City Council / Housing Authority
August 5, 2024

1707 North Towne Avenue Project
Exemption Checklist Pursuant to
CEQA Guidelines Section15183
prepared by
City of Pomona
505 South G arey Avenue
Pomona, California 91766
Contact: Vinny Tam, Senior Planner
prepared with the assistance of
R
incon Consultants, Inc.
250 East 1st Street, Suite 1400
|Los Angeles, California 90012
April 2024
Attachment No. 7

Table of Contents

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 i Table of Contents
Introduction ............................................................................................................................................ 1 Project Title ..................................................................................................................................... 1 Lead Agency Name and Address .................................................................................................... 1 Contact Person and Phone Number ............................................................................................... 1 Project Sponsor’s Name and Address ............................................................................................. 1 Project Location .............................................................................................................................. 1 Project Site General Plan Designation ............................................................................................ 1 Project Site Zoning .......................................................................................................................... 4 Existing Setting and Surrounding Land Uses .................................................................................. 4 Description of Project ..................................................................................................................... 5 Requested Entitlements ............................................................................................................... 10 Prior Environmental Document(s) Analyzing the CEQA Guidelines Section 15183 Exemption (including State Clearinghouse Number if Assigned) ................................................. 10 Location of Prior Environmental Document(s) Analyzing the Effects of the Infill Project............ 10 Other Public Agencies Whose Approval is Required (e.g., Permits, Financing Approval, or Participation Agreement) ............................................................................................................. 10

Overview of CEQA Guidelines Section 15183 ....................................................................................... 11 Overview ....................................................................................................................................... 11 GPU EIR ......................................................................................................................................... 11 Applicability of CEQA Exemption.................................................................................................. 12 Scope of CEQA Exemption ............................................................................................................ 13 CEQA Guidelines Section 15183 Exemption Checklist .......................................................................... 14 Environmental Factors Potentially Affected ......................................................................................... 15 Determination ...................................................................................................................................... 16 Exemption Checklist ............................................................................................................................. 17 1 Aesthetics ............................................................................................................................. 17 2 Agriculture and Forestry Resources ..................................................................................... 23 3 Air Quality ............................................................................................................................. 27 4 Biological Resources ............................................................................................................. 39 5 Cultural Resources................................................................................................................ 45 6 Energy ................................................................................................................................... 49 7 Geology and Soils ................................................................................................................. 55 8 Greenhouse Gas Emissions .................................................................................................. 61 9 Hazards and Hazardous Materials ........................................................................................ 71 10 Hydrology and Water Quality ............................................................................................... 77 City of Pomona
1707 North Towne Avenue Project

ii
11 Land Use and Planning ......................................................................................................... 85 12 Mineral Resources ................................................................................................................ 92 13 Noise and Vibration .............................................................................................................. 95 14 Population and Housing ..................................................................................................... 107 15 Public Services .................................................................................................................... 111 16 Recreation .......................................................................................................................... 117 17 Transportation .................................................................................................................... 121 18 Tribal Cultural Resources ................................................................................................... 131 19 Utilities and Service Systems .............................................................................................. 135 20 Wildfire ............................................................................................................................... 141 21 Mandatory Findings of Significance ................................................................................... 145 References .......................................................................................................................................... 147 Bibliography ................................................................................................................................ 147 List of Preparers .......................................................................................................................... 152 Tables
Table 1 Project Components ........................................................................................... 6 Table 2 Health Effects Associated with Criteria Pollutants ........................................... 30 Table 3 SCAQMD Air Quality Significance Thresholds ................................................... 31 Table 4 SCAQMD LSTs for Construction and Operation ................................................ 32 Table 5 Project Construction Emissions ........................................................................ 33 Table 6 Project Operational Emissions .......................................................................... 34 Table 7 Project LST Construction and Operational Emissions ....................................... 35 Table 8 Health Risks Associated with Unmitigated Construction Activity .................... 36 Table 9 Health Risks Associated with Roadway Activity ............................................... 37 Table 10 Estimated Fuel Consumption during Construction........................................... 51 Table 11 Estimated Project Annual Transportation Energy Consumption...................... 52 Table 12 Estimated Construction Greenhouse Gas Emissions ........................................ 65 Table 13 Estimated Annual Greenhouse Gas Emissions ................................................. 65 Table 14 Consistency with Applicable SCAG RTP/SCS GHG Emission Reduction Strategies 66
Table 15 Project Consistency with Applicable General Plan, Green Plan, and Energy Action Plan Implementation Strategies ............................................................................ 67 Table 16 Consistency with General Plan Update Policies ............................................... 87 Table 17 Project Consistency with Medium Density Multiple Family District Development Standards ............................................................................................................... 90 Table 18 Exterior Noise Level Standards ......................................................................... 98 Table 19 Estimated Noise Levels at Sensitive Receptors During Loudest Construction Phase (Grading) ..................................................................................................... 102 Table of Contents

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 iii Table 20 Off-site Traffic Noise Increases ....................................................................... 104 Table 21 Student Generation Rates .............................................................................. 112 Table 22 Students Generated by GPU ........................................................................... 113 Figures
Figure 1 Regional Location ............................................................................................... 2 Figure 2 Project Location Map .......................................................................................... 3 Figure 3 Proposed Site Plan .............................................................................................. 9 Appendices
Appendix A Project Plans
Appendix B1 CalEEMod Calculations
Appendix B2 Air Quality, Greenhouse Gas, and HRA Methodology Appendix C Health Risk Assessment Data
Appendix D Cultural Resources Study
Appendix E Preliminary Geotechnical Evaluation
Appendix F1 Phase I Environmental Site Assessment
Appendix F2 Phase II Environmental Site Assessment
Appendix G Noise Study
Appendix H Focused Traffic Study

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1707 North Towne Avenue Project

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Introduction

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 1 Introduction
Project Title
1707 North Towne Ave (Project)
Lead Agency Name and Address
City of Pomona, Planning Division
505 South Garey Avenue
Pomona, California 91766
Contact Person and Phone Number
Vinny Tam, AICP, Senior Planner
909-620-2284, [email protected]
Project Sponsor’s Name and Address
ADC Pomona 3, LLC
c/o RC Homes, Inc.
550 North Larchmont Blvd, Suite 201
Los Angeles, California 90004
Project Location
The 1.9-acre development site is located east of North Towne Avenue and north of San Bernardino Avenue at 1707 North Towne Avenue (Assessor’s Parcel Number [APN] 8339-001-008) in the City of Pomona (the “City”), hereinafter, referred to as the “project site.” The project site can be locally accessed from both North Towne Avenue or San Bernardino Avenue. Regionally, the site is served by Interstate 10 (I-10), which is adjacent to the northern boundary of the site. Two Foothill Transit bus stops are located approximately 1,290 feet northeast of the project site along North Town Avenue and provide access to Route 292. The project site is also accessible from two Foothill Transit bus stops located near the intersection of San Bernardino Avenue and North San Antonio Avenue, approximately 1,600 feet east of the project site, and provides access to Route 292. Figure 1 shows the location of the project site in its regional context and Figure 2 shows the site in its neighborhood context.

Project Site General Plan Designation
The City of Pomona General Plan Update (GPU) designates the southern portion of the project site as “Activity Center” and the northern portion of the project site as “Urban Neighborhood.” The northern portion of the project site is within Transect Zone T4-A and the remaining project site area is within T5.

City of Pomona
1707 North Towne Avenue Project

2 Figure 1 Regional Location

Introduction

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 3 Figure 2 Project Location Map

City of Pomona
1707 North Towne Avenue Project

4 Project Site Zoning
The project site is zoned Administrative (A-P) and within the SB330 Overlay Zone. The adoption of SB 330, the Housing Crisis Act of 2019, does require a housing development to be rezoned if the property is consistent with the objective general plan standards and criteria. Government Code Section 65589.5(j)(4) states “a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan.” The project site is zoned A-P, which does not permit the development of residential uses; however, the project site is designated as Urban Neighborhood and Activity Center under the City’s General Plan, which contemplates residential uses and parks and other similar uses, respectively. In addition, the General Plan establishes land use density and intensity standards by transect zone. As such, the project site is designated as T4-1 and T5, which allows residential densities of up to 70 dwelling units per acre and 80 dwelling units per acre, respectively. Therefore, a Change of Zone is not required development presented below demonstrates consistency with the SB 330 Overlay Zone and the project site’s General Plan designations and Transect Zone designation.

In addition, Government Code Section 65589.5(j)(4) states a local agency (i.e., the City of Pomona) may require the proposed project to comply with the zoning regulations consistent with the City’s General Plan. The zoning designation that is applicable to the City’s Urban Neighborhood General Plan land use designation is R-3 Medium Density Multiple-Family District. As such, any development on the project site is required to comply with the zoning regulations for the R-3 District. However, the R-3 District limits building height to 35 feet or two floors while the T5 transect allows a building height up to six floors. In this case, the objective heigh standards of the General Plan shall prevail, and a building height variance shall not be required to allow the proposed three-story townhomes, as discussed below.

The project site is not located within any of the City’s Specific Plan areas. The nearest Specific Plan area to the project site is the Corridors Specific Plan, located approximately 0.5-mile southwest.

Existing Setting and Surrounding Land Uses
The 1.9-acre site is relatively flat, vacant, and undeveloped, and currently contains a telecommunications tower on the northwest portion of the site and a paved parking lot.

Surrounding General Plan land use designations include “Neighborhood Edge” and “Residential Neighborhood” to the east and south, “Urban Neighborhood” to the west and north. Surrounding zoning designations include Administrative Professional (A-P) to the north, east, and west, and R-1-6000, Single Family to the south. The area surrounding the project site includes several potential historic districts identified by the City, none of which have been formally recorded, evaluated, or designated.

Existing uses adjacent to the project site include vacant land and I-10 to the north, a church along with single-family residences across North Towne Avenue to the east, single-family residences across San Bernardino Avenue to the south, and single-family residences, a private school, and a church directly adjacent to the west.

Introduction

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 5 Description of Project
The project proposes the development of 45 three-story (approximately 37-foot-tall) single-family townhomes, 102 parking spaces (90 residential garage, 12 guest), 14,850 square feet (sf) of usable open space, and 7,710 sf of landscaping (hereinafter referred to as the “project” or “proposed project”). Table 1 summarizes the project components. Figure 3 shows the project site plan. All proposed project plans, including floor plans and conceptual building elevations are included in Appendix A.

The proposed 45 dwelling units would be configured in a variety of eight buildings (five (5) 7-plex, two (2) 2-plex, and one (1) duplex). The 45 residences would be configured in rows with 16 dwelling units along the edge of the project boundaries, and 29 dwelling units located in the center of the project site. The proposed dwelling units would consist of three to four-bedroom units, ranging between 1,274 to 1,696 sf per unit.

Building materials would include stucco for most of the building façade and accented with wood fascia. Proposed roofing materials would consist of composite shingles and the exterior color palette for the proposed townhome buildings are composed of various neutral, earth-toned colors, including shades of cream, beige, and brown.

Vehicular Access, Parking, and Pedestrian Circulation
Primary vehicular access to the project site would be provided via one driveway on San Bernardino Avenue. In addition, emergency vehicle access to the project site would be provided via one driveway along North Towne Avenue. Proposed residences would be accessed through private streets that provide driveway access to all attached single-family garages.

As summarized in Table 1, a total of 102 parking spaces would be available for the 45 units.

Residential parking spaces would be provided in the form of two-car attached garages for each unit.

Of the 102 parking spaces, 12 parking spaces would be available for guest use.

Pedestrian access to the project site would be via the existing sidewalks on North Towne Avenue and San Bernardino Avenue. The project site is also accessible from two Foothill Transit bus stops approximately 1,290 feet northeast of the project site along North Towne Avenue, and two Foothill Transit bus stops located near the intersection of San Bernardino Avenue and North San Antonio Avenue, approximately 1,600 feet east of the project site. Site plans indicate internal pedestrian walkways and sidewalks along the private streets within the project site.

Landscaping
The proposed landscape plan indicates landscaping along North Towne Avenue and San Bernardino Avenue, along the private streets within the project site, and around the usable open space areas and pedestrian pathways within the project site (Appendix A). The proposed plant palette includes a variety of low maintenance, drought tolerant trees and flowering shrubs. The public landscape areas would include artificial turf and would be maintained by the Homeowners Association. In addition, the landscape area of each residence would be maintained by the private homeowner. The project would be required to comply with the city’s Water Efficient Landscape Ordinance (Ord. No. 4232) for all proposed landscaping.

City of Pomona
1707 North Towne Avenue Project

6 Table 1 Project Components
Project Component
“R-3” Medium Density
Multiple Family Zone Project1
Land Use Medium Density Multiple Family Zone Administrative Professional and SB 330 Overlay Zone
Acreage Min. 10 acres (435,600 sf) 1.9 acres (82,240 sf) Lot Size 1,500 sf min 1,839 sf min
Dwelling Units
Unit Count – 45 dwelling units
(25 3-bedroom, 20 4-bedroom)
Unit Size 1,200 sf min (for 3-bedroom)
1,400 sf min (for 4-bedroom)
1,274-1,529 sf (3-bedroom)
1,696 sf (4-bedroom)
Density 15-30 du/acre 23.7 du/acre
Height 35’ or 2 stories max 30’ and 3 stories max
Yards
Front yard 25’ min 5’
Side Yard 18.5’ min 5-15’
Rear Yard 15’ min 6-9’ 7”
Building Separation 15’ min between residential buildings 15’ min Parking
Residents 122 spaces 90 spaces
Guest 12 spaces 12 spaces
Total Parking Spaces 134 spaces 102 parking spaces
Open Space & Landscaping
Open Space -– Usable 300 sf/du
13,500 sf
330 sf/du
14,850 sf
Landscaping – 171 sf/du
7,710 sf
1 sf = square feet; du/acre = dwelling units per acre; min = minimum; max = maximum Source: City of Pomona 2018b
Project Design Features
The following noise and vibration reduction measures would be included as part of the project:
 Noticing. At least 10 days prior to the start of construction activities, a sign shall be posted at the construction site, or other conspicuous location, that includes a telephone number for project information, and a procedure in which a construction manager will respond to and investigate noise complaints and take corrective action, if necessary, in a timely manner.  Noticing. At least 21 days prior to the start of construction activities, building occupants and residents within 300 feet of the project site shall be notified of the planned construction activities. The notification shall include a brief description of the project, the activities that would occur, the hours when construction would occur, and the construction period’s overall duration. The notification shall include the telephone numbers of the City’s and contractor’s authorized representatives that are assigned to respond in the event of a noise complaint.

Introduction

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 7  Noise Complaints. If a construction noise complaint is registered and if City code enforcement is not available to make noise measurements, the Applicant, if and as directed by the City, shall retain a City-approved noise consultant to conduct noise measurements at the properties that registered the complaint. The noise measurements shall be conducted for a minimum of one hour. The consultant shall prepare a letter report for code enforcement summarizing the measurements, calculation data used in determining impacts, and potential measures to reduce noise levels to the maximum extent feasible.
 Equipment Maintenance. Prior to the start of and for the duration of construction, the contractor shall properly maintain and tune all construction equipment in accordance with the manufacturer’s recommendations to minimize noise emissions.  Equipment Maintenance. Prior to use of any construction equipment, the contractor shall fit all equipment with properly operating mufflers, air intake silencers, and engine shrouds no less effective than as originally equipped by the manufacturer.  Equipment Restriction. Stationary noise sources (e.g., generators) shall be located as far from sensitive receptors as practicable, and they shall be muffled and enclosed within temporary sheds, or insulation barriers with a minimum STC rating of 32.  Equipment Restriction. The use of bells, whistles, alarms, and horns shall be restricted to safety warning purposes only.
 Equipment Restriction. Signs shall be posted at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than five minutes. The construction manager shall be responsible for enforcing this.  Equipment Restriction. Construction activities that utilize large grading and earthmoving equipment within 77 feet of residential buildings (where people reside and sleep) and 9 feet of nonresidential buildings shall be conducted with off-road equipment that is limited to 100 horsepower (hp) or less.
 Equipment Restriction. Construction activities that utilize a roller within 133 feet of residential buildings (where people reside and sleep) and 16 feet of nonresidential buildings shall be conducted with a static or pneumatic roller in lieu of a vibratory roller.  Equipment Restriction. To the extent feasible, hydraulic equipment shall be used instead of pneumatic impact tools, and electric-powered equipment shall be used instead of diesel- powered equipment.
 Construction Staging. Staging and delivery areas shall be located as far as feasible from nearby sensitive receptors.
 Hauling. Material hauling and deliveries shall be coordinated by the construction contractor to reduce the potential of trucks waiting to unload for protracted periods of time.  Temporary Noise Barriers. Prior to the initiation of construction activities at the project site, temporary noise barriers/blankets shall with a minimum height of ten feet shall be constructed along the entire eastern, southern, and western project site boundary. Barriers shall be constructed with a solid material that has a density of at least 1 pound per square foot (such as but not limited to, 5/8-inch plywood or 5/8-inch oriented strand board) at a minimum height of 12 feet with no gaps from the ground to the top of the barrier.  Permanent Sound Wall. An eight-foot-tall sound wall shall be installed at the northwest corner of the site, extending east along the northern property line to Building 7 (approximately 80 feet City of Pomona
1707 North Towne Avenue Project

8 in length) and south along the western property line past the dog park (approximately 80 feet in length), at minimum.
 Exterior Walls. The project’s proposed exterior wall assembly shall consist of three-coat stucco over sheathing on wood studs with a single layer of gypsum board on the interior and batt insulation in the cavity.
 STC Ratings. Windows and glass doors shall achieve the minimum STC ratings shown in Table 3 of the acoustical analysis completed by Veneklasen Associates, Inc. (included as Appendix G).

Windows and glass doors shall also meet the minimum octave band transmission loss values and STC rating requirements specified in Appendix I of the acoustical analysis.  Ventilation. Residential mechanical ventilation, or other means of natural ventilation, shall be required for all units in Zones A, B, and C, as referenced in the acoustical analysis (Appendix G).

Introduction

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 9 Figure 3 Proposed Site Plan

Source: Appendix A

City of Pomona
1707 North Towne Avenue Project

10 Requested Entitlements
The project is subject to approval by the City of Pomona’s Development Services Director and Planning Commission, and would require the following discretionary entitlement from the City of Pomona:
 Development Plan Review for development of 45 townhomes and associated site improvements.
 Tentative Tract Map to subdivide the project site into 45 single-family residential lots, common outdoor areas, and private streets.
 Minor Deviation Variance to decrease the total number of parking spaces of not more than 20 percent and an increase of not more than two feet in the permitted height of a fence or wall.

Prior Environmental Document(s) Analyzing the CEQA
Guidelines Section 15183 Exemption (including State
Clearinghouse Number if Assigned)
City of Pomona General Plan Update, Pomona Corridors Specific Plan, Active Transportation Plan and Green Plan Environmental Impact Report, July 2013. State Clearinghouse Number 2012051025.

Location of Prior Environmental Document(s) Analyzing
the Effects of the Infill Project
City of Pomona Planning Division, 505 South Garey Avenue, Pomona, CA 91766 Other Public Agencies Whose Approval is Required (e.g., Permits, Financing Approval, or Participation Agreement) Los Angeles County Fire Department approval is required for permitting purposes.

Overview of CEQA Guidelines Section 15183

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 11 Overview of CEQA Guidelines Section 15183
Overview
This Statement of Reasons for Exemption from Additional Environmental Review and Community Plan Exemption Checklist Pursuant to California Environmental Quality Act (CEQA) Guidelines (CEQA Guidelines) Section 15183 (“Statement of Reasons”) evaluates whether the environmental impacts of the project are addressed in the City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan Environmental Impact Report (hereafter collectively referred to as the GPU EIR). California Public Resources Code (PRC) Section 21083.3 and CEQA Guidelines Section 15183 provide an exemption from additional environmental review for projects that are “consistent with the development density established by existing zoning, community plan or general plan policies for which an EIR was certified, except as might be necessary to examine whether there are project-specific significant effects that are peculiar to the project or its site.” (CEQA Guidelines Section 15183[a], also PRC Section 21083.3[b], states: Exemption applies to “a development project [that] is consistent with the general plan of a local agency [if] an environmental impact report was certified with respect to that general plan.) CEQA Guidelines Section 15183(c) further states that “if an impact is not peculiar to the parcel or the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, then an EIR need not be prepared for the project solely on the basis of that impact.”

GPU EIR
The City of Pomona GPU EIR, certified in March 2014, applies to the entire geographic area located within the boundaries of the City of Pomona, which encompasses 22.84 square miles. The GPU guides land use decisions within the City through the year 2035 and includes the following objectives (City of Pomona 2014b):
 Outline a vision for Pomona’s long-range physical evolution, economic development, and resource conservation that reflects the aspirations of the community for livability, prosperity, and sustainability;
 Provide strategies and specific implementing actions that will allow this vision to be accomplished;
 Establish a basis for judging whether development proposals and public projects are in harmony with the City’s vision and provide guidance for instances or opportunities not specifically covered by development regulations or other City policy documents;  Allow City departments, other public agencies, and private developers to plan projects that will enhance the character of the community, preserve and enhance critical environmental resources and minimize hazards; and
 Provide the basis for establishing and setting priorities for detailed plans and implementing programs, such as the Updated Zoning Ordinance, the Capital Improvements Program, Specific and Area Plans, facilities plans, and redevelopment measures.

City of Pomona
1707 North Towne Avenue Project

12 The GPU emphasizes a renewed Downtown and redefined corridors, proposes focus areas and activity centers to help shape and distribute new development, promotes protecting the character of existing residential neighborhoods, and outlines the future role and form of Pomona’s public realm (City of Pomona 2014b).

Density standards are expressed in various ways, including based on the number of dwelling units per acre, the number of people in a given area, floor area ratio (FAR), and other measures of building intensity, building height, and size limitations and use restrictions. The project is consistent with the “T5 Typical” density standards analyzed in the GPU EIR. The maximum allowable housing density identified for the project site in the GPU EIR is 80 dwelling units per acre. The project would have a housing density of approximately 23.7 dwelling units per acre.

The project is also consistent with the anticipated residential unit and population density presumptions analyzed in the GPU EIR. Development facilitated by the GPU would result in approximately 8,506 residential units and approximately 23,498 residents at buildout. The project entails construction of 45 residential dwelling units, which would constitute 0.53 percent of the anticipated residential units for the buildout of the GPU, which is well within the projections of the GPU EIR.

In addition, based on 2023 population and housing estimates from the California Department of Finance (DOF) for the City, the average household size is 3.41 persons (DOF 2023). Therefore, the conservative estimate is that the project would increase the local population by up to 153 persons.

The anticipated population growth associated with the project represents approximately

0.65 percent of the potential population forecast for the buildout of the GPU, which is well within the population growth projections of the GPU EIR.

Applicability of CEQA Exemption
Pursuant to CEQA Guidelines Section 15183(d), an exemption applies under the following conditions:

1. The project shall be consistent with:
a. A community plan adopted as part of a general plan,
b. A zoning action which zoned or designated the parcel on which the project would be located to accommodate a particular density of development, or
c. A general plan of a local agency, and

2. An EIR was certified by the lead agency for the zoning action, the community plan, or the general plan.

The exemption applies only to the extent that all feasible mitigation measures for a significant effect specified in the EIR are, or will, be undertaken by the public agency having jurisdiction to implement such mitigation measures, pursuant to CEQA Guidelines Section 15183(e).

As required by CEQA, the City prepared a Final EIR (State Clearinghouse Number: 2012051025), which analyzed the environmental impacts of the GPU. On March 3, 2014, the City Council adopted Resolution No. 2014-26 certifying the GPU EIR as meeting the requirements of CEQA.

On March 3, 2014, the City Council adopted Resolution No. 2014-27, which approved General Plan Amendment (GPA 13-007) to adopt the Pomona GPU and approved the adoption of the Active Transportation Plan and the Green Plan as implementation tools of the GPU.

Overview of CEQA Guidelines Section 15183

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 13 Accordingly, CEQA Guidelines Section 15183 exemption applies to the project because the project is consistent with the GPU, and all feasible mitigation measures identified in the GPU EIR identified to be applicable to the project will be implemented, as further discussed in the Exemption Checklist.

Scope of CEQA Exemption
In evaluating whether a project is exempt from further environmental review based on consistency with the GPU EIR, CEQA Guidelines Section 15183(b) specifies that examination of environmental effects shall be limited to those effects that:

1. Are peculiar to the project or the parcel on which the project would be located,

2. Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent,

3. Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or

4. Are previously identified significant effects that, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

An additional EIR, or other environmental document, need not be prepared for a project solely on the basis of an impact that is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, pursuant to CEQA Guidelines Section 15183(c). An impact is not peculiar if uniformly applied development standards or procedures are imposed with a finding that they will substantially mitigate the applicable environmental impact, pursuant to CEQA Guidelines Section 15183(f). Such uniformly adopted policies or procedures do not have to be addressed in the prior EIR nor included in the general plan (id.) City of Pomona
1707 North Towne Avenue Project

14 CEQA Guidelines Section 15183 Exemption
Checklist
This CEQA Guidelines Section 15183 Exemption Checklist provides an analysis of potential environmental impacts resulting from the project. Following the format of CEQA Guidelines Appendix G, environmental effects are evaluated to determine if the project would result in a potentially significant impact triggering additional review under CEQA Guidelines Section 15183.  Items checked “Peculiar Impact that is not Substantially Mitigated” indicate that the project could result in a peculiar impact, including a physical change that belongs exclusively or especially to the project or that is a distinctive characteristic of the project or the project site and that peculiar impact is not substantially mitigated by the imposition of uniformly applied development policies or standards, pursuant to CEQA Guidelines Section 15183(b)(1).  Items checked “Impact not Analyzed as Significant Effect in GPU EIR” indicate that the project could result in a significant effect that was not analyzed as significant in the GPU EIR. Such a project impact is not significant if it can be substantially mitigated by the imposition of uniformly applied development policies or standards, pursuant to CEQA Guidelines Sections 15183(b)(2), (c), (f).
 Items checked “Potentially Significant Off-site or Cumulative Impact Not Discussed in GPU EIR” indicate the project could result in a significant off-site or cumulative impact that was not discussed in the GPU EIR. Such an off-site or cumulative project impact is not significant if it can be substantially mitigated by the imposition of uniformly applied development policies or standards, pursuant to CEQA Guidelines Sections 15183(b)(3), (c), (f).  Items checked “Adverse Impact More Severe Based on Substantial New Information” indicate that there is new information that leads to a determination that a project impact is more severe than discussed the GPU EIR. Such an impact is not more severe if it can be substantially mitigated by the imposition of uniformly applied development policies or standards, pursuant to CEQA Guidelines Sections 15183(b)(4), (c), (f).

