation measures beyond the mitigation required to reduce significant Project -related transportation impacts would be required.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-10 December 2023
Exhibit D
4.9.7 Cumulative Impacts
Section 4.9
Land Use and Planning
When evaluating cumulative land use and planning impacts, several factors must be considered. The cumulative study area for land use impacts is the City of Downey, as well as projects in the City of Norwalk which fall within a 1.5-mile radius of the project. The combination of the proposed Project together with related present and reasonably foreseeable future projects, as provided in Table 3-1, List of Related Projects, could involve actions with the potential to result in adverse land use impacts. As with the Project, the related projects would be required to comply with relevant land use policies and regulations. Therefore, the related projects would not be expected to conflict with applicable land use plans. Compliance with these policies, plans, and regulations would ensure that proposed future development would be compatible. Where significant or potentially significant impacts are identified, implementation of all feasible mitigation will be required to reduce or preclude significant land use impacts. As demonstrated above, with implementation of mitigation to reduce Project transportation impacts, the Project would not result in significant impacts related to consistency with land use plans, policies, or regulations. As such, cumulative impacts related to consistency with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect would be less than significant and not cumulatively considerable.
4.9.8 Significant Unavoidable Impacts
No significant unavoidable impacts related to land use have been identified.
4.9.9 References
City of Downey. 2020. Downey Municipal Code Article IX, Section 3, Section 9312.02. Available at:
h11p,ZLgcode.usLcodes downe ?to is=ix&frames=on. Accessed June 2022. 2012a. General Plan Land Use Map. Available at: 12 s: www.downe ca.or home show ublisheddocument 152 636977201797100000. Accessed June 2022. 2012b. Zoning Map. Available at: hqps.JL www.downeyca.or home showpublishedclocument1 132 636977195636000000. Accessed June 2022. 2005. Vision 2025 General Plan. Available at: https:f/ www.downeyca.orgZhomeZ show ublisheddocument 154 636977201799600000. Accessed June 2022.
Linscott, Law & Greenspan (LLG). 2023. Transportation Impact Study. September 2023.
Southern California Association of Governments. 2020. Connect SoCal, the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments. September 3, 2020. Available at: https:B/scag.ca.gov%siteslmain[filesLfiie- attachmentsj0903fconnectsocal-plan O.pdf?1606001176.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-11 December 2023
Exhibit D
Section 4.9
Land Use and Planning
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Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.9-12 December 2023
Exhibit D
Section 4.10
Noise
4.10 NOISE
4.10.1 Introduction
This section of the EIR evaluates potential noise impacts resulting from implementation of the proposed Project. This analysis is based on the Noise and Vibration Report (HELIX 2023) prepared for the Project, which is included as Appendix K of this EIR.
4.10.2 Environmental Setting
4.10.2.1 Noise and Sound Level Descriptors and Terminology All noise level or sound level values presented herein are expressed in terms of decibels (dB), with A -weighting (dBA) to approximate the hearing sensitivity of humans. Time -averaged noise levels are expressed by the symbol LEQ, with a specified duration. The Community Noise Equivalent Level (CNEL) is a 24-hour average, where noise levels during the evening hours of 7:00 p.m. to 10:00 p.m. have an added 5 dBA weighting, and sound levels during the nighttime hours of 10:00 p.m. to 7:00 a.m. have an added 10 dBA weighting. This is similar to the Day Night sound level (LDN), which is a 24-hour average with an added 10 dBA weighting on the same nighttime hours but no added weighting on the evening hours. Sound levels expressed in CNEL are always based on dBA. These metrics are used to express noise levels for both measurement and municipal regulations, as well as for land use guidelines and enforcement of noise ordinances.
Sound can be described as the mechanical energy of a vibrating object transmitted by pressure waves through a liquid or gaseous medium (e.g., air) to a hearing organ, such as a human ear. Noise is defined as loud, unexpected, or annoying sound.
In the science of acoustics, the fundamental model consists of a sound (or noise) source, a receiver, and the propagation path between the two. The loudness of the noise source and obstructions or atmospheric factors affecting the propagation path to the receiver contribute to the sound level and characteristics of the noise perceived by the receiver. The field of acoustics deals primarily with the propagation and control of sound.
Continuous sound can be described by frequency (pitch) and amplitude (loudness). A low frequency sound is perceived as low in pitch. Frequency is expressed in terms of cycles per second, or Hertz (Hz) (e.g., a frequency of 250 cycles per second is referred to as 250 Hz). High frequencies are sometimes more conveniently expressed in kilohertz (kHz), or thousands of Hertz. The audible frequency range for humans is generally between 20 Hz and 20,000 Hz.
The amplitude of pressure waves generated by a sound source determines the loudness of that source.
A logarithmic scale is used to describe sound pressure level (SPL) in terms of dBA units. The threshold of hearing for the human ear is about 0 dBA, which corresponds to 20 micro Pascals (mPa).
Because decibels are logarithmic units, SPL cannot be added or subtracted through ordinary arithmetic.
Under the decibel scale, a doubling of sound energy corresponds to a 3 dBA increase. In other words, when two identical sources are each producing sound of the same loudness, the resulting sound level at a given distance would be 3 dBA higher than one source under the same conditions.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-1 December 2023
Exhibit D
Section 4.10
Noise
Under controlled conditions in an acoustical laboratory, the trained, healthy human ear is able to discern 1 dBA changes in sound levels, when exposed to steady, single -frequency ("pure -tone") signals in the mid -frequency (1,000 Hertz [Hz]-8,000 Hz) range. In typical noisy environments, changes in noise of 1 to 2 dBA are generally not perceptible. It is widely accepted, however, that people begin to detect sound level increases of 3 dB in typical noisy environments. Further, a 5 dBA increase is generally perceived as a distinctly noticeable increase, and a 10 dBA increase is generally perceived as a doubling of loudness.
4.10.2.2 Groundborne Vibration Descriptors and Terminology Groundborne vibration consists of rapidly fluctuating motions or waves transmitted through the ground with an average motion of zero. Sources of groundborne vibrations include natural phenomena and anthropogenic causes (e.g., explosions, machinery, traffic, trains, construction equipment). Vibration sources may be continuous (e.g., factory machinery) or transient (e.g., explosions). Several different methods are typically used to quantify vibration amplitude. One is the peak particle velocity (PPV); another is the RMS velocity. The PPV is defined as the maximum instantaneous positive or negative peak of the vibration wave. For the purposes of this analysis, a PPV descriptor with units of inches per second (in/sec) is used to evaluate construction -generated vibration for building damage and human complaints. Generally, a PPV of less than 0.08 in/sec does not produce perceptible vibration. At 0.12 PPV in/sec is the level at which there is a risk of architectural damage (e.g., cracking of plaster) to historical buildings and other vibration -sensitive structures and the level at which continuous vibration may become noticeable to building occupants. A level of 0.20 PPV in/sec is commonly used as a threshold for risk of architectural damage to non -engineered timber and masonry buildings (California Department of Transportation [Caltrans] 2020).
4.10.2.3 Noise and Vibration Sensitive Land Uses
Noise -sensitive land uses (NSLUs) are land uses that may be subject to stress and/or interference from excessive noise, such as residential dwellings, schools, transient lodging (hotels), hospitals, educational facilities, and libraries. Industrial and commercial land uses are generally not considered sensitive to noise. Noise receptors are individual locations that may be affected by noise. The nearest NSLU is single- family home located approximately 240 feet west of the Project site, across Hall Road, Woodruff Avenue, and the Union Pacific Railroad corridor. Additional nearby NSLUs include multi -family residences are located approximately 290 feet southeast of the Project site, across Stewart and Gray Road; single-family residences are located approximately 300 feet east of the Project site beyond a row of industrial businesses; and multi -family residences are located approximately 320 feet west of the Project site, across Woodruff Avenue and the Union Pacific Railroad corridor.
Land uses in which ground -borne vibration could potentially interfere with operations or equipment, such as research, hospitals, and university research operations (Caltrans 2020) are considered "vibration -sensitive." The degree of sensitivity depends on the specific equipment that would be affected by the ground -borne vibration. In addition, excessive levels of ground -borne vibration of either a regular or an intermittent nature can result in annoyance to residential uses, schools, or transient lodging. Land uses in the Project area that are subject to annoyance from vibration include the residences described above.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-2 December 2023
Exhibit D
Section 4.10
Noise
4.10.2.4 Existing Noise Sources
The existing on -site noise environment is dominated by typical noise from industrial businesses on and around the Project site (at the time of the NOP) and by transportation noise. Transportation noise sources in the area include: the Union Pacific Railroad approximately 95 feet north of the Project site; major roads including Stewart and Gray Road, Woodruff Avenue, and Firestone Boulevard; and commercial aircraft overflying the City. According to the City's Noise Element Noise Contour Map, the noise levels on the Project site range from 70 CNEL (to the north along Hall Road and to the south along Stewart and Gray Road) to 60 CNEL near the center of the Project site (City 2005). The distances from the centerline of major roads to the transportation noise contours, as reported in the City's Noise Element, in the Project vicinity are shown in Table 4.10-1, Existing Transportation Noise Contours.
Table 4.10-1
EXISTING TRANSPORTATION NOISE CONTOURS
Road Segment
Distance to
Distance to
Distance to
70 CNEL (feet)
65' CNEL (feet)
60 CNEL (feet)
Stewart and Gray Road — Bellflower Boulevard to
Woodruff Avenue
65 205
655
Stewart and Gray Road — Woodruff Avenue to
East City Limits
50 165
525
Woodruff Avenue — Firestone Boulevard to
Stewart and Gray Road
85 260
825
Woodruff Avenue —Stewart and Gray Road to
Imperial Highway
75 230
725
Firestone Boulevard — Lakewood Boulevard to
Woodruff Avenue
100
315
995
Firestone Boulevard —Woodruff Avenue to
Stewart and Gray Road
100
310
985
Firestone Boulevard —Stewart and Gray Road to
East City Limits
125
400
1,270
Source: City 2005
CNEL = Community Noise Equivalent Level
4.10.3 Regulatory Framework
4.10.3.1 State
California Noise Control Act
The California Noise Control Act is a section within the California Health and Safety Code that describes excessive noise as a serious hazard to the public health and welfare and that exposure to certain levels of noise can result in physiological, psychological, and economic damage. It also finds that there is a continuous and increasing bombardment of noise in the urban, suburban, and rural areas. The California Noise Control Act declares that the State of California has a responsibility to protect the health and welfare of its citizens by the control, prevention, and abatement of noise. It is the policy of the State to provide an environment for all Californians free from noise that jeopardizes their health or welfare.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-3 December 2023
Exhibit D
Section 4.10
Noise
4.10.3.2 Local
City of Downey Municipal Code
The following City of Downey Municipal Code sections would be applicable to noise generated by the Project:
4600.2 Equipment and Machinery:
(b) No person shall use, operate, or permit to be used or operated within any commercial (C) or manufacturing (M) Zone, as defined in Chapter 1 of Article IX of this code, which is within three hundred feet of a residential use, any power tool, machine, or equipment, or any other tool, machine, or equipment, between the hours of 10:00 p.m. and 7:00 a.m. in such a manner that the noise therefrom disturbs or interferes with the peace, comfort, or welfare of the neighboring residential inhabitants.
4606.3 Maximum Permissible Noise Levels by Sound Sources Across Property Boundaries (a) All activities to which this chapter is applicable shall be conducted in such a manner that any noise produced shall not create a disturbance. The maximum permissible sound pressure level measured at the property boundary of any land use in Subsection (b) of this section from any noise source not operating on a public right-of-way shall constitute prima facie evidence of a public nuisance when such noise level exceeds five dBA above the ambient noise level at any period during the course of a 24-hour day.
(b) If the alleged noise source is of a continuous nature and cannot reasonably be discontinued for a time period wherein the ambient noise level can be determined, the maximum permissible steady noise level by sound sources across the property boundary of any land use cited below may be less, but not greater than noise levels in section 4606.3(b) (reproduced as Table 4.10-2, City of Downey Exterior Noise Limits):
Table 4.10-2
CITY OF DOWNEY EXTERIOR NOISE LIMITS
Receiving Land Use
7:00 a.m. to!10 p.m.
10:00 p.m. to 7:00 a.m.
Residential
55 dBA
45 dBA
Commercial
65 dBA
65 dBA
Manufacturing
70 dBA
70 dBA
Source: City of Downey Municipal Code Section 4606.3(b) dBA = A -weighted decibel
(c) If any parcel of real property is developed and used for multiple land uses, the lower land use noise level standard shall apply.
(d) In the hours between 7:00 a.m. to 10:00 p.m., the noise levels permitted in Subsection (b) of this section may be adjusted by the inclusion of the following factors when applicable:
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-4 December 2023
Exhibit D
Section 4.10
Noise
(1) Noise source operated 12 minutes per hour or less: + 5 dBA (2) Noise source operated 3 minutes per hour or less: + 10 dBA (3) Noise source operated 1 minute per hour or less: + 15 dBA (e) Impulsive sounds, pure tone, or sounds with a cyclically varying amplitude shall be considered a public nuisance when such noises are at a sound pressure level of five dBA less than those listed in Subsection (b) of this section, with the inclusion of the corrective factors listed in Subsection (d) of this section, when applicable.
4606.4 Exemptions
The standards established in this chapter shall not apply to any of the following noise sources:
(a) Any activity to the extent preempted from regulation by State or Federal law; (b) Bells, chimes, or carillons while being used in conjunction with religious services; (c) Emergency release devices;
(d) Emergency work authorized by the City;
(e) Special events authorized by the City;
(f) The unamplified human voice;
(g) Warning systems used to protect the public health, safety, or welfare. 4606.5 Construction Projects
Construction, repair, or remodeling equipment and devices and other related construction noise sources shall be exempted from the provisions of this chapter provided a valid permit for such construction, repair, or remodeling shall have been obtained from the City. In any circumstance other than emergency work, no repair or remodeling shall take place between the hours of 9:00 p.m. of one day and 7:00 a.m. of the following day, and no repair or remodeling shall exceed 85 dBA across any property boundary at any time during the course of a 24-hour day.
City of Downey General Plan Noise Element
The Downey General Plan Vision 2025 Noise Chapter establishes noise compatibility guidelines for land uses. Residential land uses would be normally acceptable with ambient noised levels at or below 60 CNEL exterior and 45 CNEL interior; commercial land uses would be normally acceptable with ambient noised levels at or below 70 CNEL exterior and 60 CNEL interior; and industrial land uses would be normally acceptable ambient noised levels at or below 75 CNEL exterior and 60 CNEL interior (City 2005).
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-5 December 2023
Exhibit D
Section 4.10
Noise
4.10.4 Significance Criteria and Thresholds
According to Appendix G of the CEQA Guidelines, a significant noise impact would occur if implementation of the Project would:
a) Result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; b) Result in the generation of excessive groundborne vibration or groundborne noise levels; and/or c) Expose people residing or working in the Project area to excessive noise levels by being located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport.
Through the analysis in the IS/NOP (see Appendix A of this EIR), it was determined that the proposed Project would result in no impacts associated with the exposure of people residing or working in the Project area to excessive noise levels associated with airport use (Threshold c). Accordingly, this issue is not analyzed further in the EIR.
4.10.5 Methodology and Assumptions
4.10.5.1 Noise Modeling
Project construction noise was analyzed using the Roadway Construction Noise Model Version 1.1 (RCNM; USDOT 2008), which utilizes estimates of sound levels from standard construction equipment.
Modeling of the exterior noise environment for this report was accomplished using two computer noise models: Computer Aided Noise Abatement (CadnaA) version 4.5 and Traffic Noise Model (TNM) version 2020. CadnaA is a model -based computer program developed by DataKustik for predicting noise impacts in a wide variety of conditions. CadnaA assists in the calculation, presentation, assessment, and mitigation of noise exposure. It allows for the input of Project -related information, such as noise source data, barriers, structures, and topography to create a detailed CadnaA model, and uses the most up-to- date calculation standards to predict outdoor noise impacts. CadnaA traffic noise prediction is based on the data and methodology used in the TNM. TNM was released in February 2004 by the USDOT and calculates the daytime average hourly LEQ from three-dimensional model inputs and traffic data (USDOT 2004). Input variables included road alignment, elevation, lane configuration, area topography, existing and planned noise control features, projected traffic volumes, estimated truck composition percentages, and vehicle speeds.
The one -hour LEQ noise level is calculated utilizing peak -hour traffic. Peak hour LEQ can be converted to CNEL using the following equation, where LEQ(h)pk is the peak hour LEQ, P is the peak hour volume percentage of the average daily trips (ADT), d and e are divisions of the daytime fraction of ADT to account for daytime and evening hours, and N is the nighttime fraction of ADT:
CNEL = LEQ(h)pk + 10*logio(4.17/P) + 10*logio(d + 4.77*e + 10*N) Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-6 December 2023
Exhibit D
Section 4.10
Noise
For urban roads in California with typical traffic patterns, the last two terms of the equation are near zero and the model -calculated one -hour LEQ noise output is approximately equal to the CNEL (Caltrans 2013).
4.10.5.2 Construction
Construction of the proposed Project would begin in spring 2024 with demolition/site preparation lasting approximately 4 to 5 months and grading/ construction of proposed new buildings continuing for approximately 14 to 15 months. Construction activities are anticipated to be completed in summer 2024. Refer to Appendix K for additional information about Project construction.
Construction would occur primarily Monday through Friday during daytime hours (not before 7 a.m. or after 9 p.m.) with equipment operating up to 8 hours per workday. However, due to high daytime temperatures, it is likely that pouring of concrete for the building slab, walls, and sidewalks would require nighttime work. Per the Project engineering team, nighttime concrete pouring work would occur on approximately 40 nights during Project construction. Included in those 40 nights, approximately 12 consecutive nights (including on weekends) would be required to pour the building slab foundation/ floor. Typical nighttime concrete pouring work would require the use of multiple concrete mixer trucks, a concrete pump truck, and a backhoe. Nighttime concrete pouring work would typically commence at midnight with pouring completed by mid -morning and concrete finishing work continuing into the afternoon.
4.10.5.3 Operation
Anticipated operational noise sources are assumed to include diesel -powered heavy delivery trucks with backup alarms; transport refrigeration units (TRUs); rooftop -mounted heating, ventilation, and air conditioning (HVAC) systems; rooftop -mounted refrigeration condenser units; and vehicular traffic.
Please refer to Appendix K for additional information about Project operation.
Delivery Trucks
Operation of the Project would involve diesel -powered heavy trucks for the delivery of goods to the Project site and it would be operational for 24 hours a day. According to Project Transportation Impact Study (TIS), 98 one-way truck trips would occur each day, with 12 one-way truck trips during the peak hour entering and exiting the site (Linscott, Law & Greenspan [LLG] 2023).
