The City of Placentia is considering modifying its General Plan (GP) designation and Zone classification (ZC) for its R-3 (Multi -Family, HDR/R3) land use category by increasing the maximum density from 25 units to 30 units per acre. This land use designation would impact an estimated 13.4 acres in the City as candidate sites for this higher density, which would increase the total number of units under this land use category from 335 multi -family units to 402 multi- family units, or 67 units. In order to measure the potential impact of this change to the City, a review of the current Housing Stock within the City determined that the City has a current total of 17,184 dwelling units. An increase of 67 total units as a result of this GP/ZC would represent a 0.04% increase (17,251) in the number of dwelling units in the City. This change is considered a de minimus value that would have no potential to cause a significant adverse impact on the City's environment.
Therefore, after careful review of the CEQA compliance options, I am recommending that the City consider the adoption of a Common Sense Exemption for the proposed GP/ZC change (proposed project). I recommend that the City of Placentia find that a Common Sense Exemption (as defined in CEQA) applies to GP/ZC changes under Section 15061 (b) (3) of the State CEQA Guidelines, which states: "The activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA." It is my opinion, and recommendation to the City, that this circumstance applies to the proposed project because there is no possibility that the City's existing physical environment will experience significant effects on its existing environment.
Based on this review of the proposed GP/ZC change (R-3 Multi -Family, HDR/R3) land use category for the City and the pertinent sections of CEQA and the State CEQA Guidelines, I conclude that it does not constitute a project under CEQA and adoption of the common sense exemption and filing of a Notice of Exemption is the most appropriate determination to comply with CEQA for this action. Thus, the City can approve the review and findings for this action and I recommend that you notice the proposed GP/ZC change as exempt from CEQA for the reasons outlined in the State CEQA Guideline sections cited above. The City needs to file a Notice of Exemption with the County Clerk for this action once the hearing is completed to initiate the 35 -day Statute of Limitations.
A copy of this exemption recommendation should be retained in City's project file to serve as verification of this evaluation and as the CEQA environmental determination record. If you have any questions, please feel free to give me a call.
Sincerely,
Tom Dodson