As mentioned above, the a project does not qualify for a CEQA Guidelines Section 15183 exemption if the project is determined to result in one or more of the following: (1) a peculiar impact that was not identified as a significant impact under the GPU EIR, (2) a significant impact that was not analyzed as significant in the GPU EIR, (3) a potentially significant off-site impact or cumulative impact not discussed in the GPU EIR, or (4) a more severe impact due to substantial new information that was not known at the time the GPU EIR was certified. However, if a project having any of the foregoing impacts can be substantially mitigated through the imposition of uniformly applied development policies or standards, further environmental review is not required.

A summary of each potential environmental effect of the project is provided below in the exemption checklist for each subject area. A list of references, thresholds of significance guidelines, and technical studies used to support the analysis are attached as appendices.

Environmental Factors Potentially Affected

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 15 Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is: (1) a peculiar impact that was not identified as a significant impact under the GPU EIR, (2) a significant impact that was not analyzed as significant in the GPU EIR, (3) a potentially significant off-site impact or cumulative impact not discussed in the GPU EIR, or (4) a more severe impact due to substantial new information that was not known at the time the GPU EIR was certified, as indicated below and described in the checklist on the following pages. □ Aesthetics □ Agriculture and Forest
Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology and Soils □ Greenhouse Gas
Emissions
□ Hazards and Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources □ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation/Traffic □ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire
City of Pomona
1707 North Towne Avenue Project

16 Determination
Based on this initial evaluation:
□ I find that the proposed project WOULD NOT result in: (1) a peculiar impact that was not identified as a significant impact under the prior EIR; (2) a significant impact that was not analyzed as significant in the prior EIR; (3) a potentially significant off-site impact or cumulative impact not discussed in the prior EIR; or (4) a more severe impact due to substantial new information that was not known at the time the prior EIR. NO FURTHER ACTION is required and a Notice of Determination, pursuant to CEQA Guidelines Section 15094, will be filed indicating that the project IS ELIGIBLE for an EXEMPTION under CEQA Guidelines Section 15183.
□ I find that the proposed project would result in: (1) a peculiar impact that was not identified as a significant impact under the prior EIR; (2) a significant impact that was not analyzed as significant in the prior EIR; (3) a potentially significant off-site impact or cumulative impact not discussed in the prior EIR; or (4) a more severe impact due to substantial new information that was not known at the time the prior EIR. I find that FURTHER ENVIRONMENTAL REVIEW is necessary to analyze those effects that are subject to CEQA, and therefore, this project is NOT ELIGIBLE for an EXEMPTION under CEQA Guidelines Section 15183.

Signature Date

Printed Name Title

Exemption Checklist
Aesthetics

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 17 Exemption Checklist
1 Aesthetics

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Except as provided in PRC Section 21099, would the project:
a. Have a substantial adverse
effect on a scenic vista? □ □ □ □ □ ■
b. Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within a state
scenic highway? □ □ □ □ □ ■
c. In non-urbanized areas,
substantially degrade the
existing visual character or
quality of public views of the
site and its surroundings?
(Public views are those that
are experienced from
publicly accessible vantage
point). If the project is in an
urbanized area, would the
project conflict with
applicable zoning and other
regulations governing scenic
quality?
□ □ □ □ □ ■
d. Create a new source of
substantial light or glare that
would adversely affect day or
nighttime views in the area? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR analyzes aesthetics in pages 4.1-1 through 4.1-22. It reviews the potential for development accommodated by the GPU to result in adverse effects on scenic vistas and resources, light or glare that could adversely affect day or nighttime views, degradation of the visual character of the City or specific neighborhoods, and damage to scenic resources including historic buildings.

According to the GPU EIR, the City’s topography is generally flat and local aesthetics at the neighborhood level comprise various urban visual characters. The GPU EIR states that the City is nearly built out and implementation of the GPU would result in reuse of properties, conversion of uses in response to market demand, and intensification of land uses in defined areas.

City of Pomona
1707 North Towne Avenue Project

18 Areas identified for greatest potential change under the GPU would undergo new or more intense development with increased building heights that may block views of scenic vistas and affect the aesthetic character of various areas in Pomona. The GPU EIR concludes that development projects should undergo further environmental and design review on a project-by-project basis to identify and address impacts to scenic vistas at the project level. The following goals and policies were included in the GPU to minimize scenic vista and resource impacts to be less than significant:
 Pomona General Plan Goal 6C.G1, to improve the physical compatibility between the City’s major institutions and adjacent neighborhoods.
 Pomona General Plan Goal 6C.G2, to improve the function and appearance of transit, path, and corridor connections between the City’s major institutions and downtown.  Pomona General Plan Goal 6G.G10, to ensure hillside development is sensitive to existing terrain, views, and significant natural landforms or features.  Pomona General Plan Goal 7F.G5, to protect natural topographic features such as hillsides, ridgelines and mature trees and stands of trees.
 Pomona General Plan Goal 7F.G6, to minimize the visual prominence of hillside development.  Pomona General Plan Policy 7F.P10, to prohibit development on hillsides and ridgelines where structures would interrupt the skyline.
 Pomona General Plan Policy 7F.P11, to require visual impact analysis during review of public and private development projects.
 Pomona General Plan Policy 7F.P13, to require immediate re-vegetation of graded areas in new development.
 Pomona General Plan Policy 7F.P14, to allow creative development layouts that help to preserve contours and other natural features.

The GPU EIR states that there are no officially designated State Scenic Highways in Pomona, though a segment of State Route (SR) 57, between SR 90 and SR 60, is considered eligible for designation.

Several streets in the City are identified as scenic in the GPU, where damage to these streets would be avoided through implementation of GPU goals and policies, designed to protect, and enhance the visual character and quality. These GPU goals and policies overlap with guiding the desired visual character and quality of specific districts, activity centers, and corridors in the City.

The GPU EIR states that the GPU does not anticipate substantial changes in areas in the City that are occupied by established residential neighborhoods. Rather, existing conditions that may detract from the visual character and quality of corridors specified in the GPU would be updated through reuse and infill development to be complementary in type, form, scale, and character. GPU goals and policies, and objectives and strategies relating to high visual quality areas generally focus on maintaining and improving visual character and quality.

The GPU goals that pertain to the visual character and preservation of scenic resources include the following:
 Pomona General Plan Goal 6D.G1, to improve the physical character, economic vitality, and mobility function of the City’s most visible and well-traveled corridors.  Pomona General Plan Goal 6G.G1, to preserve and enhance the diversity of Pomona’s neighborhoods.
 Pomona General Plan Goal 6G.G6, to ensure new residential development is well-integrated into adjacent neighborhood street patterns and provided with pedestrian connections.

Exemption Checklist
Aesthetics

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 19  Pomona General Plan Goal 6G.G9, to ensure continuity in development scale and character with transitions between areas of differing use composition and density.

All new development would also be required to conform to applicable GPU standards. New development would also be subject to existing building and development standards specified in the Pomona Municipal Code (PMC). The GPU EIR concludes impacts to scenic resources and visual character would be less than significant with adherence to GPU goals and policies, and existing development standards in the PMC.

The City is mostly built out, and a substantial amount of ambient light from urban uses already exists. Implementation of the GPU would result in infill of vacant lands, and intensification and reuse of existing sites. Most new development would not be located adjacent to large pieces of undeveloped lands. However, for any potential new development that could occur next to undeveloped areas, Policy 7E.P6 would ensure new development adjacent to sensitive habitat minimizes nighttime lighting on sensitive habitat areas.

Project-Specific Impacts
a. Would the project have a substantial adverse effect on a scenic vista? A scenic vista is a view from a public place (roadway, designated scenic viewing spot, etc.) that is expansive and considered important. It can be obtained from an elevated position (such as from the top of a hillside) or it can be seen from a roadway with a longer-range view of the landscape. An adverse effect would occur if a proposed project would block or otherwise damage the scenic vista upon implementation.

The 1.9-acre site is relatively flat, vacant, and undeveloped, and currently contains a telecommunications tower on the northwest portion of the site, and a paved parking lot. The hillsides north of I-10 are visible when looking across the project site, but these do not constitute an actual scenic vista. Likewise, the southeast side of the project site is lined with an existing church (Covenant United Methodist Church) and existing single-family residential development, beyond which the tops of the hillsides in the Chino Hills State Park can be seen through breaks in the existing development. Distant views are not available from the roadway when looking across the project site or looking west on San Bernardino Avenue, where intervening development and some mature trees obstruct views toward the mountain.

As stated in Table 1, the proposed development would be 45 three-story (approximately 37-feet- tall) attached single family dwelling units. They would be constructed in a variety of eight buildings (five (5) 7-plex, two (2) 2-plex, and one (1) duplex). The 45 units would occur along North Towne Avenue and would be configured in rows with 16 dwelling units along the edge of the project boundaries, and 29 dwelling units located in the center of the project site, with landscaped setbacks between the houses and roadway. Proposed building heights are within the height limits specified in the City’s zoning code.

As discussed in the GPU EIR, new buildings and development anticipated in the GPU area could reduce views of scenic vistas. However, General Plan goals and policies (7F.G5, 7F.G6, 7F.P10, 7F.P11, 7F.P13, and 7F.P14), aimed to preserve scenic vistas. The project site itself is relatively flat and located in proximity to residential development. The project site and vicinity have limited distant views of the San Gabriel Mountains and Chino Hills State Park, and implementation of the project would not impact public views of these distance scenic resources.

City of Pomona
1707 North Towne Avenue Project

20 The GPU EIR found that impacts would be less than significant as all projects would be required to comply with General Plan policies and City ordinances that protect scenic vistas. This project is consistent with the analysis and conclusions provided in the GPU EIR. Therefore, the project would have a less-than-significant impact on scenic vistas.
b. Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings along a state scenic highway? Damage to scenic resources was analyzed in the GPU EIR. There are no officially designated State Scenic Highways in Pomona, though a segment of SR 57, between SR 90 and SR 60, is considered eligible for designation in the GPU. The closest eligible State Scenic Highway to the project site is SR 57, which is located approximately 7.4 miles southwest of the project site (California Department of Transportation [Caltrans] 2019). Because the project site is relatively flat, is not visible from SR 57, and is within an urbanized neighborhood with existing residential, administrative, and recreational uses, the project would not impact scenic resources along a State Scenic Highway.

Moreover, the project site does not have rock outcroppings or historic buildings, and the proposed trees would not be visible from a State Scenic Highway. Therefore, the project would not result in an adverse effect on scenic resources associated with a State Scenic Highway and impacts would be less than significant.
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of the site and its surroundings? If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The GPU EIR concludes that compliance with established development policies and standards would reduce the potential for development projects to adversely alter the visual character of the built environment and the streetscape in areas identified for infill development under the GPU, resulting in a less-than-significant impact on visual character. The GPU calls for more residential-oriented mix of uses in the Neighborhood Parkway zones, with attention paid to buffering the edges of corridor housing and adjacent neighborhoods. The project would develop 45 three-story units on the site, well within the height limits imposed by the City standards.

The project site is adjacent to existing residential land uses along North Towne Avenue. The project would result in an intensification of residential uses, an effect that was analyzed at the programmatic level in the GPU EIR. Development standards for building form and character are included in the GPU; the project follows those standards and thus, proposed single-family residential uses would be three-stories high, and would include landscaped buffers between the roadway and the new development in a way that would enhance the existing urban residential aesthetic. Exterior finishes would be neutral tones of cream, brown, and gray with stone and other naturalistic accents that would unify the design. Furthermore, the new development would add trees and ornamental plantings, and ground covers that would add to the urban forest and soften the effects of the built environment and buffer the edges between the development and the street.

Therefore, the project would have a less-than-significant impact with respect to existing visual character and quality.

Exemption Checklist
Aesthetics

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 21 d. Would the project create a new source of substantial light or glare that would adversely affect day or nighttime views in the area?
Pomona is primarily built out, and a substantial amount of ambient light from urban uses already exists. Implementation of the GPU would result in infill of vacant lands, as well as intensification and reuse of existing sites. Glare and lighting effects associated with new structures in the vicinity of open spaces would be reduced with implementation of Policy 7E.P6, which states, “Ensure that lighting from new development adjacent to sensitive habitat, including Phillips Ranch, Westmont Hills, Mountain Meadows, and Ganesha Hills, minimizes nighttime lighting on these sensitive habitat areas.”
The project site is not located in the vicinity of sensitive habitat areas. The proposed buildings would be constructed in an area that already contains commercial and residential development. As noted in the GPU EIR, the project site is in an area that currently has a substantial amount of ambient lighting from existing uses. Proposed development would comply with City of Pomona lighting standards and the primary building materials (stucco, concrete, wood grain) would not create high levels of glare. Reduced parking, increased planting, and adherence with the community and lighting design guidelines in the GPU would reduce the potential for impacts from light and glare.

The GPU EIR found that impacts would be less than significant as all projects would be required to comply with General Plan policies and City ordinances that reduce the effects of light and glare. This project is consistent with the analysis and conclusions provided in the GPU EIR. Therefore, the project would have a less-than-significant impact regarding light and glare.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to aesthetics or scenic resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to aesthetics or scenic resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan, that by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an aesthetic impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR related to recreation found all impacts to be less than significant.

There are no mitigation measures contained in the GPU EIR that apply to impacts to aesthetics.

City of Pomona
1707 North Towne Avenue Project

22 This page intentionally left blank.

Exemption Checklist
Agriculture and Forestry Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 23 2 Agriculture and Forestry Resources

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

a. Convert Prime Farmland,
Unique Farmland, or
Farmland of Statewide
Importance (Farmland), as
shown on the maps prepared
pursuant to the Farmland
Mapping and Monitoring
Program of the California
Resources Agency, to non-
agricultural use?
□ □ □ □ □ ■
b. Conflict with existing zoning
for agricultural use, or a
Williamson Act contract? □ □ □ □ □ ■
c. Conflict with existing zoning
for, or cause rezoning of,
forest land (as defined in
Public Resources Code
Section 12220(g)),
timberland (as defined by
Public Resources Code
Section 4526), or timberland
zoned Timberland Production
(as defined by Government
Code Section 51104(g))?
□ □ □ □ □ ■
d. Result in the loss of forest
land or conversion of forest
land to non-forest use? □ □ □ □ □ ■
e. Involve other changes in the
existing environment which,
due to their location or
nature, could result in
conversion of Farmland, to
non-agricultural use or
conversion of forest land to
non-forest use? □ □ □ □ □ ■
City of Pomona
1707 North Towne Avenue Project

24 City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses agricultural resources impacts on page 4.8-40. As noted therein, Pomona is an almost completely urbanized community, with a minimal amount of agricultural lands in the southwestern part of the community associated with California Polytechnic University, Pomona ([Cal Poly Pomona], Spadra Farms).

Policy 6C.P16 of the GPU calls on the City to work with Cal Poly Pomona to identify appropriate uses at Spadra Farms and along the SR 57 corridor.

The area analyzed in the GPU EIR, including the project site, is not designated as Prime Farmland, Unique Farmland or Farmland of Statewide Importance by the State’s Farmland and Mapping Program and not subject to an existing Williamson Act contract. The GPU EIR concluded that impacts associated with conversion of farmland would be less than significant, and no mitigation measures specific to agricultural impacts were required or identified.

Project-Specific Impacts
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
The project site and vicinity are within an urbanized area in the City of Pomona. There are no agricultural resources, Williamson Act-contracted land, or forest land located on or near the project site. The project site and all surrounding properties are classified as “Urban and Built-Up Land” on the State Department of Conservation’s (DOC’s) Farmland Mapping and Monitoring Maps (2016).

The project would not convert agricultural land to non-agricultural uses or result in the loss of forest land or conversion of forest land to non-forest use. The site’s urban zoning designation would not change. Therefore, the project would have no impact on agriculture or forestry resources.

Exemption Checklist
Agriculture and Forestry Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 25 Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to agriculture or forestry resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to agriculture or forestry resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered int eh City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an agriculture or forestry resource impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to agriculture and forestry resources found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to agriculture and forestry resources.

City of Pomona
1707 North Towne Avenue Project

26 This page intentionally left blank.

Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 27 3 Air Quality

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse Impact
More Severe
based on
Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

a. Conflict with or obstruct
implementation of the
applicable air quality plan? □ □ □ □ □ ■
b. Result in a cumulatively
considerable net increase of
any criteria pollutant for
which the project region is
non-attainment under an
applicable federal or state
ambient air quality
standard?
□ □ □ □ □ ■
c. Expose sensitive receptors
to substantial pollutant
concentrations? □ □ □ □ □ ■
d. Result in other emissions
(such as those leading to
odors) adversely affecting a
substantial number of
people? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses air quality impacts on pages 4.2-1 through 4.2-23. The GPU EIR examined a range of potential impacts related to local and regional air quality and determined that the GPU would be consistent with the adopted 2012 South Coast Air Quality Management Plan (AQMP) growth forecasts. The GPU EIR includes several goals and policies aimed at reducing air emission and improving air quality. As such, impacts related to potential conflicts with the adopted AQMP would be less than significant with adherence to GPU goals and policies. Specific GPU policies relevant to development anticipated under the GPU include the following:
 Pomona General Plan Policy 7E.P17, to require all large projects (exceeding 150,000 square feet of development) to incorporate Transportation Demand Management (TDM) techniques, such as promoting carpooling and transit use and providing bicycle and showers, as a condition of project approval.
 Pomona General Plan Policy 7E.P21, to require all large construction projects to mitigate diesel exhaust emissions through use of alternative fuels and control devices, as appropriate and cost effective.
 Pomona General Plan Policy 7E.P22, to minimize emissions from residential and commercial uses by incorporating sustainable design solutions, requiring high efficiency heating and City of Pomona
1707 North Towne Avenue Project

28 appliances, requiring compliance or exceedance of Title 24 for new development, encouraging passive solar building design and landscaping, incorporating drought resistant landscaping, and providing natural gas hookups.

The air quality discussion herein is based on a project-specific air quality and greenhouse gas (GHG) analysis. The section below provides an overview of air quality and project-related impacts. See Appendix B1 of this checklist for the air quality methodology.

Regulatory Compliance Measures
Regulatory Compliance Measures (RCMs) are existing requirements and reasonably anticipated standard conditions that are based on local, State, or federal regulations and laws that are frequently required independently of CEQA review and serve to offset or prevent specific impacts.

RCMs are not included as mitigation measures in the environmental clearance document because the project is required to comply with RCMs through State and local regulations.

RCM-1 Demolition, Grading, and Construction Activities: Compliance with Provisions of SCAQMD Rule 403
The project shall comply with all applicable standards of the Southern California Air Quality Management District (SCAQMD), including the following provisions of Rule 403:
 All unpaved demolition and construction areas shall be wetted at least twice daily during excavation and construction, and temporary dust covers shall be used to reduce dust emissions and meet SCAQMD Rule 403. Wetting could reduce fugitive dust by as much as 61 percent.  The construction area shall be kept sufficiently dampened to control dust caused by grading and hauling, and at all times provide reasonable control of dust caused by wind.  All clearing, earth moving, or excavation activities shall be discontinued during periods of high winds (i.e., greater than 15 mph), in order to prevent excessive amounts of dust.  All dirt/soil shall be secured by trimming, watering, or other appropriate means to prevent spillage and dust.
 All dirt/soil materials transported off-site shall be either sufficiently watered or securely covered to prevent excessive amounts of dust.
 General contractors shall maintain and operate construction equipment to minimize exhaust emissions.
 Trucks having no current hauling activity shall not idle but be turned off.

RCM-2 Odors: Compliance with Provisions of SCAQMD Rule 402 The project shall comply with the following provision of SCAQMD Rule 402: a person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.

RCM-3 Engine Idling
In accordance with Section 2485 of Title 13 of the California Code of Regulations, the idling of all diesel-fueled commercial vehicles (weighing over 10,000 pounds) during construction shall be limited to five minutes at any location.

Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 29 RCM-4 Emission Standards
In accordance with Section 93115 of Title 17 of the California Code of Regulations, operation of any stationary, diesel-fueled, compression-ignition engines shall meet specified fuel and fuel additive requirements and emission standards.

RCM-5 Architectural Coatings: Compliance with SCAQMD Rule 1113 The project shall comply with SCAQMD Rule 1113 limiting the volatile organic compound (VOC) content of architectural coatings, through use of low VOC coatings as issued by the contractor.

Air Quality Overview
The project site is in the South Coast Air Basin (SCAB), which is under the jurisdiction of SCAQMD.

The regional climate in the SCAB is semi-arid and is characterized by warm summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity. Air quality in the SCAB is primarily influenced by meteorology and a wide range of emission sources, such as dense population centers, substantial vehicular traffic, and industry.

Air pollutant emissions in the SCAB are generated primarily by stationary and mobile sources.

Stationary sources can be divided into two major subcategories: point and area sources. Point sources occur at a specific location and are often identified by an exhaust vent or stack. Examples include boilers or combustion equipment that produce electricity or generate heat. Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products. Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, and self-propelled construction equipment. Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles.

Regulatory Setting
As the regional air quality management district, the SCAQMD is required to monitor air pollutant levels to ensure that State and federal air quality standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether the standards are met or exceeded, the SCAB is classified as being in “attainment” or “nonattainment.” The health effects associated with criteria pollutants upon which attainment of State and federal air quality standards is measured are described in Table 2.

City of Pomona
1707 North Towne Avenue Project

30 Table 2 Health Effects Associated with Criteria Pollutants Pollutant Adverse Effects
Ozone (1) Short-term exposures: pulmonary function decrements and localized lung edema in humans and animals, and risk to public health implied by alterations in pulmonary morphology and host defense in animals; (2) long-term exposures: risk to public health implied by altered connective tissue metabolism and altered pulmonary morphology in animals after long-term exposures, and pulmonary function decrements in chronically exposed humans; (3) vegetation damage; and (4) property damage.

Carbon monoxide (CO) Reduces oxygen delivery leading to: aggravation of chest pain (angina pectoris) and other aspects of coronary heart disease; decreased exercise tolerance in persons with peripheral vascular disease and lung disease; impairment of central nervous system functions; and possible increased risk to fetuses.

Nitrogen dioxide (NO2) (1) Potential to aggravate chronic respiratory disease and respiratory symptoms in sensitive groups; (2) risk to public health implied by pulmonary and extra-pulmonary biochemical and cellular changes and pulmonary structural changes; and (3) contribution to atmospheric discoloration.

Sulfur dioxide (SO2) Bronchoconstriction accompanied by symptoms that may include wheezing, shortness of breath, and chest tightness during exercise or physical activity in persons with asthma.

Suspended particulate
matter (PM10 and
PM2.5)
(1) Excess deaths from short- and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes, including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease, including asthma).

Lead (1) Short-term lead poisoning overexposures can cause anemia, weakness, kidney damage, and brain damage; (2) long-term exposures to lead increases risk for high blood pressure, heart disease, kidney failure, and reduced fertility.

Source: USEPA 2024
To meet the National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS), the SCAQMD has adopted a series of air quality management plans (AQMPs) that serve as a regional blueprint to develop and implement an emission reduction strategy that will bring the area into attainment with the standards in a timely manner. The most significant air quality challenge in the SCAB is to reduce NOX emissions to meet the 2037 ozone standard deadline for the non-Coachella Valley portion of the SCAB, as NOX plays a critical role in the creation of ozone.

The 2022 AQMP includes strategies to ensure the SCAQMD does its part to further the district’s ability to meet the 2015 federal ozone standards (SCAQMD 2022). The 2022 AQMP builds on the measures already in place from the previous AQMPs and includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technology, best management practices, co-benefits from existing programs, incentives, and other Clean Air Act measures to meet the 8-hour ozone standard.

The Southern California Association of Governments’ (SCAG) projections for socio-economic data (e.g., population, housing, employment by industry) and transportation strategy and transportation control measures are incorporated into the 2022 AQMP from the latest 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) Plan (Connect SoCal) (SCAG 2020).

SCAQMD recommends quantitative regional significance thresholds for temporary construction activities and long-term project operation in the SCAB. These thresholds are shown in Table 3.

Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 31 Table 3 SCAQMD Air Quality Significance Thresholds
Pollutant Construction (pounds per day) Operation (pounds per day) NOx 100 55
VOC 75 55
PM10 150 150
PM2.5 55 55
SOx 150 150
CO 550 550
VOC: volatile organic compound; NOX: nitrogen oxides; CO: carbon monoxide; SOX: sulfur oxides; PM10: particulate matter measuring 10 microns in diameter or less; PM2.5: particulate matter measuring 2.5 microns in diameter or less.

Source: SCAQMD 2023
In addition to the above regional thresholds, the SCAQMD has developed Localized Significance Thresholds (LSTs) in response to the Governing Board’s Environmental Justice Enhancement Initiative (1-4), which was prepared to update the CEQA Air Quality Handbook (1993). SCAQMD’s Final LST Methodology was developed to be used as a tool to analyze localized air quality impacts associated with project-level development. If the calculated emissions for construction or operation of the project are below the LST emission levels found on the LST mass rate look-up tables (Appendix C of Final LST Methodology; SCAQMD 2009) and no potentially significant impacts to air quality are found to be associated with other environmental issues, then the proposed construction or operation activity is not significant for air quality. LSTs were devised in response to concern regarding exposure of individuals to criteria pollutants in local communities and have been developed for NO
X, CO, PM10, and PM2.5. LSTs represent the maximum emissions from a project that will not cause or contribute to an air quality exceedance of the most stringent applicable federal or State ambient air quality standard at the nearest sensitive receptor, taking into consideration ambient concentrations in each SRA, distance to the sensitive receptor, and project size. LSTs have been developed for emissions within site areas that measure one, two, or five acres. If a site is greater than five acres, SCAQMD recommends a dispersion analysis be performed. LSTs only apply to emissions in a fixed stationary location (such as fugitive dust, equipment exhaust, and operational energy and area sources) and are not applicable to off-site mobile sources, such as cars on a roadway (SCAQMD 2008, 2009).

The project site is within SRA 10 (Pomona/Walnut Valley). SCAQMD provides LST lookup tables for project sites that measure one, two, or five acres. The project site is approximately 1.9 acres; therefore, the LST analysis conservatively uses one-acre LSTs. LSTs are provided for receptors at a distance of 25 meters (82 feet) 50 meters (164 feet), 100 meters (328 feet), 200 meters (656 feet), 500 meters (1,640 feet) from the project disturbance boundary to the sensitive receptors. The border of construction activity would occur adjacent, west of the project site, at the American CRIP Academy. The school enrolls students from kindergarten to 12 th grade. Therefore, the analysis
below uses the LST values for 25 meters to evaluate emissions. LSTs for construction and operations in SRA 10 on a one-acre site with a receptor 25 meters away are shown in Table 4.