The proposed building would have 39 loading docks on the west side, 28 loading docks on the north side, and 42 loading docks on the east side. Delivery trucks access the site via three driveways on Hall Road, and two driveways on Stewart and Gray Road. Modeling of peak -hour noise assumed that the delivery trucks would be divided between the driveways in accordance with the Project truck distribution analysis in the TIS: 35 percent on Hall Road and 65 percent on Stewart and Gray Road (LLG 2023). On -site truck circulation was modeled assuming 35 percent of trucks (four peak hour trucks) would enter via the middle driveway on Hall Road and proceed to the north docks, 33 percent of trucks (four peak hour trucks) would enter via the east driveway on Stewart and Gray Road and proceed to the east docks, and 32 percent of trucks (four peak hour trucks) would enter via the west driveway on Stewart and Gray Road and proceed to the west docks. Each truck was assumed to circulate on the Project site at an average speed of 8 miles per hour (mph), then reverse to a loading bay at 3 mph.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-7 December 2023
Exhibit D
Section 4.10
Noise
Each truck was assumed to idle at the loading bay for the maximum allowable time of five minutes, in accordance with California Code of Regulations Title 13, Section 2485.
The Project would provide a parking area for trucks/trailers along the Project's western, northern, and eastern sides. It is unknown how many trucks would use the parking areas during each day or peak hour.
To be conservative in evaluating the highest potential noise, every truck entering the Project site was assumed to travel to a nearby parking area, reverse into a parking spot, and idle for five minutes before departing the Project site. Truck circulation noise was modeled using the default heavy truck noise in CadnaA.
Some trucks would generate noise from the use of transport refrigeration units (TRUs; typically, a diesel - powered refrigeration unit mounted on the truck trailer or box). Specific TRU noise would vary from unit to unit. Typical noise from a TRU was modeled as producing 75 dBA at 21 feet, based on field measurements of truck and TRU noise conducted by HELIX. Only trucks transporting goods to and from the Project's refrigerated warehouse space (five percent of the total Project warehouse space) would be anticipated to be equipped with an operating TRU. Because the location of the refrigerated warehouse space within the Project building was unknown at the time of this analysis, one out of the four peak hour trucks going to each loading dock area was assumed to be equipped with an operating TRU. Each TRU was assumed to operate at a 50 percent duty cycle during the analyzed peak noise hour.
There are no California or federal regulations which require on -road trucks to be equipped with backup warning devices. However, backup alarms are commonly used on delivery trucks due to safety/liability concerns. The most common truck backup alarm is a pulsing single tone, typically at one kHz. To be conservative, all trucks were assumed to be equipped with a traditional one kHz back up alarm, mounted on the back of the truck at a height of three feet. Backup alarms were modeled with typical noise levels of 109.7 dBA measured at a distance of four feet.
Stationary Refrigeration Units
The Project would include stationary commercial -sized refrigeration units for the refrigerated warehouse space (approximately 26,785 SF). The location of the refrigerated warehouse space within the Project building was not known at the time of this analysis. To be conservative, four rooftop refrigeration condensers were assumed, one located near the roof edge on each side of the building and would be surrounded by standard parapet walls approximately four feet high. For this analysis, four Hussman Proto-Air 3280 refrigeration systems were assumed, which have a sound power level (SWL) of
86.3 dBA when operating at the maximum speed of 1,150 revolution per minute. Noise data for the rooftop refrigeration condenser unit and associated fan is shown in Table 4.10-3, Stationary Refrigeration Unit Fan Noise Data.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-8 December 2023
Exhibit D
Section 4.10
Noise
Table 4.10-3
STATIONARY REFRIGERATION UNIT FAN NOISE DATA
Overall Noise Level
Fan Type
63 Hz
125 Hz
250 Hz
500 Hz
1 kHz
2 kHz
4 kHz
in'A-weighted Scale
(dBA)1
Single Fan
90.6 93.6
89.6 86.6
84.6 79.6
75.6 89.3
1,150 RPM
Source: HELIX 2023
1 Sound Power Levels (Swi)
Hz = Hertz; kHz = kilohertz; RPM = revolutions per minute Heating, Ventilation, and Air Conditioning Units
The Project would use commercial -sized HVAC units located on the rooftop of the building for the proposed office space. Specific planning data for the future HVAC systems was not available at the time of this analysis. Standard HVAC planning assumes approximately one ton of HVAC for every 350 to 500 SF of occupied office space (American Society of Heating, Refrigeration, and Air Conditioning Engineers [ASHRAE] 2012). For the purposes of this analysis, one Carrier 50PG 12-ton HVAC unit, which has a sound power level NO of 80.0 dBA, was assumed for each of the Project three office spaces (see Figure 3). The HVAC systems were assumed to be mounted on the Project building roof and would be surrounded by standard parapet walls approximately four feet high. The manufacturer's noise data for the HVAC units is provided below in Table 4.10-4, Condenser Noise Data.
Table 4.10-4
CONDENSER NOISE DATA
Overall Noise Level
63 Hz
125 Hz
250 Hz
500 Hz
1 kHz
2 kHz
4 kHz '
8 kHz
in A -weighted
Scale; (dBA)1
90.4 83.1
80.9 77.8
75.2 70.0
66.1 57.6
80.0 Source: HELIX 2023
1 Sound Power Levels (Swi)
Note: Noise levels in decibels (dB) measured at octave frequencies Hz = Hertz; kHz = kilohertz
Vehicular Traffic
Modeled existing traffic data for the roadways in the Project vicinity were based on volumes provided by the Project TIS (LLG 2023) for four scenarios: existing, existing plus project, cumulative 2024, and cumulative 2024 plus project. The mix of cars and trucks on the analyzed roadways was not provided in the TIS. Therefore, all analyzed road segments were assumed to carry a mix typical of urban areas with significant industrial activity: 92 percent cars and light trucks, 4 percent medium trucks; and 4 percent heavy duty trucks. Trip generation rates and trip distribution were also provided in the TIS. Speed limits and road widths analyzed road segments were used in the modeling to calculate existing and future noise levels. Table 4.10-5, PM Peak Hour Traffic Volumes, shows the p.m. peak hour traffic volumes used in the modeling for the analyzed roadway segments.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-9 December 2023
Exhibit D
Section 4.10
Noise
Table 4.10-5
PM PEAK HOUR TRAFFIC VOLUMES
Existing +
2024 +
Existing
2024
Roadway Segment
Project
Project
ADT
ADT
ADT
ADT
Firestone Boulevard
Woodruff Avenue to Stewart & Gray Road 2858 2871 2975 2988 Stewart & Gray Road to 1-605 3739 3803 3925 3989
Woodruff Avenue
Firestone Boulevard to Hall Road
1342
1388
1399
1445
Hall Road to Stewart & Gray Road
1126
1211
1180
1265
Stewart & Gray Road to Washburn Road
1057
1094
1146
1183
Washburn Road to Imperial Highway
1239
1257
1311
1329
Hall Road
Project to Woodruff Avenue 163 260 166 263
Stewart & Gray Road
Project to Woodruff Avenue 1337 1374 1363 1400
Woodruff Avenue to Firestone Boulevard 1035 1087 1109 1160 Washburn Road
Bellflower Road to Woodruff Avenue 220 237 224 2-41
Imperial Highway
Source: LLG 2023
ADT = average daily trips
4.10.6 Impacts and Mitigation Measures
Threshold 4.10-a: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Significant and Unavoidable Impact. Per the City Municipal Code Section 4606.3, noise generated on the Project site would be significant if noise exceeds ambient noise levels by 5 dBA or more, measured at the receiving land use property line. If ambient noise levels cannot be measured, noise generated on the Project site would be significant if steady noise exceeds 55 dBA LEQ between the hours of 7:00 a.m. and 10:00 p.m. or 45 dBA LEQ between the hours of 10:00 p.m. and 7:00 a.m. for residential uses; 65 dBA LEQ for commercial uses; or 70 dBA LEQ for industrial uses.
The City has not established standards for determining the significance of increases in transportation noise resulting from a development project. Therefore, the standards of significance are based on perceived increases in ambient noise levels. Impacts would be significant in areas where existing traffic noise at NSLUs exceeds 60 CNEL (the City General Plan noise compatibility level for residential uses) and implementation of the Project would result in an increase of the noise level by 3 CNEL or more (a just Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-10 December 2023
Exhibit D
Section 4.10
Noise
perceivable increase in typical noisy environments), or where existing traffic noise is less than 60 CNEL and implementation of the Project results in an increase of 5 CNEL or more.
Per the City Municipal Code Section 4606.5, construction noise is exempt from the provisions of City Noise Ordinances provided a valid permit for such construction has been obtained from the City. CEQA case law establishes that a project's noise impact analysis must consider the increase in ambient noise levels (King and Gardiner Farms v, County of Kern). Neither the City nor any state regulatory agency have established criteria for determining the significance of an increase in ambient noise levels resulting from temporary and short-term construction noise. Therefore, temporary Project construction noise measured at off -site NSLUs would be significant if it would result in a perceived doubling of loudness, estimated to be an increase of 10 dBA above exterior ambient noise levels (Caltrans 2013). This threshold provides a reasonable balance between the need to operate noise generating equipment for most temporary construction activities and the desire to protect NSLUs from temporary disturbances.
Temporary Construction and Demolition Noise
Construction of the Project would require demolition/site preparation, grading, installation of underground utilities/infrastructure, construction of new buildings, paving, and architectural coating.
The magnitude of the noise impact would depend on the type of construction activity, equipment, duration of each construction phase, distance between the noise source and receiver, and any intervening structures. Construction would generate elevated noise levels that may disrupt NSLUs in the area. The closest NSLU to the Project site is a single-family home located approximately 240 feet east of the Project site, across Hall Road, Woodruff Avenue, and the Union Pacific Railroad corridor. In addition, multi -family residences are located approximately 290 feet southwest of the Project site, across Stewart and Gray Road. The single-family residences located approximately 300 feet west of the Project site and multi -family residences located approximately 320 feet east of the Project site are substantially shielded from noise on the Project site by large existing industrial/commercial buildings.
Construction equipment would not all operate at the same time or location and would not be in constant use during the 8-hour operating day. Further, not all the pieces of equipment would be used within 240 feet of the closest off -site residences. It is anticipated that, over the course of an hour, demolition and earthmoving equipment would operate an average distance of 100 or more feet from the Project property lines, or 340 or more feet from the closest NSLU. Table 4.10-6, Construction Equipment Noise Levels, provides the 340-foot distance noise levels for equipment anticipated to be used for general construction activities.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-11 December 2023
Exhibit D
Section 4.10
Noise
Table 4.10-6
CONSTRUCTION EQUIPMENT NOISE LEVELS
Unit
Percent
Operating Time
LmAx'
at 340 feet
dBA LEQ
at 340 feet
Backhoe
40 60.9
56.9 Compressor
40 61.0
57.0 Concrete/Industrial Saws
20 72.9
65.9 Concrete Mixer Truck
40 60.9
58.2 Concrete Pump Truck
20 62.1
57.8 Crane
16 63.9
55.9 Dozer
40 65.0
61.0 Excavator
40 64.1
60.1 Generator
50 64.0
61.0 Grader
40 68.3
64.4 Paver
50 60.6
57.6 Scraper
40 66.9
63.0 Roller
20 63.3
56.4 Source: RCNM
LMAX = maximum noise level; dBA = A -weighted decibel; LEQ = time -averaged noise level The noisiest anticipated construction activity would be during site preparation/demolition, a dozer, an excavator, and a concrete saw may be working concurrently and would produce a combined noise level of 67.9 dBA LEQ at 340 feet, as modeled using the RCNM. The RCNM output is included in Appendix B to the attached Noise and Vibration report (HELIX 2023). The closest NSLU, a single-family residence, is approximately 100 feet from the Union Pacific railroad tracks and approximately 50 feet from the centerline of Woodruff Avenue. According to the City General Plan Noise Element, this residence is located in an area with an ambient noise level of 70 CNEL or more and Project construction would not exceed ambient noise levels. The next closest NSLU, multi -family residences are south of Stewart and Gray Road and adjacent to existing industrial land uses. According to the City General Plan Noise Element, these residences are located in an area with an ambient noise level of 65 CNEL resulting from traffic on Stewart and Gray Road. Therefore, the maximum calculated Project site preparation/ demolition noise level of 67.9 dBA LEQ would be approximately 3 dBA above daytime ambient noise levels at the multi -family residences to the south, and the increase over ambient noise would be less than the 10 dBA increase significance level. However, nighttime ambient noise levels are typically lower than daytime levels -the CNEL reported in the General Plan Noise Element includes a 10 dBA weighting during nighttime hours. Therefore, Project site preparation/demolition noise would be potentially significant if it would occur at night or during other periods with reduced transportation noise, such as Sundays and holidays.
As described in Section 4.10.5.2, due to high daytime temperatures, pouring of concrete for Project construction may be required to be conducted at night. The combined noise from two concrete mixer trucks, a concrete pump truck, and a backhoe (all working in close proximity to each other) would result in a combined noise level of 64.9 dBA LEQ at 300 feet, as modeled using the RCNM. Unlike demolition and earthmoving activities, concrete pouring equipment could be stationary for more than an hour and positioned near the Project property lines. Therefore, NSLUs within 300 feet of the Project site could be exposed to temporary construction noise more than 10 dBA above nighttime ambient noise levels, and Project nighttime concrete pouring noise would be potentially significant.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-12 December 2023
Exhibit D
Section 4.10
Noise
With implementation of mitigation measure N0I-1, affected residents would be informed of potential nighttime and weekend disturbances and the duration of those disturbances. However, mitigation measure N0I-1 would not reduce Project temporary construction -related noise levels to acceptable limits.
Further, because some of the affected residents within 300 feet of the Project site are within the upper levels of a two-story building, other noise -reducing mitigation such as temporary sound walls would have to be unreasonably high (more than 20 feet) to provide adequate noise reduction and would not be feasible.
Therefore, the Project would generate a substantial temporary increase in ambient noise levels in the vicinity of the Project, and the impact would be significant and unavoidable.
Construction Traffic Noise
Demolition and site preparation would result in approximately 1,969 one-way haul trips over the course of 4 to 5 months, resulting in approximately 22 trips per day. Project grading would require one-way haul trips over the course of 14 to 15 months, which would result in approximately 208 daily one-way haul truck trips or approximately 26 hourly haul truck trips over the course of an 8-hour workday. Paving would require approximately 45 trips per day to import materials. The closest NSLU to the Project site is a single-family residence east of the Project site on Woodruff Avenue just north of the railroad tracks (between Firestone Boulevard and Hall Road). As shown in the table above, this segment of Woodruff Avenue carries 1,342 vehicle trips during the peak hour, of which approximately 54 (four percent) are heavy trucks. Using the CadnaA and the TNM model, an additional 26 heavy truck trips per hour would temporarily increase the hourly noise level along that roadway from 68.3 dBA to 68.6 dBA. This increase in noise levels of 0.3 dBA would be well below the just perceivable 3 dBA increase level for noisy outdoor environments. Therefore, construction traffic noise impacts would be less than significant.
Warehouse Operational Noise
The proposed on -site truck circulation routes, loading dock areas, rooftop HVAC units, and rooftop refrigeration condensers would generate elevated noise levels compared to existing conditions. The primary noise sources for the loading dock areas are delivery truck engines idling, truck backup alarms, and transportation refrigeration unit engines. The Project would operate 24 hours per day resulting in nighttime noise generated on the Project site. HVAC systems and refrigeration condensers were assumed to operate for one hour or more continuously at night. For truck circulation and loading dock operations, it is unknown how many trucks per hour would arrive and depart the Project site at night.
The Traffic Impact Study (TIS) estimated the Project would result in 98 one-way daily truck trips during operations (LLG 2023). If truck trips were spread throughout the day evenly, the result would be approximately 4 trucks per hour. However, the traffic report estimated that 12 of the truck trips (approximately 12 percent of the daily trips) would occur during the peak afternoon hour (LLG 2023) indicating truck trips would not be distributed uniformly throughout the day. To be conservative in analyzing the highest reasonably foreseeable nighttime noise level, 6 nighttime peak hour trucks (50 percent of daytime peak truck trips) entering and exiting the Project site were assumed.
Daytime and nighttime operations of noise -generating components was modeled using CadnaA. The Project building and four surrounding existing buildings were included in the model. The closest existing NSLU to the Project site is a single-family home located approximately 240 feet to the east, across Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-13 December 2023
Exhibit D
Section 4.10
Noise
Hall Road, Woodruff Avenue, and the Union Pacific Railroad corridor. In addition, multi -family residences are located approximately 250 feet southwest of the Project site, across Stewart and Gray Road; single-family residences are located approximately 300 feet west of the Project site beyond a row of industrial businesses; and multi -family residences are located approximately 320 feet east of the Project site, across Woodruff Avenue and the Union Pacific Railroad corridor. Six receivers were placed in the model at the property line of the closest residential properties east, west, and southwest of the Project site (R1 through 116). Five receivers were placed in the model at the industrial buildings west and south of the Project site (11 through 15). Two receivers were placed in the model at the commercial buildings east of the Project site (Cl through C2). Figure 4.10-1 shows the locations of the modeled receivers.
The calculated daytime peak hour noise level results are compared to the City's noise standard for the maximum permissible level measured at the receiving property boundary in Table 4.10-7, Daytime Operational Noise.
Table 4.10-7
DAYTIME OPERATIONAL NOISE
Receiver
Number
Land Use
Ambient Noise
(CNEL)
Project Noise
(dBA LEQ)
City Noise Limit
(dBA)
Exceed
Standard?
R1
Residential
651
59.6 701
No
R2
Residential
701
59.2 751
No
R3
Residential
Unknown
39.7 553
No
R4
Residential
Unknown
33.5 553
No
R5
Residential
Unknown
34.1 553
No
R6
Residential
701
54.6 702
No
11 Industrial
Unknown
59.8 703
No
12 Industrial
Unknown
63.8 703
No
13 Industrial
Unknown
62.1 703
No
14 Industrial
Unknown
67.7 703
No
15 Industrial
Unknown
66.8 703
No
C1
Commercial
Unknown
62.4 653
No
C2
Commercial
Unknown
64.8 653
No
Source: HELIX 2023
1 Existing ambient noise based on 2004 traffic noise contours from City General Plan Noise Element, see Table 2 of this report. z Noise standard is 5 dBA above existing ambient level Per City Municipal Code Section 4606.3(a). 3 Noise standard is per City Municipal Code Section 4606.3(b) based on receiving land use and time of day, see Table 1 of this report.
dBA = A -weighted decibel; CNEL = Community Noise Equivalent Level; LEQ = time -averaged noise level The Project would operate 24 hours per day resulting in nighttime noise generated on the Project site.