City of Pomona
1707 North Towne Avenue Project

32 Table 4 SCAQMD LSTs for Construction and Operation
Pollutant
Allowable Emissions for a one-Acre Site in SRA-10 for a Receptor 25 meters Away (pounds per day)
Construction Operation
Gradual conversion of NOX to NO2 103 103
CO 612 612
PM10 4 1
PM2.5 3 1
NOx = Nitrogen Oxides; NO2 = Nitrogen Dioxide; CO = Carbon Monoxide; PM10 = Particulate Matter with a diameter no more than 10 microns; PM2.5 = Particulate Matter with a diameter no more than 2.5 microns Source: SCAQMD 2009
Toxic Air Contaminants Thresholds
SCAQMD has developed significance thresholds for the emissions of TACs based on health risks associated with elevated exposure to such compounds. For carcinogenic compounds, cancer risk is assessed in terms of incremental excess cancer risk. A project would result in a potentially significant impact if it would generate an incremental excess cancer risk of 10 in one million (1 x 106) or a cancer burden of 0.5 excess cancer cases in areas exceeding one in one million risks.

Additionally, non-carcinogenic health risks are assessed in terms of a hazard index. A project would result in a potentially significant impact if it would result in a chronic and acute hazard index greater than 1.0 (SCAQMD 2023).

Project-Specific Impacts
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? A project may be inconsistent with the AQMP if it would generate population, housing, or employment growth exceeding forecasts used in the development of the AQMP. The 2022 AQMP, the most recent AQMP adopted by the SCAQMD, incorporates local city general plans and the SCAG’s Connect SoCal socioeconomic forecast projections of regional population, housing, and employment growth.

According to DOF, the City of Pomona has an estimated population of 149,721, a household count of 42,464, and an average household size of 3.41 (DOF 2023). The project involves infill development of 45 residential units on a site currently vacant. Therefore, the project would increase the local population by up to 153 persons (45 units x 3.41 persons per unit). The population growth forecasts in Connect SoCal estimate that the City of Pomona’s population would increase to 187,600 people by 2045, which is an increase of 32,900 residents from the City’s estimated 2016 baseline (SCAG 2020). Therefore, the potential population growth generated by the project would be within the SCAG growth forecast for the City of Pomona.

The AQMP also provides strategies and measures to reach attainment with the thresholds for 8-hour and 1-hour ozone and PM

2.5. As shown in Table 5 and Table 6 in the following analysis, the project would not generate criteria pollutant emissions that would exceed SCAQMD thresholds for ozone precursors (VOC and NOX) and PM2.5. Since the project would also be consistent with population growth projections for the City, the project would not conflict with or obstruct implementation of the AQMP and impacts would be less than significant.

Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 33 b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard?
In accordance with CEQA Guidelines Section 15064(h)(3), the SCAQMD’s approach for assessing cumulative impacts is based on the AQMP forecasts of attainment of ambient air quality standards in accordance with the requirements of the federal and State Clean Air Acts. If the project’s mass regional emissions do not exceed the applicable SCAQMD, then the project’s criteria pollutant emissions would not be cumulatively considerable. Air pollutant emissions generated by project construction and operation were estimated using the California Emissions Estimator Model (CalEEMod), version 2022.1.

CalEEMod uses project-specific information, including the project’s land uses, square footages for different uses (e.g., townhomes and parking lot), and location, to estimate a project’s construction and operational emissions. For more details on the modeling methodology, see Appendix B1.

Construction
Table 5 summarizes the estimated maximum daily emissions of pollutants associated with construction of the project. As shown below, VOC, NOX, CO, SO2, PM10, and PM2.5 emissions would not exceed SCAQMD regional thresholds. Because air pollutant emissions generated by project construction would not exceed SCAQMD’s regional significance thresholds, project construction would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment, and impacts would be less than significant.

Table 5 Project Construction Emissions
Year
Maximum Daily Emissions (lbs./day)
VOC NOX CO SO2 PM10 PM2.5
2024 <1 6 12 <1 3 1
2025 9 7 12 <1 1 <1
2026 <1 4 9 <1 1 <1
SCAQMD Regional Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
lbs/day = pounds per day; VOC = volatile organic compounds; NOx = nitrogen oxide; CO = carbon monoxide; PM10 = particulate matter with a diameter no more than 10 microns; PM2.5 = particulate matter with a diameter no more than 2.5 microns; SOx = sulfur oxide Notes: Some numbers may not add up precisely due to rounding considerations. Maximum on-site emissions are the highest emissions that would occur on the project site from on-site sources, such as heavy construction equipment and architectural coatings, and excludes off-site emissions from sources such as construction worker vehicle trips and haul truck trips.

Source: Table 2.1 “Overall Construction-mitigated” emissions. Highest of Summer and Winter emissions results are shown for all emissions. See CalEEMod worksheets in Appendix B1.

Operational
Table 6 summarizes the project’s operational emissions by emission source (mobile and area). Since the project would not consume natural gas, air quality emissions from energy sources are assumed not be generated. As shown below, the emissions generated by operation of the project would not exceed SCAQMD regional thresholds for criteria pollutants. Therefore, the project would not contribute substantially to an existing or projected air quality violation. In addition, because criteria pollutant emissions and regional thresholds are cumulative in nature, the project would not result in a cumulatively considerable net increase of criteria pollutants.

City of Pomona
1707 North Towne Avenue Project

34 Table 6 Project Operational Emissions
Maximum Daily Emissions (lbs/day)
Emission Source VOC NOX CO SO2 PM10 PM2.5
Mobile 1 1 10 <1 2 1
Area 1 <1 3 <1 <1 <1
Total Project Emissions 2 1 13 <1 2 1
SCAQMD Regional Thresholds 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: Mobile and area emissions modeling was completed using CalEEMod; see Appendix B1 for modeling results. Some numbers may not add up due to rounding. Emission data is pulled from “mitigated” results that include compliance with regulatory compliance measures. Emissions presented are the highest of the winter and summer modeled emissions.

Cumulative Impacts
The cumulative context for air quality is regional. The SCAB is designated a nonattainment area for the federal and State one-hour and eight-hour ozone standards, the State PM10 standards, the federal 24-hour PM2.5 standard, and the federal and state annual PM2.5 standard. SCAB is in attainment of all other federal and State standards. The project would contribute particulate matter and the ozone precursors VOC and NO
X to the area during construction and operation. As described above, regional emissions during construction and operations would not violate an air quality standard or contribute substantially to an existing or projected air quality violation; and would be less than significant. The project would not contribute a cumulatively considerable amount of emissions from construction and operations.
c. Would the project expose sensitive receptors to substantial pollutant concentrations? Localized Carbon Monoxide Hotspot Impact
A CO hotspot is a localized concentration of CO that is above a CO ambient air quality standard. The SCAB has been attaining federal CO standards since 2007, and most air quality monitoring stations no longer report CO levels (SCAQMD 2017). The SCAQMD monitoring station in SRA 10 (Pomona/Walnut Valley) that monitors CO reported maximum 1-hour and 8-hour concentrations of

1.6 ppm and 1.1 ppm, respectively, in 2022 (SCAQMD 2023b). These concentrations are well below the respective 1-hour and 8-hour standards of 20 ppm and 9 ppm. Typical development projects, such as the project, do not emit the levels of CO necessary to result in a localized hot spot.

As an example, a detailed carbon monoxide analysis was conducted during the preparation of the SCAQMD’s 2003 AQMP. The locations selected for microscale modeling in the 2003 AQMP included high average daily traffic (ADT) intersections in the SCAB that are expected to experience the highest CO concentrations. The highest CO concentration observed was at the intersection of Wilshire Boulevard and Veteran Avenue on the west side of Los Angeles near Interstate 405, approximately 40 miles west of the project site. The concentration of CO at this intersection was

4.6 ppm, which is well below the State and federal standards. The Wilshire Boulevard/Veteran Avenue intersection had an ADT of approximately 100,000 vehicles per day at the time of the study (SCAQMD 2003). According to the traffic study for the project (Appendix H), the highest project plus existing traffic volume conditions is North Towne Avenue with approximately 23,530 ADT. 1 This is

1 Peak p.m. traffic counts on North Towne Avenue are estimated in Figure 23 of the Traffic Study. Based on standard industry assumptions that peak hour is 10% of ADT, the highest traffic volume is 23,530 ADT.

Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 35 well below the 100,000 ADT at the intersection studied by SCAQMD in the 2003 AQMP, which found that CO emissions at that intersection were below the federal standards. Therefore, the project would not result in a CO hotspot and impacts would be less than significant.

Localized Significance Threshold
The project analysis assumes main construction activity would occur adjacent, west of the project site, at the American CRIP Academy. The allowable emission for the project utilizes the 25 meters receptor distance, and the project site is in SRA 10 (Pomona/Walnut Valley). Table 7 summarizes the project’s maximum localized daily construction and operation emissions. As shown therein, localized construction and operation emissions would not exceed SCAQMD LST thresholds. Therefore, localized criteria pollutant emissions impacts from project construction and operation would be less than significant.

Table 7 Project LST Construction and Operational Emissions Year
Maximum Daily Emissions (lbs/day)
VOC NOX CO SO2 PM10 PM2.5
Maximum On-site Construction Emissions <1 6 11 <1 <1 <1 SCAQMD Construction LST N/A 57 612 N/A 4 2
Threshold Exceeded? N/A No No N/A No No
Maximum On-site Operational Emissions 1 <1 3 <1 <1 <1
SCAQMD Operational LST N/A 57 612 N/A 1 1
Threshold Exceeded? N/A No No N/A No No
lbs/day = pounds per day; VOC = volatile organic compounds; NOx = nitrogen oxide; CO = carbon monoxide; PM10 = particulate matter with a diameter no more than 10 microns; PM2.5 = particulate matter with a diameter no more than 2.5 microns; SOx = sulfur oxide Notes: Some numbers may not add up precisely due to rounding considerations. Maximum on-site emissions are the highest emissions that would occur on the project site from on-site sources, such as heavy construction equipment and architectural coatings, and excludes off-site emissions from sources such as construction worker vehicle trips and haul truck trips.

Source: CalEEMod worksheets in Appendix A, see Table 3.2 – 3.16 “Overall Construction-mitigated” emissions. Highest of Summer and Winter emissions results are shown for all emissions. The mitigated emissions account for project sustainability features and/or compliance with specific regulatory standards.

Toxic Air Contaminants (TACs)

CONSTRUCTION IMPACTS
TACs are defined by California law as air pollutants that may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health. The following construction Health Risk Assessment (HRA) evaluates the potential health risk to off-site receptors due to construction of the project. Site-specific air dispersion modeling was conducted using the Lakes Environmental American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) View model. The dispersion modeling is consistent with SCAQMD’s Modeling Guidance for AERMOD (SCAQMD 2024) and was used to characterize diesel particulate matter (DPM) emissions and ground-level concentrations associated with on-site construction activities over the approximately 19-month construction period. Results of the analysis are compared to SCAQMD thresholds for a cancer risk threshold of 10 in a million and a chronic Hazard Index significance threshold of 1.0. Neither DPM nor PM

2.5 have an
acute reference exposure level (OEHHA 2019); therefore, acute risk was not evaluated. For more details on the health risk modeling, see Appendix C.

City of Pomona
1707 North Towne Avenue Project

36 The maximally exposed individual receptor (MEIR) is the modeled receptor experiencing the highest incremental excess cancer risk under the total exposure duration. The air dispersion and risk analysis identified the American CRIP Academy to be the MEIR, located immediately southeast of the site. As shown in Table 8, the MEIR would be exposed to an excess cancer risk of 3.7 in one million and a chronic hazard index less than 1. This result is conservative since the receptors at the American CRIP Academy were applied with residential risk factors, which includes a greater age sensitivity factor from the 3
rd trimester to two years old age bin, higher breathing rates, and exposure duration. Therefore, health risk to students and nearby residents due to project construction would not be potentially significant.

Table 8 Health Risks Associated with Unmitigated Construction Activity Scenario
Excess Cancer Risk
(per million)
Chronic
Health Risk1
Maximally Exposed Individual Receptor (MEIR) 3.7 0.03
SCAQMD Significance Threshold >10 >1
Threshold Exceeded? No No
µg/m3 = micrograms per cubic meter; SCAQMD = South Coast Air Quality Management District. 1Noncancer health impacts are determined by dividing the airborne concentration at the receptor by the appropriate Reference Exposure Level (REL) for that substance. A REL is defined as the concentration at which no adverse noncancer health effects are anticipated. Because noncancer health impacts are assessed as the ratio of airborne concentration versus the REL, the resulting hazard index is unitless.

For health risk assumptions and calculations, see Appendix A in the HRA.

OPERATIONAL IMPACTS
The California Air Resources Board’s (CARB) Air Quality and Land Use Handbook: A Community Health Perspective recommends that local agencies avoid siting new, sensitive land uses within specific distances of potential sources of TACs, such as freeways and high-traffic roads, distribution centers, railroads, and ports (CARB 2005). In particular, CARB recommends that local agencies avoid siting new, sensitive land uses within 500 feet of a freeway. In addition, the City of Los Angeles, approximately 30 miles west of Pomona, Planning Commissions Zoning Information No 2472 recommends a site-specific HRA within 1,000 feet of a freeway and install Minimum Efficiency Reporting Value (MERV) of 11 or higher (City of Los Angeles 2012). The primary concern is the effect of DPM on sensitive uses. The project site is located approximately 100 feet south of I-10 and 500 feet within on and off ramps. Therefore, an HRA was prepared to analyze the possible health effects associated with DPM emissions from proximity to the freeway on residents at the project site.

Health risks for a total of 239 sensitive receptor points distributed throughout the project site were modeled. Each of these receptors represents a proposed location of residential units.

Cancer risk was determined for a 30-year residency scenario at all receptor locations. Chronic risk was determined for maximum hour and maximum annual exposure. Risk levels for the MEIR are shown in Table 8. Refer to Appendix C for a more detailed accounting of total health risks for all receptors of concern.

The 2022 California Energy Code Subchapter 7, Section 150(m) requires all new sensitive use structures constructed to install MERV 13 air filters in the building ventilation systems. Therefore, this analysis included an adjustment for the inclusion of MERV 13 filters, which remove up to approximately 90 percent of diesel PM from the intake air (Singer et al. 2017). As shown in Table 8, the MEIR would be exposed to a high end (95
th percentile), 30-year excess cancer risk of
approximately 9.91 in one million, which does not exceed SCAQMD’s recommended health risk Exemption Checklist
Air Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 37 criteria of ten excess cases of cancer in one million individuals (1.0E-05) (SCAQMD 2023). As shown in Table 9, potential chronic health risks were approximately 0.0078, which is also less than SCAQMD’s health risk criteria of one. Therefore, sensitive receptors in the proposed residential units would not experience cancer and chronic risk exceeding the health risk thresholds. Therefore, no further action is recommended for the HRA.

Table 9 Health Risks Associated with Roadway Activity
Maximum Exposed Individual Resident (MEIR)1
Cancer Risk
Incremental Excess Cancer Risk 9.91 in one million
Threshold 10 in one million
Threshold Exceeded? No
Chronic Risk
Chronic Hazard Index 0.00783
Threshold 1.0
Threshold Exceeded? No
1 Based on 30-year resident exposure. Cancer risk includes adjustment for use of MERV 13 filters, pursuant to Los Angeles Municipal Code and 2019 California Energy Code requirements. The MEIR is a residence located in the northwest portion of the project site. For cancer and chronic risk, the MEIR is Receptor ID 239.
2Cancer risk without MERV 13 is 27.83 in one million.

See Appendix C for model outputs, summary form, and the MERV 13-adjusted cancer risk. d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The project entails construction of 45 townhome units with private and common outdoor spaces, and residential and guest parking. The GPU EIR acknowledges that certain uses may generate odors that affect the public. Residential uses, such as the project, are not identified on Figure 5-5, Land Uses Associated with Odor Complaints, of the 1993 SCAQMD CEQA Air Quality Handbook as uses that generate odors and thereby require analysis of odor impacts. Substantial objectionable odors are normally associated with such uses as agriculture, wastewater treatment, industrial facilities, or landfills. The proposed residential use would not generate objectionable odors affecting a substantial number of people. Therefore, the project would have no impact on other emissions such as odors.

City of Pomona
1707 North Towne Avenue Project

38 Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to air quality found all impacts to be less than significant.

There are no mitigation measures contained in the GPU EIR that apply to impacts to air quality.

Exemption Checklist
Biological Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 39 4 Biological Resources

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Would the project:
a. Have a substantial adverse
effect, either directly or
through habitat
modifications, on any
species identified as a
candidate, sensitive, or
special status species in local
or regional plans, policies, or
regulations, or by the
California Department of
Fish and Game or U.S. Fish
and Wildlife Service?
□ □ □ □ ■ □
b. Have a substantial adverse
effect on any riparian
habitat or other sensitive
natural community
identified in local or regional
plans, policies, regulations
or by the California
Department of Fish and
Game or US Fish and
Wildlife Service? □ □ □ □ □ ■
c. Have a substantial adverse
effect on federally protected
wetlands (including, but not
limited to, marsh, vernal
pool, coastal, etc.) through
direct removal, filling,
hydrological interruption, or
other means?
□ □ □ □ □ ■
d. Interfere substantially with
the movement of any native
resident or migratory fish or
wildlife species or with
established native resident
or migratory wildlife
corridors, or impede the use
of native wildlife nursery
sites? □ □ □ □ □ ■
e. Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance? □ □ □ □ □ ■
City of Pomona
1707 North Towne Avenue Project

40 Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
f. Conflict with the provisions
of an adopted Habitat
Conservation Plan, Natural
Community Conservation
Plan, or other approved
local, regional, or state
habitat conservation plan? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses biological resources impacts on pages 4.3-1 through 4.3-27. As noted therein, “the majority of development in the City under the proposed GPU and CSP would consist of infill and urban expansion of developed areas, which do not support a wide diversity of biological resources. Land inside the City boundaries are largely urbanized and contain few significant biological resources. Further, existing natural resources are fragmented and surrounded by development.” However, the following General Plan policies were amended and added as a result of the GPU EIR to reduce project impact on biological resources:
 Pomona General Plan Policy 7E.P7, amended as GPU EIR Mitigation Measure BIO-4 to state:

Coordinate with Los Angeles County to protect the East San Gabriel Valley Significant Ecological Area (SEA #6). Develop local regulations to protect areas in and adjacent to SEA #6 and adjacent SEAs such as Buzzard Peak – San Jose Hills SEA, including the possibility of identifying the East San Gabriel Valley SEA area with an overlay district in the Zoning Ordinance.  Pomona General Plan Policy 7E.P11, included as GPU EIR Mitigation Measure BIO-3 to state:

Prior to development of areas with drainage features such as ponds, detention basins, or wetlands, a site specific investigation shall be conducted to define the extent of drainage features, determine wetland permit requirements, and propose measures to mitigate any impacts on the resources.
 Pomona General Plan Policy 7E.P12, amended as GPU EIR Mitigation Measure BIO-1 to state:

Conduct presence/absence biological surveys for sensitive plant and animal species during the appropriate time of year and time of day in natural areas prior to any construction activities proposed adjacent to or in natural areas. If no special-status species are detected during these surveys, then construction-related activities may proceed. If listed special-status species are found in the construction zone, then avoid these species and their habitat or consult with U.S.

Fish and Wildlife prior to the commencement of construction.  Pomona General Plan Policy 7E.P13, included as GPU EIR Mitigation Measure BIO-2 to state:

Conduct nesting bird surveys prior to any construction activities, including projects proposed to remove/disturb native and ornamental landscaping and other nesting habitat for native birds during bird breeding season from March 1 through August 31 (as early January 1 for some raptors). If no nesting birds are detected during these surveys, then construction-related activities may proceed. Active nests in and adjacent to the construction zone should be avoided and provided a minimum buffer as determined by a biological monitor (CDFW recommends a Exemption Checklist
Biological Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 41 300 foot nest avoidance buffer or 500 feet for all active raptor nests) or consult with the U.S.

Fish and Wildlife Service and/or California Department of Fish and Wildlife prior to the commencement of construction.

The GPU EIR concluded that impacts associated with biological resources would be less than significant following implementation of General Plan goals and policies, and additional and amended policies stated above, to reduce impacts to special-status species, nesting birds, and wetlands where they may occur.

Biological Resources Setting
The analysis presented in this section is based on a review of available technical information on biological resources in the project vicinity. The analysis herein is based on a database and literature review of the CDFW California Natural Diversity Database (CNDDB; CDFW 2023a), California Department of Fish and Wildlife (CDFW) Biogeographic Information and Observation System (BIOS; CDFW 2023b), California Native Plant Society (CNPS) Online Inventory of Rare and Endangered Plants (CNPS 2023), U.S. Fish and Wildlife Service (USFWS) Critical Habitat Portal (USFWS 2023a), USFWS Information for Planning and Consultation (IPaC; USFWS 2023b), and the USFWS National Wetlands Inventory (NWI; USFWS 2023c).

The project site is a 1.90-acre flat, vacant, and undeveloped lot. There is a telecommunications tower on the northwest portion of the project site. Approximately half of the project site contains bare soil, and the other half is a paved parking lot. Surrounding General Plan land use designations include “Neighborhood Edge” and “Residential Neighborhood” to the east and south and “Urban Neighborhood” to the west and north. Surrounding zoning designations include A-P to the north, east, and west, and R-1-6000, Single Family to the south.

Existing uses adjacent to the project site include vacant land and I-10 to the north, North Towne Avenue to the east beyond which are a church and single-family residences San Bernardino Avenue to the south beyond which are single-family residences, and single-family residences, a private school, and a church to the west.

Soils
The soils within the project site were mapped as Urban land-Palmview-Tujunga complex with 0 to 5 percent slopes. The site is somewhat excessively drained with a rare frequency of flooding (USDA NRCS 2023).

Vegetation Communities and Land Cover Types
D

EVELOPED/DISTURBED
Developed/Disturbed land cover consists of areas that have been previously developed or otherwise physically modified to the extent that they no longer contain native soil and habitat conditions and no longer support most vegetation. The project site consists of paved areas and bare soil areas. This land cover type may also contain areas that are sparsely vegetated, primarily with non-native (ruderal) species.

City of Pomona
1707 North Towne Avenue Project

42 Wildlife Habitat
The project site has the potential to provide habitat or passage for common wildlife species that occur in residential and disturbed areas of the region such as raccoon (Procyon lotor), California ground squirrel (Otospermophilus beecheyi), black rat (Rattus rattus), Virgina opossum (Didelphis virginiana) and coyote (Canis latrans), and a variety of common avian species.

Project-Specific Impacts
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
According to the City of Pomona’s GPU EIR, lands in the City are largely urbanized and contain few significant biological resources (City of Pomona 2014b). The City has identified specific areas that may provide habitat for special-status species. These areas are primarily located in two distinct locations: (1) immediately east of SR 57, between W. Mission Boulevard and the Union Pacific Railroad, as well as portions of the City in the East San Gabriel Valley Sensitive Ecological Area (SEA), and (2) northeastern corner of the City immediately south of East Arrow Highway. However, the project does not overlap with either of these areas. The GPU EIR has also identified special-status wildlife and plant species locations and critical habitat, none of which are present within the project site.

However, burrowing owls (Athene cunicularia) have been known to occupy disturbed land. The non- paved portion of the project site could provide habitat for burrowing owls if suitable burrows (e.g., California ground squirrel burrows) are present. In accordance with Pomona General Plan Policy 7E.P13, and included as GPU EIR Mitigation Measure BIO-1, presence/absence biological surveys for burrowing owl during the appropriate time of year and time of day shall be conducted in natural areas prior to any construction activities proposed adjacent to or in natural areas. If no special-status species are detected during these surveys, then construction-related activities may proceed. If listed special-status species are found in the construction zone, these species and their habitat will be avoided or consultation with CDFW will be initiated prior to the commencement of construction.

Four landscaped trees and several shrubs located on the south and east sides of the project site have the potential to provide suitable habitat for nesting bird species. California Fish and Game Code 3503 (CFGC) and the Migratory Bird Treaty Act (MBTA) protect native birds and their nests from direct take. In accordance with Pomona General Plan Policy 7E.P13, and included as GPU EIR Mitigation Measure BIO-2, nesting bird surveys shall be conducted by a qualified biologist prior to any construction activities during bird breeding season from January 1 through August 31. If no nesting birds are detected during these surveys, then construction-related activities may proceed.

Active nests in and adjacent to the construction zone shall be avoided and a minimum protection buffer shall be implemented as determined by a qualified biologist. The project’s impact on nesting birds would be less than significant following the implementation of Mitigation Measure BIO-2, which is included as Policy 7E.P13 of the GPU EIR.

Exemption Checklist
Biological Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 43 b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Based on an assessment of aerial imagery (Google Earth Pro 2023, Imagery Date: January 31, 2024), the project site and vicinity do not contain any sensitive natural communities or riparian habitat.

The project site and surrounding area is dominated by urban sprawl consisting of residential development and City streets. There are no riparian habitats or sensitive nature communities in the vicinity of the project site. Therefore, the project would not result in impacts to sensitive natural communities or riparian habitat.
c. Would the project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? According to the National Wetlands Inventory and review of aerial imagery (Google Earth Pro 2023, Imagery Date: January 31, 2024), the project site is not located near any riparian or federally protected wetlands. Therefore, the project would not impact any jurisdictional waters. d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Based on an assessment of aerial imagery (Google Earth Pro 2023, Imagery Date: January 31, 2024), the surrounding area is highly urbanized and contains primarily residential development and City streets. As such, no wildlife corridors are present in the vicinity of the project site. The project would not impact wildlife movement, corridors, or nursery sites. e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
The City’s Tree Protection and Preservation Program protects Mature Significant Trees that are located on either public or private property in accordance with the City of Pomona Tree Preservation Ordinance. The trees restricted by this ordinance include any oak tree species with a trunk more than 8-inches in diameter, other tree species with a trunk more than ten inches in diameter, or multi-trunk trees with a total circumference of 38 inches or more. The diameter or circumference of the tree trunk is measured at breast height. Based on review of aerial imagery (Google Earth Pro 2023, Imagery Date: January 31, 2024), it does not appear that there are any protected trees on or immediately adjacent to the project site. Therefore, the project would not conflict with any local policies or ordinances.
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No adopted Habitat Conservation Plans, Natural Community Conservation Plans or other approved local, regional, or State habitat conservation plans apply to the project site. Therefore, no impacts would occur.

Conclusion
Further environmental analysis is not required because:

City of Pomona
1707 North Towne Avenue Project

44 1. No peculiar impacts to biological resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU and CSP policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to biological resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a biological resource impact that is more severe than anticipated by the GPU EIR.

6. The GPU EIR included four mitigation measures to address impacts to biological resources.

These mitigation measures were incorporated into the GPU policies. Implementation of GPU Policy 7E.P12 and 7E.P13 would ensure potential project impacts to biological resources would be less than significant. No additional mitigation measures contained in the GPU EIR apply to impacts to biological resources.

Exemption Checklist
Cultural Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 45 5 Cultural Resources

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Would the project:
a. Cause a substantial adverse
change in the significance of
a historical resource as
defined in Section 15064.5? □ □ □ □ □ ■
b. Cause a substantial adverse
change in the significance of
an archaeological resource
pursuant to
Section 15064.5? □ □ □ □ ■ □
c. Disturb any human remains,
including those interred
outside of formal
cemeteries? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses cultural resources impacts on pages 4.4-1 through 4.4-24. According to the GPU EIR, there are several designated historic resources throughout the City that may be affected by development under the GPU. However, Pomona’s existing development review processes protect locally designated historic resources from demolition, inappropriate alteration, and incompatible adjacent development. Furthermore, all projects in the City are subject to CEQA review, which would include evaluation of potential project-related impacts to national or California Register-listed properties. The GPU EIR concludes that impacts to historical resources would be less than significant with mitigation incorporated. General Plan policies were amended or added as a result of the GPU EIR to reduce project impact on cultural resources:
 Pomona General Plan Goal 7F.G10, to promote the protection and preservation of important archaeological sites.
 Pomona General Plan Policy 7F.P40, amended as GPU EIR Mitigation Measure CUL-1 to state:

Require that, prior to the issuance of a permit to demolish or substantially alter any of the potential historic resources identified in the Appendix of the Historic Resources Technical Report prepared by Architectural Resources Group (July 2012), the City shall require the completion of a historical evaluation of the affected potential resources(s). The evaluation shall be completed by an architectural historian satisfying the Secretary of the Interior’s Historic Preservation Professional Qualifications Standards and shall determine whether or not each of the affected potential resources appears eligible for design45ation as a local landmark or as a contributor to a local district.

If a project is found to affect one or more resources that appear eligible for local designation, then the project shall be fully subject to the Certificate of Appropriateness procedures as specified in City of Pomona
1707 North Towne Avenue Project

46 Section .5809-13(F) of Pomona’s Zoning Ordinance. (In other words, for purposes of project review, the resources(s) found to be eligible for local designation shall be treated the same as locally designated resources, whether or not they have been formally designated.)  Pomona General Plan Policy 7F.P41, to maintain sources of information regarding paleontological and archeological sites and the names and addresses of responsible organizations and qualified individuals, who can analyze, classify, record, and preserve paleontological or archaeological findings.
 Pomona General Plan Policy 7F.P42, to require a qualified paleontologist/archaeologist to monitor all grading and/or excavation where there is a potential to affect cultural, archaeological, or paleontological resources.
 Pomona General Plan Policy 7F.P43, to require new development to donate scientifically valuable paleontological or archaeological materials to a responsible public or private institution with a suitable repository, located in Pomona or Los Angeles County, whenever possible.

Project-Specific Impacts
a. Would the project cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5?
As stated in the GPU EIR, the types of project impacts that may cause a “substantial adverse change” in the significance of a historical resource include one or more of the following:
 Demolition or substantial alteration without consideration of historic features  Incompatible massing, size, scale, or architectural style of new development adjacent to one or more historical resources
 Obstruction or extensive shading of significant views to and from a historical resource by new development
 Incompatible re-use of a historical resource
 Disruption of a historical resource’s integrity of setting  Long-term loss of access to a historical resource
The cultural resources discussion herein is based on a project-specific cultural resources memorandum that was prepared by Rincon Consultants, Inc. (Appendix D). The project site is within an urbanized neighborhood surrounded by single-family homes to the east and south, a church to the east, and a school and a church to the west. There are no buildings or structures of historic significance on the project site or immediate vicinity according to General Plan Figure 7-F.2, Historic Districts and Landmarks (City of Pomona 2014a). In addition, according to the cultural resources memorandum, no built environment historical resources were identified within the project site. The records search and background research for the project site identified five potential built- environment historical resources in the vicinity of the project site, the Presidential Park Potential Local Historic District in addition to two other potential historic districts, the Central Baptist Church at 395 San Bernardino Avenue and the Covenant Korean Church at 1750 North Towne Avenue (City of Pomona 2023a and 2024). However, no properties contributing to the districts nor the potential individual resources will be physically altered by the proposed project. Additionally, the development proposed by the project is keeping with the scale and current development patterns surrounding the historic resources such that their setting will not be altered by the proposed project. The proposed project would therefore result in no impact on historical resources pursuant to CEQA. No impact would occur.

Exemption Checklist
Cultural Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 47 b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
As discussed in the GPU EIR, archaeological materials associated with occupation of the City are known to exist throughout the City and have the potential to provide important scientific information regarding history and prehistory. The GPU EIR identified impacts to unrecorded subsurface archaeological resources as less than significant with mitigation incorporated.

According to the project’s cultural resources memorandum (Appendix D), no archaeological resources or archaeological deposits were identified on the project site. Although Sacred Lands Files (SLF) search results were positive, a positive SLF search alone does not indicate the presence of known Native American resources or sacred lands in the immediate vicinity of the project site. As the Native American Heritage Commission identifies sacred lands by quadrangle, a positive search result indicates that sacred lands may exist anywhere within the Ontario, California topographic quadrangle (an approximately 62-square-mile area). Additionally, previous development of the project site including a commercial building and an associated parking lot and utilities indicates a high level of disturbance, yielding a low potential for encountering intact subsurface archaeological deposits within the project site.

The absence of substantial prehistoric or historic-period archaeological remains within the immediate vicinity, along with the existing level of disturbance in the project site, suggest there is a low potential for encountering intact subsurface archaeological deposits within the project site.

Adherence to GPU Policy 7F.P42 would reduce project impacts to archaeological resources to a less- than-significant level. Furthermore, the project would comply with the City’s standard conditions pertaining to archaeological resources should such resources, previously unknown, be encountered during ground disturbing construction activities. The City’s standard conditions include procedures to halt work until found resources are appropriately handled, assessed, and/or recorded by qualified personnel to prevent damage to found resources. Therefore, the project would have a less-than- significant impact on archaeological resources.
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
Though unanticipated, construction activities on the project site have the potential to impact previously unidentified human remains. Section 7050.5 of the California Health and Safety Code states:
“In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site, or any nearby area reasonably suspected to overlay adjacent remains, until the County Coroner has examined the remains. If the Coroner determines the remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner shall contact by telephone within 24 hours the NAHC. In addition, any person who mutilates or disinters, wantonly disturbs, or willfully removes any human remains in or from any location other than a dedicated cemetery without authority of law is guilty of a misdemeanor.” If Native American human remains are identified during construction, the Native American Heritage Commission will identify a Native American Most Likely Descendant to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods.

CEQA Guidelines Section 15064.5 directs the lead agency (or applicant), under certain circumstances, to develop an agreement with the Native Americans for the treatment and City of Pomona
1707 North Towne Avenue Project

48 disposition of the remains and any associated grave goods. Native American human remains and associated grave goods shall be treated with culturally appropriate dignity. Compliance with these existing requirements would reduce project impacts to human remains to a less than significant level. Therefore, the project would have a less-than-significant impact on human remains.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to cultural resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to cultural resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts proposed under the project that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is severe than anticipated by the GPU EIR.

6. The GPU EIR included four mitigation measures to address impacts to cultural resources. These mitigation measures were incorporated into the GPU policies. Implementation of GPU Policy 7F.P40 through 7F.P43, along with California Health and Safety Code requirements, would ensure potential project impacts to cultural resources would be less than significant. No additional mitigation measures contained in the GPU EIR apply to impacts to cultural resources.

Exemption Checklist
Energy

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 49 6 Energy

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Would the project:
a. Result in potentially
significant environmental
impact due to wasteful,
inefficient, or unnecessary
consumption of energy
resources, during project
construction or operation? □ □ □ □ □ ■
b. Conflict with or obstruct a
state or local plan for
renewable energy or energy
efficiency? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses energy usage intermittently in various locations of the document, including pages 2-1 through 2-45 (Project Description), pages 4.2-1 through 4.2-23 (Air Quality), pages 4.8-1 through 4.8-46 (Land Use and Planning), and pages 4.15-1 through 4.15-17 (Greenhouse Gases). As stated in the GPU EIR, the Conservation component of the GPU addresses energy usage in the City, indicating that the City will reduce Pomona’s demand for energy by:
 Encouraging or requiring “green building” techniques, which reduce a building’s energy use through efficient lighting, heating, and cooling; and
 Promoting compact, clustered, high density patterns of development, which reduces energy demand by reducing vehicle trips/trip length and by more efficiently utilizing energy for lighting, heating, and cooling.

In addition, the City’s Energy Action Plan (EAP) overlaps with a number of the other Green Plan topics and is an integral element of the Green Plan. The EAP identifies a comprehensive set of electricity-related energy efficiency targets, goals, policies, and actions to assist the community and City in becoming more energy-efficient and provides policies and actions to assist with their implementation. The City’s EAP and the project’s consistency with both the Green Plan and EAP are discussed further in Section 8, Greenhouse Gas Emissions.

The GPU EIR examined a range of potential impacts associated with energy use, including air quality and GHG emissions generated by energy consumption and consistency with applicable energy- related SCAG RTP/SCS policies, and concluded that there would be no impacts. No energy-related mitigation measures were required or identified.

While no significant energy-related impacts have been identified in relation to adoption and implementation of the GPU, and no mitigation is required, the GPU includes policies that will further City of Pomona
1707 North Towne Avenue Project

50 reduce the energy usage from individual development projects that take place through 2035. GPU goals and policies that focus on energy efficiency and usage reductions include:
 Pomona General Plan Policy 7E.P22, to minimize emissions from residential and commercial uses by incorporating sustainable design solutions, requiring high efficiency heating and appliances, requiring compliance or exceedance of Title 24 for new development, encouraging passive solar building design and landscaping, incorporating drought resistant landscaping, and providing natural gas hookups.
 Pomona General Plan Policy 7E.P41, to promote energy efficient development patterns by implementing compact, clustered, transit-oriented City structure.  Pomona General Plan Policy 7F.P16, to prepare and implement “green” building guidelines and/or standards, appropriate to the Pomona context, to ensure high levels of energy efficiency and reduction of environmental impacts associated with construction and operations of buildings.

Project-Specific Impacts
a. Would the project cause result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
The project would use nonrenewable resources for construction and operation of the project.

Natural resources that would be utilized by the project include petroleum-based fuels for vehicles and equipment, operational building energy usage, and operational water consumption. The anticipated use of these resources is detailed in the following subsections. As supported by the discussion below, the project would not create energy demand that would result in a significant environmental impact.

Construction Energy Demand
During project construction, energy would be consumed in the form of petroleum-based fuels used to power off-road construction vehicles and equipment on the project site, construction worker travel to and from the project site, and vehicles used to deliver materials to the site. The project would require site preparation and grading, including hauling material off-site; pavement and asphalt installation; building construction; architectural coating; and landscaping and hardscaping.

The total consumption of gasoline and diesel fuel during project construction was estimated using the assumptions and factors from CalEEMod Version 2022.1 (Appendix B1). As shown in Table 10, construction equipment, hauling and vendor trips, and worker trips would consume approximately 25,395 gallons of fuel over the project construction period. Of this total, construction equipment would consume an estimated 16,287 gallons of fuel; hauling trips would consume approximately 277 gallons of fuel; vendor trips would consume approximately 2,329 gallons of fuel; and worker trips would consume approximately 6,502 gallons of fuel. Appendix B1 includes energy calculations associated with project construction.

Exemption Checklist
Energy

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 51 Table 10 Estimated Fuel Consumption during Construction Fuel Type Gallons of Fuel MMBtu
Diesel Fuel (Construction Equipment) 16,287 1,788
Diesel Fuel (Hauling Trips) 277 30
Diesel Fuel (Vendor Trips) 2,329 256
Other Petroleum Fuel (Worker Trips) 6,502 714
Total 25,395 2,788
See Appendix D for energy calculation sheets.

The construction energy estimates represent a conservative estimate because the construction equipment used in each phase of construction was assumed to be operating every day of construction. Construction equipment would be maintained to all applicable standards, and construction activity and associated fuel consumption and energy use would be temporary and typical for construction sites. It is also reasonable to assume contractors would avoid wasteful, inefficient, and unnecessary fuel consumption during construction to reduce construction costs.

Therefore, the project would not involve the inefficient, wasteful, and unnecessary use of energy during construction, and the construction-phase impact related to energy consumption would be less than significant.

Operational Energy Demand
Operation of the project would contribute to area energy demand by consuming electricity and gasoline consumption. Electricity would be used for heating and cooling systems, lighting, appliances, water use, and the overall operation of the project. Gasoline consumption would be attributed to the trips generated by people living on-site. The estimated number of average daily trips associated with the project is used to determine the energy consumption associated with fuel use from operation of the project. Most of the fuel consumption would be from motor vehicles traveling to and from the project site. According to CalEEMod calculations (Appendix B1), the project would result in approximately 1,092,385 annual VMT. This is based on the most conservative estimate of daily trip generation determined in the traffic study (see Appendix H). Table 11 shows the project’s estimated total annual fuel consumption using the estimated trip generation and VMT with the assumed vehicle fleet mix. One gallon of gasoline is equivalent to approximately 120,286 Btu, while one gallon of diesel is equivalent to approximately 137,381 Btu (United States Energy Information Administration [EIA] 2024). Appendix B1 includes energy calculations associated with project operation.

City of Pomona
1707 North Towne Avenue Project

52 Table 11 Estimated Project Annual Transportation Energy Consumption Vehicle Type1
Percent of
Vehicle Trips2
Annual Vehicle
Miles
Traveled3
Average Fuel
Economy
(miles/gallon)4
Total Annual Fuel
Consumption
(gallons)
Total Fuel
Consumption
(MMBtu)5
Passenger Cars 49.9 545,450 24.1 22,633 2,485
Light/Medium Trucks 42.1 459,975 17.6 26,135 2,869
Heavy Trucks/Other 5.8 63,235 7.5 8,451 1,077
Motorcycles 2.1 23,752 44 540 59
Total 100 1,092,386 – 57,739 6,499
Notes: Totals may not add up due to rounding.

See Appendix D for energy calculation sheets.

As shown in Table 11, the project would consume approximately 57,739 gallons of fuel, or 6,499 MMBtu, each year for transportation uses from project operation under the most conservative estimate. The County of Los Angeles consumed three billion gallons of gasoline and 295 million gallons of diesel in 2022 (CEC 2023). The project’s transportation fuel consumptions would represent 0.002 percent of the fuel consumed in the county.

Project operation would consume approximately 0.32 GWh of electricity per year (Appendix B1).

The project’s electricity demand would be served by Southern California Edison (SCE), which provided 85,870 GWh of electricity in 2022 (California Energy Commission [CEC] 2024). The project’s electricity demand would represent less than 0.001 percent of the electricity provided by SCE.

Therefore, SCE would have sufficient supplies for the project.

The project would be required to comply with all standards set in California Building Standards Code (CBC) Title 24, which would minimize the wasteful, inefficient, or unnecessary consumption of energy resources during operation. The Building Energy Efficiency Standards (CBC Title 24, Part 6) requires newly constructed buildings to meet energy performance standards set by the Energy Commission. The California Green Building Standards (CALGreen) Code (CBC Title 24, Part 11) requires implementation of energy efficient light fixtures and building materials into the design of new construction projects. These standards are specifically crafted for new buildings to result in energy efficient performance so that the buildings do not result in wasteful, inefficient, or unnecessary consumption of energy. The standards are updated every three years and each iteration is more energy efficient than the previous standards. Furthermore, the project would continue to reduce its use of nonrenewable energy resources as the electricity generated by renewable resources provided by SCE continues to increase to comply with state requirements through Senate Bill (SB) 100, which requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

In conclusion, construction of the project would be temporary and typical of similar projects, and would not result in the wasteful, inefficient, or unnecessary consumption of energy. Operation of the project would consume fuel, and electricity; however, the project would conform to the latest versions of the Building Energy Efficiency Standards and CALGreen Code, and would therefore not lead to wasteful, inefficient, or unnecessary consumption of energy resources. In addition, SCE and SoCal Gas have sufficient energy supplies to serve the project. Therefore, the project would have a less-than-significant impact.

Exemption Checklist
Energy

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 53 b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The project would be designed to comply with the performance levels and residential mandatory measures of the latest version of the Building Energy Efficiency Standards and CALGreen Code (Title 24, Parts 6 and 11), effective January 1, 2023, which would reduce energy consumption compared to standard building practices. Measures to meet these energy standards may include low-flow plumbing fixtures, water-efficient irrigation systems, high-efficiency heating, ventilation, and air conditioning (HVAC) and hot water storage tank equipment, and lighting conservation features. Compliance with these regulations would ensure the project would not conflict with adopted energy conservation plans. Impacts would be less than significant.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to air quality and GHG emissions generated by energy consumption and consistency with applicable energy-related SCAG RTP/SCS policies found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to energy. The project would conform to the latest versions of the Building Energy Efficiency Standards and CALGreen Code.

City of Pomona
1707 North Towne Avenue Project

54 This page intentionally left blank.

Exemption Checklist
Geology and Soils

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 55 7 Geology and Soils

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Would the project:
a. Directly or indirectly cause
potential substantial
adverse effects, including
the risk of loss, injury, or
death involving: □ □ □ □ □ ■
i. Rupture of a known
earthquake fault, as
delineated on the most
recent Alquist-Priolo
Earthquake Fault Zoning
Map issued by the State
Geologist for the area or
based on other
substantial evidence of a
known fault? Refer to
Division of Mines and
Geology Special
Publication 42.
□ □ □ □ □ ■
ii. Strong seismic ground
shaking? □ □ □ □ □ ■
iii. Seismic-related ground
failure, including
liquefaction? □ □ □ □ □ ■
iv. Landslides? □ □ □ □ □ ■
b. Result in substantial soil
erosion or the loss of
topsoil? □ □ □ □ □ ■
c. Be located on a geologic
unit or soil that is unstable,
or that would become
unstable as a result of the
project, and potentially
result in on- or off-site
landslide, lateral spreading,
subsidence, liquefaction or
collapse?
□ □ □ □ □ ■
d. Be located on expansive soil,
as defined in Table 18-1-B of
the Uniform Building Code
(1994), creating substantial
risks to life or property? □ □ □ □ □ ■
City of Pomona
1707 North Towne Avenue Project

56 Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
e. Have soils incapable of
adequately supporting the
use of septic tanks or
alternative wastewater
disposal systems where
sewers are not available for
the disposal of wastewater?
□ □ □ □ □ ■
f. Directly or indirectly destroy
a unique paleontological
resource or site or unique
geologic feature?
□ □ □ □ □ ■
City of Pomona General Plan Update, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses impacts related to geology and soils on pages 4.5-1 through 4.5-19. The basic geologic setting of the project area has not changed since certification of the GPU EIR. The GPU EIR found that all impacts related to geology and soils would be less than significant with required implementation of existing regulations, policies, and standard practices, including the following:
 Current CBC, Uniform Building Code (UBC), and the City’s General Plan Development Code requirements and guidelines for buildings constructed in areas of high seismic risk.  Pomona General Plan Policy 7E.P24, to encourage rainwater and wastewater Best Management Practices (BMPs) in private and public construction in new development and renovations to minimize rainwater runoff and maximize rainwater and greywater collection and reuse.  Pomona General Plan Goal 7G.G10, to avoid exposure to hazards and reduce the potential for damage to future development.
 Pomona General Plan Policy 7G.P26, to limit development in areas with high seismic risks and landscape hazards.
 Pomona General Plan Policy 7G.P36, to require new development to be located above or below areas of potential landslide to include risk mitigation measures, such as barriers to moving earth or strategic placement of parking lots to lessen risk of injury or death from landslides.  All work requiring a grading permit would be required to have an Erosion Control Plan approved by the City.
 Pomona General Plan Policy 7F.P40, to require that, prior to the issuance of a permit to demolish or substantially alter any of the potential historic resources identified in the appendix of the Historic Resources Group (July 2012), the City shall require the completion of a historical evaluation of the affected potential resources(s). The evaluation shall be completed by an architectural historian satisfying the Secretary of the Interior’s Standards for and Guidelines for Archeology and Historic Preservation, Professional Qualifications and Standards and shall determine whether or not each of the affected potential resources appears eligible for designation as a local landmark or as a contributor to a local district. If a project is found to affect one or more resources that appear eligible for local designation, then the project shall be Exemption Checklist
Geology and Soils

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 57 fully subject to the Certificate of Appropriateness procedures as specified in Section .5809-13(F) of Pomona’s Zoning Ordinance. (In other words, for purposes of project review, the resources(s) found to be eligible for local designation shall be treated the same as locally designated resources.)
 Pomona General Plan Policy 7F.P41, to maintain sources of information regarding paleontological and archeological sites and the names and addresses of responsible organizations and qualified individuals, who can analyze, classify, record, and preserve paleontological or archeological findings.
 Pomona General Plan Policy 7F.P42, to require a qualified paleontologist/archeologist to monitor all grading and/or excavation where there is a potential to affect cultural, archeological, or paleontological resources. If these resources are found, the applicant shall implement the recommendations of the paleontologist/archeologist, subject to the approval of the Planning Division.
 Pomona General Plan Policy 7F.P43, to require new development to donate scientifically valuable paleontological or archaeological materials to a responsible public or private institution with a suitable repository, located within Pomona, or Los Angeles County, whenever possible.

According to the GPU EIR, no mitigation measures were necessary, as the policies included in the proposed GPU fully mitigate potential impacts associated with implementation of the GPU, CSP, and any infill development and urban expansion projects as a result.

Project-Specific Impacts
a. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including liquefaction? iv. Landslides?
As stated in the GPU EIR, Pomona is not located within an Alquist Priolo Fault Zone and is therefore not an area where structures are at significant risk from fault rupture. According to the project’s Geotechnical Evaluation prepared by LGC Geotechnical (LGC) in 2022, the project site is not within an Alquist-Priolo Earthquake Fault Zone and the possibility of damage due to ground rupture is considered low since no active faults are known to cross the site. Project development would be required to adhere to the applicable policies and requirements listed in the City’s GPU and Development Code related to geotechnical design and requirements. In addition, the proposed project would be subject to comprehensive regulatory requirements related to geotechnical design that are intended to reduce risks associated with seismic issues to the extent feasible, including compliance with the most recent CBC.

Furthermore, according to the DOC, the project site not located within an earthquake fault zone or

landslide zone (DOC 2019). However, the project site is located within a liquefaction zone. Based on available groundwater data and modeling calculation provided in the Geotechnical Evaluation, historic high groundwater is mapped at a depth of approximately 30 feet below existing grade (LGC 2022). The alluvial soils encountered below a depth of 30 feet were generally found to be a medium City of Pomona
1707 North Towne Avenue Project

58 dense to very dense sands interfingered with fine grained clayey soils which are generally not susceptible to liquefaction except for a few isolated sandy layers. Because proposed structures would be constructed to comply with the seismic design criteria of the CBC, property and structural damage would be minimized. The CBC is intended to provide minimum requirements to prevent major structural failure and loss of life in seismic events. Therefore, impacts associated with the development of the proposed project would be consistent with the analysis in the GPU EIR and impacts would be less than significant.
b. Would the project result in substantial soil erosion or the loss of topsoil? As stated in the GPU EIR, the local topography of Pomona is generally flat with gentle slopes to the southwest. The potential for soil erosion throughout the City is low (City of Pomona 2014b). All demolition and construction activities in the City are required to comply with CBC Chapter 70 standards, which ensure implementation of appropriate measures during grading activities to reduce soil erosion (City of Pomona 2014b). All new developments are subject to regional and local regulations pertaining to construction activities. Development greater than one acre in size is required to comply with the provisions of the General Construction Activity Stormwater Permit adopted by the State Water Resources Control Board (SWRCB), which would require the employment of best management practices (BMPs) to limit the extent of eroded materials from a construction site. In order to implement the project, a grading permit and Erosion Control Plan would be required. Compliance with CBC Chapter 70 standards and City requirements for a grading permit would reduce soil erosion impacts to a less-than-significant level. Therefore, the project would have a less-than-significant impact.
c Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
The GPU EIR did not identify a significant environmental impact with respect to the location of development under the GPU area being located on a geologic unit or soil that is unstable or that would become unstable. The GPU EIR identified a less than significant impact related to the potential for unstable soil resulting in landslides, lateral spreading, subsidence, liquefaction, or collapse. As noted in the GPU EIR, the soils in the City are predominantly alluvium within the valley area and bedrock on the San Jose and Puente/Chino Hills. As noted in the GPU EIR, there are a variety of soils series in the City, and the Altamont and San Andreas soils have the highest shrink/swell potential. As described in the GPU EIR, the CBC includes requirements to address these soil related hazards. Typical measures to treat hazardous soil conditions involve removal, proper fill selection, and compaction. As concluded on the GPU EIR, when these practices are employed on a project-by-project basis, the potential for structural damage is minimal.

The Geotechnical Evaluation was conducted that involved a subsurface exploration of the project site; it also provides geotechnical recommendations concerning earthwork and the design and construction of the foundations, floor slabs, retaining walls, infiltration systems, and pavements for the proposed project (LGC 2022). These recommendations are made in accordance with the CBC and are required to be implemented through the City’s building permit process.

As such, impacts associated with the development of the proposed project within the GPU area would be consistent with the analysis in the GPU EIR and the proposed project would not result in any significant impacts related to liquefaction, lateral spreading, and subsidence.

Exemption Checklist
Geology and Soils

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 59 d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? As stated in the GPU EIR, soils in Pomona are predominantly alluvium in the valley area and bedrock on the San Jose and Puente/Chino hills (City of Pomona 2014b). Near surface soil tests completed for the project site determined the site to have “low” to “medium” expansion potential and did not identify existing soil conditions as a potential hazard (LGC 2022). Therefore, the project would have a less-than-significant impact from expansive soils.
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
As discussed in the GPU EIR and in Section 19, Utilities and Service Systems, of this Exemption Checklist, Pomona and the project site are served by a sanitary sewer system provided by the City of Pomona. The project would connect to existing systems and would not require the use of septic tanks. Therefore, the project would have no impact.
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
As discussed in the GPU EIR, paleontological resources may be present in fossil-bearing rock formations below the ground surface. Ground-disturbing activities in fossil-bearing soils and rock formations have the potential to damage or destroy paleontological resources that may be present below the ground surface.

GPU Policies 7F.P40, 7F.P41, 7F.P42, and 7F.P43 are in place to protect paleontological resources (City of Pomona 2014a). The GPU EIR states that adherence to GPU policies would ensure impacts to paleontological resources would be less than significant. Furthermore, the project is required to comply with the City’s standard conditions pertaining to paleontological resources should such resources, previously unknown, be encountered during ground disturbing construction activities.