HVAC systems and refrigeration condensers were assumed to operate for one hour or more continuously at night. For truck circulation and loading dock operations, it is unknown how many trucks per hour would arrive and depart the Project site at night. The TIS estimated the Project would result in 98 one-way daily truck trips (LLG 2023). If truck trips were spread throughout the day evenly, the result would be approximately 4 trucks per hour. However, the traffic report estimated that 12 of the truck trips (approximately 12 percent of the daily trips) would occur during the peak afternoon hour (LLG 2023) indicating truck trips would not be distributed uniformly throughout the day.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-14 December 2023
Exhibit D
0 600 Feet Source: Aerial (Maxar, 2021)
HELIX Noise Receiver locations
Environmental Planning
Figure 4.10-1
Exhibit D
Section 4.10
Noise
To be conservative in analyzing the highest reasonably foreseeable nighttime noise level, 6 nighttime peak hour trucks (50 percent of daytime peak truck trips) entering and exiting the Project site were assumed. The calculated peak nighttime hour noise level results are compared to the City's noise standard for the maximum permissible level measured at the receiving property boundary in Table 4.10-8, Nighttime Operational Noise.
Table 4.10-8
NIGHTTIME OPERATIONAL NOISE
Receiver
Number
Land Use
Ambient Noise
(dBA LEQ) ;
Project Noise
(dBA LEQ)
City Noise Limit
(dBA)
Exceed
Standard?
R1
Residential
551
56.6 602
No
R2
Residential
601
56.2 652
No
R3
Residential
Unknown
36.7 453
No
R4
Residential
Unknown
30.6 453
No
R5
Residential
Unknown
31.2 453
No
R6
Residential
601
51.5 65'
No
11 Industrial
Unknown
56.8 703
No
12 Industrial
Unknown
60.8 703
No
13 Industrial
Unknown
59.1 703
No
14 Industrial
Unknown
64.7 703
No
15 Industrial
Unknown
63.8 703
No
C1
Commercial
Unknown
59.4 653
No
C2
Commercial
Unknown
61.8 653
No
Source: HELIX 2023
1 Existing nighttime ambient noise based on 2004 traffic noise contours from City General Plan Noise Element and removing the CNEL 10 dBA nighttime weighting, see Table 2 of this report. z Noise standard is 5 dBA above existing ambient level Per City Municipal Code Section 4606.3(a). 3 Noise standard is per City Municipal Code Section 4606.3(b) based on receiving land use and time of day, see Table 1 of this report.
dBA = A -weighted decibel; CNEL = Community Noise Equivalent Level; LEQ = time -averaged noise level As shown in Table 4.10-7 and Table 4.10-8, noise levels from the Project on -site operational sources would not exceed the limits for land uses in the vicinity of the Project at any of the modeled receivers.
Noise impacts generated by on -site Project operations would be less than significant.
Operational Traffic Noise
The Project would generate vehicular traffic along nearby roadways. CadnaA/TNM software was used to calculate the peak p.m. hour noise for the Existing, Existing + Project, Cumulative (year 2024) and Cumulative (year 2024) + Project conditions along Project -affected roadways. Traffic noise levels presented in this analysis are based on traffic volumes provided in the Project TIS (LLG 2023). The off -site roadway modeling represents a conservative analysis that does not consider topography or attenuation provided by existing structures. The results of the analysis for the Existing and Existing + Project conditions are shown in Table 4.10-9, Existing Off -Site Traffic Noise Levels. The results of the analysis for the Cumulative and Cumulative + Project conditions are shown in Table 4.10-10, Cumulative (Year 2024) Off -Site Traffic Noise Levels.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-15 December 2023
Exhibit D
Section 4.10
Noise
Table 4.10-9
EXISTING OFF -SITE TRAFFIC NOISE LEVELS
Distance to
Existing
Existing + Project
Increase
Roadway Segment
Nearest
P.M. Peak Hour
P.M. Peak Hour
(dBA LEq) ;
NSLU (feet)
(dBA'Lro)
(dBA LEn)
Firestone Boulevard
Woodruff Avenue to Stewart & Gray Road 64 71.3 71.3 0.0 Stewart & Gray Road to 1-605' 105 70.8 70.9 0.1
Woodruff Avenue
Firestone Boulevard to Hall Road
74 68.4
68.5 0.1
Hall Road to Stewart & Gray Road'
70 69.3
69.6 0.3
Stewart & Gray Road to Washburn Road
77 68.1
68.2 0.1
Washburn Road to Imperial Highway
70 69.3
69.3 0.0
Hall Road
Project to Woodruff Avenue' 40 59.3 60.8 1.5
Stewart & Gray Road
Project to Woodruff Avenue' 55 70.5 70.6 0.1
M/nnriniff Ovaniia to Firactnna RniilavarH Rn f7 R f7 9 n 1 Washburn Road
Bellflower Road to Woodruff Avenue 35 62.5 62.7 0.2
Imperial Highway
Bellflower Road to Woodruff Avenue 63 74.0 74.0 0.0
Woodruff Avenue to 1-605 101 69.9 69.9 0.0
Source: HELIX 2023
' No NSLU along this roadway segment, distance and noise level shown for nearest commercial or industrial building.
NSLU = noise sensitive land use; dBA = A -weighted decibels; LEa = 1-hour time -averaged noise level Table 4.10-10
CUMULATIVE (YEAR 2024) OFF -SITE TRAFFIC NOISE LEVELS
Distance to
2024
2024 + Project
Increase
Roadway Segment
Nearest
P.M. Peak Hour
P.M. Peak Hour
(dBA LEq)
NSLU (feet)
(dBALEo)
(dBA LEq)
Firestone Boulevard
Woodruff Avenue to Stewart & Gray Road 64 ( 71.4 71.5 0.1 Stewart & Gray Road to 1-605' 105 71.0 71.1 0.1
Woodruff Avenue
Firestone Boulevard to Hall Road
74 68.6
68.7 0.1
Hall Road to Stewart & Gray Road'
70 69.5
69.7 0.2
Stewart & Gray Road to Washburn Road
77 68.4
68.5 0.1
Washburn Road to Imperial Highway
70 69.5
69.5 0.0
Hall Road
Project to Woodruff Avenue' 40 59.2 60.6 1.4
Stewart & Gray Road
Project to Woodruff Avenue' 55 70.5 70.7 0.2
M/nnriniff Avaniia to Firactnna Rniilavarrl Rn r,R n r,R ? n Washburn Road
Bellflower Road to Woodruff Avenue 35 62.6 62.8 0.2
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-16 December 2023
Exhibit D
Section 4.10
Noise
Distance to
2024
2024 + Project
Roadway Segment
Nearest
P.M. Peak Hour
P.M. Peak Hour
Increase
(dBA LEQ)
NSLU (feet)
(dBA LEQ)
(dBA LEQ)
Imperial H
Bellflower Road to Woodruff Avenue 1 63 74.1 74.1 0.0
Woodruff Avenue to 1-605 1 101 70.0 70.0 0.0
Source: HELIX 2023
z No NSLU along this roadway segment, distance and noise level shown for nearest commercial or industrial building.
NSLU = noise sensitive land use; dBA = A -weighted decibels; LEQ = 1-hour time -averaged noise level Impacts would be significant in areas where existing traffic noise at NSLUs exceeds 60 CNEL and implementation of the Project would result in an increase of the noise level by 3 CNEL or more (a just perceivable increase in typical noisy environments), or where existing traffic noise is less than 60 CNEL and implementation of the Project results in an increase of 5 CNEL or more. As shown in Table 4.10-9 and Table 4.10-10, the existing traffic noise exceeds 60 CNEL for all road segments except on Hall Road.
The maximum traffic noise increase as a result of the addition of Project traffic on any analyzed road segment would be 1.5 dBA on Hall Road for both the Existing and Cumulative conditions. The segment of Hall Road analyzed (from Woodruff Avenue to the Project's western driveway) does not have any NSLUs (Hall Road west of the Project site would not carry any Project truck traffic and was not analyzed).
The maximum traffic noise increase along a roadway segment with NSLUs would be 0.2 dBA (segments on Woodruff Avenue, Stewart and Gray Road, and Washburn Road) for the Existing conditions.
Therefore, the increase in traffic noise resulting from the addition of Project -related traffic would be less than 3 dBA and would not result in a perceptible increase in ambient noise levels. Noise impacts from Project -generated traffic would be less than significant.
Mitigation Measures
NOI-1: Construction Activity Limits
The Project applicant or designated contractor shall obtain permits for Project construction activities from the City. The City shall ensure all permits contain restrictions to construction hours, and nighttime work requirements described below.
All construction activity with the exception of concrete pouring as specified below shall be prohibited between the hours of 9:00 p.m. and 7:00 a.m. Monday through Saturday, and at any time on Sundays or on any City recognized public holiday. Delivery of materials or equipment to the site and construction truck traffic coming to and from the site shall be prohibited during the same hours specified above.
If, due to weather condition (e.g., high temperatures), pouring of concrete at night or on Sundays or on any City recognized public holiday is required, the Project applicant or designated contractor shall provide written notification of nighttime/weekend concrete work to all residences located within 300 feet of the Project site. The notification shall:
• Be delivered a minimum of 48 hours prior to commencement of nighttime work; • Include the days and hours of upcoming concrete pouring nighttime work; and • Include noise complaint contact information, including phone numbers and email addresses to register noise complaints with both the construction contractor and the City.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-17 December 2023
Exhibit D
Section 4.10
Noise
The City and the construction contractor shall log all received noise complaints. The construction contractor shall submit to the City a daily log of all noise complaints received, including the date and time of the complaint and address of the complainant (if provided). The City shall work with the construction contractor to respond to noise complaints and limit nighttime work and locations of noise generating equipment to the extent feasible.
Threshold 4.10-b: Would the Project result in the generation of excessive groundborne vibration or groundborne noise levels?
Less than Significant Impact. Ground -borne vibration would be potentially significant if the Project would result in ground -borne vibration which exceeds the "strongly perceptible" vibration annoyance potential criteria for human receptors of 0.1 inch per second peak particle velocity (PPV) for nearby residences, or exceed the threshold for architectural damage potential criteria for buildings in good repair with gypsum bard walls of 0.4 inch per second PPV, for continuous/frequent intermittent construction sources (such as impact pile drivers, vibratory pile drivers, and vibratory compaction equipment (Caltrans 2020).
Construction activities known to generate excessive ground -borne vibration, such as pile driving, would not be conducted by the Project. A possible source of vibration during general Project construction activities would be a vibratory roller used for gravel or pavement compaction. A vibratory roller could be used up to 25 feet from the closest off -site structure (two commercial buildings to the east). A large vibratory roller can create approximately 0.210 inch per second PPV at 25 feet (Caltrans 2020), which would not exceed the 0.4 inch per second PPV threshold for damage to buildings in good repair with gypsum wall boards, for continuous/frequent intermittent construction sources. The closest residential building would be a single-family residence appropriately 240 feet east of the Project site.
A 0.210 inch per second PPV vibration level would equal 0.017 inch per second PPV at a distance of 240 feet.' This would be significantly lower than what is considered a "strongly perceptible" level for humans of 0.1 inches per second PPV. While the use of a vibratory roller during construction may be perceptible in the adjacent commercial buildings, construction of the Project would not exceed applicable thresholds for groundborne vibration or noise for adjacent commercial or nearby residential buildings. Therefore, the impact would be less than significant.
Land uses that may generate substantial operational vibration include heavy industrial or mining operations that would require the use of vibratory equipment. The proposed warehouse land use does not include equipment that would generate substantial vibration. Therefore, operational vibration impacts are less than significant.
Neither construction nor long-term operation of the Project would generate excessive ground -borne vibration or ground borne noise levels. Impacts would be less than significant.
Mitigation Measures
No mitigation measures are required.
z Equipment PPV = Reference PPV * (25/D)" (in/sec), where Reference PPV is PPV at 25 feet, D is distance from equipment to the receiver in feet, and n = 1.1 (the value related to the attenuation rate through the ground); formula from Caltrans 2020.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-18 December 2023
Exhibit D
Section 4.10
Noise
4.10.7 Cumulative Impacts
The analysis of potential cumulative noise and vibration impacts attributable to construction and stationary sources considers the proposed Project along with other cumulative projects in the City and neighboring areas due to the localized nature of noise impacts. As discussed above, with the implementation of mitigation measure NOI-01, the proposed Project would result in less than significant impacts to noise. As shown in Table 3-1, List of Related Projects, in Section 3.2, Cumulative Projects, there are seven projects in the City of Downey and two projects in the City of Norwalk which have been identified as part of the analysis of cumulative impacts. The projects identified in the City of Downey include a truck terminal, a warehouse, housing, manufacturing, retail, and a hotel. The two projects in the City of Norwalk are car washes. As shown in Figure 3-1, Related Project Locations, five of the projects in the City of Downey are located within 0.5 mile of the proposed Project. The closest project (D1) is a truck terminal at 12021 Woodruff Avenue and is approximately 710 feet south of the Project. At the time of the analysis, project D1 is at an advanced stage of construction and is anticipated to be completed before Project construction starts.
Due to the distance between the proposed Project and other cumulative projects and with the implementation of mitigation measure NOI-01 to prohibit project construction noise generating activities during nighttime hours, on Sundays and City recognized holidays (as defined by the City's Municipal Code Section 4606.5), the Project's contribution to cumulative noise impacts would be less than significant and less than cumulatively considerable.
4.10.8 Significant Unavoidable Impacts
Nighttime construction activities associated with concrete pours could potentially expose NSLUs within 300 feet of the Project site to temporary construction noise more than 10 dBA above nighttime ambient noise levels. Mitigation measure NOI-1 is identified and would be implemented; however, it would not reduce Project temporary construction -related noise levels to acceptable limits. Therefore, impacts associated with nighttime concrete pouring noise would be significant and unavoidable.
4.10.9 References
California Department of Transportation (Caltrans). 2020. Transportation and Construction Vibration Guidance Manual. April. Available at: https:/Zdot.ca.gov/-ZmediaZdot- i rams environmental -anal sis documents env tcv m-a r2020-a11 df. 2013. Technical Noise Supplement (TeNS) to the Traffic Noise Protocol. September. Available at:
http:ZZvvvvvv.dot.ca. ov h env no iseZpub TeNS Set 2013B, df.
City of Downey. January 2005. Vision 2025 General Plan. Available at:
htt s: www.downe ca.or home show ubiisheddocument 154 636977201799600000.
Accessed February 6, 2023.
HELIX Environmental Planning, Inc. (HELIX). 2023. Prologis Stewart and Gray Road Warehouse Project Noise and Vibration Report. October.
Linscott, Law & Greenspan, Engineers (LLG). 2023. Transportation Impact Study, Prologis Stewart & Gray Road Warehouse Project. September.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.10-19 December 2023
Exhibit F1
Section 4.10
Noise
U.5.Department ofTransportation (U5DOT). 2OOO.Roadway Construction Noise Model Version 1.1.
Available at:
2004. Traffic Noise Model Version 2.5. Available at:
pmloobStewart and Gray Road Warehouse Project City ofDowney
Exhibit D
4.11 TRANSPORTATION
4.11.1 Introduction
Section 4.11
Transportation
This section of the EIR evaluates potential impacts on the transportation system resulting from implementation of the Project. The analysis is based, in part, on a Transportation Impact Study (TIS; Linscott, Law & Greenspan, Engineers [LLG] 2023) prepared for the Project which is included as Appendix L of this EIR.
4.11.2 Environmental Setting
The Project site is located within a multi -modal transportation network within the City of Downey. Each component of the multi -modal transportation network is discussed in more detail below.
4.11.2.1 Roadway Network
Primary regional access to the Project site is provided by the San Gabriel River (1-605) Freeway and the Glenn Anderson (1-105) Freeway. The 1-605 Freeway is a major north -south freeway connecting the 1-210 Freeway to the north and 1-405 Freeway to the south. In the Project vicinity, five to six mixed -flow freeway lanes and one high occupancy vehicle (HOV) lane are provided in each direction on the 1-605 Freeway with auxiliary merge/weave lanes provided between some interchanges. Northbound and southbound on/off ramps are provided to and from the 1-605 Freeway at Firestone Boulevard, approximately 0.75 mile east of the Project site. The 1-105 Freeway is an east -west oriented freeway connecting the LAX/El Segundo area to the west with the 1-605 Freeway to the east. In the Project vicinity, three to four mixed -flow freeway lanes and one HOV lane are provided in each direction on the 1-105 Freeway. Eastbound and westbound on/off ramps are provided to and from the 1-105 Freeway at Bellflower Boulevard in the Project area. The existing roadway network in the Project vicinity is described in Table 4.11-1, Existing Roadways in the Project Vicinity.
Table 4.11-1
EXISTING ROADWAYS IN THE PROJECT VICINITY
Travel
Lanes
Number of
Speed Limit
Roadway
Classification
Direction
Lanes in Both
Median Type
(miles per
Directions
hour)'
on Roadway
Woodruff Avenue
Primary Arterial
Northbound-
41,2
2-Way Left Turn
35 to 40
Southbound
Lane
Newville Avenue
Local Street
Northbound-
21 N/A
25 Southbound
Hoxie Avenue
Collector
Northbound-
42 N/A
35 Southbound
Firestone
Major Arterial
Eastbound-
6 to 41,2
Raised Median
40 Boulevard
Westbound
Island
Hall Road
Collector
Eastbound-
21 N/A
25 Westbound
Stewart and Gray
Secondary Arterial
Eastbound-
I
41 2-Way Left Turn
40 Road
Westbound
Lane
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-1 December 2023
Exhibit D
Section 4.11
Transportation
Travel
Lanes
Number of
Speed Limit
Roadway
Classification
direction
Lanes in Both
Median Type
(miles per
Directions
hour)
on Roadway
Washburn Road
Collector
Eastbound-
21 N/A
30 Westbound
Imperial Highway
Major Arterial
Eastbound-
61,2
Raised Median
40 Westbound
Island
Source: LLG 2023
1 City of Downey
z City of Norwalk
Vehicular access to the Project site is currently provided via four driveways off Stewart and Gray Road and three driveways off Hall Road that lead to private internal roads. The on -site internal roads connect together around each of the existing buildings on site. These internal roads provide parking for employees, parking for trailers and containers, recycling equipment and storage of heavy operation equipment.
4.11.2.2 Public Transit Network
Public bus transit service is provided within the Project vicinity. Public bus transit service is currently provided by the City of Downey (DowneyLink) and the Los Angeles County Metropolitan Transportation Authority (Metro). A summary of the existing transit service in the vicinity of the Project site is presented in Table 4.11-2, Existing Transit Routes, and are shown in Figure 4.11-1, Existing Transit Routes. As summarized in Table 4.11-2, a total of seven public transit routes provide service within the Project vicinity. The nearest Metro transit stops are provided on both sides of Firestone Boulevard, west of Woodruff Avenue (within an approximate 0.3-mile walk (north) of the Project site) and at the northwest and southwest corners of the Stewart and Gray Road/Firestone Boulevard intersection (within an approximate 0.4-mile walk (east) of the Project site). Transit service at these stops is provided every 1S minutes during the weekday morning and afternoon peak hours.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-2 December 2023
Exhibit D
Prologis Stewart & Gray Road Warehouse Project
HELIX
Environmental Planning
Source: Linscott, Law & Greenspan, 2022
a • —
Exhibit D
Section 4.11
Transportation
Table 4.11-2
EXISTING TRANSIT ROUTES
Number of
Buses/Trains
Roadways Near the
during
Peak Hours
Direction
A.M.