The City’s standard conditions include procedures to halt work until found resources are appropriately handled, assessed, and/or recorded by qualified personnel to prevent damage to found resources. Therefore, the project would have a less-than-significant impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to geology and soils that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to geology and soils that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

City of Pomona
1707 North Towne Avenue Project

60 Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a geology and soils impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to geology and soils found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to geology and soils. Specific to paleontological resources, the implementation of GPU Policies 7F.P40 through 7F.P43 would ensure potential project impacts to paleontological resources would be less than significant. No additional mitigation measures contained in the GPU EIR apply to impacts to paleontological resources.

Exemption Checklist
Greenhouse Gas Emissions

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 61 8 Greenhouse Gas Emissions

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
Would the project:
a. Generate greenhouse gas
emissions, either directly
or indirectly, that may
have a significant impact
on the environment?
□ □ □ □ □ ■
b. Conflict with an applicable
plan, policy or regulation
adopted for the purpose
of reducing the emissions
of greenhouse gases?
□ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses GHG emissions on pages 4.15-1 through 4.15-17. The GPU EIR states that implementation of the GPU would generate new greenhouse gas emissions, directly and indirectly.

However, GPU policies would help the City achieve the goals of SCAG’s 2012-2035 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which would contribute to the achievement of SCAG’s goal for per capita GHG emissions reductions required by SB 375. Therefore, the GPU EIR concluded that there would be no GPU-related impacts to GHG emissions and no mitigation measures were required or identified.

While no significant GHG-related impacts have been identified in relation to adoption and implementation of the GPU, and no mitigation is required, the GPU includes policies that will further reduce the GHG emissions from individual development projects that take place through 2035. GPU goals and policies that focus on GHG emissions reductions include:
 Pomona General Plan Goal 7B.G12 and Policy 7B.P5, to promote housing of various types in diverse settings that serve the needs of Pomona’s core household population while also attracting compact, one- and two-person households.
 Pomona General Plan Policy 7E.P41, to promote energy efficient development patterns by implementing compact, clustered, transit-oriented City structure.

Moreover, though no mitigation measures for GHG emissions are included in the GPU EIR, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Such project-specific mitigation measures may include the incorporation of specific measures or policies found in the City’s Green Plan or ordinance. However, GHG impacts of the GPU would be less than significant without mitigation.

This GHG section provides project-related analysis and is briefly summarized below. See Appendix B2 of this checklist for GHG methodology.

City of Pomona
1707 North Towne Avenue Project

62 Greenhouse Gas Overview
Climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period of time. Climate change is the result of numerous, cumulative sources of Greenhouse Gases (GHG) emissions contributing to the “greenhouse effect,” a natural occurrence which takes place in Earth’s atmosphere and helps regulate the temperature of the planet. The majority of radiation from the sun hits Earth’s surface and warms it. The surface, in turn, radiates heat back towards the atmosphere in the form of infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all directions.

GHG emissions occur both naturally and from human activities, such as fossil fuel burning, decomposition of landfill wastes, raising livestock, deforestation, and some agricultural practices.

GHGs produced by human activities include carbon dioxide (CO 2), methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO
2) is used to relate the amount of heat
absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of a specific GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane has a GWP of 30, meaning its global warming effect is 30 times greater than CO
2 on a molecule per molecule basis (Intergovernmental Panel on Climate Change [IPCC] 2021).

The United Nations IPCC expressed that the rise and continued growth of atmospheric CO2 concentrations is unequivocally due to human activities in the IPCC’s Sixth Assessment Report (2021). Human influence has warmed the atmosphere, ocean, and land, which has led the climate to warm at an unprecedented rate in the last 2,000 years. It is estimated that between the period of 1850 through 2019, that a total of 2,390 gigatons of anthropogenic CO 2 was emitted. It is likely that
anthropogenic activities have increased the global surface temperature by approximately 1.07 degrees Celsius between the years 2010 through 2019 (IPCC 2021). Emissions resulting from human activities are thereby contributing to an average increase in Earth’s temperature. Potential climate change impacts in California may include loss of snowpack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years (California Natural Resource Agency 2019).

Greenhouse Gas Emissions Inventory
Global
In 2015, worldwide anthropogenic GHG emissions totaled 47,000 million metric tons (MT) of CO2e, which is a 43 percent increase from 1990 GHG levels. Specifically, 34,522 MT of CO2e, 8,241 MT of CO2e of CH4, 2,997 MT of CO2e of N2O, and 1,001 MT of CO2e of fluorinated gases were emitted in 2015. The largest source of GHG emissions were energy production and use (includes fuels used by vehicles and buildings), which accounted for 75 percent of the global GHG emissions. Agriculture uses and industrial processes contributed 12 percent and six percent, respectively. Waste sources contributed three percent, international transport contributed two percent, and land-use change and forestry contributed to two percent of the total global GHG emissions (United States Environmental Protection Agency [USEPA] 2023a).

Exemption Checklist
Greenhouse Gas Emissions

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 63 United States
United States GHG emissions were 6,347.7 MT of CO2e in 2021 or 5,593.5 MT CO2e after accounting for sequestration. Emissions increased by 6.8 percent from 2020 to 2021. The increase from 2020 to 2021 was driven by an increase in CO2 emissions from fossil fuel combustion which increased seven percent relative to previous years and is primarily due to the economic rebounding after the COVID-19 Pandemic. In 2020, the energy sector (including transportation) accounted for 81 percent of nationwide GHG emissions while agriculture, industrial, and waste accounted for approximately 10 percent, six percent, and three percent respectively (USEPA 2023b).

California
Based on the California Air Resource Board (CARB) California Greenhouse Gas Inventory for 2000- 2021, California produced 381.3 MT of CO2e in 2021, which is 12.6 MT of CO2e higher than 2020 levels, but 23.1 MT of CO2e lower than 2019 levels. Both the 2019 to 2020 decrease and the 2020 to 2021 increase in emissions are likely due in large part to the impacts of the COVID-19 pandemic that were felt globally. The major source of GHG emissions in California is the transportation sector, which comprises 38 percent of the State’s total GHG emissions. The industrial sector is the second largest source, comprising 19 percent of the State’s GHG emissions, while electric power accounts for approximately 16 percent. The magnitude of California’s total GHG emissions is due in part to its large size and large population compared to other states. However, a factor that reduces California’s per capita fuel use and GHG emissions compared to other states is its relatively mild climate. In 2016, the State of California achieved its 2020 GHG emission reduction target of reducing emissions to 1990 levels as emissions fell below 431 MT of CO
2e (CARB 2022). The annual 2030 statewide
target emissions level is 260 MT of CO2e (CARB 2017).

Local
The City of Pomona’s EAP contains GHG emissions inventory and forecasts for both community-wide activities and municipal operations. In 2007, GHG emissions for community-wide activities were estimated at 987,170 MT CO2e, while GHG emissions for municipal operations were estimated at approximately 14,300 MT CO2e. The majority of community-wide activities emissions were associated with on-road transportation (53 percent) and commercial/industrial energy (24 percent), while the majority of municipal operations emissions were associated with water use and supply and the City-owned vehicle fleet (City of Pomona 2012a).

Project-Specific Efficiency Threshold
The vast majority of individual projects do not generate sufficient GHG emissions to directly influence climate change. However, physical changes caused by a project can contribute incrementally to significant cumulative effects, even if individual changes resulting from a project are limited. As a result, the issue of climate change typically involves an analysis of whether a project’s contribution towards an impact would be cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines Section 15064[h][1]).

To determine a project-specific threshold, guidance on GHG significance thresholds in the region from SCAQMD, the air district in which the project site is located, was used. The SCAQMD’s GHG CEQA Significance Threshold Working Group considered a tiered approach to determine the City of Pomona
1707 North Towne Avenue Project

64 significance of residential and commercial projects. The draft tiered approach is outlined in meeting minutes dated September 29, 2010 (SCAQMD 2010):
 Tier 1. If the project is exempt from further environmental analysis under existing statutory or categorical exemptions, there is a presumption of less than significant impacts with respect to climate change. If not, then the Tier 2 threshold should be considered.  Tier 2. Consists of determining whether the project is consistent with a GHG reduction plan that may be part of a local general plan, for example. The concept embodied in this tier is equivalent to the existing concept of consistency in CEQA Guidelines Section 15064(h)(3), 15125(d) or 15152(a). Under this Tier, if the project is consistent with the qualifying local GHG reduction plan, it is not significant for GHG emissions. If there is not an adopted plan, then a Tier 3 approach would be appropriate.
 Tier 3. Establishes a screening significance threshold level to determine significance. The Working Group has provided a recommendation of 3,000 MT CO 2e per year for nonindustrial
projects.
 Tier 4. Establishes a service population threshold to determine significance. The Working Group has provided a recommendation of 4.8 MT CO2e per year for land use projects.

Tier 1 would not apply to the project as it is not exempt from environmental analysis. For Tier 2, the City of Pomona does not have a qualified GHG reduction plan in its general plan or climate adaptation plan. Therefore, for a project-specific threshold, the City of Pomona has selected SCAQMD’s 3,000 MT CO
2e per year threshold for nonindustrial projects as the applicable project- specific threshold, in accordance with Tier 3. The SCAQMD’s 3,000 MT CO2e per year threshold is frequently used by jurisdictions across Southern California to determine GHG emissions impacts from nonindustrial projects.

Project-Specific Impacts
a. Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
GHG emissions associated with project construction and operation were estimated using CalEEMod, version 2022.1, with the assumptions described under Section 3, Air Quality. For more details on GHG modeling, see Appendix B1.

Construction Emissions
As shown in Table 12, construction activity for the project would generate an estimated 233 MT of CO
2e. When amortized over a 30-year period, construction of the project would generate approximately 8 MT of CO2e per year.

Exemption Checklist
Greenhouse Gas Emissions

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 65 Table 12 Estimated Construction Greenhouse Gas Emissions Construction Year Annual Emissions MT CO2e
2024 40
2025 170
2026 23
Total Emissions 233
Amortized over 30 years 8
Notes: See Appendix B for modeling results. Some numbers may not add up precisely due to rounding considerations.

Operational and Total Project Emissions
Table 13 combines the construction and operational GHG emissions associated with development of the project. As shown, annual emissions from the project would be approximately 457 MT of CO2e.

These emissions would not exceed SCAQMD’s 3,000 MT of CO2e per year threshold. Therefore, impacts from GHG emissions would be less than significant.

Table 13 Estimated Annual Greenhouse Gas Emissions
Emission Source Annual Emissions MT CO2e
Construction 8
Operational
Mobile 383
Area 1
Energy 50
Water 4
Waste 10
Refrigerant <1
Net Total 449
SCAQMD Threshold 3,000
Exceeds Threshold? No
Notes: Emissions modeling was completed using CalEEMod, except for N2O mobile emissions. See Appendix B for modeling results and N2O emissions calculations. Some numbers may not add up precisely due to rounding considerations. b. Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Consistency with Applicable Plans and Policies
The principal State plan to monitor and regulate GHGs is AB 32, the California Global Warming Solutions Act of 2006, which was followed by SB 32. The quantitative goal of AB 32 was to reduce GHG emissions to 1990 levels by 2020. According to CARB, California achieved its 2020 GHG emission reduction target in 2016. The goal of SB 32 is to reduce GHG emissions to 40 percent below 1990 levels by 2030. In 2022, the State passed AB 1279, which declares the State would City of Pomona
1707 North Towne Avenue Project

66 achieve net-zero GHG emissions by 2045 and would reduce GHG emissions by 85 percent below 1990 levels by 2045. The latest iteration of the Scoping Plan is the 2022 Scoping Plan (CARB 2023), which focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the state’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities. The 2022 Scoping Plan's strategies that apply to the project include the following:
 Reducing fossil fuel use, energy demand and VMT.
 Building Decarbonization.
 Maximizing recycling and diversion from landfills.

The project would be consistent with these goals through project design, which includes energy fixtures and appliances consistent with the latest Title 24 Green Building Code and Building Efficiency Energy Standards. In addition, the project would not include natural gas appliances and would install all-electric building appliances. Pursuant to the Title 24 CALGreen Standards, the project would install water-efficient fixtures to conform to state water conservation requirements.

The project would be served by Southern California Edison, which is required to increase its renewable energy procurement in accordance with SB 100 targets. The project site has access to Foothill Transit Line 292 along San Bernardino Avenue and North Towne Avenue, within half a mile of the project site, that connects the Claremont, Pomona, and Montclair. Therefore, promoting alternative modes of transportation and reliance on vehicular motor use. The project would not conflict with the 2022 Scoping Plan.

Senate Bill 375, signed in August 2008, directs each of the State’s 18 major MPO to prepare a SCS that contains a growth strategy to meet these emission targets for inclusion in the RTP. SCAG’s RTP/SCS includes a commitment to reduce emissions from transportation sources by promoting compact and infill development to comply with SB 375. The residential project would not conflict with any of the SCAG’s RTP/SCS goals, as outlined in Table 14.

Table 14 Consistency with Applicable SCAG RTP/SCS GHG Emission Reduction Strategies
Strategy/Action Project Consistency
Focus Growth Near Destinations & Mobility Options
 Emphasize land use patterns that facilitate multimodal access to work, educational and other destinations.
 Focus on a regional jobs/housing balance to reduce
commute times and distances and expand job
opportunities near transit and along center-focused
main streets.
 Plan for growth near transit investments and support
implementation of first/last mile strategies.
 Promote the redevelopment of underperforming retail
developments and other outmoded nonresidential
uses.
 Prioritize infill and redevelopment of underutilized
land to accommodate new growth, increase amenities
and connectivity in existing neighborhoods.
 Encourage design and transportation options that
reduce the reliance on and number of solo car trips
Consistent. The project would involve the construction of 3-story townhome residential units, community lawn area, and associated road and parking that would include a net increase of 153 residents. The project would be within
walking and biking distance of existing residential and commercial uses. In addition, the project is located west of North Towne Avenue which is serviced by Foothill
Transit Bus Line 292 and the nearest bus stop is located within half a mile north and east of the site. These
features would incentivize the use of public transit, active transportation, and fuel-efficient vehicles for traveling to and from the site. Therefore, the project would focus
growth near destinations and mobility options.

Exemption Checklist
Greenhouse Gas Emissions

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 67 Strategy/Action Project Consistency
(this could include mixed uses or locating and
orienting close to existing destinations).

Promote Diverse Housing Choices
 Preserve and rehabilitate affordable housing and
prevent displacement.

Consistent. The project would involve construction of 45 townhome units, which would increase housing supply
from the existing housing conditions.

Leverage Technology Innovations
 Promote low emission technologies such as
neighborhood electric vehicles, shared rides hailing,
car sharing, bike sharing and scooters by providing
supportive and safe infrastructure such as dedicated
lanes, charging and parking/drop-off space.
 Improve access to services through technology—such
as telework and telemedicine as well as other
incentives such as a “mobility wallet,” an app-based
system for storing transit and other multi-modal
payments.
 Identify ways to incorporate “micro-power grids” in
communities, for example solar energy, hydrogen fuel
cell power storage and power generation.

Consistent. The project would incorporate all applicable measures of the 2022 CALGreen Building Standards, which are comparable to (and more stringent in certain
categories than) LEED standards. All residential units
would be consistent with the solar provisions in the 2022 Energy Code and equipped with high efficiency insulation, high efficiency water heaters, energy efficient LED lighting fixtures, high-efficiency temperature control systems,
MERV-13 air filters, and water-efficient appliances and fixtures. Proposed buildings would be equipped for
electricity use.

Promote a Green Region
 Support development of local climate adaptation and
hazard mitigation plans, as well as project
implementation that improves community resiliency
to climate change and natural hazards.
 Support local policies for renewable energy
production, reduction of urban heat islands and
carbon sequestration.
 Promote more resource efficient development
focused on conservation, recycling and reclamation.

Consistent. The project would involve the construction of 45 townhomes units, an open area, and associated
parking and would therefore not interfere with regional wildlife connectivity or convert agricultural land. The project would comply with Pomona’s Green Plan, Title 24, and CALGreen. Therefore, the project would support
development of a green region.

Source: SCAG 2020
The City’s General Plan, Green Plan, and EAP also contain several policies that would reduce citywide levels of GHG emissions. Table 15 illustrates the project’s consistency with relevant goals and policies of the City’s General Plan, Green Plan, and EAP.

Table 15 Project Consistency with Applicable General Plan, Green Plan, and Energy Action Plan Implementation Strategies
Goals, Policies, and Actions Project Consistency
City of Pomona General Plan
6E.P1. Permit a range of multi-family residential and
residentially compatible development types in clusters at major crossroads throughout the City as identified in
Figure 6.3 Pomona Tomorrow and Figure 7-A.8 Transect
Tomorrow.

Consistent. The project would involve the construction of 45 dwelling units and is surrounded by existing residential, and commercial uses. Implementation of the project
would intensify the project site with residential uses that would be compatible with existing uses in the project
area. Therefore, the project would be consistent with
Policy 6E.P1.
7E.P22. Minimize emissions from residential and
commercial uses through the following:
 Encourage new development to incorporate
sustainability design solutions such as those outlines in the LEED rating systems.

Consistent. The project would incorporate all applicable measures of the 2022 CALGreen Building Standards, which are comparable (and more stringent in certain categories) than LEED standards. All residential units would be
consistent with the provisions of the Energy Code
City of Pomona
1707 North Towne Avenue Project

68 Goals, Policies, and Actions Project Consistency
 Require high efficiency heating and other appliance,
such as cooking equipment, refrigerators, furnaces and
low NOx water heaters in new and renovated
residential units.
 Require new residential and commercial buildings to
comply with or exceed requirements of CCR Title 24.
 Encourage passive solar building design and
landscaping conducive to passive solar energy use for
both residential and commercial uses, (e.g., building
orientation in a south to southeast direction, planting deciduous trees on west sides of structures,
landscaping with drought resistant species, and use of
groundcover rather than pavement to reduce heat
reflection).
 Encourage the use of battery-powered, electric, or
other similar equipment that does not impact local air
quality for non-residential maintenance activities.
 Provide natural gas hookups to fireplaces or require
residential use of EPA-certified wood stoves, pellet
stoves, or fireplace inserts.
regarding solar photovoltaic systems, high efficiency
insulation, high efficiency water heaters, energy efficient light emitting diode lighting fixtures, high-efficiency temperature control systems, MERV-13 air filters, and
water-efficient appliances and fixtures. Proposed
buildings would be equipped for electricity use. Therefore, the project would be consistent with Policy 7E.P22.

Policy 7E.P25. Encourage the use of water efficient
appliances and fixtures in new development and upgrades in existing development.

Consistent. The project would include water-efficient
appliances and fixtures in every residential unit in
accordance with the 2022 Title 24 standards.
7E.P41. Promote energy efficient patterns of development by implementing the vision of compact, clustered, transit- oriented City structure outlined in Section 6 of Pomona Tomorrow (General Plan).

Consistent. The project would involve the construction of 45 dwelling units and is surrounded by existing residential and commercial uses. Implementation of the project
would intensify the project site with residential uses that would be compatible with existing uses in the project
area. Therefore, the project would be consistent with
Policy 7E.P41.

City of Pomona Green Plan

1.2.2. Promote infill development to maximize land use
efficiencies and the optimum utilization of the limited vacant land remaining in the City.

Consistent. The project site is located within a highly urbanized area. Implementation of the project would
intensify uses at the site. Therefore, the project would be consistent with Policy 1.2.2.

1.2.3. Promote higher densities and a mix of uses in the downtown, transit centers, and activity centers and along transportation corridors.

Consistent. The project site is located along North Towne Avenue which is identified as a crucial transportation
corridor for the Lincoln Park Historic District.

Implementation of the project would entail development
with intensified residential uses for the site, which would complement existing residential, commercial, and
recreational uses in the vicinity. Therefore, the project would be consistent with Policy 1.2.3.

1.2.5. Encourage new housing and mixed-use
developments be built to LEED standards for
neighborhood development (LEED ND) or its equivalent.

Consistent. The project incorporates design elements and materials to comply with applicable measures in the
2022 CALGreen Building Standards, which is comparable
(and more stringent in certain categories) than Leadership in Energy and Environmental Design (LEED) standards. The project applicant is not seeking LEED certification for the project; however, projects that are compliant with 2022 CALGreen Building Standards are pre-approved for
streamlining of fundamental LEED requirements.

Therefore, the project would be consistent with
Policy 1.2.5.

Exemption Checklist
Greenhouse Gas Emissions

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 69 Goals, Policies, and Actions Project Consistency
City of Pomona Energy Action Plan
Policy 3.3. Encourage the use of energy-efficient
appliances and equipment in new buildings.

Consistent. The project would install all-electric
appliances and include energy and water-efficient
appliances in every residential unit in accordance with the 2022 Title 24 standards.

Policy 5.2. Promote the use of energy and water efficient fixtures for indoor use.

Consistent. The project would incorporate all applicable measures of the 2022 CALGreen Building Standards, which are comparable (and more stringent in certain categories) than LEED standards). All residential units would be
equipped with high-efficiency temperature control
systems, and water-efficient appliances and fixtures.

Source: City of Pomona 2012a; 2012b; 2014a
The project is consistent with State and local policies for reducing GHG emissions, including the 2022 Scoping Plan, Pomona General Plan, Green Plan, and EAP, and SCAG’s 2020-2045 RTP/SCS.

Therefore, the project would have a less-than-significant impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to GHG emissions found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to GHG emissions.

City of Pomona
1707 North Towne Avenue Project

70 This page intentionally left blank.

Exemption Checklist
Hazards and Hazardous Materials

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 71 9 Hazards and Hazardous Materials

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Create a significant hazard
to the public or the
environment through the
routine transport, use, or
disposal of hazardous
materials? □ □ □ □ □ ■
b. Create a significant hazard
to the public or the
environment through
reasonably foreseeable
upset and accident
conditions involving the
release of hazardous
materials into the
environment? □ □ □ □ □ ■
c. Emit hazardous emissions
or handle hazardous or
acutely hazardous
materials, substances, or
waste within one-quarter
mile of an existing or
proposed school? □ □ □ □ □ ■
d. Be located on a site which
is included on a list of
hazardous materials sites
compiled pursuant to
Government Code Section
65962.5 and, as a result,
would it create a significant
hazard to the public or the
environment?
□ □ □ □ □ ■
e. For a project located within
an airport land use plan or,
where such a plan has not
been adopted, within two
miles of a public airport or
public use airport, would
the project result in a
safety hazard for people
residing or working in the
project area? □ □ □ □ □ ■
City of Pomona
1707 North Towne Avenue Project

72 Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
f. Impair implementation of
or physically interfere with
an adopted emergency
response plan or
emergency evacuation
plan? □ □ □ □ □ ■
g. Expose people or
structures, either directly
or indirectly, to a significant
risk of loss, injury or death
involving wildland fires? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses hazards and hazardous materials impacts on pages 4.6-1 through 4.6-32. It addresses the following issues, discussed below: potential hazardous materials and emergency response and evacuation.

Potential Hazardous Materials
The GPU EIR identifies construction materials, and use of materials for periodic cleaning, repair, and maintenance or for landscape maintenance/pest control as potential sources of exposure to hazardous materials. However, it concludes that although the overall quantity of hazardous materials and waste generated in the City could increase as result of implementation of the GPU, all new developments that handle or use hazardous materials would be required to comply with regulations, standards, and guidelines established by the USEPA, State, Los Angeles County, and the City of Pomona, including:
 General Plan Policy 7G.P38, which requires site remediation, cleanup, and risk evaluation prior to reuse in identified areas where hazardous materials and petroleum products have impacts soil or groundwater.
 General Plan Policy 7G.P41, which pertains to public awareness and participation in household hazardous waste management, hazardous materials impacts would be less than significant.  General Plan Policy 7G.P44, which requires project applicants to prepare a Health Risk Assessment as part of the environmental review process to determine actual risks posed to schools from proposed development for any proposed development of industrial or commercial uses of more than 100,000 square feet in size within 0.25 mile of an existing or proposed school, would ensure hazardous impacts to schools to be less than significant.

According to the GPU EIR, a database search conducted through California Environmental Protection Agency’s (CalEPA) “Cortese List Data Resources” (CalEPA 2012) found over 190 sites in the City either containing or potentially containing hazardous materials contamination. These sites include leaking underground storage tanks and other hazardous materials sites listed by the California Department of Toxic Substances Control (DTSC), which are in various stages of cleanup, active Exemption Checklist
Hazards and Hazardous Materials

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 73 remediation, and monitoring, or closed cases. Seven locations in Pomona are listed by the USEPA under the Superfund Amendments and Reauthorization Act, Title III, but are not on the National Priority List. The Toxics Release Inventory, also managed by the USEPA, lists 30 facilities in Pomona, most of which are clustered in industrial areas along rail corridors in the western, southeastern, and northern areas of Pomona. The GPU EIR concludes that any development on these sites would require remediation of the site contamination, and impacts associated with development on these sites would be considered less than significant after remediation and adherence to the GPU Policies.

Similarly, the GPU EIR concludes that, although there are schools in the GPU areas that could be within 0.25 mile of facilities with the potential to release hazardous materials, compliance with existing regulations and standard safety procedures related to the handling of hazardous materials at these facilities would be expected to reduce potential impacts to a less than significant level.

Emergency Response and Evacuation
The GPU EIR found that additional growth in the City’s population from implementation of the GPU could result in increased traffic congestion, which in turn may impede the rate of evacuation for residents and affect response times for emergency medical or containment services. The Pomona Police Department’s Office of Emergency Services manages the City’s Emergency and Disaster Preparedness plans, which consist of the Standardized Emergency Management System (SEMS) Multihazard Functional Plan (MHFP) to respond to natural disasters, technological incidents, and national security emergencies. The City’s Natural Hazards Mitigation Plan works in conjunction with other City plans and documents, such as the General Plan and the MHFP. The GPU EIR concludes implementation of the following policies associated with emergency response and evacuation in the City would result in less than significant impacts on emergency response and evacuation.  General Plan Policy 7G.50, requires that the City maintain its SEMS and implement the National Incident Management System into the City’s disaster response plan, in addition to working with the County of Los Angeles to update joint-emergency and disaster response plans, as needed.  General Plan Policy 7G.P51, requires the City to develop an evacuation route plan and incorporate it into the SEMS.

According to the GPU EIR, Mitigation Measure HAZ-1 would apply to the GPU areas to ensure hazardous impacts are less than significant. All components of Mitigation Measure HAZ-1 were incorporated into the GPU as the following additional policies:
 Pomona General Plan Policy 6C.P10, for the City to maintain consistency with the Los Angeles County Airport Land Use Compatibility Plan [once adopted] as it pertains to Brackett Field.  Pomona General Plan Policy 7G.P54, for the City to coordinate disaster preparedness and emergency response with appropriate agencies, including the Pomona Police Department, Los Angeles County Fire Department, Los Angeles County Airport Land Use Commission, Brackett Field operators and emergency response providers, and neighboring cities.  Pomona General Plan Policy 7G.P55, to ensure that land uses, densities, and building heights in Airport Land Use Compatibility Zones are compatible with safe operation of Brackett Field.  Pomona General Plan Policy 7G.P56, to review and update City procedures for responding to airport and aircraft related emergencies.

City of Pomona
1707 North Towne Avenue Project

74 The GPU EIR concluded that impacts associated with hazards and hazardous materials would be less than significant following implementation of General Plan goals and policies stated above, and implementation of the additional policies from Mitigation Measure HAZ-1.

Project-Specific Impacts
a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
As stated in the GPU EIR, the overall quantity of hazardous materials and waste generated in the City is anticipated to increase as a result of infill development and urban expansion from implementation of the GPU. New developments that handle or use hazardous materials would be required to comply with regulations, standards, and guidelines established by the USEPA, State, Los Angeles County, and the City, including Title 49 of the Code of Federal Regulations and Title 22, Division 4.5 of the California Code of Regulations.

The project entails the development of 45 three-story single-family townhomes. Construction activities would not generate hazardous waste materials (such as asbestos or lead) from demolition since the project site is vacant and undeveloped. Limited quantities of hazardous materials (such as solvents and low VOC paints or finishes) may be used during building construction. However, the transportation, use, storage, and disposal of construction materials and equipment would be required to comply with applicable federal, State, and local regulations, standards, and guidelines, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Material Management Act, and the California Code of Regulations, Title 22.

According to the Phase I Environmental Site Assessment (ESA) prepared for the project site by Frey in 2022, the former agricultural use of the site as groves from 1928 through 1953 is considered a recommended environmental concern due to the potential application of arsenical pesticides and herbicides and organochlorine pesticides (OCPs) to irrigated crops. Based on the Phase II ESA, the OCP soil samples did not exceed the screening level for residential soil. The concentration of arsenic found in the soil samples exceeds the screening level for residential soil. The USEPA and DTSC have recognized that the screening level for arsenic is commonly less than the concentrations which occur naturally in southern California soils. The DTSC conducted an extensive study of naturally occurring arsenic concentration in soils at school properties throughout Los Angeles County and determined that arsenic occurs naturally at concentrations of up to about 12 milligrams per kilograms in southern California soils. Based on arsenic concentrations at the site in comparison to the southern California arsenic concentration study, Frey determined that the arsenic levels in the soil samples collected are naturally occurring. Therefore, the site has not been adversely affected by former agricultural use. Impacts are less than significant.

Proposed residential uses would not emit or handle hazardous materials beyond typical household and landscape waste and materials, and the project would not create a hazard to the public through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts would be less than significant.

Exemption Checklist
Hazards and Hazardous Materials

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 75 c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? There is one school within a one-quarter-mile radius of the project site – American CRIP Academy (395 San Bernardino Avenue), which is immediately west of the project site. However, as discussed in Thresholds a and b, above, the transport, use, and storage of hazardous materials during the construction and operation of the project would be conducted in accordance with all applicable federal, State, and local regulations; therefore, the project would not release hazardous substances to schools within a 0.25-mile radius of the project. Impacts would be less than significant. d. Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Figure 4.6-1, Hazardous Materials Sites, in the GPU EIR indicates there are no hazardous sites located in the vicinity of the project site. Review of Cortese List sites indicate that the project site is not listed as a hazardous waste site according to the EnviroStor and GeoTracker databases (DTSC 2024; SWRCB 2024a). There is one cleanup program site within 1,000 feet of the project site at Quality Radiator & Heater located at 555 East Vinton Avenue. The status of the site is Open – Inactive as of January 1, 1985. The project site and vicinity are not contaminated nor under Statewide investigative orders for per- and polyfluoroalkyl substances testing in drinking and non- drinking water sources (SWRCB 2024b). Therefore, the project would have a less-than-significant impact.
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? There are no existing public or private airstrips in the City (City of Pomona 2014b). The closest airport to the project site is Brackett Field, located approximately 2.1 miles northwest of the project site. The project site is located within Zone E of the Brackett Field Airport Influence Area. While the proposed project would be subject to general noise from aircraft overflights from this airport, the project site is outside the range of all the airport’s noise contours (Los Angeles County 2015).

Therefore, the project would have a less-than-significant impact. f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The project would increase traffic around the project site and vicinity, due to the addition of residents. However, the project would not result in any street closures that could impede emergency access or evacuation. The GPU EIR includes updates for several General Plan policies pertaining to disaster preparedness and emergency response and concludes that implementation of updated policies associated with emergency response and evacuation in the City would result in a less-than-significant impact (see Section 17, Transportation and Traffic, for additional information).

Therefore, the project would have a less-than-significant impact.

City of Pomona
1707 North Towne Avenue Project

76 g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
The project site is within an urbanized area in the northern portion of the City; as such, there are no wildlands in the vicinity of the project site. As stated in the GPU EIR, the southwestern corner of the City is particularly susceptible to wildland fires. The project site and vicinity are not identified as a Very High Fire Hazard Severity Zone by CalFire (CalFire 2023). Implementation of the project would not significantly increase exposure of people or structures to a significant risk of loss, injury, or death involving wildland fires. Therefore, the project would have a less-than-significant impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts from hazards or hazardous materials that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts from hazards or hazardous materials that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a hazardous or hazardous materials impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to hazards and hazardous materials found all impacts to be less than significant with the incorporation of Mitigation Measure HAZ-1, which were adopted as GPU Policies 6C.P10, 7G.P54, 7G.P55, and 7G.P56. No additional mitigation measures contained in the GPU EIR apply to impacts to hazards and hazardous materials.

Exemption Checklist
Hydrology and Water Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 77 10 Hydrology and Water Quality

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Violate any water quality
standards or waste
discharge requirements or
otherwise substantially
degrade surface or
groundwater quality? □ □ □ □ □ ■
b. Substantially decrease
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may
impede sustainable
groundwater management
of the basin?
□ □ □ □ □ ■
c. Substantially alter the
existing drainage pattern of
the site or area, including
through the alteration of
the course of a stream or
river or through the
addition of impervious
surfaces, in a manner which
would:

i) Result in substantial
erosion or siltation on-
or off-site; □ □ □ □ □ ■
ii) Substantially increase
the rate or amount of
surface runoff in a
manner which would
result in flooding on- or
off-site
□ □ □ □ □ ■
iii) Create or contribute
runoff water which
would exceed the
capacity of existing or
planned stormwater
drainage systems or
provide substantial
additional sources of
polluted runoff; or
□ □ □ □ □ ■
iv) Impede or redirect
flood flows? □ □ □ □ □ ■
City of Pomona
1707 North Towne Avenue Project

78 Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
d. In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation? □ □ □ □ □ ■
e. Inundation by seiche,
tsunami, or mudflow?
□ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses hydrology and water quality impacts on pages 4.7-1 through 4.7-23. It addresses the following potential impacts, as summarized below: water quality standards; groundwater; alteration of existing drainage patterns resulting in erosion or flooding; urban runoff in relation to storm drainage system capacity and increased pollutants; flood hazards; and inundation by seiche, tsunami, or mudflow.

Water Quality Standards
Development under the GPU would result in demolition and/or construction activity that could generate pollutants that might adversely affect urban runoff. Such activities could include road improvements and realignments, installation and realignment of utilities, demolition of existing structures for replacement, new development, and the potential replacement and/or improvement of drainage facilities. Though development under the GPU and CSP could result in an increase in pollutants in stormwater and wastewater, new development would be concentrated in areas ideal for infill development and urban expansion and would be required to comply with all City of Pomona requirements under the National Pollutant Discharge Elimination System (NPDES) permit.

Pomona requires the preparation of a stormwater pollution prevention plan (SWPPP) to achieve compliance with the NPDES General Construction Stormwater Activity Permit. All development would also be subject to regional and local regulations including PMC Section 18-495, Reduction of pollutants in stormwater, which states, “Any person engaged in activities that will or may result in pollutants entering the City storm sewer system shall undertake all practicable measures to reduce such pollutants.” Contractors constructing new development projects are required to implement BMPs, such as regular watering of exposed soils to control dust during construction and vegetation of proposed landscaped/grassed swale areas as soon as feasible following grading activities.

Furthermore, the following General Plan policies were included in the GPU to minimize stormwater and erosion impacts during construction:
 Pomona General Plan Policy 7E.P24, to encourage rainwater and wastewater BMPs to minimize rainwater runoff and maximize rainwater and greywater collection and reuse for both private and public construction in new development and renovation projects.  Pomona General Plan Policy 7E.P30, to call for the City to continue working with the Los Angeles Regional Water Quality Control Board (RWQCB) in the implementation of the NPDES for the protection of surface water and groundwater quality.

Exemption Checklist
Hydrology and Water Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 79  Pomona General Plan Policy 7E.31, to require the City to review and update City-adopted rainwater and runoff BMPs as needed.

The GPU EIR states that although the increase in volumes or rates of discharge and associated pollutants in runoff would be minimal, the operation of future development envisioned in the GPU could potentially result in the addition of contaminants into both the stormwater runoff entering the City’s drainage system and the wastewater stream entering the local wastewater collection and treatment system. Under the RWQCB’s NPDES permit system, all existing and future municipal and industrial discharges to surface waters in the City would be subject to regulations. All development in the City would be subject to the provisions of the City’s NPDES Municipal Separate Storm Sewer Systems (MS4) Permit (Order No. R4-2012-0175).

PMC Sections 18-491 through 18-496 prohibit any discharge that would result in or contribute to degradation of water quality via stormwater runoff. All discharges of material other than stormwater must comply with an NPDES permit issued for the discharge with appropriate structural BMPs, such as hydrodynamic devices, swales/biofilters, and basins, and nonstructural BMPs, such as activity restrictions and drought-tolerant landscaping.

Taken together, these measures were determined to reduce potential adverse impacts to water quality to a level of less than significant.

Groundwater
Due to the urban nature of the area, development facilitated by the GPU would consist of infill in already urbanized areas, where increases in impervious surfaces would be minimal. The GPU EIR states that new development must comply with Los Angeles County’s MS4 permit by employing BMPs for onsite detention/retention of stormwater runoff. Therefore, development would not substantially interfere with groundwater recharge, and this impact would be less than significant.

Alteration of Existing Drainage Patterns Resulting in Erosion or Flooding Development under the GPU would result in alterations to drainage, such as changes in ground surface permeability via paving, and changes in topography via grading and excavation. The GPU encourages integration of Low Impact Development (LID) stormwater management practices to specifically reduce the potential for development to alter existing drainage patterns. Integration of LID stormwater management practices combined with GPU policies, the PMC, and NPDES regulations were determined to reduce erosion risks from drainage alterations to less than significant.

Urban Runoff in Relation to Storm Drainage System Capacity and Increased Pollutants
The vast majority of development under the GPU would be infill development or urban expansion in or adjacent to areas that are already paved and would not result in any significant increase in stormwater runoff that would be likely to exceed existing storm drainpipe capacity or creek culvert capacity, or increase pollutants in stormwater runoff. Required storm drain facility upgrades could result in short-term construction impacts due to earth trenching and other earth moving activities, which were noted in the GPU EIR as being similar to construction impacts. Any upgrades, expansion, and construction of necessary utilities to accommodate new development would be subject to project-specific environmental review. Therefore, the impact was determined to be less than significant.

City of Pomona
1707 North Towne Avenue Project

80 Flood Hazards
The GPU EIR states that Pomona does not lie in a 100- or 500-year floodplain, as delineated by the Federal Emergency Management Agency (FEMA). All creeks in the City have been channelized and remain dry except during storm events. The following General Plan policies were included in the GPU EIR to further minimize risks associated with storm flooding:
 Pomona General Plan Policy 7G.P46, which calls for the preparation of a Master Drainage Plan to analyze existing system deficiencies and proposed improvements to support development of the General Plan vision.
 Pomona General Plan Policy 7G.P47, which ensures floodplain protection by retaining existing open space and creating new open areas needed to retain stormwater, recharge aquifers, and prevent flooding.
 Pomona General Plan Policy 7G.P48, which calls for the City to maintain current flood hazard data and coordinate with USACE, FEMA, Los Angeles County Department of Public Works, and other responsible agencies to coordinate flood hazard analysis and management activities.  Pomona General Plan Policy 7G.P49, which requires that new development incorporate features into site drainage plans that would reduce impermeable surface area, increase surface water infiltration, and minimize surface water runoff during storm events.

The potential for flood events via dam inundations exists in Pomona since the City is on the edge of the San Antonio Dam and Live Oak Reservoir inundation limits. The U.S. Army Corps of Engineers (USACE) established a Dam Safety Program to protect residents and businesses in areas that may be affected in case of failures of the San Antonio Dam and Live Oak Reservoir. PMC Sections 18-640 through 18-642 establish methods and provisions that would minimize flood damage to new development projects.
 PMC Section 18-640, which requires all new construction and substantial improvements in a flood-prone area to be designed and adequately anchored to prevent flotation, collapse, or lateral movement.
 PMC Sections 18-641 and 18-642, which establish requirements for the construction of utilities in flood-prone areas.

Therefore, the GPU EIR determined impacts to flood hazards would be less than significant with adherence to General Plan policies and City’s municipal codes.

Inundation by Seiche, Tsunami, or Mudflow
The GPU is located well above sea level and nearly 40 miles from the nearest coastline. Any risk of inundation by seiche, tsunami or mudflow in the City would be remote, and would not be increased because of development under the GPU. Therefore, no impact would occur.

Project-Specific Impacts
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? As discussed in the GPU EIR, new development projects in the City are required to comply with all City requirements under its NPDES permit (Order No. 2009-0009-DWQ, NPDES No. CAS000002, dated July 1, 2010). The City requires the preparation of a project-specific Stormwater Pollution Prevention Plan (SWPPP) to comply with the NPDES. The SWPPP must describe the site, the facility, Exemption Checklist
Hydrology and Water Quality

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 81 erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation and approved local plans, control of construction sediment and erosion control measures, maintenance responsibilities, and non-stormwater management controls, as well as incorporation of BMPs. The SWPPP requirements would need to be satisfied prior to beginning construction on any project located on a site greater than one acre. Because the project site is

1.9 acres, the project would be required to prepare a SWPPP to comply with the City’s NPDES permit prior to construction activities.

As stated in the GPU EIR, construction contractors are responsible for implementing and monitoring BMPs, which include, but are not limited to, erosion and sedimentation control/drainage plans to ensure requirements of the City’s NPDES permit are being met, and that contaminants are not released into urban runoff.

As seen in the project plans stormwater runoff flows from the project site will gutter flow to the proposed infiltration trench located on the west portion of the site and then flow via a proposed diversion storm drain pipe to the southwest corner of the project site and be discharged off-site.

The proposed infiltration trench would treat the runoff flow to improve water quality. The project would not violate water quality standards or otherwise substantially degrade water quality with adherence to the City’s GPU policies, municipal codes, and compliance with the applicable NPDES permit. Therefore, the project would have a less-than-significant impact on water quality. b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Groundwater was not encountered in the subsurface exploration to the maximum depths explored of approximately 50 feet below current grade (LGC 2022; see Appendix E). The proposed residential uses would not rely on groundwater sources from the project site to meet consumer demands.

Though the project would increase the amount of impervious surface on the site than compared to existing conditions, the incorporation of the underground infiltration trench system would ensure stormwater is captured and treated on the project site prior to conveying to the off-site storm drain systems. Therefore, the project would not significantly interfere with groundwater recharge, and the project would have a less-than-significant impact on groundwater supplies or recharge. 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:
i. Result in substantial erosion or siltation on- or off-site? ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? or, iv. Impeded or redirect flood flows?
The project site is relatively flat, vacant, and undeveloped, and currently contains a telecommunications tower on the northwest portion of the site and a paved parking lot. The project site is approximately 950 feet above sea level. The proposed residential use would not generate substantial sources of polluted runoff. Runoff is currently managed via existing stormwater drainage City of Pomona
1707 North Towne Avenue Project

82 systems. As such, the project would improve site drainage to accommodate the 45 three-story attached single-family residential dwelling units and proposed changes.

The project, as designed, would increase the amount of impervious surface on the project site due to the proposed building footprints, and pedestrian and vehicle circulation pathways. The project also includes landscaped areas. Project construction activities would implement BMPs to prevent substantial erosion or siltation on- or off-site, and the project site would be fully developed with no bare dirt left exposed.

Stormwater runoff on the project site would gutter flow to the proposed infiltration trench located on the west portion of the site and then flow via a proposed diversion storm drain pipe to the southwest corner of the project site and be discharged off-site. The proposed infiltration trench would treat the runoff flow to improve water quality.

With implementation of the proposed stormwater detention system, the project would not alter existing drainage patterns in a manner that would result in erosion or flooding, nor increase the rate or amount of stormwater runoff to exceed the existing or planned drainage system capacity. The proposed residential use would not generate a substantial amount of polluted runoff. The project would be consistent with Pomona General Plan Policies 7E.P24 and 7E.P49, which require new developments to incorporate features that minimize surface water runoff during storm events, such as stormwater detention basins and biofiltration systems. Therefore, the project would have a less- than-significant impact.
d. Would the project be in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
As stated in the GPU EIR, no portion of the City, including the project site, is within a 100-year flood hazard area. As stated above, the proposed residential use would not generate substantial amounts of pollutants. The project site elevation ranges between approximately 940 feet and 950 feet above sea level and is approximately 31 miles northeast from the nearest coastline. The project would therefore have no impact related to flood or tsunami hazards.

According to Figure 4.7-2, Dam and Reservoir Inundation Zones, in the GPU EIR, the project site is within the sphere of influence of the San Antonio Dam which is located approximately 6.58 miles northeast of the project site. The GPU EIR states that implementation of PMC Sections 18-640 through 18-642, FEMA requirements, and the USACE’s Dam Safety Program would ensure public safety from potential dam inundations and impacts would be less than significant.

The Puddingstone Reservoir is approximately 3.4 miles northwest from the project site in the City of San Dimas, is the nearest body of open water. Due to existing topography and distance between the project site and the Puddingstone Reservoir, risk of inundation by seiches would be remote and would not increase as a result of the project. Therefore, the project would have a less-than- significant impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to hydrology or water quality that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

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0BExemption Checklist Pursuant to CEQA Guidelines Section15183 83

2. There are no potentially significant impacts to hydrology or water quality that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to hydrology and water quality found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to hydrology and water quality.

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Exemption Checklist
Land Use and Planning

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 85 11 Land Use and Planning

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Physically divide an
established community? □ □ □ □ □ ■
b. Cause a significant
environmental impact due
to a conflict with any
applicable land use plan,
policy, or regulation
adopted for the purpose of
avoiding or mitigating an
environmental effect? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses land use and planning-related impacts on pages 4.8-1 through 4.8-46. The GPU EIR discussions of land use and planning-related impact areas are summarized below.  Physical Division of an Established Community. Development under the GPU would not include components that would physically divide the existing community. Future development would take place largely on existing parcels throughout Pomona. Street modifications anticipated under the GPU could be expected to unite the City’s existing districts and neighborhoods with an overall City identity that builds upon Pomona’s existing urban structure, and through improvements to the City’s existing transportation network that focuses on improving mobility through means other than constructing new roads.
 Introduction of New Land Uses that Could Conflict with Existing Land Uses. The City is largely developed with a mix of land uses. Implementation of the GPU and CSP would be expected to replace some existing uses and buildings to add new residential units, office space, and commercial services to support those living and working throughout Pomona. These uses would be similar in character to the uses that are currently found in the City, with increased density and intensity in select areas throughout Pomona. Implementation of the GPU and CSP would not introduce new uses that would conflict with established uses in Pomona.  Conflict with Applicable Land Use Plans, Policies or Regulations. Implementation of the GPU and CSP would not fundamentally conflict with any of Pomona’s land use plans, policies or regulations adopted for the purpose of avoiding or mitigating effects that could result in adverse physical changes in the environment. The GPU was developed to provide specific policy guidance for future development in Pomona, consistent with the land use plans, policies and regulations of the City. Adoption of the GPU would make it an amendment to the Pomona General Plan, which would effectively eliminate any conflict with General Plan Policies, reducing any potential impact to a level of less than significant.

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1707 North Towne Avenue Project

86 The GPU EIR includes a listing of policies specific to projects anticipated under the GPU, and implementation of these policies would ensure land use impacts are less than significant. The GPU EIR also includes two mitigation measures that propose additional GPU policies to ensure projects under the GPU are consistent with adopted SCAG policies:
 Pomona General Plan Policy 7E.P8, included as GPU EIR Mitigation Measure LU-2 to state:

Consider the most recent annual report on open space conservation in planning and evaluating projects in areas with regionally significant open space resources, including Bonelli Regional Park, East San Gabriel Valley Significant Ecological Area, and others, to ensure consistency with the open space conservation policies and goals of the SCAG Regional Comprehensive Plan.  Pomona General Plan Policy 7E.P17, to require large projects (exceeding 150,000 square feet of development) to incorporate Transportation Demand Management techniques.  Pomona General Plan Policy 7E.P18, to require dust abatement for all new construction and redevelopment projects.
 Pomona General Plan Policy 7E.P24, to encourage rainwater and wastewater BMPs to minimize rainwater runoff and maximize rainwater and greywater collection and reuse for private and public construction in new development and renovations.  Pomona General Plan Policy 7E.P37, included as GPU EIR Mitigation Measure LU-1 to state:

Encourage provision of dual plumbing new construction, and provide incentives for plumbing retrofits in existing development, to enable the safe and easy use of recycled water in toilets and for landscaping.

Project-Specific Impacts
a. Would the project physically divide an established community? Consistent with the discussion in the GPU EIR for the City, the project would be constructed on an existing parcel in the Urban Neighborhood and Activity Center place type and T4-1 and T5 transect zone which allow densities of up to 70 dwelling units per acre and 80 dwelling units per acre, respectively. The proposed project includes the development of 45 three-story attached single- family residential dwelling units. The proposed parking spaces, and public improvements/on-site improvements such as streets, curbs, gutters, sidewalks, sewer, water, storm drain and landscaping along North Towne Avenue and San Bernardino Avenue would not alter the existing roadway network off-site. Therefore, the project would not physically divide an established community and no impact would occur.
b. Would the project cause a significant environmental impact due to a conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Consistent with the discussion in the GPU EIR for the plan area, the project would not introduce new land uses that do not already exist in the City. There are existing residential, commercial, and recreational uses adjacent to the project site, and the proposed residential use would intensify permitted uses for the site.

The project site’s General Plan Land Use designation is Urban Neighborhood and Activity Center, which includes a mix of densities, street network types, housing types, and architectural styles. The project would be consistent with the Urban Neighborhood and Activity Center as it will add the type of walkable urbanism that can increase housing choices in the community, attract households in Exemption Checklist
Land Use and Planning

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 87 demographics currently lacking in Pomona, and accommodate growth in ways that can improve the physical condition of residential neighborhoods and quality of life.

The GPU has policies that apply to the project. A discussion of project consistency with selected policies follows. The emphasis is on the GPU policies because the GPU was developed to provide specific policy guidance for future development in select corridors throughout the City, consistent with the land use plans, policies and regulations of the City. As specified in the environmental checklist (CEQA Guidelines Appendix G), the discussion focuses on policies adopted for the purpose of avoiding or mitigating an environmental effect. Table 16 provides project consistency analysis according to GPU policies.

Table 16 Consistency with General Plan Update Policies
GPU Goal or Policy Analysis
6G.G1. Pomona’s neighborhoods are diverse, and each
neighborhood’s character should be preserved and
enhanced.

Consistent. The proposed project involves the
development of 45 three-story (approximately 37-feet-
tall) attached single-family residential dwelling units.

Therefore, the project is consistent with Goal 6G.G1.
6G.G3. Improve neighborhoods exhibiting substandard
conditions and declining private reinvestment.

Consistent. The project site is currently vacant and
undeveloped with a telecommunications tower located
on the northwest portion of the site and a paved parking lot. The proposed project would improve the site with
the development of 45 three-story (approximately 37-
feet-tall) attached single-family residential dwelling
units. Therefore, the project would be consistent with
Goal 6G.G3.
6G.G4. Respect and maintain historic residential
neighborhood scale and character.

Consistent. As stated in the GPU, historic neighborhoods are largely found in the downtown area and include
Lincoln Park, Wilton Heights, Hacienda Park, Edison,
Ganesha Hills, Indian Hill, Westmont, Reservoir, Phillips Ranch, Mission Corona, Yorba, and Angela-Chanslor (City of Pomona 2014a). As described in Section 5, Cultural
Resources, there are five potential historic resources in the vicinity of the project site, the Presidential Park Potential Local Historic District, in addition to two other potential historic districts (Central Baptist Church and Covenant Korean Church). However, no properties
contributing to the districts nor the potential individual resources would be physically altered by the proposed
project. In addition, the development proposed by the
project is keeping with the scale and current
development patterns surrounding the historic
resources such that their setting would not be altered by the proposed project. Therefore, the proposed project is consistent with Goal 6G.G4.

City of Pomona
1707 North Towne Avenue Project

88 GPU Goal or Policy Analysis
6G.G7. Promote attractive community character as viewed from public streets, while providing adequate buffer areas between homes and heavily traveled roads.

Consistent. The proposed project will be landscaped
along North Towne Avenue, San Bernardino Avenue, and
the northern project site boundary as well as around the proposed homes, and outdoor dining area and
community lawn area in the northwest corner of the
site. The proposed plant palette includes a variety of low maintenance, drought tolerant trees and flowering
shrubs. The public landscape areas would include
artificial turf and would be maintained by the Home
Owners Association (HOA). In addition, the proposed
project would include a community lawn area, a dog
park, resident garden beds, and an outdoor dining area
with a BBQ counter and cornhole court in the northwest
corner of the site. Therefore, the project would be
consistent with Goal 6G.G7.
6G.G8. Ensure safe, family-oriented, human-scaled,
walkable and livable residential neighborhoods.

Consistent. The project would include development of
public and private open space, including walking paths
with open turf, a community lawn area, and an outdoor
dining area for residential use. Therefore, the project is consistent with Goal 6G.G8.
6G.G9. Ensure continuity in development scale and
character with careful transitions between areas of differing use composition and density.

Consistent. The project site is surrounded by single-
family residences to the east and south, a school and a church to the west, and a church to the east. The
proposed project would improve the site with the
development of 45 three-story (approximately 37-feet-
tall) attached single-family residential dwelling units. The project would be similar in visual character and height asssurroundrounding single-family residences.