_
P.M.
Route
Destinations
Project Site
DowneyLink-
Northeast Downey
Woodruff Avenue,
Clockwise
0 0
Counter
1 2
Northeast
Firestone Boulevard
Clockwise
DowneyLink-
Southeast Downey
Woodruff Avenue,
Clockwise
3 2
Southeast
Firestone Boulevard,
Counter
0 0
Imperial Highway
Clockwise
Metro 115
Playa Del Rey to Norwalk
Woodruff Avenue,
Eastbound
4 4
Westbound
4 4
via Westchester, Inglewood,
Stewart and Gray
Los Angeles, Florence, South
Road, Hoxie Avenue,
Gate, and Downey
Firestone Boulevard
Metro 120
El Segundo to Whittier
Woodruff Avenue,
Eastbound
1 1
Westbound
_
1 1
via Inglewood, Los Angeles,
Imperial Highway
Willowbrook, Lynwood,
Downey, Norwalk, and Santa
Fe Springs
Metro 125
El Segundo to Norwalk
Woodruff Avenue,
Eastbound
4 3
via Lawndale, Los Angeles,
Imperial Highway
Westbound
3 3
Compton, and Downey
Metro 127
Los Angeles to Downey via
Lakewood Boulevard,
Eastbound -
1 1
Rosewood, Compton,
Firestone Boulevard
Northbound
Westbound-
2 2
and Paramount
Southbound
Metro 266
Pasadena to Lakewood
Lakewood Boulevard,
Northbound
3 3
Southbound
3 3
via Temple City, South El
Firestone Boulevard
Monte, Pico Rivera, Downey,
and Bellflower
Total
30 29
Source: LLG 2023
4.11.2.3 Pedestrian and Bicycle Facilities
Non -vehicular transportation generally encompasses walking, biking, and other active transportation modes. Distinct facilities are often provided for these non -vehicular modes. Most prominently, paved sidewalks are typically provided to facilitate pedestrian travel outside of the roadway. In some cases, bicycle facilities such as painted bike lanes or separated bike paths are provided within the roadway in order to separate bike traffic from vehicular traffic. Roadways which are designed to prioritize non - vehicular transportation modes utilize complimentary non -vehicular infrastructure in order to promote comfortable, safe travel for both pedestrians and bicyclists.
Pedestrian infrastructure consists of facilities such as sidewalks, crosswalks, pedestrian signals, curb access ramps, Americans with Disabilities Act (ADA) compliant tactile warning strips, and curb extensions, among other things. These facilities are provided within the Project vicinity at major intersections, including the Woodruff Avenue/Stewart and Gray Road intersection, located at the southeast corner of the Project site. Sidewalks are provided along most major corridors in the Project Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-3 December 2023
Exhibit D
Section 4.11
Transportation
vicinity, and marked crosswalks, pedestrian signals, and curb ramps are also provided at signalized intersections. Existing public sidewalks in closest proximity to the Project site are provided on the south side of Hall Road west of Woodruff Avenue (directly adjacent to the north of the Project site), on both sides of Woodruff Avenue between Hall Road and Stewart and Gray Road (adjacent to the east of the Project site), and on both sides of Stewart & Gray Road west of Woodruff Avenue (adjacent to the south of the Project site). Existing pedestrian facilities within an approximate 1,320-foot (0.25 mile) radius of the Project site are presented in Figure 4.11-2, Existing Nearby Pedestrian and Transit Facilities.
Bicycle infrastructure consists of both facilities within the roadway as well as public bicycle parking spaces. The federal and State transportation systems recognize three primary bikeway facilities: Bicycle Paths (Class 1), Bicycle Lanes (Class 11), and Bicycle Routes (Class III). Bicycle Paths (Class 1) are exclusive car free facilities that are typically not located within a roadway area. Bicycle Lanes (Class 11) are part of the street design that is dedicated only for bicycles and identified by a striped lane separating vehicle lanes from bicycle lanes. Bicycle Routes (Class 111) are preferably located on collector and lower volume arterial streets.
The existing and proposed bicycle infrastructure in the City of Downey is illustrated in Figure 4.11-3, Existing and Planned Bikeways. The Southern California Regional Bikeway Shapefile (RBS) identifies potential bicycle routes within the City. As shown in Figure 4.11-3, potential bicycle routes in closest proximity to the Project site include Woodruff Avenue, Firestone Boulevard, Stewart and Gray Road, Washburn Road, and Imperial Highway. Additionally, the Downey Bike Master Plan Implementation Phase 1 Downtown/Transit project under Capital Improvement Program (CIP) 19-14 would include installation of Class 11 bicycle facilities on nine roadway segments, bicycle parking facilities, and way - finding signs.
4.11.3 Regulatory Framework
4.11.3.1 State
Senate Bill 743
Senate Bill (SB) 743, which was codified in Public Resources Code Section 21099 on September 27, 2013, required changes to the guidelines implementing California Environmental Quality Act (CEQA) regarding the analysis of transportation impacts. Specifically, SB 743 required the Governor's Office of Planning and Research (OPR) to amend the CEQA Guidelines to provide an alternative to level of service (LOS) for evaluating transportation impacts. Particularly within areas served by transit, those alternative criteria must promote the reduction of greenhouse gas emissions, the development of multi -modal transportation networks, and a diversity of land uses. To that end, OPR published its Technical Advisory on Evaluating Transportation Impacts in CEQA (2018 Technical Advisory) in December 2018, and the California Natural Resources Agency has certified and adopted changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project's transportation impacts. With the California Natural Resources Agency's certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by LOS and other similar metrics, are no longer the basis for determining a significant environmental effect under CEQA. State-wide implementation of the new metric was required by July 1, 2020.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-4 December 2023
Exhibit D
vroiogis Stewart & uray Koaa warenouse vroject
',
SIGNAL TRUNCATED DOME ✓ YLLLUVV
BIKE RACK
STOP SIGN TRASH
BUS STOP
4�\b
7 BIKE ROUTE
BB
BUS STOP WITH
oil
MAIL BOX
BUS BENCH
BUS STOP WITH
BUS BENCH P,.-,HFI TFR I
Source: Linscott, Law & Greenspan, 2022
HELIX Existing Nearby Pedestrian and Transit Facilifflies Fawroamonfal Planning Figure 4.11-2
Exhibit D
s Stewart & uraV Koaci warenouse
Existing Bilkew3y5_ Proposed/Planned Bikeways
IV Class I Class 11 IV Class III IV Class IV Class I Class, IIg,Class III Class IV MAP SOURCE: SCAG -THE 2024 REGIONAL TRANSPORTATION PLAN/SUSTAINABLE COMMUNITIES STRATEGY Source: Linscott, Law & Greenspan, 2022
HELIX Existing and Planned Bikeways
Environmental Planning Figure 4.11-3
Exhibit D
Section 4.11
Transportation
4.11.3.2 Local
SCAG Regional Transportation Plan/Sustainable Communities Strategy The 2020 RTP/SCS (SCAG 2020) is a major planning document for the regional transportation and land use network. It balances the region's future mobility and housing needs with economic, environmental, and public health goals. This long-range Plan, required by the state of California and the federal government, is updated by SCAG every four years as demographic, economic, and policy circumstances change. The 2020-2045 RTP/SCS' "Core Vision" prioritizes the maintenance and management of the region's transportation network; expanding mobility choices by co -locating housing, jobs, and transit; and increasing investment in transit and complete streets. Strategies to achieve the 2020 RTP/SCS Core Vision include, but are not limited to: Smart Cities and Job Centers, Housing Supportive Infrastructure, Go Zones, and Shared Mobility. The goals of the 2020 RTP/SCS fall into four core categories — economy, mobility, environment, and healthy/complete communities. As discussed in Section 4.9, Land Use and Planning, the 2020 RTP/SCS include a number of goals to achieve the Core Vision of increased mobility options and a more sustainable growth pattern. The goals specific to transportation and mobility include:
• Improve mobility, accessibility, reliability, and travel safety for people and goods. • Enhance the preservation, security, and resilience of the regional transportation system. • Increase person and goods movement and travel choices within the transportation system. • Adapt to a changing climate and support an integrated regional development pattern and transportation network.
• Leverage new transportation technologies and data -driven solutions that result in more efficient travel.
City of Downey General Plan
The Circulation Element and the Safety Element identifies a number of applicable goals, policies, and programs related to transportation. Goals, policies, and programs related to transportation that are applicable to the Project include the following:
Circulation Element
• Goal 2.1. Increase the capacity of the existing street system. o Policy 2.1.2. Promote improvements in the street system through the development process.
■ Program 2.1.2.3. Reduce the number of driveway access points on streets. ■ Program 2.1.2.5. Discourage projects that generate high amounts of traffic onto local and collector streets.
■ Program 2.1.1.6. Identify and concentrate land uses with high traffic generation near major transportation corridors and public transit facilities.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-5 December 2023
Exhibit D
Section 4.11
Transportation
• Goal 2.2. Promote the use of alternative modes of travel, other than single -occupant vehicles, to relieve traffic congestion.
o Policy 2.2.1. Promote walking as an attractive alternative to vehicular transportation. ■ Program 2.2.1.1. Promote site development design that is safe and convenient to pedestrians.
■ Program 2.2.1.2. Provide sidewalks in new development and major remodeling consistent with the sidewalk Master Plan.
o Policy 2.2.2. Promote bicycling as an attractive alternative to vehicular transportation. ■ Program 2.2.2.3. Promote the provision of bicycle racks at retail service and other businesses for use by customers and employees.
■ Program 2.2.2.4. Encourage the provision of showers, changing rooms, and bicycle storage areas at retail, office, industrial, and other businesses for use by employees.
• Goal 2.3. Reduce adverse impacts from truck traffic.
o Policy 2.3.1. Promote the safe and efficient movement of truck traffic through the City. ■ Program 2.3.1.1. Enforce truck traffic to use designated truck routes in the City. ■ Program 2.3.1.5. Support truck mobility efforts to keep container truck traffic traveling through the region on freeways.
o Policy 2.3.2. Minimize negative impacts associated with truck traffic. ■ Program 2.3.2.1. Discourage truck parking on public streets. ■ Program 2.3.2.2. Maintain landscape islands on and/or adjacent to truck routes with mature specimen fully grown landscape screens to minimize noise, dust, and visual impacts.
■ Program 2.3.2.3. Promote property development designs along truck routes that minimize noise, dust, and visual impacts through the use of berms, landscape screening, walls, and other design features.
■ Program 2.3.2.4. Ensure that land uses generating high amounts of truck traffic provide compensation to the city for projected pavement wear of public streets. o Policy 2.3.3. Discourage land uses that generating high amounts of truck traffic. ■ Program 2.3.3.1. Discourage land uses that attract high amounts of truck traffic without corresponding benefits to the community.
Program 2.3.3.2. Provide discretionary approvals for land uses generating high amounts of truck traffic, including general warehouses, truck parking, truck company headquarters, and distribution centers.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-6 December 2023
Exhibit D
Section 4.11
Transportation
Safety Element
• Goal 5. 7. Reduce the likelihood of traffic accidents. o Policy 5. 7 .1. Promote traffic safety along streets. ■ Program 5. 7 .1.3. Promote street design that impedes the use of local residential streets as bypass and through routes.
■ Program 5. 7 .1.6. Promote the parking and access agreements and parking consolidation to reduce the number of driveway access points on streets. ■ Program 5.7.1.7. Provide for vehicles to enter onto streets in a perpendicular manner.
■ Program 5.7.1. 8. Promote designs to provide for vehicles to enter onto streets in a forward manner.
o Policy 5.7.2. Promote the installation of sidewalks and walkways to improve traffic safety.
■ Program 5.7.2.2. Encourage the installation of sidewalks in new developments and major remodeling consistent with the sidewalk Master Plan. ■ Program 5.7.2.4. Promote internal walkways and bikeways on private property that are safe and convenient to bicyclists.
4.11.4 Significance Criteria and Thresholds
According to Appendix G of the CEQA Guidelines, a significant impact associated with transportation would occur if implementation of the proposed Project would:
a) Conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency access?
4.11.5 Methodology and Assumptions
The City of Downey has not formally adopted VMT methodology, screening criteria, or thresholds for VMT analysis of land use development projects within its jurisdiction. Instead, the City follows the methodology set forth in the Los Angeles County Public Works Transportation Impact Analysis Guidelines (County Guidelines). The County Guidelines provide guidance for projects to determine whether a Transportation Impact Analysis should be performed and screening criteria to determine if a project may generate a significant transportation impact. Consistent with the recommendations provided by the California Governor's Office of Planning and Research (OPR) in the 2018 Technical Advisory, the County Guidelines recognize four screening criteria which may be applied to screen Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-7 December 2023
Exhibit D
Section 4.11
Transportation
proposed projects out of detailed VMT analysis: non -retail project trip generation screening criteria, retail project site plan screening criteria, proximity to transit based screening criteria, and residential land use -based screening criteria. If a project satisfies one of the screening criteria, then it can be screened out of detailed VMT analysis requirements. Section 3.1.2 of the County Guidelines contain the screening criteria, which are listed below:
• Section 3.1.2.1. - Non -Retail Project Trip Generation Screening Criteria If the development project does not generate a net increase of 110 or more daily vehicle trips, further analysis is not required, and a less than significant determination can be made. • Section 3.1.2.2. - Retail Project Site Plan Screening Criteria A project that contains a local serving retail use is assumed to have less than significant VMT impacts for the retail portion of the project. If the project does not contain retail uses that exceed 50,000 square feet of gross floor area, a less than significant determination can be made for the portion of the project that contains retail uses. • Section 3.1.2.3. — Proximity to Transit Based Screening Criteria If the project is located within a one-half mile radius of a major transit stop or an existing stop along a high -quality transit corridor, then the following subsequent questions should be considered:
o Does the project have a Floor Area Ratio less than 0.75? o Does the project provide more parking than required by the County Code? o Is the project inconsistent with the SCAG RTP/SCS?
o Does the project replace residential units set aside for lower income households with a smaller number of market -rate residential units?
If the answer to all four questions is no, further VMT analysis is not required, and a less than significant determination can be made.
• Section 3.1.2.4. — Residential Land Use Based Screening Criteria Independent of the screening criteria for non -retail and retail projects, certain projects that further the State's affordable housing goals are presumed to have less than significant impact on VMT. If the project requires a discretionary action and 100% of the units, excluding manager's units, are set aside for lower income households, further analysis is not required, and a less than significant determination can be made.
The proposed Project does not satisfy any of the four screening criteria stated in the County Guidelines and is not screened out of further VMT analysis.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-8 December 2023
Exhibit D
Section 4.11
Transportation
4.11.6 Impacts and Mitigation Measures
Threshold 4.11-a: Would the Project conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
Less than Significant Impact. The Project's consistency with the applicable portions of the 2020 RTP/SCS and Downey General Plan (DGP) Vision 2025 are discussed below.
SCAG Regional Transportation Plan/Sustainable Communities Strategy As discussed in Section 4.9, Land Use and Planning, the overarching strategy of the 2020 RTP/SCS is to integrate land use and transportation with policies that are directed towards the development of regional land use patterns that contribute to reductions in VMT and improvements to transportation systems. As the Project is proposed on an already developed site within a developed industrial area, the opportunity for integrating land use in a manner that improves mobility and enhances the regional transportation system and the movement of persons and goods within the system is limited. The Project does not directly conflict or result in inconsistencies with the identified goals. As discussed under threshold 4.11-b below, with implementation of mitigation, the Project would not result in significant VMT impacts. Truck traffic associated with the Project would utilize truck routes designated by the City for accessing nearby freeways, minimizing impacts to the local and regional transportation system by utilizing routes intended for such uses. As discussed in Table J-1 in Appendix J, the Project would be consistent with the transportation and mobility -related goals of the RTP/SCS. As such, the Project would not result in conflicts with the 2020 RTP/SCS.
City of Downey General Plan
The Project site is designated General Manufacturing (GM) in the DGP Vision 2025, which is intended for manufacturing, wholesaling, and other industrial land uses. There are a number of General Plan goals, policies, and programs specific to transportation that are relevant to the Project, as described in Section 4.11.3.2. The goals, policies, and programs of the General Plan that are relevant to transportation are generally contained in the Circulation Element, although a few are contained in the Safety Element. As demonstrated in Table J-2 in Appendix J, the Project is consistent with the applicable goals, polices, and programs of the Circulation Element and Safety Element. With respect to Circulation Element policies, Policy 2.3.3 discourages land uses that generate high amounts of truck traffic. The Project would operate 24 hours a day, 7 days a week and would generate truck traffic resulting in an increase in traffic in the Project vicinity. Over a 24-hour period, the Project is forecast to result in an increase of 167 passenger car equivalent adjusted vehicles trips during a typical weekday, consisting of approximately 84 more inbound trips and 84 more outbound trips (LLG 2023) than the existing conditions. As discussed further in response to Threshold 4.11-b below, while the Project would result in an increase in traffic in the Project vicinity, with the implementation of mitigation, the Project would not result in significant VMT impacts. Furthermore, the proposed project would implement a TDM program to reduce VMT impacts which would include onsite facilities to support bicycling and alternative modes of transportation for employees, which would be consistent with Policy 2.2.2 of the General Plan.
Moreover, the supporting Programs identified in the Circulation Element under Policy 2.3.3 further specify to discourage land uses that attract high amounts of truck traffic without corresponding benefits Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.11-9 December 2023
Exhibit D
Section 4.11
Transportation
to the community (Program 2.3.3.1). The Project would provide additional industrial sector uses that provide goods movement services and employment opportunities for the community and region.
Program 2.3.3.2 requires discretionary approvals for land uses generating high amounts of truck traffic, including general warehouses, truck parking, truck company headquarters, and distribution centers. The Project is subject to the City's discretionary approval process to identify and minimize potential impacts.
With regard to transportation, the Project would not result in significant VMT impacts with implementation of mitigation identified in Threshold 4.11-b below. As such, the Project would be consistent with General Plan Policy 2.3.3.
In addition to the goals, programs, and policies discussed above, the Circulation Element identifies acceptable level of service (LOS) as A, B, C, or D: "...the general plan advances programs to reduce congestion to provide acceptable LOS, defined as A, B, C, or D." While LOS is no longer a measure of transportation impacts for the purposes of CEQA, it is discussed here in the context of consistency with a program plan, ordinance, or policy addressing the circulation system (i.e., the General Plan Circulation Element). Based on the Project's Transportation Impact Study (LLG 2023), analyzed intersections in the Project vicinity that are part of the City's Circulation Element roadway network would operate at a LOS D or higher during the a.m. and p.m. peak hours. As such, the Project would be consistent with the Circulation Element requirement for acceptable LOS.
With regard to other transportation modes, the Project would be consistent with Circulation Element Goal 2.2 to promote the use of alternative modes of travel. Sidewalks are present on all streets surrounding the Project site, providing pedestrian access to the site; however, the Project would provide improved sidewalks with landscaping and parkway plantings along Hall Road and Stewart and Gray Road for the entire Project site frontage. The Project site is located within one -quarter mile three Metro bus lines, which would provide Project employees with access to alternative transportation. The Project would implement a TDM Program to reduce transportation VMT impacts, which would include measures to promote alternative transportation modes, including the provision of bicycle racks, bicycle storage areas, showers, and changing rooms.
General Plan Program 2.3.1.1 requires that the City enforce designated truck routes through the City.
Truck traffic generated by the proposed Project, both during construction and operations, would be required to follow the designated truck routes as a condition of approval. Truck routes in the vicinity of the proposed Project include Stewart and Gray Road, Woodruff Avenue, and Firestone Boulevard. Hall Road also borders the proposed Project site but is not a designated truck route, and therefore truck traffic generated by the proposed Project would be required to use Stewart and Gray Road instead in order to comply with the General Plan.
Project impacts associated with a program plan, ordinance, or policy addressing the circulation system, would be less than significant.
Mitigation Measures
No mitigation is required.
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Exhibit D
Section 4.11
Transportation
Threshold 4.11-b: Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less than Significant with Mitigation Incorporated. CEQA Guidelines section 15064.3 describes specific considerations for evaluating a project's transportation impacts and states that generally, VMT is the most appropriate measure of transportation impacts. VMT refers to the amount and distance of automobile travel attributable to a project. Consistent with the requirements in the County Guidelines, the Project was screened based on the County screening criteria (refer to Section 4.11.4 for screening criteria) to determine if a detailed VMT analysis would be required. While the Project is located within a high -quality transit corridor (which is one of the four screening criteria identified in Section 3.1.2 of the County Guidelines), it does not meet all of the criteria identified in the four subsequent questions to screen out of VMT analysis based on proximity to transit. As such, the Project does not meet any of the four screening criteria (non -retail project trip generation, retail project site plan, proximity to transit, or residential land use) stated in the County Guidelines. A VMT analysis is required to determine if the Project would result in significant transportation impacts.
VMT Analysis Impact Criteria
While the proposed Project is not an office project, employees are expected to be the main source of VMT generated by the Project. Therefore, the office land use impact criterion has been used for VMT analysis. The proposed Project is located in the South County Baseline Area, which generally consists of the region of Los Angeles County that is situated below the Santa Susana and San Gabriel Mountain Ranges. The County Guidelines state that the South County employment VMT baseline is 18.4 VMT per employee. Therefore, the threshold of 16.8 percent below the baseline employment VMT (18.4) is
15.3 VMT per employee. A significant transportation impact would result if the Project VMT exceeds
15.3 VMT per employee.
VMT Analysis
The Southern California Association of Governments Regional Travel Demand Model (SCAG RTDM) has been utilized to determine the employment VMT per employee for the proposed Project. The Project site is located within Traffic Analysis Zone (TAZ) 21791300. The TAZ is generally bounded by Firestone Boulevard to the north, Woodruff Avenue to the east, Stewart & Gray Road to the south, and Lakewood Boulevard and Bellflower Boulevard to the west. The existing land uses within the TAZ includes a mix of residential, commercial, and industrial land uses. Therefore, the proposed Project is consistent with the land uses assumed for the TAZ, and the existing VMT per employee for the TAZ is an adequate proxy for the VMT per employee expected to be generated by the proposed Project. Based on the SCAG RTDM model output for TAZ 21791300, the proposed Project is forecast to generate a baseline employment VMT of 19.2 VMT per employee, which exceeds the County Guidelines threshold of 15.3 VMT.
Project Design Features
The following Transportation Demand Management (TDM) strategy from the California Air Pollution Control Officers Association's (CAPCOA) Handbook forAnalyzing Greenhouse Gas Emissions, Assessing Climate Vulnerabilities, and Advancing Health Equity (CAPCOA 2021) has been determined to be applicable to the Project as a project design feature:
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Exhibit D
Section 4.11
Transportation
T-2. Increase Job Density. This measure accounts for the VMT reduction achieved by a project that is designed with a higher density of jobs compared to the average job density in the country. When reductions are being calculated from a baseline derived from a travel demand model, the job density of the relevant TAZ is used for the comparison instead. Increased densities affect the distance people travel and provide greater options for the mode of travel they choose. Increasing job density results in shorter and fewer trips by single -occupancy vehicles and thus a reduction in VMT.
The Project VMT forecast is derived from the SCAG RTDM output data. Therefore, the reduction in VMT that is expected to result due to the development of the proposed Project is determined by comparing the existing job density in TAZ 21791300 without and with the proposed Project. The number of existing jobs and acres in the TAZ was obtained from the RTDM. The number of jobs with the proposed Project was developed based on trip rates provided by ITE for the proposed Project and for the existing land use, resulting in a forecast net increase of 2,097 employees in the TAZ.
Project design feature T-2 described above is expected to result in a 9.9 percent reduction in VMT generated by the proposed Project. Application of the VMT reduction to the Project VMT forecast derived from the RTDM is forecast to generate 17.3 VMT per employee', when accounting for the identified project design feature. Thus, the Project -generated VMT per employee exceeds the South County threshold of 15.3 VMT per employee; therefore, the Project would result in a significant VMT impact. A summary of the project -level VMT analysis is presented in Table 4.11-3, Summary of Vehicle Miles Traveled Analysis, which presents the baseline VMT forecast, the VMT reductions due to project design features, and the VMT reductions due to mitigation measures.
Table 4.11-3
SUMMARY OF VEHICLE MILES TRAVELED ANALYSIS
Vehicle Miles Traveled (VMT) Analysis Conditions
VMT
Baseline VMT per Employee from SCAG Regional Transportation Demand Model'
19.2 VMT Reductions Due to Project Design Features
-9.9%
Project -Generated VMT Per Employee
17.3 Significant Impact?'
Yes
VMT Reductions Due to Mitigation Measures
-11.9%
Project -Generated VMT per Employee After Mitigation
15.2 Significant Impact?'
No
Source: LLG 2023
1 Baseline VMT per employee obtained from the Southern California Association of Governments (SCAG) Regional Travel Demand Model (RTDM) for transportation analysis zone (TAZ) 21791300. z A significant impact occurs when the Project -generated VMT per employee exceeds the South County threshold of
15.3 VMT per employee.
Mitigation Measures
TR-1: Transportation Demand Management Plan. The Project Applicant shall prepare a formal Transportation Demand Management (TDM) Plan for review and approval by the City prior to the issuance of grading or building permits. The TDM Plan shall identify the TDM measures that will be implemented for the Project and shall include documentation of how both physical measures ' 19.2 VMT/employee * (1-0.099) = 17.3 VMT/employee.
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Exhibit D
Section 4.11
Transportation
(e.g., bike lockers, designated carpool parking spaces, etc.) and programmatic measures (e.g., guaranteed ride home program, employee transportation coordinator, etc.) will be provided. The TDM Plan shall be implemented for the life of the Project and shall include, at a minimum, the TDM strategies listed below (TDM Strategies T-7, T-8, and T-10) to reduce significant VMT impacts. If new TDM measures are proposed by the site owner or tenant after City approval of the TDM Plan, a new TDM plan shall be submitted for review and approval and shall include an analysis that demonstrates that the selected measures are expected to achieve the same or greater trip and VMT reductions as demonstrated by this Project -specific analysis.
T-7. Implement Commute Trip Reduction Marketing. The Project Applicant shall implement a marketing strategy to promote the Commute Trip Reduction (CTR). Information sharing and marketing educates employees about their travel choices to and from the location and promotes alternatives to driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT. Effective marketing strategies incorporate the following features or similar alternatives:
o On -site or online commuter information services.
o Employee transportation coordinators.
o On -site or online transit pass sales.
o Guaranteed ride home service.
The Project Applicant shall provide information on available travel options to and from the Project site in a clear and easily accessible location (e.g., a bulletin board in a common employee area), including information on where transit passes may be purchased online or in person. The Project Applicant shall also designate an employee transportation coordinator who will be able to provide information and/or administer a guaranteed ride home service. Such services may consist of providing free or subsidized rides upon request via taxis or other transportation network companies (TNC) such as Uber or Lyft.
T-8. Provide Ridesharing Program. The Project Applicant shall implement a ridesharing program.
Ridesharing encourages carpooled vehicle trips in place of single -occupancy vehicle trips, thereby reducing the number of trips and VMT. Ridesharing may be promoted through a multifaceted approach, such as designating parking spaces for ridesharing/carpooling vehicles, dedicating loading and waiting zones, and coordinating rides. The Project Applicant shall provide designated parking spaces for carpool vehicles in a convenient/preferential location, and a designated waiting area for employees participating in ridesharing which is comfortable and convenient. The Project Applicant should facilitate the process of arranging ridesharing or carpooling matches, either through a website/app or via the employee transportation coordinator (refer to TDM measure T-7 above).
T-10. Provide End -of -Trip Bicycle Facilities. The Project Applicant shall provide end -of -trip bicycle facilities such as secure bike parking, showers, and personal lockers. Providing and maintaining securing bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT. The Project Applicant shall provide secure bicycle parking (e.g., bicycle lockers) in an easily accessible, well -lit location. Additionally, the Project Applicant shall provide showers and changing rooms.
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Exhibit D
Section 4.11
Transportation
Implementation of mitigation measure TR-1 described above is expected to result in an 11.9 percent reduction in commute VMT generated by the proposed Project, as shown in Table 4.11-3. Since the VMT per employee analysis for the proposed Project is based on home -based work trips (i.e., commute trips), the 11.9 percent reduction in commute VMT equates to an 11.9 percent reduction in VMT per employee. The 11.9 percent reduction is derived from an equation' that factors specific reduction percentages for each type of VMT reduction, which for the Project was calculated as 4 percent for T-7 Commute Trip reduction Marketing, 8 percent for T-8 Provide Rideshare Program, and 0.2 percent for T-10 Provide End -of -Trip Bicycle Facilities. Application of the 11.9 percent VMT reduction would result in
15.2 VMT per employee.3 This is below the significance threshold of 15.3 VMT. As such, VMT impacts would be reduced to a less than significant level through implementation of mitigation.
Threshold 4.11-c: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less than Significant Impact. There are five proposed driveway access points that would be provided to the site. Two would occur along Stewart and Gray Road and three would occur on Hall Road. The Project site access points from Stewart and Gray Road and Hall Road would be designed in accordance with City standards to consider adequate sight distances for both directions. These transportation improvements are intended to improve safety for motorists, bicyclists, and pedestrians. Additionally, a series of 26-foot-wide fire lanes would be provided on -site to ensure emergency vehicle access is provided and adequate ingress and egress are provided for employees and trucks at the Project site. The design of improvements at the Project site would be required to conform with applicable City and Downey Fire Department design criteria which contain provisions to minimize transportation hazards and provide emergency access. Based on compliance with City and Downey Fire Department design criteria, and the City's review process for approval of Project design and plans, impacts associated with hazards due to geometric design would be less than significant.
Mitigation Measures
No mitigation is required.
Threshold 4.11-d: Would the Project result in inadequate emergency access? Less than Significant Impact. During construction of the Project, heavy construction vehicles could interfere with emergency response to the site or emergency evacuation procedures in the event of an emergency (e.g., vehicles traveling behind the slow -moving truck). Emergency access to all surrounding properties, however, would be maintained throughout the construction period. As a result, the Project's construction -related impacts associated with emergency access would be less than significant.
The Project site would be accessible via five driveways: two on Stewart and Gray Road and three on Hall Road. The Project would provide adequate emergency access within the site via a series of 26-foot-wide ' Reduction = 1— [(1-A) x (1-B) x (1-C)]; A = 4% reduction for T-7 Commute Trip Reduction Marketing, B = 8% reduction for T-8 Provide Rideshare Program, and C = 0.2% reduction for T-10 Provide End -of -Trip Bicycle Facilities.
See Appendix B to EIR Appendix L for additional details. s 17.3 VMT/employee * (1-0.119) = 15.2 VMT/employee
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Exhibit D
Section 4.11
Transportation
fire lanes, which would be provided throughout the Project site to allow for unobstructed emergency vehicle access. These on -site fire lanes would accommodate emergency response vehicles such that adjacent roads (Stewart and Gray Road and Hall Road) would not be obstructed for public safety vehicle movement or non -emergency roadway traffic in the event of an on -site emergency.
The Project would operate 24 hours a day, 7 days a week, and would result in an increase in truck traffic from existing conditions. Over a 24-hour period, the Project is forecast to result in an increase of 167 passenger car equivalent adjusted vehicles trips during a typical weekday, consisting of approximately 84 more inbound trips and 84 more outbound trips (LLG 2023). The designated truck route in the area is Stewart and Gray Road, which connects to both Woodruff Avenue and Firestone Boulevard to the east, both of which are also designated truck routes; Firestone Boulevard provides direct access to 1-605 east of the Project site. Other designated truck routes include Bellflower Boulevard and Lakewood Boulevard to the west of the Project site; Lakewood Boulevard provides direct access to I-10S to the south of the Project site and to 1-5 to the north of the Project site. The use of the City's designated truck routes, which are intended for truck traffic trips, would ensure that local non -truck route roadways are not hindered by Project truck traffic, and emergency access on those roadways would not be affected.
Therefore, the Project would not result in inadequate emergency access. Impacts would be less than significant.
Mitigation Measures
No mitigation is required.
4.11.7 Cumulative Impacts
The geographic scope for the analysis of cumulative impacts related to transportation is defined as the City of Downey and immediate surrounding areas.
The County's Guidelines state that short-term effects are evaluated in the detailed project -level VMT analysis, while long-term or cumulative effects are determined through consistency with SCAG's current RTP/SCS, which is the regional plan that demonstrates compliance with air quality conformity requirements and greenhouse gas (GHG) reduction targets. As such, projects that are consistent with this plan in terms of development location, density, and intensity are part of the regional solution for meeting air pollution and GHG goals. Projects that are deemed to be consistent would have a less than significant cumulative impact on VMT. Developments in a location where the RTP/SCS does not specify any development may indicate a significant impact on transportation. However, if a project does not demonstrate a significant impact in the project impact analysis, a less than significant impact in the cumulative impact analysis can also be determined. Projects that fall under an efficiency -based impact threshold (e.g., residential VMT per capita, employment VMT per employee, or total VMT per service population) are already shown to align with the long-term VMT and GHG reduction goals. Land use projects that demonstrate a project -level impact and which are not found to be consistent with the SCAG RTP/SCS could have a significant transportation impact.
The 2018 Technical Advisory provides the following additional discussion of cumulative impacts:
"[M]etrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency -based threshold that is aligned with long-term goals and relevant plans has no cumulative impact distinct from the project impact.
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Exhibit D
Section 4.11
Transportation
Accordingly, a finding of a less -than -significant project impact would imply a less than significant cumulative impact, and vice -versa."
The proposed Project has been determined to have a less than significant project -level impact after mitigation in comparison to the efficiency -based employment VMT impact thresholds. Therefore, it is concluded that the proposed Project would not result in a significant cumulative VMT impact.
Additionally, the Project would not result in significant adverse cumulative impacts with respect to consistency with transportation plans, transportation design hazards, or emergency access. Therefore, implementation of the proposed Project would not result in a cumulatively considerable contribution to a significant cumulative impact to transportation.
4.11.8 Significant Unavoidable Impacts
No significant unavoidable impacts have been identified.
4.11.9 References
California Air Pollution Control Officers Association (CAPCOA). 2021. Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. December 2021. Available at: htt s: www.caleemod.eom 11hanndbook index.html.
Accessed June 1, 2023.
City of Downey. 2005. Vision 2025 General Plan. January.
County of Los Angeles Public Works. 2020. Transportation Impact Analysis Guidelines. July 23, 2020.
Linscott, Law & Greenspan, Engineers (LLG). 2023. Transportation Impact Study. September 2023.
Southern California Association of Governments (SCAG). 2020. Connect SoCal, the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments. September 3, 2020. Available at: https://scag.ca.gov/sites/mainjfiles/file- attachments/0903fconnectsocakolan O.pdf?1606001176.
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Exhibit D
Section 4.12
Tribal Cultural Resources
4.12 TRIBAL CULTURAL RESOURCES
4.12.1 Introduction
This section of the EIR describes the regulatory framework and existing conditions related to tribal cultural resources (TCRs), evaluates the potential impacts that could occur as a result of implementation of the proposed Project, and details mitigation measures needed to reduce significant impacts, as necessary. Information in this section is based on a cultural resources study prepared by HELIX which included a records search, Sacred Lands File search, Native American outreach, and a review of historic aerial photographs and maps of the Project area. This cultural resources study is included in its entirety as Appendix C. Information in this section also comes from tribal consultation conducted by the City pursuant to Assembly Bill (AB) 52. Documentation of AB 52 outreach and consultation is included as Appendix M.
4.12.2 Environmental Setting
4.12.2.1 Ethnographic Setting
The Project site is located within the region that has traditionally been occupied by the Gabrieleno people (also spelled as Gabrieleno or Gabrielino; Bean and Smith 1978:538; Kroeber 1925: Plate 57).
Other Indigenous groups in the surrounding areas include the Chumash to the north and northwest, the Tataviam/Alliklik to the north, the Serrano to the east, and the Luiseno and Juaneno to the south.
Interactions between these groups are well -documented, comprised primarily of trade and intermarriage. For more information about the ethnographic setting of the Project area, please see Section 4.3.2.2 Ethnographic Setting.
4.12.3 Regulatory Framework
4.12.3.1 Federal
Native American Graves and Repatriation Act of 1990
The Native American Graves Protection and Repatriation Act of 1990 sets provisions for the intentional removal and inadvertent discovery of human remains and other cultural items from federal and tribal lands. It clarifies the ownership of human remains and sets forth a process for repatriation of human remains and associated funerary objects and sacred religious objects to the Native American groups claiming to be lineal descendants or culturally affiliated with the remains or objects. It requires any federally funded institution housing Native American remains or artifacts to compile an inventory of all cultural items within the museum or with its agency and to provide a summary to any Native American tribe claiming affiliation.
National Register Bulletin 38
The National Park Service has prepared guidelines to assist in the documentation of traditional cultural properties (TCP's) by public entities. While it is federal guidance, it serves as the best and most recognized guidance for identifying TCP's. National Register Bulletin 38 is intended to be an aid in determining whether properties have traditional cultural significance and if they are eligible for inclusion in the National Register of Historic Places (National Register). It is also intended to assist federal Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-1 December 2023
Exhibit D
Section 4.12
Tribal Cultural Resources
agencies, State Historic Preservation Officers (SHPOs), Certified Local Governments, tribes, and other historic preservation practitioners who need to evaluate such properties when considering their eligibility for the National Register as part of the review process prescribed by the Advisory Council on Historic Preservation (ACHP).