Therefore, the project would be consistent with
Goal 6G.G9.
6G.G10. Ensure that hillside development is sensitive to existing terrain, views and significant natural landforms or features.

Consistent. The project site is in a relatively flat area surrounded by residential and commercial development.

As discussed in Section 1, Aesthetics, the project site does not have any scenic views visible from on site.

Therefore, the project is consistent with Goal 6G.G10.
6G.P1. Revise the Zoning Ordinance to include standards for residential neighborhood “preservation areas” which
require new development to be consistent with the scale, setbacks, orientation, and character of adjacent homes.

Consistent. The proposed project would install
landscaping along the northern, eastern, and southern
project site boundaries, which would act as a buffer
between the project site and I-10 to the north, North
Towne Avenue to the east, and San Bernardino Avenue
to the south. Therefore, the project would be consistent with Goal 6G.P1.
6G.P4 Improve the City’s physical appearance through
maintenance and façade renovations of older residential building stock.

Consistent. The proposed project includes the
development of new residential units only and therefore Policy 6G.P4 is not applicable to the project.
6G.P7. Do not permit sound walls or perimeter walls along major streets or corridors, except along freeways and
railroad tracks. In all other instances, permit sound walls only upon finding that alternative noise attenuation
measures are not available.

Consistent. The proposed project does not include
perimeter walls along major streets or corridors. An
eight-foot sound wall barrier is proposed along the
northern project site boundary to attenuate noise from
I-10 located adjacent north of the project site.

Therefore, the project is consistent with Policy 6G.P7.

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Land Use and Planning

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 89 As demonstrated in Table 16, the proposed project is consistent with the applicable goals and policies in the GPU.

Government Code Section 65589.5(j)(4) states that a local agency, such as the City of Pomona, may require proposed projects to comply with the zoning regulations consistent with the City’s General Plan. The R-3 zone development standards are consistent with the City’s Urban Neighborhood and Activity Center General Plan land use designation (City of Pomona 2010). As such, the City determined that the proposed project is required to comply with the zoning regulations for the R-3 zone. Table 17 summarizes the project consistency analysis according to the City’s R-3 zone development standards.

City of Pomona
1707 North Towne Avenue Project

90 Table 17 Project Consistency with Medium Density Multiple Family District Development Standards
Project Component
“R-3” Medium Density Multiple
Family Zones Project1 Consistent?
Land Use Medium Density Multiple Family
Zone
Administrative Professional
and SB 330 Overlay Zone
Yes
Lot Area per Unit 1,500 sf min 1,839 sf Yes
Dwelling Units
Unit Count – 45 dwelling units (25 3-
bedroom, 20 4-bedroom)
Yes
Density 15-30 du/acre min 23.7 du/acre Yes
Unit Size 1,200 sf min (for 3-bedroom)
1,400 sf min (for 4-bedroom
1,274-1,529 sf (3 bedroom)
1,696 sf (4-bedroom)
Yes
Height 35’ or 2 stories max 30’ and 3 stories max Yes
Yards
Front yard 25’ min 5’ Yes (eligible for
relief per
Section
65589.5(f)1
Side Yard 18.5’ min 5-15’
Rear Yard 15’ min 6-9’ 7”
Building Separation 15’ min between residential
buildings
15’ min Yes
Parking
Residential 122 spaces 90 spaces Yes (Minor
Deviation
Variance)
Guest 12 spaces 12 spaces Yes
Total Parking Spaces 134 spaces 102 spaces Yes (Minor
Deviation
Variance)
Open Space
Private Open Space 100 sf/du Yes
Ground Floor Units 100 sf/du N/A
Above Ground Floor Units 70 sf/du 75 sf/du
Common Open Space

3-Bedroom 12,500 sf 12,500 sf Yes
4-Bedroom 12,000 sf 12,000 sf
1 sf = square feet; du/acre = dwelling units per acre; min = minimum; max = maximum Source: City of Pomona 2018b
The adoption of SB 330 (Housing Crisis Act of 2019) does not require a housing development to be rezoned if the property is consistent with the objective general plan standards and criteria.

Government Code Section 65589.5(j)(4) states, “a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan.” Government Code Section 65589.5(j)(4) further states, “If the local agency has complied with paragraph (2), the local Exemption Checklist
Land Use and Planning

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 91 agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the site by the general plan and proposed by the proposed housing development project.” According to State regulations, the City may only apply applicable development standards to the extent that they accommodate the allowed density for the subject site. If the application of an objective development standard would not accommodate the allowed density for the subject site, the City would be limited from applying that standard.

The project is eligible for relief for the proposed setbacks per Government Code Section 65589.5(f)(1), which states “nothing in this section shall be construed to prohibit a local agency from requiring the housing development project to comply with objective, quantifiable, written development standards, conditions, and policies appropriate to, and consistent with, meeting the jurisdiction's share of the regional housing need pursuant to Section 65584. However, the development standards, conditions, and policies shall be applied to facilitate and accommodate development at the density permitted on the site and proposed by the development.” In addition, a Minor Deviation Variance is required to allow a decrease in the total number of parking spaces of not more than 20 percent. Therefore, the project is consistent with the City’s R-3 zoning standards.

In conclusion, the proposed project is consistent with the City’s GPU and Zoning Code. Therefore, the project would have a less-than-significant impact related to land use and planning.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to land use and planning that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to land use and planning that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a land use and planning impact that is more severe than anticipated by the GPU EIR.

6. The GPU EIR included two mitigation measures to address impacts to land use and planning.

These mitigation measures were incorporated into the GPU policies, Policies 7E.P8 and 7E.P37.

Pursuant to the provisions of SB 330 and Government Code Section 65589.5(j)(4), the project is considered in compliance with the land use designation criteria and impacts to land use and planning would be less than significant. No additional mitigation measures contained in the GPU EIR apply to impacts to land use and planning.

City of Pomona
1707 North Towne Avenue Project

92 12 Mineral Resources

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Result in the loss of
availability of a known
mineral resource that
would be of value to the
region and the residents of
the state? □ □ □ □ □ ■
b. Result in the loss of
availability of a locally-
important mineral resource
recovery site delineated on
a local general plan, specific
plan or other land use
plan? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses mineral resources impacts on page 5-3 and identified no known mineral deposits of local importance or value to the region or residents of the state, or locally important mineral resource recovery sites in Pomona. Consequently, the GPU EIR identified no impacts on mineral resources under implementation of the City’s GPU, Active Transportation Plan, or Green Plan.

Project-Specific Impacts
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? There are no mineral resource zones identified in the City or project site (DOC 1983). Because the project site is within an urbanized area without known mineral resources of value, impacts would remain as identified in the GPU EIR. The project would have no impact on mineral resources.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to mineral resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

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0BExemption Checklist Pursuant to CEQA Guidelines Section15183 93

2. There are no potentially significant impacts to mineral resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a mineral resources impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to mineral resources found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to mineral resources.

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Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 95 13 Noise and Vibration

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project result in:
a. Generation of a substantial
temporary or permanent
increase in ambient noise
levels in the vicinity of the
project in excess of
standards established in
the local general plan or
noise ordinance, or
applicable standards of
other agencies? □ □ □ □ □ ■
b. Generation of excessive
groundborne vibration or
groundborne noise levels? □ □ □ □ □ ■
c. For a project within the
vicinity of a private airstrip
or an airport land use plan
or, where such a plan has
not been adopted, within
two miles of a public
airport or public use
airport, would the project
expose people residing or
working in the project area
to excessive noise levels? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses noise and vibration impacts on pages 4.9-1 through 4.9-26. The GPU EIR examined a range of potential impacts related to noise and vibration, including exposure of existing and new development to excessive noise levels, increased traffic noise, a cumulative increase in citywide noise levels, and construction-related noise and vibration. Impacts were assessed in the context of adopted planning documents.

Implementation of the GPU would generate or expose residents to ambient noise levels in excess of standards established in the City’s General Plan or noise ordinance; however, adherence to the General Plan policies below was determined to reduce noise impacts to less than significant. In addition, the GPU EIR identifies Mitigation Measure N-1 to specifically address vibration impacts on new development near rail lines.
 Pomona General Plan Policy 7G.P2, to discourage location of new noise-sensitive uses, primarily residential and educational facilities, in areas with projected noise levels greater than 65 dB CNEL, as shown in Figure 7-G.2 (Future Noise Contours) [of the General Plan Update].

City of Pomona
1707 North Towne Avenue Project

96 Where such uses are permitted, require incorporation of mitigation measures to ensure that interior noise levels do not exceed 45 dB CNEL, including:
 Require that applicants for new noise-sensitive development, in areas subject to noise levels greater than 65 dB CNEL, first obtain the services of a professional acoustical engineer to provide a technical analysis and design of mitigation measures.  In the Zoning Ordinance, require placement of fixed equipment, such as air conditioning units and condensers, inside or in the walls of new buildings or on rooftops of central units to reduce noise impacts on any nearby sensitive receptors.  Establish appropriate noise-emission standards to be used in connection with the purchase, use and maintenance of City vehicles.
 Pomona General Plan Policy 7G.P3, to require the City to restrict noise and require mitigation measures for any noise-emitting construction equipment or activity.  Pomona General Plan Policy 7G.P4, to require noise mitigating measures including, but not limited to, the use of double-paned soundproof windows near Metrolink stations to allow transit-oriented development to include office and residential uses.  Pomona General Plan Policy 7G.P7, included as GPU EIR Mitigation Measure N-1 to state:

Require applicants for new residential development within 130 feet of the Union Pacific Railroad (UPRR) tracks running through central Pomona, and within 100 feet of the Burlington Northern/Santa Fe Railroad (BNSF) tracks running through northern Pomona, to obtain the services of a professional acoustical consultants with demonstrated experience in vibrational analysis in order to assess vibrational impacts on the proposed development from current, planning, and reasonably anticipated future rail service, and to design mitigation measures, if necessary, to reduce the VdB level at the proposed residences to 72 VdB or lower as defined in the Federal Transit Administration’s (FTA’s) 2006 Transit Noise and Vibration Impact Assessment.

Noise Overview
Noise is unwanted sound that disturbs human activity. Environmental noise levels typically fluctuate over time, and different types of noise descriptors are used to account for this variability. The unit of measurement used to describe a noise level is the decibel (dB). Decibels are measured on a logarithmic scale that quantifies sound intensity. A doubling of the energy of a noise source, such as a doubling of traffic volume, would increase the noise level by 3 dB; similarly, dividing the energy in half would result in a decrease of 3 dB (The Engineering ToolBox 2003a).

The impact of noise is not a function of loudness alone. The time of day when noise occurs, and the duration of the noise are also important. In addition, most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors has been developed.

The noise descriptors used for this analysis are the one-hour equivalent noise level (L eq) and the
community noise equivalent level (CNEL).
2 Sound changes in both level and frequency spectrum as it travels from the source to the receiver.

The most obvious change is the decrease in sound level as the distance from the source increases.

Sound levels from a point source (e.g., construction, industrial machinery, ventilation units) typically attenuate, or drop off, at a rate of approximately 6 dBA per doubling of distance. Sound from a line

2 CNEL is defined as the 24-hour average noise level with a +5 dBA “penalty” for noise occurring during evening hours (7:00 p.m. to 10:00 p.m.) and a +10 dBA “penalty” for noise occurring during nighttime hours (10:00 p.m. to 7:00 a.m.).

Exemption Checklist
Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 97 source (e.g., roadway, pipeline, railroad) typically attenuates at approximately 3 dBA per doubling of distance (The Engineering Toolbox 2003b).

Noise levels may also be reduced by intervening structures. The amount of attenuation provided by this “shielding” depends on the size of the object and the frequencies of the noise levels. Generally, any large structure blocking the line of sight will provide at least a 5-dBA reduction in source noise levels at the receiver (FHWA 2011). Structures can substantially reduce occupants’ exposure to noise as well. The Federal Highway Administration’s (FHWA) guidelines indicate that modern building construction generally provides an exterior-to-interior noise level reduction of 20 to 35 dBA with closed windows.

Vibration Overview
Typical outdoor sources of perceptible groundborne vibration are construction equipment, steel- wheeled trains, and traffic on rough roads. Groundborne vibration of concern in environmental analysis consists of the oscillatory waves that move from a source through the ground to adjacent structures. While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration may also damage infrastructure when foundations or utilities, such as sewer and water pipes, physically connect the structure and the vibration source. The primary concern of vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.

Vibration amplitudes are usually expressed in peak particle velocity (PPV) or root mean square (RMS) vibration velocity. The PPV and RMS velocity are normally described in inches per second (in./sec.). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that are experienced by buildings (FTA 2018).

Regulatory Setting
The Noise & Safety chapter of the City of Pomona 2014 GPU provides a description of existing noise levels and sources and incorporates comprehensive goals and policies. The GPU includes the Community Noise Exposure table, which establishes acceptable noise levels for different land uses to minimize the negative impacts of noise, especially at sensitive receiver locations. According to the Community Noise Exposure table, ambient noise levels up to 60 dBA CNEL are normally acceptable and ambient noise levels up to 70 dBA CNEL are conditionally acceptable for single-family residential development. In addition to the exterior noise standards, the GPU identifies a residential interior noise standard of 45 dBA CNEL (City of Pomona 2014a).

To implement the City’s noise policies, PMC Chapter 18, Article VII, Noise and Vibration Control, establishes a series of regulations and standards to prevent excessive noise that may jeopardize the health, welfare or safety of the citizens or degrade their quality of life. PMC Section 18-311, Exterior Noise Standards, establishes exterior noise standards categorized by various noise zones in the City, shown in Table 18.

City of Pomona
1707 North Towne Avenue Project

98 Table 18 Exterior Noise Level Standards
Noise Zone Land Use
Allowable Exterior Noise Level (dBA1)
Daytime
(7:00 a.m. to 10:00 p.m.)
Nighttime
(10:00 p.m. to 7:00 a.m.)
1 Single-Family Residential 60 dBA 50 dBA
2 Multi-Family Residential 65 dBA 50 dBA
3 Commercial 65 dBA 60 dBA
1 A-weighted decibel (dBA) is defined as a decibel (dB) adjusted to be consistent with human response.

Source: PMC Sections 18-310 (Designated Noise Zones) and 18-311 (Exterior Noise Standards) As shown in Table 18, the noise standards for these zones differ between daytime (7:00 a.m. to 10:00 p.m.) and nighttime (10:00 p.m. to 7:00 a.m.) hours.

PMC Section 18-311(b) further specifies that the noise levels in Table 18 shall not exceed one or more of the following, when measured on any other property:
 The noise standard for a cumulative period of more than 30 minutes in any hour;  The noise standard plus 5 dBA for a cumulative period of more than 15 minutes in any hour;  The noise standard plus 10 dBA for a cumulative period of more than five minutes in any hour;  The noise standard plus 15 dBA for a cumulative period of more than one minute in any hour; or  The noise standard plus 20 dBA for any period of time.

In addition, PMC Section 18-316(d), Residential Property Nuisance Noise, prohibits the operation on a residential property of any such set, instrument, stereo, television set, machine, loudspeaker, or similar device between the hours of 10:00 p.m. and 7:00 a.m. in such a manner as to be plainly audible at 50 feet from the building, structure, or vehicle in which it is located. Similarly, PMC Section 18-316(e), prohibits the operation of the same devices between the hours of 7:00 a.m. and 10:00 p.m. in such a manner as to be plainly audible at 150 from the building, structure, or vehicle in which it is located.

PMC Section 18-305, Exemptions, exempts construction noise and vibration from the PMC standards provided that such activities do not take place between the hours of 8:00 p.m. and 7:00 a.m. on weekdays, including Saturday, or at any time on Sunday or a federal holiday, and provided that (1) the noise levels created by such activities do not exceed the noise standard of 65 dBA at a residential property or the standards specified in PMC Section 18-311(b) described above, and (2) the vibration levels do not endanger the public health, welfare, and safety.

PMC Section 18-309, Vibration establishes the following relative to vibration impacts:
“…[I]t shall be unlawful for any person to create, maintain or cause any ground vibration which is perceptible without instruments at any point on any affected property adjoining the property on which the vibration source is located. For the purpose of this article, the perception threshold shall be presumed to be more than 0.05 inch per second RMS vertical velocity.” Vibration thresholds specified in the FTA’s Transit Noise and Vibration Impact Assessment Manual (FTA 2018) were used to evaluate construction vibration annoyance and damage potential at nearby buildings. Based on FTA criteria, a threshold of 72 VdB should be used for frequent events affecting residences and buildings where people sleep, while a threshold of 100 VdB should be used for minor cosmetic damage to fragile buildings.

Exemption Checklist
Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 99 Sensitive Receivers
Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. Generally, a sensitive receptor is identified as a location where human populations (especially children, senior citizens, and sick persons) are present, and where there is a reasonable expectation of continuous human exposure to noise. The Noise & Safety chapter of the GPU describes noise-sensitive land uses as residences, schools, childcare facilities, convalescent centers and retirement homes (City of Pomona 2014a). These uses are considered sensitive because the presence of excessive noise may interrupt normal activities typically associated with their uses.

Vibration-sensitive receptors, which are similar to noise-sensitive receptors, include residences and institutional uses, such as schools, churches, and hospitals. However, vibration-sensitive receptors also include buildings where vibrations may interfere with vibration-sensitive equipment that is affected by vibration levels that may be well below those associated with human annoyance (e.g., recording studies or medical facilities with sensitive equipment).

The nearest sensitive receptors to the project site include the Covenant Korean Church (located approximately 100 feet east of the eastern project boundary), single-family residences (located approximately 330 feet east and 100 feet south of the eastern and southern project boundaries, respectively), American Christian Academy (located directly west of the project site), a single-family residence (located approximately 195 feet west of the western project boundary), and the Central Baptist Church (located approximately 200 feet west of the western project boundary).

Project Design Features
As described in Description of Project, the following noise and vibration reduction measures would be included as part of the project:
 Noticing. At least 10 days prior to the start of construction activities, a sign shall be posted at the construction site, or other conspicuous location, that includes a telephone number for project information, and a procedure in which a construction manager will respond to and investigate noise complaints and take corrective action, if necessary, in a timely manner.  Noticing. At least 21 days prior to the start of construction activities, building occupants and residents within 300 feet of the project site shall be notified of the planned construction activities. The notification shall include a brief description of the project, the activities that would occur, the hours when construction would occur, and the construction period’s overall duration. The notification shall include the telephone numbers of the City’s and contractor’s authorized representatives that are assigned to respond in the event of a noise complaint.  Noise Complaints. If a construction noise complaint is registered and if City code enforcement is not available to make noise measurements, the Applicant, if and as directed by the City, shall retain a City-approved noise consultant to conduct noise measurements at the properties that registered the complaint. The noise measurements shall be conducted for a minimum of one hour. The consultant shall prepare a letter report for code enforcement summarizing the measurements, calculation data used in determining impacts, and potential measures to reduce noise levels to the maximum extent feasible.
 Equipment Maintenance. Prior to the start of and for the duration of construction, the contractor shall properly maintain and tune all construction equipment in accordance with the manufacturer’s recommendations to minimize noise emissions.

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 Equipment Maintenance. Prior to use of any construction equipment, the contractor shall fit all equipment with properly operating mufflers, air intake silencers, and engine shrouds no less effective than as originally equipped by the manufacturer.  Equipment Restriction. Stationary noise sources (e.g., generators) shall be located as far from sensitive receptors as practicable, and they shall be muffled and enclosed within temporary sheds, or insulation barriers with a minimum STC rating of 32.  Equipment Restriction. The use of bells, whistles, alarms, and horns shall be restricted to safety warning purposes only.
 Equipment Restriction. Signs shall be posted at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than five minutes. The construction manager shall be responsible for enforcing this.  Equipment Restriction. Construction activities that utilize large grading and earthmoving equipment within 77 feet of residential buildings (where people reside and sleep) and 9 feet of nonresidential buildings shall be conducted with off-road equipment that is limited to 100 horsepower (hp) or less.
 Equipment Restriction. Construction activities that utilize a roller within 133 feet of residential buildings (where people reside and sleep) and 16 feet of nonresidential buildings shall be conducted with a static or pneumatic roller in lieu of a vibratory roller.  Equipment Restriction. To the extent feasible, hydraulic equipment shall be used instead of pneumatic impact tools, and electric-powered equipment shall be used instead of diesel- powered equipment.
 Construction Staging. Staging and delivery areas shall be located as far as feasible from nearby sensitive receptors.
 Hauling. Material hauling and deliveries shall be coordinated by the construction contractor to reduce the potential of trucks waiting to unload for protracted periods of time.  Temporary Noise Barriers. Prior to the initiation of construction activities at the project site, temporary noise barriers/blankets shall be constructed along the entire eastern, southern, and western project site boundaries. Barriers shall be constructed with a solid material that has a density of at least 1 pound per square foot (such as but not limited to, 5/8-inch plywood or 5/8- inch oriented strand board) at a minimum height of 12 feet with no gaps from the ground to the top of the barrier.
 Permanent Sound Wall. An eight-foot-tall sound wall shall be installed at the northwest corner of the site, extending east along the northern property line to Building 7 (approximately 80 feet in length) and south along the western property line past the dog park (approximately 80 feet in length), at minimum.
 Exterior Walls. The project’s proposed exterior wall assembly shall consist of three-coat stucco over sheathing on wood studs with a single layer of gypsum board on the interior and batt insulation in the cavity..
 STC Ratings. Windows and glass doors shall achieve the minimum STC ratings shown in Table 3 of the acoustical analysis completed by Veneklasen Associates, Inc. (included as Appendix G).

Windows and glass doors shall also meet the minimum octave band transmission loss values and STC rating requirements specified in Appendix I of the acoustical analysis.  Ventilation. Residential mechanical ventilation, or other means of natural ventilation, shall be required for all units in Zones A, B, and C, as referenced in the acoustical analysis (Appendix G).

Exemption Checklist
Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 101 Project-Specific Impacts
a. Would the project generate 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? The project would consist of the development of eight three-story attached single-family residential buildings (containing a total of 45 dwelling units). The project would feature residential amenities such as private open space, a community lawn area, resident garden beds, an outdoor recreation area, a dog park, and landscaping along North Towne Avenue, San Bernardino Avenue, internal streets within the project site, and around open space areas within the project site.

The following discussion addresses the potential noise impacts associated with construction and operation of the project.

Construction
Temporary noise levels caused by construction activity would be a function of the noise generated by construction equipment, the location and sensitivity of nearby land uses, and the timing and duration of noise-generating activities. For a construction noise assessment, construction equipment can be considered to operate in two modes: stationary and mobile. As a rule, stationary equipment operates in a single location for one or more days at a time, with either fixed-power operation (e.g., pumps, generators, and compressors) or variable-power operation (e.g., pile drivers, rock drills, and pavement breakers). Conversely, mobile equipment moves around the construction site with power applied in cyclic fashion, such as bulldozers, graders, and loaders (FTA 2018).

Construction equipment is typically dispersed in various areas of the site, with only a limited amount of equipment operating near a given location at a particular time. The FTA Transit Noise and Vibration Impact Assessment (FTA 2018) document recommends evaluating construction noise impacts from the center of the construction site, stating that the distance variable in its recommended construction noise calculation “assumes that all equipment operates at the center of the project.” Therefore, it is a common, industry-standard practice to analyze average construction noise from the center of the site because this is the approximate center of where noise would be generated as equipment moves around the site throughout the workday. In accordance with FTA recommendations, construction noise for all phases was analyzed from the center of the site.

Construction noise was estimated using the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM). Typical construction projects have long-term noise averages that are lower than louder short-term noise events due to equipment moving from one point to another on the site, work breaks, and idle time. Each phase of construction has a specific equipment mix depending on the work to be carried out during that phase. Accordingly, each phase also has its own noise characteristics; some will have higher continuous noise levels than others, and some may have discontinuous high-impact noise levels. The maximum hourly L eq of each phase is determined by
combining the Leq contributions from each piece of equipment used in that phase (FTA 2018).

Project construction phases would include site preparation, grading, building construction, paving, and architectural coating. It is assumed that diesel engines would power all construction equipment.

For assessment purposes, the loudest phase (grading) was modeled under the conservative assumption that a backhoe, compactor, grader, and loader would be operating simultaneously.

Table 19 presents the results of the construction noise modeling from RCNM, showing the noise level expected at nearby sensitive receptors.

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Table 19 Estimated Noise Levels at Sensitive Receptors During Loudest Construction Phase (Grading)
Sensitive Receptor Distance (feet)1 Noise Level (dBA Leq) Covenant Korean Church 195 62
Single-family residences to the east 425 56
Single-family residences to the south 290 59
American Christian Academy 100 59
Single-family residence to the west 310 59
Central Baptist Church 300 59
1 Noise levels were calculated assuming that a backhoe, compactor, grader, and loader would be operating simultaneously from the center of the project site and include the proposed temporary noise barriers along the southern, eastern, and western project boundaries.

See Appendix G for construction noise modeling output.

As shown in Table 19, construction noise levels would not exceed the City’s construction noise threshold of 65 dBA Leq at nearby residences. Therefore, temporary noise impacts associated with construction would be less than significant.

Operation
Noise sources associated with operation of the proposed project would consist of residential activities (general conversations, recreational use of outdoor activity areas and dog park), mechanical equipment (e.g., heating, ventilation, and air conditioning [HVAC] units), and off-site traffic.

DOG PARK
The project’s proposed dog park would generate noise from the use of this outdoor area. Based on data collected previously for noise studies conducted according to CEQA guidelines, noise levels generated by use of dog parks reached up to approximately 58 dBA Leq at a distance of 25 feet when between 5 and 11 dogs were present (GEPermit 2019). The dog park would be located at the northwest corner of the site adjacent to the American Christian Academy property. While accounting for the eight-foot-tall sound wall that will be included as a Project Design Feature at the northwest corner of the site, noise levels generated by use of the dog park would be approximately 57 dBA L
eq at the American Christian Academy property line. Note that while this is not a residential property, noise levels at this school would be below the City’s required daytime exterior noise limit of 60 dBA L
eq. Additionally, it is not expected that the dog park would be operational during nighttime hours. Therefore, dog park noise impacts would be less than significant.

MECHANICAL EQUIPMENT
The primary noise source of concern would be associated with mechanical/HVAC equipment (i.e., outdoor condensing units). Condensing units would be located outside each townhome, placed at either the front or side of each building. The closest condensing unit would be located approximately 42 feet from the western property line, which neighbors the American Christian Academy property. Detailed mechanical specifications for the future HVAC systems are not available at this stage of project design, however typical HVAC equipment generates noise levels up to 72 dBA at a distance of 3 feet. At a distance of 42 feet, noise levels from HVAC noise would attenuate to approximately 49 dBA at the western property line. Therefore, noise generated by HVAC equipment Exemption Checklist
Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 103 would not exceed the City’s 60 and 50 dBA daytime and nighttime exterior noise level limits, respectively, and mechanical equipment noise impacts would be less than significant.