American Indian Religious Freedom Act
This Act became law in 1978 (Public Law 95-341, 42 USC 1996 and 1996a) in order to protect and preserve for American Indians their inherent right of freedom to believe, express and exercise their traditional religions. These religious rights extend to, but are not limited to, access to sites, use and possession of sacred objects and the freedom to worship through ceremonial and traditional rites.
Under this regulation, federal agencies and departments are charged with evaluating their policies and procedures in consultation with native traditional religious leaders in order to eliminate interference with the free exercise of native religion. Agencies must determine and make appropriate changes necessary to protect and preserve Native American religious cultural rights and practices, and to accommodate access to and use of religious sites "to the extent that the use is practicable and not inconsistent with an agency's essential functions." The intent is to protect Native Americans' First Amendment right to "free exercise" of religion.
4.12.3.2 State
Assembly Bill 52
Governor Brown signed Assembly Bill (AB) 52, which creates a new category of environmental resources that must be considered under CEQA: "tribal cultural resources". AB 52 is applicable to a project for which a Notice of Preparation is filed on or after July 2015.
AB 52 adds tribal cultural resources to the categories of cultural resources in CEQA, which has formerly been limited to historic, archaeological, and paleontological resources. "Tribal cultural resources" are defined as either (1) sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are included in the State register of historical resources or a local register of historical resources, or that are determined to be eligible for inclusion in the State Register; or (2) resources determined by the Lead Agency, in its discretion, to be significant based on the criteria for listing in the State register.
Recognizing that tribes may have expertise with regard to their tribal history and practices, AB 52 requires lead agencies to provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a proposed project if they have requested notice of projects proposed within that area. If the tribe requests consultation within 30 days upon receipt of the notice, the Lead Agency must consult with the tribe. Consultation may include discussing the type of environmental review necessary, the significance of tribal cultural resources, the significance of the project's impacts on the tribal cultural resources, and alternatives and mitigation measures recommended by the tribe. The parties must consult in good faith, and consultation is deemed concluded when either the parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource (if such a significant effect exists) or when a party concludes that mutual agreement cannot be reached.
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Exhibit D
Section 4.12
Tribal Cultural Resources
California Native American Graves Protection and Repatriation Act of 2001 Codified in the California Health and Safety Code (HSC) Section 8010-8003, the California Native American Graves Protection and Repatriation Act (Cal NAGPRA) is consistent with the federal NAGPRA.
Intended to "provide a seamless and consistent state policy to ensure that all California Indian human remains and cultural items be treated with dignity and respect," Cal NAGPRA also encourages and provides a mechanism for the return of remains and cultural items to lineal descendants. Section 8025 established a Repatriation Oversight Commission to oversee this process. The Cal NAGPRA also provides a process for non -federally recognized tribes to file claims with agencies and museums for repatriation of human remains and cultural items.
Native American Heritage Commission
PRC Section 5097.91 established the Native American Heritage Commission (NAHC), whose duties include the inventory of places of religious or social significance to Native Americans and the identification of known graves and cemeteries of Native Americans on private lands. Under PRC Section 5097.9, a state policy of noninterference with the free expression or exercise of Native American religion was articulated along with a prohibition of severe or irreparable damage to Native American sanctified cemeteries, places of worship, religious or ceremonial sites, or sacred shrines located on public property. PRC Section 5097.98 specifies a protocol to be followed when the NAHC receives notification of a discovery of Native American human remains from a county coroner. Section 5097.5 defines as a misdemeanor the unauthorized disturbance or removal or archaeological, historic, or paleontological resources located on public lands.
Public Resources Code Section 5097.5
California Public Resources Code (PRC) Section 5097.5 prohibits excavation or removal of any "vertebrate paleontological site... or any other archaeological, historical, or paleontological materials or sites located on public lands is a misdemeanor."
Health and Safety Code 7050
Health and Safety Code (HFC) Section 7050.5 declares that, in the event of the discovery of human remains outside a dedicated cemetery, all ground disturbance must cease and the county coroner must be notified. Section 7052 establishes a felony penalty for mutilating, disinterring, or otherwise disturbing human remains, except by relatives.
4.12.4 Significance Criteria and Thresholds
State CEQA Guidelines Appendix G includes questions concerning tribal cultural resources. The questions presented in the Initial Study Checklist have been used as significance criteria. Accordingly, the Project would have a significant effect on the environment if it would:
• Cause a substantial adverse change in the significance of a tribal cultural resource, defined in the PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
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Exhibit D
Section 4.12
Tribal Cultural Resources
o Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or o A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
According to PRC §21084.2, a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment. While what constitutes a "substantial adverse change" to a tribal cultural resource is not defined in the section, guidance on what constitutes a substantial adverse change under CEQA can be drawn from State CEQA Guidelines §15064.5 (b). Although applicable specifically to historical resources (as defined in §15064.5(a)), an analogy can be drawn when assessing if there has been a substantial adverse change to a tribal cultural resource. State CEQA Guidelines §15064.5(b)(1) defines a substantial adverse change as the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings, resulting in material impairment of the historical resource. According to State CEQA Guidelines §15064.5(b)(2), the significance of a historical resource is materially impaired when a project:
Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register; or • Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the PRC or its identification in a historical resources survey meeting the requirements of Section 5024.1(g) of the PRC, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.
A substantial adverse change to a tribal cultural resource could be considered to be the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings, resulting in material impairment of the tribal cultural resource. Similarly, material impairment could include:
• Demolition or material alteration in an adverse manner those characteristics of a tribal cultural resource that justify its eligibility for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC §5020.1(k); or • Demolition of material alteration in an adverse manner those characteristics of a tribal cultural resource that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.
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Exhibit D
Section 4.12
Tribal Cultural Resources
PRC §21084.3 provides guidance on addressing impacts to tribal cultural resources and states that:
• Public agencies shall, when feasible, avoid damaging effects to any tribal cultural resource. • If the lead agency determines that a project may cause a substantial adverse change to a tribal cultural resource, and measures are not otherwise identified in the consultation process provided in §21080.3.2, the following are examples of mitigation measures that, if feasible, may be considered to avoid or minimize the significant adverse impacts:
o Avoidance and preservation of the resources in place, including, but not limited to, planning and construction to avoid the resources and protect the cultural and natural context, or planning greenspace, parks, or other open space, to incorporate the resources with culturally appropriate protection and management criteria. o Treating the resource with culturally appropriate dignity taking into account the tribal cultural values and meaning of the resource, including but not limited to the following:
■ Protecting the cultural character and integrity of the resource. ■ Protecting the traditional use of the resource.
■ Protecting the confidentiality of the resource.
■ Permanent conservation easements or other interests in real property with culturally appropriate management criteria for the purposes of preserving or utilizing the resources or places.
■ Protecting the resource.
State CEQA Guidelines §15370 provides additional guidance on the types of mitigation that may be considered, and includes avoiding impacts altogether; minimizing impacts; rectifying impacts through repair, rehabilitation, or restoration; reducing impacts through preservation; and compensating for impacts by providing substitute resources.
PRC §21082.3(b) indicates that if a project may have a significant impact on a tribal cultural resource, the agency's environmental document shall discuss whether the proposed project has a significant impact on an identified tribal cultural resource and whether feasible alternatives or mitigation measures avoid or substantially less the impact on the identified tribal cultural resource.
PRC §21080.3.2 indicates that as part of the consultation pursuant to §21080.3.1, California Native American Tribes may propose mitigation measures, including, but not limited to, those recommended in §21084.3, capable of avoiding or substantially lessening potential significant impacts to a tribal cultural resource or alternatives that would avoid significant impacts to a tribal cultural resource. Also, the lead agency may incorporate changes or additions to a project even if not legally required to do so.
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Exhibit D
Section 4.12
Tribal Cultural Resources
4.12.5 Methodology and Assumptions
4.12.5.1 Native American Heritage Commission Sacred Lands File As described in the Cultural Resources Report (Appendix C), HELIX requested a Sacred Lands File (SLF) search for the Project area from the Native American Heritage Commission (NAHC) on February 17, 2022. The NAHC indicated in a response dated April 11, 2022, that no known sacred lands or Native American cultural resources are within the Project area, but that the area may be sensitive for cultural resources. Absence of specific cultural resource information in the SLF does not negate the potential presence of cultural resources within the Project area. As outlined in the Native American consultation efforts described below, the City requested cultural resource information from the tribes noted on the SLF search results.
4.12.5.2 Native American Consultation
The City requested a Native American Contacts List from NAHC in conformance with AB 52. A reply letter was received with recommendations for consultation with California Native American tribes as well as recommended requirements for consultation during the environmental review process. The City provided formal notification pursuant to AB 52 on October 11, 2022. Correspondence was sent to the designated contact/tribal representative for the following tribes:
• Gabrieleno/Tongva San Gabriel Band of Mission Indians • Gabrielino/Tongva Nation
• Gabrielino Tongva Indians of California Tribal Council • Gabrielino-Tongva Tribe
Pursuant to AB 52, tribes must respond in writing and request consultation within 30 days of receipt of the formal notification from the City. The City received a response from the Gabrieleno Band of Mission Indians — Kizh Nation and met with the Tribe to discuss the potential impacts of the Project on TCRs. The Tribe summarized the discussion and proposed mitigation measures in a letter to the City. The mitigation measures are included in the discussion below and all AB 52 related correspondence is included as Appendix M. No other responses to AB 52 consultation were received.
4.12.6 Impacts and Mitigation Measures
Threshold 4.12-a: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place. Or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k); or
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-6 December 2023
Exhibit D
Section 4.12
Tribal Cultural Resources
ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.
Less than Significant with Mitigation Incorporated. The cultural resources records search and literature review discussed in Threshold a in Section 4.3, Cultural Resources, of this EIR, did not identify any tribal cultural resources listed or eligible for listing in the CRHR or a local register of historical resources. As discussed under Section 4.3, Cultural Resources, the NAHC indicated in a response dated April 11, 2022, that no known sacred lands or Native American cultural resources are within the Project area, but that the area may be sensitive for cultural resources.
During the AB 52 tribal consultation with the Kizh Nation, tribal representatives expressed concerns regarding subsurface activities associated with future development within the Project area. The Kizh Nation provided their knowledge of the Project area, including information about the natural environment and the area's general history, and known villages and trade routes in the larger area.
During the consultation call and in subsequent email communication, the Kizh Nation indicated that the Project area has a high sensitivity for the presence of unknown, subsurface tribal cultural resources. The Kizh Nation provided confidential information to the City identifying culturally sensitive areas within the Project area that may be affected by subsurface ground disturbance activities.
In addition to MM CUL-1 and MM CUL-2 identified in Section 4.3, Cultural Resources, the Project would incorporate mitigation measures recommended by the Kizh Nation concerning potential impacts to as - yet undiscovered tribal cultural resources. The mitigation measures include requirements for procedures in the event of an unanticipated discovery of tribal cultural and archaeological resources (MM TCR-1), retaining a Native American Monitor/Consultant (MM TCR-2), and procedures for the unanticipated discovery of burials and human remains (TCR-3). Following compliance with MM TCR-1, MM TCR-2, and MM TCR-3 in addition to MM CUL-1 and MM CUL-2, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource. With mitigation, the Project's potential impacts to tribal cultural resources would be reduced to below the threshold of significance.
Mitigation Measures
TCR-1: Retain a Native American Monitor Prior to Commencement of Ground -Disturbing Activities A) The Project applicant/lead agency shall retain a Native American Monitor from or approved by the Gabrieleno Band of Mission Indians — Kizh Nation. The monitor shall be retained prior to the commencement of any ground -disturbing activity for the subject Project at all Project locations (i.e., both on -site and any off -site locations that are included in the project description/ definition and/or required in connection with the Project, such as public improvement work).
Ground -disturbing activity shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
B) A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground -disturbing activity, or the issuance of any permit necessary to commence a ground -disturbing activity.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-7 December 2023
Exhibit D
Section 4.12
Tribal Cultural Resources
C) The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -disturbing activities, the type of construction activities performed, locations of ground - disturbing activities, soil types, cultural -related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or TCR), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the Project applicant/lead agency upon written request to the Tribe.
D) On -site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the Project applicant/lead agency that all ground -disturbing activities and phases that may involve ground -disturbing activities on the Project site or in connection with the Project are complete; or (2) a determination and written notification by the Kizh to the Project applicant/lead agency that no future, planned construction activity and/or development/construction phase at the Project site possesses the potential to impact Kizh TCRs.
E) Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe's sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.
TCR-2: Unanticipated Discovery of Human Remains and Associated Funerary Objects A) Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.
B) If Native American human remains and/or grave goods discovered or recognized on the Project site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground -disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.
C) Human remains and grave/burial goods shall be treated alike per California PRC Section 5097.98(d)(1) and (2).
D) Construction activities may resume in other parts of the Project site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-8 December 2023
Exhibit D
Section 4.12
Tribal Cultural Resources
measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).)
E) Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.
F) Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
TCR-3: Procedures for Burials and Funerary Remains
A) As the Most Likely Descendant (MILD), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term "human remains" encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.
B) If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.
C) The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.
D) In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the Project and keeping the remains in situ and protected. If the Project cannot be diverted, it may be determined that burials will be removed.
E) In the event preservation in place is not possible despite good faith efforts by the Project applicant/developer and/or landowner, before ground -disturbing activities may resume on the Project site, the landowner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects.
F) Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-9 December 2023
Exhibit D
Section 4.12
Tribal Cultural Resources
retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the Project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.
G) The Tribe will work closely with the Project's qualified archaeologist to ensure that the excavation is treated carefully, ethically, and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery -related forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.
4.12.7 Cumulative Impacts
This section presents an analysis of the cumulative effects of the proposed Project in combination with other past, present, and reasonably foreseeable future projects that could cause cumulatively considerable impacts. The geographic context for the analysis of cumulative impacts related to tribal cultural resources is the City of Downey and immediately surrounding lands, including cumulative Projects occurring in the City of Norwalk as identified in Table 3-1, Related Projects.
Cumulative impacts to tribal cultural resources could occur if any of these projects, in conjunction with the proposed Project, would have impacts to resources that, when combined together, would be significant; however, the proposed Project would not affect known tribal cultural resources. Further, while there is potential for impacts to unknown tribal cultural resources, such as those that might be discovered during ground -disturbing activities like construction and demolition associated with the proposed Project, MM CUL-1 and MM CUL-2 would provide procedures for inadvertent discovery of cultural resources or human remains and require a cultural resources monitoring program to ensure that impacts are reduced to a less -than -significant level. Taken together, implementation of these mitigation measures would ensure that the Project would not have an impact on tribal cultural resources. Therefore, the Project's contribution to cumulative impacts related to tribal cultural resources would be less than significant and not cumulatively considerable.
4.12.8 Significant Unavoidable Impacts
No significant unavoidable Native American tribal cultural resource impacts have been identified.
4.12.9 References
HELIX Environmental Planning, Inc. (HELIX). 2023a. Prologis Stewart and Gray Road Warehouse Project.
Cultural Resources Study. March.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 4.12-10 December 2023
Exhibit D
5.0 ALTERNATIVES
5.1 INTRODUCTION
Under CEQA, an Environmental Impact Report (EIR) must identify and describe a reasonable range of alternatives to the proposed Project. The following discussion considers alternatives to implementation of the Project. The section identifies potential alternatives to the proposed Project and examines the potential environmental impacts resulting from each alternative. Through comparisons of these alternatives to the Project, the relative advantage(s) of each can be weighed and analyzed.
State CEQA Guidelines §15126.6 identifies the parameters within which consideration and discussion of alternatives to the proposed Project should occur:
An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.
In selecting alternatives to the Project, the City of Downey (City), as Lead Agency, is to consider alternatives that could feasibly attain most of the basic objectives of the Project and avoid or substantially lessen one or more of the significant effects. The State CEQA Guidelines emphasize that the selection of project alternatives be based primarily on the ability to reduce impacts relative to a proposed project, "even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly" (§15126.6(b)).
The State CEQA Guidelines also direct that the range of alternatives be guided by a "rule of reason," that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. An alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative need not be considered. State CEQA Guidelines §15126.6(f)(1) states that:
Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site...
Additionally, the State CEQA Guidelines require the analysis of a "no project" alternative and an evaluation of alternative location(s) for the project, if feasible. State CEQA Guidelines §15126.6(c) also requires that an EIR identify any alternatives that were considered for analysis but rejected as infeasible and discuss the reasons for their rejection. Based on the alternatives analysis, an environmentally superior alternative is to be designated.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-1 December 2023
Exhibit D Section 5.0
Alternatives
5.1.1 Summary of the Project
This EIR has been prepared to evaluate the potential environmental impacts associated with the construction and operation of the proposed Project. The proposed Project would include the demolition of the existing buildings on the site totaling approximately 433,000 square feet (SF) and the construction of an approximately 535,685-square-foot industrial concrete tilt -up building for warehouse/logistics uses. The Project would include 683 auto parking spaces, 255 trailer and/or container parking spaces and 109 dock loading doors. The new industrial building would be used for logistics and distribution purposes, and specifically as a fulfillment center and for cold storage. Approximately 95 percent of the warehouse (508,900 SF) would be high cube fulfillment and the remaining 5 percent (26,785 SF) would be for cold storage (i.e., refrigerated warehouse space). The facility would also include 20,000 SF of office area and 25,000 SF of mezzanine area within the 535,685-SF building. On -site activities would include storage, distribution, and/or consolidation of manufactured goods, and last -mile fulfillment and delivery; and general industrial/ warehouse with refrigeration and cold storage component for the purposes of receiving, storing, shipping of food and/or beverage products. The office space would be used for office uses ancillary to the warehouse operations. The proposed facility would operate 24 hours a day, seven days a week.
5.1.2 Project Objectives
The fundamental purpose and goal of the Project is to accomplish the orderly development of an appropriately zoned and designated warehouse building in the City while also contributing to increased employment opportunities within the area. The Project objectives have been refined throughout the planning and design process for the proposed Project and are listed below:
• Create a professional, well -maintained, and attractive environment for the development of a warehouse building consistent with the underlying zoning adjacent to nearby transportation infrastructure.
• Expand economic development, attract new businesses, and provide employment opportunities in the City of Downey.
• Increase the industrial base in the City of Downey by providing a Class A industrial facility that meets industry standards for operational design and can accommodate a wide variety of industrial uses.
• Facilitate a project that provides goods for the regional economy. • Design the facility for energy efficiency and sustainability. • Encourage warehouse development as attractive and productive uses while minimizing conflicts to the extent possible with the surrounding existing uses. • Encourage new warehouse distribution services that take advantage of the area's close proximity to various freeways and transportation corridors to reduce traffic congestion on surface streets and to reduce concomitant air pollution emission from vehicle sources. • Encourage new development consistent with the capacity and municipal service capabilities.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-2 December 2023
Exhibit D Section 5.0
Alternatives
5.1.3 Summary of Proposed Project Significant and Unavoidable Impacts The analysis in Sections 4.1 through 4.12 of this EIR concludes that implementation of the proposed Project would result in no impact, a less than significant impact, or a less than significant impact with incorporation of applicable mitigation measures for most of the thresholds evaluated in this EIR.
Section 4.10, Noise, concludes that the proposed Project would have a significant and unavoidable impact related to the generation of noise during nighttime construction activities.
Mitigation measures have been developed to address the significant impacts identified in this EIR.
Section 4.10, Noise, identified a temporary significant impact related to noise during nighttime construction. Even with the implementation of Mitigation Measure N01-1 to limit construction hours and notify surrounding residents of anticipated nighttime construction activities in advance, this impact would remain significant and unavoidable. Mitigation measures are required to reduce potentially significant construction -related impacts to levels considered less than significant for: Section 4.3, Cultural Resources (due to the potential to encounter previously unknown, buried cultural resources); Section 4.7, Hazards and Hazardous Materials (due to the potential to encounter contaminated soils, asbestos -containing material or lead -based paints); Section 4.9, Land Use and Planning (due to Project consistency with land use plans, policies, or regulations); Section 4.11, Transportation (due to the Project's potential to result in Vehicle Miles Traveled [VMT] impacts); and Section 4.12, Tribal Cultural Resources (due to the potential to encounter previously unknown, buried tribal cultural resources).
Please refer to the relevant sections of the EIR for more information about these potential impacts and applicable mitigation measures. The majority of the potentially significant impacts identified are associated with construction activities, not operation of the Project.
FURTHER ANALYSIS
State CEQA Guidelines §15126.6(a) requires that an EIR identify alternatives that were considered by the Lead Agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process and briefly explain the reasons underlying the Lead Agency's determination. According to this section of the State CEQA Guidelines "...an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision -making and public participation." An EIR is not required to consider alternatives which are infeasible. The City, as lead agency, is responsible for selecting a range of Project alternatives for examination based on the "rule of reason" (State CEQA Guidelines §15126.6 (a)).
Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to an alternative (State CEQA Guidelines §15126.6 (f)(1)).
With respect to the selection of alternatives to be considered in an EIR, State CEQA Guidelines §15126.6(b) states "...the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly." That is, each alternative must be capable of avoiding or substantially lessening any significant effects of the proposed Project.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-3 December 2023
Exhibit D Section 5.0
Alternatives
The following alternatives were considered but not selected for detailed analysis in this EIR. As described in greater detail below, the main reason for rejecting these alternatives was that they would not avoid or substantially reduce the impacts associated with the Project and/or would not be consistent with the Project objectives.
5.2.1 Alternative Site Location
CEQA requires that the alternatives discussion focus on alternatives to the proposed Project or its location which are capable of avoiding or substantially lessening any significant effects of the Project.
One alternative to consider is whether any of the significant effects of the project would be avoided or substantially lessened by developing the project at another location. CEQA Guidelines §15162.6(f) states that only locations which would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR.
To meet the Project objectives and implement the Prologis Stewart and Gray Warehouse, an alternative site could include other parcels in other industrial land use areas where the City of Downey anticipates future industrial development. For this alternative to be feasible, any development within such areas would need to be consistent with the Project, the Project objectives, and development anticipated in the area, as presented in the City of Downey General Plan and zoning.
The City of Downey is generally developed, with limited undeveloped parcels available. Implementing the Project on a different parcel would require the acquisition of a developed property, demolition of existing operational structures, and discontinuation or relocation existing land uses, which is likely to disrupt existing businesses and operations, and would result in environmental impacts similar to those identified for the Project. As identified in the analysis presented in Sections 4.1 through 4.12 of this EIR, many of the potential impacts that would require mitigation are related to the inadvertent discovery of cultural or tribal cultural resources during grading activities, the potential to encounter hazardous materials during construction, and construction -related noise during nighttime construction activities.
Potential hazardous materials are site -specific and may or may not occur on alternative sites. Noise impacts on surrounding noise -sensitive receptors are also site -specific. These potential impacts would be applicable for any redevelopment or development within the City limits. The Project -related VMT impacts, which would be less than significant with the implementation of the mitigation measure TR-1, would also occur with the development at an alternative site location. Development of an alternative site would only move these impacts to a different location and the severity of potential impacts would likely be very similar to those identified for the proposed Project.
Additionally, the Project applicant does not own other property in the City of Downey that could accommodate the Project other than the Project site. CEQA does not require the consideration of infeasible sites that are not owned by the landowner or that could not be reasonably acquired by the landowner to be analyzed as alternatives to the Project site. Therefore, an alternative site location is not carried forward for further analysis.
5.2.2 Alternatives to Reduce Potential VMT Impacts
While the majority of the impacts evaluated in this EIR that would require mitigation would result from construction of the Project, Section 4.11, Transportation, of the EIR identified potential impacts related to VMT that would occur during Project operations. With the implementation of the project design features and the Transportation Demand Management (TDM) plan identified in mitigation measure Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-4 December 2023
Exhibit D Section 5.0
Alternatives
TR-1, the potential impacts of the Project related to VMT would be reduced to a less than significant level. These traffic demand measures include commute trip reduction marketing, providing ridesharing programs, and providing end -of -trip bicycle facilities During the alternatives development process, the City considered whether an alternative could be developed which would reduce Project -related VMT even further. The CAPCOA Handbook forAnalyzing Greenhouse Gas Emissions, Assessing Climate Vulnerabilities, and Advancing Health Equity (CAPCOA 2021) was consulted to determine whether an alternative could be developed that would implement any additional TDM measures identified in the handbook. As discussed in Section 4.11, the proposed Project already includes increasing job density as a feature of project design and commute trip reduction marketing, providing a ridesharing program, and providing end -of -trip bicycle facilities as part of Mitigation Measure TR-1. Many of the measures identified in the CAPCOA handbook relate to residential development or transit and are not applicable to the Project. Other measures, such as pricing workplace parking or implementing an employer -sponsored vanpool, would not constitute the development of a new alternative. Ultimately it was determined that there was not a feasible alternative associated with an industrial warehouse use that would further reduce potential VMT impacts. Therefore, no alternatives to further reduce VMT impacts are carried forward for further analysis.
5.3 COMPARISON OF PROJECT ALTERNATIVES
When considering potential alternatives to the Project, the City focused on alternatives that would reduce or eliminate some of the potential impacts identified. The Project alternatives are evaluated below to determine their potential environmental impacts as well as whether they would meet the identified Project objectives. For the alternatives evaluated below, it is assumed that relevant regulatory requirements and Project -specific mitigation measures would also be implemented and thus serve to reduce or avoid potential significant impacts similar to the Project. The following alternatives are analyzed for relative impacts as compared to the Project:
• Alternative A: No Project Alternative
• Alternative B: Reuse of Existing Buildings
• Alternative C: Reduced Building Height
• Alternative D: Reduced Project
A summary matrix that compares the impacts associated with the Project with the impacts of each of the analyzed alternatives is provided below in Table 5-1, Summary of Comparison of Alternatives to the Project.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-5 December 2023
Exhibit D Section 5.0
Alternatives
Table 5-1
SUMMARY OF COMPARISON OF ALTERNATIVES TO THE PROJECT
Environmental
Resource Topic'
Proposed
Project
Alternative A:
No Project
Alternative B:
Reuse of Existing
Buildings
Alternative C:
Reduced
Building Height
Alternative D:
Reduced
Project
Aesthetics
LTS
N
LTS (>)
LTS ( )
LTS(=)
LTS (_)
GHG Emissions
LTS
N
LTS ( = comparatively greater impact relative to the Project (if impact designation is the same and impact varies) _' = same/similar impacts relative to the Project
5.3.1 Alternative A: No Project
State CEQA Guidelines §15126.6(e) requires that the "no project" alternative be evaluated along with its impacts to allow decision makers to compare the impacts of approving the project with the impacts of not approving the project. The "no project" analysis is required to discuss the existing conditions (at the time the Notice of Preparation is published), as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.
If the project is not a land use or regulatory plan, for example a development project on identifiable property such as the proposed Project, the "no project" alternative is the circumstance under which the project does not proceed. Under this Alternative, the discussion would compare the environmental effects of the property remaining in its existing condition against environmental effects which would occur if the Project is approved.
Under this alternative, the physical conditions of the Project site would remain as they are as the date of the NOP. The Project site is currently completely developed with existing industrial structures, associated parking areas, storage yards, and canopy areas. The Project site has a General Plan Land Use Designation of GM (General Manufacturing) and is currently zoned M-2 (General Manufacturing Zone).
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-6 December 2023
Exhibit D Section 5.0
Alternatives
5.3.1.1 Comparative Analysis of Environmental Impacts
The focus of this analysis is to determine if the No Project Alternative is capable of eliminating or reducing any of the identified impacts of the proposed Project. As previously discussed, this EIR identified one potentially significant impact related to noise which could not be mitigated to a less than significant level. Under the No Project Alternative, this impact would not occur. As shown in Table 5-1, several impacts were identified as less than significant with the implementation of mitigation. The majority of the impacts necessitating mitigation are related to construction of the proposed Project. The No Project Alternative would not involve construction, which would eliminate the need for mitigation measures related to cultural resources, hazards and hazardous materials, noise, and tribal cultural resources. Because the No Project Alternative would not involve construction, and specifically nighttime construction activities, it would avoid the significant unavoidable temporary construction noise impact resulting from the proposed Project. The No Project Alternative would also not result in any changes to VMT in comparison to existing conditions and would therefore, eliminate the need for mitigation related to transportation, which is also related to land use plan policy consistency impacts. It would also avoid all other less than significant impacts of the Project.
5.3.1.2 Attainment of Project Objectives
When evaluating the desirability and feasibility of an alternative, it is important to evaluate the ability of that alternative to meet project objectives. An alternative does not need to meet all project objectives to be considered potentially feasible. However, Alternative A would not achieve most of the objectives of the proposed Project and the benefits of the proposed Project would not be realized under the No Project Alternative. This alternative would leave the site as -is and the proposed Project would not be constructed, and therefore this alternative would not create a warehouse building that would provide expand the City's industrial base, expand economic development, provide a new Class A industrial facility, or provide a new energy -efficient and sustainable facility.
5.3.2 Alternative B: Reuse of Existing Buildings
Under this alternative, the existing buildings and associated facilities on -site would be retained and reoccupied by the Project applicant for use as a warehouse and logistics facility. The existing vacant buildings, which encompass a total of approximately 433,000 SF, would be re -used as a warehouse and logistics center. The physical conditions of the Project site would generally remain as they are today.
5.3.2.1 Comparative Analysis of Environmental Impacts
Under this alternative, the environmental impacts would be largely similar to those identified for Alternative A: No Project and discussed above in Section 5.3.1.1. The reuse of existing buildings would eliminate the need for demolition and construction of new structures and therefore would eliminate the need for the mitigation measures related to construction that were identified in this EIR for cultural resources, hazards and hazardous materials, noise, and tribal cultural resources. Thus, it would avoid the significant unavoidable temporary construction noise impact of the proposed Project. However, unlike Alternative A, the reuse of existing buildings as a warehouse and logistics center under Alternative B may result in an increase in VMT over existing conditions. However, due to the reduced square footage of the warehouse and logistics center, this increase in VMT would likely be less than the projected increase in VMT under the proposed Project and with the implementation of mitigation measure TR-1 identified in this EIR would be reduced to a less than significant level. Impacts related to land use plan Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-7 December 2023
Exhibit D Section 5.0
Alternatives
policy consistency also would be similar to the proposed Project given the potential increase and associated VMT impacts. As with the proposed Project, impacts to aesthetics would be less than significant but visual quality would not be improved if the existing buildings would remain and the site improvements associated with the proposed Project would not be constructed. Potential geology and soils impacts would also be less than significant like the Project, but could be slightly more severe because the existing older buildings would not be replaced with a new modern building designed in conformance with current seismic design parameters. Both the Project and the Alternative B would have less than significant impacts related to air quality, energy, and GHG emissions, but the impacts associated with Alternative B would be slightly less than those associated with the Project given the reduce building space.
5.3.2.2 Attainment of Project Objectives
Alternative B would not meet the majority of the objectives identified for this Project. As described in the Project objectives, this alternative would locate the warehouse near efficient access points to various freeways and transportation corridors, facilitate a project that provides goods for the regional economy, and provide employment opportunities in the City. While this alternative would continue to generate revenue, the Project site is currently underutilized. This alternative would continue using the existing buildings and facilities on the Project site for warehouse and office uses and has the potential to continue providing goods to the local economy. Due to changing demands in the warehouse industry and the condition and type of buildings on the existing site, the availability of potential tenants could be limited due to the age of the existing buildings. Therefore, this alternative may not be able to meet the objective of expanding economic development and attracting new businesses to the City. This alternative would also fail to provide a Class A industrial facility that meets industry standards for operational design. The existing facilities also lack the energy efficiency and sustainability design features included as an objective for the proposed Project.
5.3.3 Alternative C: Reduced Building Height
This alternative would develop the warehouse largely as described in this EIR, but with a reduced maximum building height of 45 feet. As the maximum building height of the proposed Project evaluated in this EIR is 55 feet, this would be a 10-foot reduction in overall building height. The square footage and other components of the site would remain the same as the proposed Project evaluated in this EIR.
5.3.3.1 Comparative Analysis of Environmental Impacts
Under Alternative C, most of the environmental impacts identified in this EIR would remain the same as they would for the proposed Project. Construction would still be required to develop the site, and the mitigation measures identified in this EIR to reduce impacts related to cultural resources, hazards and hazardous materials, noise, and tribal cultural resources during construction would still be required.
Because nighttime construction would still be required, Alternative C would also result in a significant unavoidable temporary construction noise impact. Alternative C would also increase employment and therefore increase VMT, which would necessitate the implementation of mitigation measure TR-1 to reduce potential VMT impacts and land use plan policy consistency.
The reduced building height of Alternative C would eliminate the need for a variance from the Downey Municipal Code with regard to maximum building height. As discussed in Section 4.9, Land Use and Planning, the Project site is zoned M-2 (General Manufacturing Zone), which has a maximum building Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-8 December 2023
Exhibit D Section 5.0
Alternatives
height of 45 feet or three stories, whichever is less. The proposed Project has a maximum building height of 55 feet, which exceeds the maximum allowable building height of the M-2 zone and would require a variation of standards for building height as part of Project approvals. However, with a maximum building height of 45 feet, Alternative C would not require the variance. Section 4.1, Aesthetics, of the EIR also discusses the building height of the proposed Project in the context of aesthetics, ultimately concluding that the height of the proposed Project would have a less than significant impact because it would not be inconsistent with the heights of surrounding buildings and would therefore not substantially degrade the visual character or quality of the Project site and its surroundings. Alternative C would lessen these impacts even further by reducing the height of the building. All other less than significant Project impacts would be the same under Alternative C.
5.3.3.2 Attainment of Project Objectives
Alternative C would attain most of the Project objectives described above in Section 5.1.2. Alternative C would create a warehouse building consistent with the underlying zoning and provide goods for the regional economy, it would expand economic development in the City while expanding its industrial base, and it would take advantage of the area's close proximity to various freeways and transportation corridors. With the reduced building height, this alternative could still be designed for energy efficiency and sustainability. The warehouse would take advantage of the area's close proximity to various freeways and transportation corridors. However, the lower height proposed under Alternative C would not be ideal for Project operations because the lower ceiling could potentially create some operational constraints. Lower building height limits prospective users of the facilities and could make it more difficult for the Project to meet some of the objectives because redevelopment of the site with new modern Class A buildings would not occur.
5.3.4 Alternative D: Reduced Project
This alternative would develop a warehouse similar to the proposed Project, but with an overall building space reduction of 25 percent. Instead of the 535,685 SF building that would be included under the proposed Project, Alternative D would develop an approximately 401,764 SF industrial concrete tilt -up building for warehouse/logistics uses. The auto parking spaces, trailer and/or container parking spaces, and dock loading doors would also be reduced by approximately 25 percent as compared to the proposed Project. The on -site uses and operating hours would remain the same as under the proposed Project.
5.3.4.1 Comparative Analysis of Environmental Impacts
Under Alternative D, many of the potential impacts related to construction would be similar to those of the proposed Project. Construction would still be required to develop the site, and the mitigation measures identified in this EIR to reduce impacts related to cultural resources, hazards and hazardous materials, noise, and tribal cultural resources during construction would still be required. Because nighttime construction would still be required, Alternative C would also result in a significant unavoidable temporary construction noise impact. However, as shown in Table 5-1 operational impacts under Alternative D would be reduced in comparison to the proposed Project. While Alternative D would also increase employment in comparison to existing conditions and therefore also increase VMT, this impact would be less than that of the proposed Project because Alternative D would require fewer employees to operate the warehouse and logistics center. Furthermore, this reduced project alternative would also have less of an impact on air quality, greenhouse gas emissions, and energy than the Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-9 December 2023
Exhibit D Section 5.0
Alternatives
proposed Project because Alternative D would have less square footage and therefore require less energy and fuel to construct and operate.
5.3.4.2 Attainment of Project Objectives
Alternative D would attain most of the Project objectives described in Section 5.1.2. The warehouse would take advantage of the area's close proximity to various freeways and transportation corridors, it would increase the City's industrial base, and the new development would be consistent with the capacity and municipal service capabilities. A reduced footprint alternative would still provide a Class A industrial facility that meets industry standards for operational design, however the reduced footprint may limit the variety of industrial uses that the facility could accommodate. Therefore, while Alternative D would meet most of the Project objectives, it would not attain all the Project objectives.
CEQA requires the identification of an environmentally superior alternative. As discussed above and shown in Table 5-1, the No Project Alternative would not require construction and would not cause construction -related impacts and also would avoid significant unavoidable temporary construction noise impacts. However, §15126.6(e)(2) of the CEQA Guidelines states that, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives. Therefore, in accordance with CEQA Guidelines, the environmentally superior alternative is Alternative D: Reduced Project. As discussed above, Alternative D would further reduce the impacts identified in the EIR for the proposed Project. Like the Proposed project, all environmental impacts except for noise would be less than significant with the implementation of the mitigation measures identified in the EIR. Temporary construction noise impacts would remain significant and unavoidable. As with the proposed Project, Alternative D would further lessen significant and mitigable impacts due to the reduced development of the project. Additionally, Alternative D would meet all but one of the identified Project objectives. For these reasons, Alternative D has been identified as the environmentally superior alternative.
5.5 REFERENCES
California Air Pollution Control Officers Association (CAPCOA). 2021. Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. December 2021. Available at: https:Bf www.caleemod.comjhandbookJindex.html .
Accessed June 28, 2023.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 5-10 December 2023
Exhibit D
6.0 OTHER CEQA CONSIDERATIONS
This chapter of the EIR addresses other mandatory CEQA considerations to be addressed in an EIR pursuant to State CEQA Guidelines Section 15126, including significant and unavoidable environmental effects, significant irreversible environmental effects, and growth -inducing impacts.
6.1 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL EFFECTS
Section 15126.2(c) of the State CEQA Guidelines requires that an EIR describe any significant impacts that cannot be avoided, even with the implementation of feasible mitigation measures. The environmental impacts of the Project are discussed in Sections 4.1 through 4.12 of this EIR, as applicable. With incorporation the Project -specific mitigation measures described in this EIR, impacts related to all the issue areas evaluated in this EIR would be less than significant with the exception of noise. Section 4.10, Noise, identified a significant temporary impact related to noise during nighttime construction activities. Even with the implementation of Mitigation Measure N01-1, the impact would remain significant and unavoidable.
6.2 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL EFFECTS
Pursuant to State CEQA Guidelines Section 15126.2(d), an EIR must include a description of significant irreversible environmental changes that would be caused by the proposed action. Section 15126.2(d) reads as follows:
Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.
An impact could fit into this category if:
• The project would involve a large commitment of nonrenewable resources; • The primary and secondary impacts of the project would generally commit future generations of people to similar uses;
• The project involves uses in which irreversible damage could result from any potential environmental accidents associated with the project; and/or, • The proposed consumption of resources is not justified (e.g., the project results in wasteful use of energy).
Determining whether the proposed Project may result in significant irreversible effects requires a determination of whether key resources would be degraded or destroyed in such a way that there would be little possibility of restoring them.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 6-1 December 2023
Exhibit D Section 6.0
Other CEQA Considerations
6.2.1 Irreversible Commitment of Resources
The proposed Project would include the demolition of five existing industrial buildings and the construction of one industrial building for warehouse and logistics uses. Although construction and operation of the proposed warehouse and associated commercial uses at the Project site would contribute to the incremental depletion of renewable and nonrenewable resources, the proposed Project would be consistent with other existing and planned development in the Project vicinity.
Construction of the proposed Project will require the use of renewable resources such as lumber and other forest products, which could be expected to be replenished over the lifetime of the Project because sustainably harvested lumber supplies are increased as seedlings mature into trees. As such, the development of the Project would not result in the irreversible commitment of renewable resources. Nevertheless, there would be an incremental increase in the demand for these resources during construction of the Project.
Construction of the Project will also result in the use of non-renewable resources including building materials (e.g., concrete asphalt, petrochemical construction materials, steel, copper and other metals, and sand and gravel) and fossil fuels, including the use of fossil fuels for construction equipment, the transport of construction materials to the Project site and the transportation of construction workers to and from the Project site (e.g., natural gas, gasoline, diesel fuel and other petroleum -based products).
These materials and the resources used in their production are available in a finite supply and are generally not retrievable, although some of the materials are recyclable. Construction materials like concrete and asphalt, for example, can be crushed and recycled as road base.
During Project operation, the Project would result in an irretrievable commitment of nonrenewable resources, such as energy resources and fossil fuels. Energy resources including petroleum and natural gas will be consumed during construction and operational phases of new development. Short-term, or construction -related, energy uses will include electricity for lights and construction equipment, and fossil fuels for construction equipment, and the transport of construction materials and workers to and from the Project site. Long-term energy resources include fuel consumed for the heating and cooling of the building, transportation of people and goods, as well as for lighting and other energy -related needs.
Electricity consumption during construction and operation phases will increase the consumption of oil, coal, and natural gas used at power plants located outside the City of Downey. Accordingly, this represents a long-term commitment to the continued consumption of these resources.
As discussed in Section 4.4, Energy, of this EIR, natural gas, energy, and fuel consumption will not be a significant impact and the Project will not result in wasteful use of these resources. Further, this is a justified consumption of resources because the proposed Project is consistent with the City's planned non-residential and employment generating use at the site and because there are no unique characteristics of the proposed Project that would make this Project operate at a less energy efficient level than other similar developments.
6.2.2 Irreversible Environmental Changes
The proposed Project would include the demolition of five existing industrial buildings and the construction of one industrial building for warehouse and logistics uses. The EIR found that potential environmental effects resulting from implementation of the proposed Project are below the level of significance or can be mitigated to below the level of significance. Therefore, although the Project would Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 6-2 December 2023
Exhibit D Section 6.0
Other CEQA Considerations
result in changes to the existing site conditions, the Project would not cause any significant irreversible environmental changes.
6.2.3 Potential Environmental Damage from Accidents
The proposed Project consists of a warehouse and logistics center. Demolition and construction activities associated redevelopment of the proposed Project would involve some risk for environmental accidents. These activities would be monitored, however, by local, State, and federal agencies that would follow industry standards governing the use, storage, transport, and disposal of hazardous materials. Section 4.7, Hazards and Hazardous Materials, of this EIR found that potential impacts related to the creation of a significant hazard to the public or environment through the routine transportation, use, or disposal of hazardous materials, and the creation of a significant hazard to the public or environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials into the environment.
The Project site is located within a seismically active region and would be exposed to ground shaking during a seismic event. In order to address the potential for moderate to severe ground -shaking that may occur during the lifetime of the proposed structures, the Project will follow engineering and design parameters in accordance with the most recent edition of the California Building Code and/or the Structural Engineers Association of California parameters.
6.3 GROWTH INDUCING IMPACTS
According to State CEQA Guidelines Section 15126.2(e), a project may foster economic or population growth, or additional housing, either indirectly or directly, in a geographical area if it meets any one of the following criteria below:
• A project would remove obstacles to population growth; • Increases in the population may tax existing community service facilities, requiring construction of new service facilities that could cause significant environmental effects; or • A project would encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.
The Project would not remove obstacles to population growth or directly contribute to population growth. The proposed Project involves construction and operation of a warehouse and logistics center in an area that currently consists of industrial buildings.
Project implementation may indirectly induce population growth in the short term because it would be a new source of employment within the City. However, the extent to which the new jobs created by a project are filled by existing residents is a factor that tends to reduce the growth inducing effect of a project. Construction of the proposed Project would create short-term construction jobs which are anticipated to be filled by workers who, for the most part, reside in the Project area; therefore, construction of the proposed Project would not generate a permanent increase in population within the Project area. The workers constructing the Project are also not expected to require additional housing needs beyond those which are currently available in the City of Downey, or the surrounding County areas.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 6-3 December 2023
Exhibit D Section 6.0
Other CEQA Considerations
SCAG publishes population, housing, and employment predictions for all cities within their region, including the City of Downey, based on information gathered from local planning documents, such as general and specific plans, within each SCAG-participating jurisdiction. As shown in Table 6-1 Demographics and Growth, the City's population was 114,400 in 2020 and is anticipated to grow to 121,700 in 2040. Additionally, the number of jobs is anticipated to increase to 53,000 in 2040 from its current level of 50,100.
Table 6-1
DEMOGRAPHICS AND GROWTH: CITY OF DOWNEY
2020
2035
2040
Population
114,400
119,000
121,700
Employment
50,100
51,900
53,000
Source: SCAG 2020
The proposed Project consists of a warehouse and logistics center, which is consistent with the current industrial land use and zoning of the site. The Project is expected to create approximately 300 construction jobs and approximately 250 permanent jobs, which would likely pull from the existing local workforce. As discussed in Section 7.4, Population and Housing, of this EIR, the proposed Project is not anticipated to result in an increase in population in the City of Downey or surrounding areas and is therefore not anticipated to cause a significant change in the SCAG projections.
The proposed Project would not include any off -site infrastructure or roadway improvements.
Stormwater drainage improvements would be made on -site, and new driveways would be constructed to accommodate the proposed Project. These improvements would not create an expansion of infrastructure that could induce population growth. Therefore, the Project would not remove barriers to population growth, nor would it create growth that would overwhelm or exceed existing services. As such, growth inducement would not be significant as a result of the Project.
6.4 REFERENCES
Southern California Association of Governments (SCAG). 2020. 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction. Available at: https://sca .ca.govZsites/main files file- attachments/2016 2040rtpscs finalg-rowthforecastb,,urisdiction.pdf?1605576071. Accessed June 2, 2023.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 6-4 December 2023
Exhibit D
7.0 EFFECTS FOUND NOT TO BE SIGNIFICANT
State CEQA Guidelines Section 15128 requires that an EIR contain a brief statement disclosing the reasons why various possible significant effects of a project were found not to be significant and therefore were not discussed in detail in the EIR. As concluded by the Project's NOP (included in Appendix A of this EIR) and after consideration of all comments received by the City of Downey (City) on the scope of the EIR and documented in the City's administrative record, eight environmental resource topics were determined by the City to clearly have no potential to be significantly impacted by the Project: Agriculture and Forestry Resources, Biological Resources, Mineral Resources, Population and Housing, Public Services, Recreation, Utilities and Service Systems, and Wildfire.
7.1 AGRICULTURE AND FORESTRY RESOURCES
Pursuant to CEQA Section 21060.1, agricultural land means Prime Farmland, Farmland of Statewide Importance, or Unique Farmland, as defined by the U.S. Department of Agriculture land inventory and monitoring criteria as modified for California. The State CEQA Guidelines Appendix G thresholds of significance used by the City for CEQA purposes states that a significant impact to agriculture could occur if a project was to convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) to non-agricultural use. Based on the California Department of Conservation's (DOC's) Farmland Mapping and Monitoring Program, the Project site is classified as Urban and Built Up Land (DOC 2022) and is surrounded by areas also designated as Urban and Built -Up Land. The Project site and surrounding areas are not currently being utilized for agricultural purposes. Moreover, the Project site is not within an area subject to a California Land Conservation Act of 1965 (Williamson Act) contract and is not otherwise zoned by the City for agricultural use. Similarly, the Project site does not contain forest resources or timber land. Therefore, the Project would have no impact related to agriculture and forestry resources.
7.2 BIOLOGICAL RESOURCES
The Project site and its surroundings are disturbed and developed with little to no natural habitat that could be utilized by migratory or nesting wildlife. Implementation of the Project would involve demolition of multiple industrial buildings and construction of a new, larger warehouse, which would maintain similar biological conditions as the existing site. No native vegetation exists on site, and any remaining vegetation due to landscaping is ornamental and not a special status species. No wetlands, protected waters, riparian habitat or other sensitive habitat is located at the site or its immediate surroundings. The Project would not affect the riverine habitat 0.5 mile southwest of the Project, which is the nearest habitat identified in the National Wetlands Inventory. No Significant Ecological Areas are located within the City, and thus the Project site is not in or near a Significant Ecological Area. The Project would not interfere with wildlife movement, established corridors, or nursery sites. The Project site contains very few trees and conditions would be improved by the landscaping of the proposed Project, which would cover 10.5 percent of the site. There are no Habitat Conservation Plans, Natural Community Conservation Plans, or otherwise applicable habitat conservation plans in the City and therefore the Project site. No significant impacts to biological resources are expected as a result of the proposed Project.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 7-1 December 2023
Exhibit D Section 7.0
Effects Found Not to be Significant
7.3 MINERAL RESOURCES
According to the City's General Plan EIR, their review of the state of California's mineral resource maps indicated that there are no known mineral resources located within the City (City 2004). Therefore, the Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. Additionally, the Project area is not used for mineral extraction and is not known as a locally important mineral resource recovery site. Therefore, implementation of the proposed Project would not result in the loss of availability of a regionally or locally important mineral resource and no impact would occur.
7.4 POPULATION AND HOUSING
The proposed Project does not include residential development that would directly or indirectly affect the number of residents in the area and would not contribute to the creation of additional housing in the City. The proposed Project includes a warehouse building, which would replace existing industrial buildings with similar business uses. It is anticipated that the proposed Project will generate approximately 300 construction jobs and approximately 250 permanent jobs. During both construction and operations, the Project is expected to hire from the existing population in the area and has no other features that would directly or indirectly induce population growth. The proposed Project includes demolition of industrial buildings and construction of a warehouse building The existing development does not contain housing; thus, the Project would not remove housing or displace people, necessitating the construction of replacement housing. No significant impacts related to population or housing are expected as a result of the proposed Project.
7.5 PUBLIC SERVICES
The Project would involve the demolition of five existing industrial buildings (totaling approximately 433,000 SF) and the construction of a new warehouse (totaling 535,685 SF). The Downey Fire Department operates four stations with four corresponding service districts. The Project site is in District 2 and serviced by Fire Station #2, which is located at 9556 Imperial Highway, approximately 1 mile south of the Project site. In addition to the City's four fire stations, the City is a member of mutual aid agreements with nearby cities that assist the other jurisdictions as necessary (City 2005). The Project would require fire protection services comparable to the existing conditions at the site and would not result in an increase in services such that new facilities or resources would need to be added to the Fire Department's capacity.
The proposed Project would include the construction and operation of a warehouse and logistics facility that would replace existing industrial facilities. The Downey Police Department would service the Project site and is headquartered at 10911 Brookshire Avenue, 1.1 miles northwest of the Project site. The Project would require police protection services however, no new land uses that would increase the City's population or would require unique police protection services would be involved. As such, the Project would not result in the need for expanded facilities.
Furthermore, the Project would involve demolition of existing industrial facilities and construction of a warehouse and logistics facility which would not introduce new residents to the area and therefore would not require additional schools. The Project is not anticipated to result in increased use or demand on parks that would require the construction or expansion of additional park and recreational facilities.
Other public facilities may include libraries, senior centers, community centers, and pools, all of which Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 7-2 December 2023
Exhibit D Section 7.0
Effects Found Not to be Significant
are intended to serve the general public. The proposed Project would not result in a change of demand on these services. Therefore, there would be no need for the construction or expansion of other public facilities. No significant impacts to public services are expected to occur as a result of the proposed Project.
7.6 RECREATION
The proposed Project is a warehouse site, which would not induce population growth or otherwise increase the use of or create the need for new parks and recreational facilities. Similarly, the proposed Project would not result in physical deterioration of existing recreation facilities such that there would be a need to construct expanded facilities. Therefore, no impact would occur in relation to recreation facilities.
7.7 UTILITIES AND SERVICE SYSTEMS
The proposed Project is an existing industrial site in a developed area with existing infrastructure related to water, wastewater, stormwater, electricity, natural gas, and telecommunications facilities. The Project site has connections to these utilities related to the existing buildings and would make connections to the utilities during construction. Connections would not require relocation or construction of the related facilities. Water usage for the Project would be similar to the water usage for existing site conditions, which the City has the capacity to meet during normal, dry, and multiple dry years. Wastewater is currently generated by the existing facilities at the Project site and would not be expected to substantially increase as a result of the Project. The City of Downey does not currently have a wastewater facility within its jurisdiction, but utilizes recycled water provided by CBMWD and treated by the Los Angeles County Sanitation District (LACSD) at the Los Coyotes Water Reclamation Plant in Cerritos. According to the CBMWD UWMP, the Los Coyotes Water Reclamation Plant is operating at 50 percent below capacity. Therefore, the Project would not result in a demand increase such that the wastewater treatment provider would be unable to fulfill its existing commitments.
Solid waste disposal services in the City of Downey are provided by CalMet Services, Inc, which transports waste to the Downey Area Recycling and Transfer Facility, which is owned by the County Sanitation Districts of Los Angeles County. Policies and programs listed under Utilities and Service Systems in Appendix A of the City's General Plan EIR require recycling and waste reduction, educational programs, and waste reporting (City 2004). Federal, State, and local statutes and regulations regarding solid waste generation, transport, and disposal are intended to decrease solid waste generation through mandatory reductions in solid waste quantities (e.g., through recycling and composting of green waste) and the safe and efficient transport of solid waste. Article V, Chapter 8 (Ordinance No. 09-1252) of the Downey Municipal Code requires that 100 percent of inert debris and at least 50 percent of the remaining construction and demolition debris generated during a construction or demolition project, be diverted from landfill, unless the applicant is exempt under Section 5870. The proposed Project would be required to comply with applicable practices enacted by the City under the California Integrated Waste Management Act of 1989 (AB 939) and any other applicable local, State, and federal solid waste management regulations. Therefore, no significant impact to utilities and service systems are expected to occur as a result of the proposed Project.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 7-3 December 2023
Exhibit D Section 7.0
Effects Found Not to be Significant
7.8 WILDFIRE
According to the Very High Fire Hazard Severity Zone (VHFHSZ) in Map prepared by CAL FIRE for Los Angeles County, the Project site is not in a VHFHSZ (CAL FIRE 2011). The City's Safety Chapter of the General Plan recognizes structure fires as the main threat in the City due to the lack of undeveloped land with vegetation (City 2005). The Project is located within the limits of the City of Downey and is therefore not within a State Responsibility Area (SRA), which is land where the State of California is financially responsible for the prevention and suppression of wildfires. The proposed Project would comply with the fire code in Municipal Code Article III Chapter 3, including adopting the latest CBC standards, and the California Fire Code to minimize impacts related to fires. The proposed Project would not exacerbate wildfire risks due to slope, prevailing winds, or other factors, and thereby would not expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. The Project would not physically interfere with evacuation plans or exacerbate the risk of wildfire. Therefore, no significant impacts related to wildfire are expected to occur as a result of the Project.
7.9 REFERENCES
California Department of Conservation (DOC). 2022. California Important Farmland Map. Available at:
htt s: ma s.conservation.ca. ov DLRP CIFF . Accessed May 18, 2023.
California Department of Forestry and Fire Protection (CAL FIRE). 2011. Very High Fire Hazard Severity Zones in Local Responsibility Area for Los Angeles County.
Downey, City of (City). 2005. General Plan. Available at: https:[Z www.downeyca.orgLour- cityZdepartments/community-development/planning/general-plan-map. Accessed January 26, 2022.
2004. General Plan EIR. Available at: https://www.downeyca.o our- city/departmentslcommunity-development/planningenvironmental-documents. Accessed January 26, 2022.
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 7-4 December 2023
Exhibit D
8.0 LIST OF EIR PREPARERS
The document has been completed for the City of Downey, as CEQA Lead Agency for the proposed Project, with support from the following professional staff:
8.1 LEAD AGENCY
City of Downey
Irma Huitron, Community Development Director
Edwin Noris, Deputy Director of Public Works
Alfonso Hernandez, Principal Planner
HELIX Environmental Planning, Inc.
Yara Fisher, AICP, Principal Planner
Tim Belzman, Principal Planner
Kurt Schlyer, Senior Environmental Project Manager
Erin Gustafson, AICP, Environmental Project Manager
Sheryl Horn, Senior Environmental Planner
Ellia Simmons, Environmental Planner
Anviti Singh, Environmental Planner
Sean Bohac, Senior GIS Specialist
Ana Topete, Document Specialist
Prologis Stewart and Gray Road Warehouse Project City of Downey Draft Environmental Impact Report Page 8-1 December 2023
Exhibit D
Section 8.0
List of EIR Preparers
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