OFF-SITE TRAFFIC
The project would generate new vehicle trips that would increase noise levels on nearby roadways.

As discussed in the traffic study (Appendix H), the project is anticipated to generate 324 daily vehicle trips (Ganddini 2024).

The project would not make alterations to roadway alignments or substantially change the vehicle classifications mix on local roadways. Therefore, the primary factor affecting off-site noise levels would be increased traffic volumes. Noise levels with and without project-generated traffic were developed based on algorithms and reference levels from the Federal Highway Administration’s (FHWA’s) Traffic Noise Model.

Average daily traffic (ADT) volumes for roadway segments near the project site with and without project-generated traffic and associated noise levels are shown in Table 20.

As shown in Table 20, traffic noise levels would increase as much as 1 dBA under existing + project- generated traffic and future (year 2026) + project-generated traffic on San Bernardino Avenue.

Similarly, traffic noise levels due to project-generated traffic would increase by less than 1 dBA on surrounding roadway segments. Therefore, project-generated traffic on roadways near the project site would not exceed the 3 dBA threshold increase for off-site traffic noise and impacts would be less than significant.

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Table 20 Off-site Traffic Noise Increases
Roadway Segment
Speed
(mph)
Existing
Volume1
(ADT)
Existing
+ Project
Volume2
(ADT)
Existing
Noise
Level1
(dBA)
Existing
+ Project
Noise
Level2
(dBA)
Noise
Level
Increase
(dBA)
Year
2026
Volume3
(ADT)
Year
2026 +
Project
Volume4
(ADT)
Year
2026
Noise
Level2
(dBA)
Year
2026+
Project
Noise
Level2
(dBA)
Noise
Level
Increase
(dBA)
San
Bernardino
Avenue
North Palomares
Street to North
Towne Avenue
25 2,900 3,178 53 54 1 3,000 3,330 53 54 1
North Towne Avenue
to North San Antonio
Avenue
25 8,800 8,849 58 58 <1 9,200 9,200 58 58 <1
North Towne
Avenue
Verde Vista Avenue
to San Bernardino
Avenue
40 18,300 18,381 66 66 <1 19,000 19,100 66 66 <1
San Bernardino
Avenue to San
Bernardino Freeway
40 22,500 22,646 67 67 <1 23,400 23,600 67 67 <1
Palomares
Street
East McKinley
Avenue to San
Bernardino Avenue
25 1,000 1,049 49 49 <1 1,000 1,100 49 49 <1
1 Existing Average Daily Traffic Volumes.
2 Project Average Daily Traffic Volumes.
3 Opening Year (2026) Without Project Average Daily Traffic Volumes. 4 Opening Year (2026) With Project Average Daily Traffic Volumes.

Source: Ganddini 2024
Exemption Checklist
Noise and Vibration

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 105 Land Use Compatibility
The Pomona General Plan Noise Element establishes acceptable exterior noise levels corresponding to various land uses. The project proposes single-family residential uses. According to the Pomona General Plan Noise Element, ambient noise levels up to 60 dBA CNEL are normally acceptable, ambient noise levels up to 70 dBA CNEL are conditionally acceptable, and ambient noise levels up to 75 dBA CNEL are normally unacceptable for single-family residential. Per GPU Policy 7G.P2, a detailed analysis of the noise reduction requirements must be made, and necessary noise insulation features must be included in the design (City of Pomona 2014a). For conditionally acceptable projects (located in noise environments up to 70 dBA CNEL), conventional construction, but with closed windows and fresh air supply systems or air conditioning will normally suffice.

Existing noise levels at the project site were determined in an acoustical analysis completed by Veneklasen Associates, Inc. (Veneklasen Associates 2024). The analysis consisted of four short-term (15-minute durations) and two long-term (24-hour durations) noise measurements at various locations within the project site. Measured noise levels from the acoustical analysis determined that the noise level at the site was 73 dBA CNEL, placing the site in a normally unacceptable noise environment unacceptable according to the City’s noise land use compatibility standards. The acoustical analysis then included an evaluation of the proposed building construction and determined noise insulation features necessary to achieve an interior noise level below 45 dBA CNEL, as required by the City. These insulation features include window and door STC ratings 3 for
each building corresponding to the level of noise impact expected. Additionally, the acoustical analysis specifies an eight-foot-tall noise barrier (160 feet in length) along the northwestern corner of the project site to reduce noise levels to below 70 dBA CNEL in the proposed outdoor recreation areas in this area of the site, as required by the GPU.

With these recommended noise insulation and site features, the project would be compatible with the City’s required exterior and interior noise standards and noise impacts relative to onsite land use compatibility would be less than significant.
b. Would the project generate excessive groundborne vibration or groundborne noise levels? The project does not include any substantial vibration sources associated with operation. Therefore, operational vibration impacts would be less than significant.

Construction activities known to generate ground-borne vibration, such as pile-driving, would not be conducted by the project. The greatest source of vibration during construction would be a roller and earthmoving equipment (such as a bulldozer), which may be used as close as 100 feet to the nearest building where people reside and sleep (single-family residences south of the site) and 7 feet to the nearest off-site structure (American Christian Academy to the west). Based on the Project Design Features, a static/pneumatic roller and small earthmoving equipment (limited to 100 hp or less) would be used during construction. A static/pneumatic roller would generate vibration levels of approximately 60 VdB at the nearest residential building and 96 VdB at the nearest nonresidential building. Small earthmoving equipment would generate vibration levels of approximately 40 VdB at the nearest residential building and 75 VdB at the nearest nonresidential building. Therefore, vibration levels produced by these types of equipment would not exceed the vibration thresholds of 72 VdB and 100 VdB at the closest residential and nonresidential structures, respectively. In

3 The Sound Transmission Class (STC) rating is a single-number metric describing the amount of noise reduction provided by a partition (wall, window, door); the higher the STC rating, the greater the noise reduction from one side of the partition to the other.

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addition, the restrictions on construction hours specified in the PMC would prevent construction activities that exceed the 72 VdB threshold at the nearest sensitive receptors from interfering with peoples’ sleep. Therefore, construction vibration impacts would be less than significant. c. For a project located in within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The nearest airport to the project site is Brackett Field Airport (POC), located approximately

2.5 miles to the northwest. The project would not be located within the noise contours of Brackett Field, as shown in Exhibit 5 of the Brackett Field Airport Land Use Compatibility Plan (Los Angeles County Airport Land Use Commission 2015). Therefore, no substantial noise exposure from airport noise would occur to construction workers, users, or residents of the project, and no impacts would occur.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to noise or vibration that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies and Project Design Features substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to noise or vibration that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The GPU EIR included one mitigation measure to address impacts related to noise. This mitigation measure was incorporated into GPU Policy 7G.P7 to address groundborne vibration impacts from rail line operations within 100 feet of anticipated residential development. The project site is located more than 1.0 mile from the nearest railroad tracks to the north and south and is outside of the 100-foot vibration impact area. No additional mitigation measures contained in the GPU EIR apply to impacts related to noise.

Exemption Checklist
Population and Housing

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 107 14 Population and Housing

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Induce substantial
unplanned population
growth in an area, either
directly (for example, by
proposing new homes and
businesses) or indirectly
(for example, through
extension of roads or other
infrastructure)? □ □ □ □ □ ■
b. Displace substantial
numbers of existing people
or housing, necessitating
the construction of
replacement housing
elsewhere?
□ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses population and housing impacts on pages 4.10-1 through 4.10-11. The 2035 population forecast by SCAG predicts Pomona’s population will increase by 47,450 new residents by 2035 for a total population of 197,400 residents. Development facilitated by the GPU would result in approximately 8,506 residential units and approximately 23,498 residents at buildout.

While the land use designations in the GPU could potentially accommodate higher levels of growth than envisioned by SCAG, the built-out nature of the City, focus on infill development, and State and regional demographic trends are anticipated to limit Citywide growth to within the forecast amounts. The GPU EIR concluded that population growth would not exceed anticipated forecasts, substantial growth would not occur, and GPU-related impacts to population and housing would be less than significant. No mitigation measures were required or identified.

Project-Specific Impacts
a. Would the project induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The project entails infill development of 45 residential units on a site that is relatively flat, vacant, and undeveloped, and currently contains a telecommunications tower on the northwest portion of the site and a paved parking lot. According to the DOF, the City of Pomona has an estimated population of 149,721 with an average household size of 3.41 persons (DOF 2023). Therefore, the project would increase the local population by up to 153 persons (45 units x 3.41 persons per unit).

Furthermore, as a residential development, the project would not directly contribute to population City of Pomona
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or employment growth in the City through new employment. The SCAG RTP/SCS has been updated since 2012, with the most recent update in 2020. Therefore, the following analysis uses population and housing information for the City from the updated 2020 RTP/SCS to evaluate the project’s impacts to population and housing growth.

The population growth forecasts in SCAG’s 2020 RTP/SCS estimate that the City’s population would increase to 187,600 in 2045 (SCAG 2020), which is an increase of 37,879 people from the City’s population in 2023 (DOF 2023). Based on an estimated increase of 153 persons, the project would account for approximately 0.4 percent of the forecasted population growth between 2023 and 2045. Therefore, the project would not contribute to population growth in the City beyond that planned for by the SCAG 2020 RTP/SCS.

This population increase would also be within the population projections in the GPU EIR. The anticipated population growth associated with the project represents approximately 0.6 percent4 of the potential population growth that would result from the GPU. The project would not increase population growth in Pomona beyond that planned for by the City in the GPU.

Similarly, the household growth forecasts in SCAG’s 2020 RTP/SCS estimate that the total number of households in Pomona would increase to 52,800 in 2045 (SCAG 2020), for an increase of 8,843 households from 2023 estimates of 43,957 households (DOF 2023). The project would increase the number of households by 45, which would account for approximately 0.5 percent of the forecasted increase between 2023 and 2045. Therefore, the project’s contribution to housing in the City would be within SCAG growth projections. In addition, according to the City’s RHNA 6th Cycle and Housing Strategies Discussion on August 19, 2019, the City has currently met approximately 24 percent of their RHNA need which equates to approximately 870 units (City of Pomona 2019). Therefore, implementation of the project would contribute an additional 45 units and further assist the City in meeting RHNA requirements. Furthermore, the project does not include off-site improvements that would extend roadways or infrastructure into areas that do not currently support residential or other urban uses. Therefore, the project would have a less-than- significant impact.
b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The project site is vacant with a telecommunications tower on the northwest portion of the site which would be demolished to accommodate the proposed 45 residential units. No people or housing would need to be constructed to replace any buildings due to the project. Therefore, the project would have no impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to population and housing that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to population and housing that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4 Project population percentage of GPU estimated growth: (143 project persons)/(23,498 GPU & CSP estimate) = 0.6 percent Exemption Checklist
Population and Housing

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 109

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in a population and housing impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to population and housing found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to population and housing.

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Exemption Checklist
Public Services

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 111 15 Public Services

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in the
prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures
apply to this
Project
Yes No
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

Fire protection? □ □ □ □ □ ■
Police protection? □ □ □ □ □ ■
Schools? □ □ □ □ □ ■
Parks? □ □ □ □ □ ■
Other public facilities? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses impacts to public services on pages 4.11-1 through 4.11-18. Each of the following public services is discussed separately in the Public Services chapter:

Fire Protection
The Los Angeles County Fire Department (LACoFD) serves the City of Pomona. Pomona is part of the LACoFD Division VIII, which also serves the neighboring cities of Diamond Bar, Walnut, Hacienda Heights, and Industry. There are 19 fire stations among the cities in Division VIII, eight of which are located in Pomona. Resources in adjacent jurisdictions provide additional support as needed.

LACoFD uses national guidelines of a 5-minute response time for the first-arrival unit for fire and emergency responses and eight minutes for the advanced life support unit in urban areas. The actual response time in 2011-2012 was 4 minutes and 46 seconds.

The GPU EIR states, “while fire and emergency medical service capacity is primarily based on service area, an increase in population could incrementally increase the number of service calls and could eventually necessitate the need for additional staff and possibly facilities.” LACoFD is currently meeting response time goals, and new development facilitated by the GPU would be inside the existing City limits and the five-minute response zone. The GPU EIR concluded that adherence to General Plan policies would reduce potential land use conflicts between new or expanded fire facilities and surrounding uses, and if required, that new or expanded facilities would likely be located in existing urban areas of the City.

Police Protection
The Pomona Police Department (PPD) provides local police services for Pomona. The GPU EIR states that police protection services are not necessarily “facility-driven,” and an expansion or intensification of development within a beat does not necessarily result in the need for additional City of Pomona
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facilities if police officers and patrol vehicles are equipped with adequate telecommunications equipment in order to communicate with police headquarters.

According to the GPU EIR, the PPD had 163 sworn officers and 106 civilian personnel in 2012. This represented a ratio of 1.1 officers per 1,000 residents, which was below the national average of

1.9 officers per 1,000 residents for cities with populations between 100,000 and 249,999 residents.

Therefore, the PPD operated at staffing levels below the national average.

The GPU EIR concludes that based on population growth estimates for the GPU, PPD would need to provide an additional 54 officers to maintain the 2012 ratio of 1.1 offers per 1,000 residents. An additional 213 officers would be needed to reach the national average. The GPU EIR includes the following GPU policies to address police protection services and to ensure impacts are less than significant:
 Pomona General Plan Policy 7G.P11, for the PPD to maintain a minimum standard of 1.3 police officers per 1,000 residents.
 Pomona General Plan Policy 7G.P12, to collect development impact fees for all development projects to help pay for needed police facilities.
 Pomona General Plan Policy 7G.P14, for the City and PPD to apply for state and federal grants to help increase police patrols and target gang activity.

Schools
Pomona is primarily served by the Pomona Unified School District (PUSD), and a small portion of the northern part of the City is served by the Claremont Unified School District (CUSD). There are several higher education institutions located in the City: California State Polytechnic University, Mount San Antonio Community College, and Western University of Health Science.

The GPU EIR uses student generation rates based on land use category to determine the impact of GPU and Corridor Specific Plan on schools. These student generation rates were established by PUSD. Table 21 contains student generation rates that were presented in the GPU EIR.

Table 21 Student Generation Rates
Land Use Category
Generation Rates (per unit)
Elementary Middle School High School
Single-family Detached 0.31 0.15 0.21
Single-family Attached 0.24 0.12 0.15
Multi-family 0.10 0.05 0.08
Source: City of Pomona 2014b
The GPU EIR states that implementation of the GPU would add an estimated 2,275 single-family dwelling units and 17,617 multi-family dwelling units in Pomona. Such an increase in dwelling units would increase enrollment in local schools serving Pomona. Table 22 shows the number of students that would be generated by development facilitated by the GPU using the generation rates shown in Table 21.

Exemption Checklist
Public Services

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 113 Table 22 Students Generated by GPU
Land Use Category Housing Units Elementary Middle School High School Total Students Single-family Detached 2,275 705 341 478 1,524
Multi-family 17,617 1,762 881 1,409 4,052
Total 19,892 2,467 1,222 1,887 5,576
Source: City of Pomona 2014b
According to the GPU EIR, PUSD has adequate educational facilities to house additional enrollment in elementary and middle schools generated by the GPU, and construction of additional elementary and middle schools in the PUSD is not anticipated to be necessary. However, additional high school enrollment facilitated by the GPU would exceed available high school capacity and construction of high school facilities may be needed. The GPU EIR states that payment of mandatory school impact fees by developers in the City, pursuant to California Government Code Section 65995 (3)(h), would reduce the impact on schools to less than significant.

Project-Specific Impacts
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services?
The potential for the project to result in such impacts to public services is analyzed below for the following public services: fire protection, police protection, and schools. Section 16, Recreation, contains analysis of project impact on recreational resources. Section 19, Utilities and Service Systems, contains analysis of project impact on water, wastewater infrastructure, and solid waste collection and disposal. The GPU EIR did not contain discussion on other public services.

Fire Protection
LACoFD provides fire protection services to the City and the project site. Fire Station 183, located at 708 North San Antonio Avenue, is approximately 0.8-mile southeast of the project site. The project would not result in substantial population or housing growth beyond that already anticipated under the GPU EIR. The GPU EIR concluded that increase in population and intensification of development in Pomona facilitated by the GPU could result in the need for new or expanded fire facilities in the future. The project would incrementally increase the service population of the LACoFD by adding 45 townhomes to the project area. However, the project site is in an area that is already serviced by LACoFD, approximately 0.8-mile northwest of Fire Station 183. Therefore, the project would not generate a need for new or expanded facilities to support fire protection and emergency response providers, and this impact would be less than significant.

Police Protection
The PPD is located at 490 West Mission Boulevard, approximately 1.6 miles southwest of the project site. The project site is within the northeast quadrant of the PPD’s service area. The GPU EIR states that development facilitated by the GPU would increase demand for police protection services, which would exacerbate existing service ratio deficiencies, and could result in the need to construct new police facilities in the future. Based on the PPD’s 2020 Crime Fighting Blueprint, the PPD has City of Pomona
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169 sworn officers, 111 civilian employees, and 55 volunteers (PPD 2020). The City’s current estimated population is 149,721 residents (DOF 2023). Therefore, the current police protection service ratio is 1.13 sworn officers per 1,000 residents, which is below the GPU EIR’s 2012 existing service level and the City’s General Plan minimum standard of 1.3 officers per 1,000 residents. With the addition of up to 153 persons, the total estimated population would increase to 149,874 residents and the police protection service ratio would remain at approximately 1.13 sworn officers per 1,000 residents, which would be below the minimum standard of 1.3 officers per 1,000 residents.

Though police protection service ratios are below the City’s minimum standard and the national average, the GPU EIR concludes that this impact would be less than significant with the collection of development impact fees for all development projects to help pay for police facilities. Therefore, the project applicant would be required to pay development impact fees and this impact would be less than significant. Furthermore, the City’s Police Department evaluates staffing needs on a continual basis as growth occurs throughout the City. Funding for additional police service, including new staff, is obtained through the City’s General Fund.

Schools
San Antonio Elementary School (855 East Kingsley Avenue) is located nearest to the project site, approximately 0.7-mile southeast of the project site, and is in the PUSD. The GPU EIR provides student generation rates based on land use categories, which were established by PUSD. Table 23 shows the number of students that would be generated by the project based on the GPU EIR student generation rates (Table 21).

Table 23 Students Generated by Project
Land Use Category Housing Units Elementary Middle School High School Total Students
Generated
Single-Family Attached 45 11 5 7 23
Source: Adapted from City of Pomona 2014b
The number of students generated by the project would account for approximately 0.4 percent of the estimated number of additional students generated by GPU buildout conditions (Table 22).

Therefore, project impact on schools would be less than the findings in the GPU EIR, such that additional student enrollment for elementary through high schools, generated by the project, would be accommodated by PUSD and existing facilities would be adequate. As stated in the GPU EIR, payment of mandatory school impact fees is required from the project applicant, pursuant to California Government Code Section 65995 (3)(h). Therefore, the project’s impact on school facilities would be less than significant.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to public services that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigate potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to public services that were not analyzed as significant in the GPU EIR.

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Public Services

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3. There are no potentially significant off-site impacts proposed under the project that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to public services found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to public services. The project shall be conditioned to pay appropriate development fees as fair- share contribution towards police facilities and personnel.

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Exemption Checklist
Recreation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 117 16 Recreation

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Increase the use of existing
neighborhood and regional
parks or other recreational
facilities such that
substantial physical
deterioration of the facility
would occur or be
accelerated?
□ □ □ □ □ ■
b. Does the project include
recreational facilities or
require the construction or
expansion of recreational
facilities which might have
an adverse physical effect
on the environment? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses recreational resource impacts on pages 4.12-1 through 4.12-13. As noted therein, in 2010, the City owned and operated 211 acres of developed park land, or about 1.4 acres per 1,000 residents. The GPU EIR concludes that the current inventory of parks would not meet the City’s target of three acres of active parkland per 1,000 residents, and that development facilitated by the General and Specific Plans would increase the City’s population with commensurate increased in demand for parks and recreation facilities. The GPU identifies approximately 415 acres of potential park land that could be developed to meet the City’s parkland target. Funding for park improvements and additions would be available through fees collected under the Quimby Act and other funds and would be expected to keep pace with population growth as it occurs under implementation of the GPU. The following policies were included in the GPU to ensure this impact would be less than significant:
 Pomona General Plan Policy 7C.P1, to develop a master community parks layout to ensure parks accessibility for all neighborhoods.
 Pomona General Plan Policy 7C.P4, to revise developer impact fees to provide the capital necessary for the creation of new open space and improvements to existing open space.  Pomona General Plan Policy 7C.P16, to update the Citywide Parks Facilities Master Plan to identify needs and establish priorities for development of new parks, open spaces, and recreational and cultural facilities identified in the General Plan.  Furthermore, the GPU EIR notes Pomona General Plan Policy 7C.P11 as one of the many policies intended to help the City meet its parks, recreation, and open space goals by calling for City of Pomona
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the City to consider allowing in-lieu fee payments based on project site in higher intensity districts (such as North Pomona Center) or for small developments.

Project-Specific Impacts
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
According to the City’s General Plan, there are 221 acres of parks and open space and the City currently provides about 1.3 acres of parkland per 1,000 residents (City of Pomona 2014a). The City has a goal of providing three acres of parkland per 1,000 residents. Jaycee Park, approximately

0.4-mile northeast, and Ted Greene Park, approximately 0.4-mile northwest, are located within a one-half-mile radius of the project site.

Project residents would use local parks and recreational facilities in the vicinity of the project site.

According to the General Plan Open Space Network section, approximately 110 new acres of parkland will be needed over the next 20 years, based on anticipated population growth, to meet the City’s park standards. The GPU EIR and General Plan identified 368 acres of land for development as additional parkland within City boundaries. Although the addition of residents would incrementally increase use of community and regional parks and recreation facilities, the increase in use would be within that anticipated by the GPU EIR and is not expected to result in substantial physical deterioration of existing facilities. Furthermore, the project includes approximately 7,710 sf of open space for landscaping and approximately 14,850 sf of open space in the northwest corner of the site to accommodate a dog park and future clubhouse for the new residents. Therefore, the project would have a less-than-significant impact. b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The project entails infill development of 45 townhomes on vacant land. As stated above, the project includes a total of approximately 22,560 sf of open space for residential use. Population growth resulting from the project would be within the City’s 2035 population growth estimate, as discussed in Section 14, Population and Housing. The project does not require the construction or expansion of off-site public recreational facilities. Therefore, the project would have no impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to recreational facilities that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigate potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to recreational facilities that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts proposed under the project that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development Exemption Checklist
Recreation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 119 anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to recreation found all impacts to be less than significant.

There are no mitigation measures contained in the GPU EIR that apply to impacts to recreation.

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Transportation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 121 17 Transportation

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
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 design
feature (e.g., sharp curves
or dangerous intersections)
or incompatible uses (e.g.,
farm equipment)?
□ □ □ □ □ ■
d. Result in inadequate
emergency access? □ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses transportation/traffic impacts on pages 4.13-1 through 4.13-40. Impacts were assessed in the context of adopted planning documents and were based on the GPU EIR Traffic Impact Analysis completed by Fehr & Peers (Appendix D of the GPU EIR 2013). The GPU EIR states that traffic generated because of development facilitated by the GPU and CSP would degrade operations at several intersections throughout the City and identified four mitigation measures related to improving traffic flow and refinement of the City’s Truck Route Designation Map. These mitigation measures would ensure that transportation and traffic impacts from development under the GPU and CSP remain less than significant, except for the Pomona Boulevard and Temple Avenue intersection and two freeway segments (I-10, west of Indian Hill Boulevard, and I-10 at Dudley Street), which would be significant and unavoidable. Furthermore, the GPU EIR concludes that because freeway facilities are controlled by Caltrans, the City cannot guarantee implementation of any capacity improvements to these segments.

The four GPU EIR mitigation measures, Mitigation Measures T-1 through T-4, required the following updates to the General Plan:
 Mitigation Measure T-1 calls for the addition of Figure 4.13-4 of the GPU EIR to the General Plan (Figure 7-D.11, Intersection Improvements). Pomona General Plan Policy 7D.P16 was incorporated as a result of Mitigation Measure T-1 to ensure future developers implement the improvements identified in GPU EIR Figure 4.13-4.

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 Mitigation Measure T-2 states that the Active Transportation Plan will be updated to incorporate GPU EIR Figure 4.13-4 for the Garey Avenue/Arrow Highway and Garey Avenue/Philadelphia Street intersections.
 Mitigation Measure T-3 is recommended to assist in managing increased traffic in the Westmont Avenue segment as a result of completion of the SR 71 project, which is outside of the project area. As a result, Pomona General Plan Policy 7D.P23 was incorporated, which works with the traffic calming measures listed under Pomona General Plan Policy 7D.P22.  Mitigation Measure T-4 calls for an update of the City’s designated truck routes. As a result, the segment of Bonita Avenue between Fulton Road and Carnegie Avenue would no longer be used a designated truck route. Figure 7-D.12, Future Truck Routes, of the General Plan indicates the designation changes from GPU EIR Mitigation Measure T-4.

The following GPU goals and policies were noted in the GPU EIR, to ensure development under the GPU would have a less-than-significant impact on transportation/traffic:
 Pomona General Plan Goal 7D.G24, to require new development or redevelopment to provide bicycle parking where appropriate and ensure it is located in safe, prominent locations.  Pomona General Plan Goal 7D.G26, to align the amount of parking available and the amount of parking provide by new development with the real pattern of anticipated parking demand.  Pomona General Plan Policy 7D.P10, to require proposed development to implement or fund capital improvements to 1) maintain sidewalks, roadway paving, and landscaping 2) implement streetscape design improvements, and 3) accommodate growth with an emphasis on reduced reliance on the automobile.
 Pomona General Plan Policy 7D.P11, to investigate the feasibility of creating a special assessment district or value sharing arrangement to fund capital improvements related to traffic calming, active transportation, and transit.
 Pomona General Plan Policy 7D.P18, to ensure new developments provide an integrated pattern of streets and pedestrian paths that provide connections between neighborhood, and establish street connectivity that discourages gated entrances, provides street and pedestrian connection to adjacent areas to enable efficient movement throughout the City, aligns streets with existing arterials and collector streets in adjacent areas, and limits block lengths to no more than 500 feet and encourages four-way intersections.
 Pomona General Plan Policy 7D.P33, to require site designs that complement transit stops and pedestrian linkages nearby.
 Pomona General Plan Policy 7D.P35, to identify ways to improve vehicular and pedestrian access to the North Pomona Metrolink Station.
 Pomona General Plan Policy 7D.P67, to reduce parking requirements for mixed-use developments and for developments providing shared parking or a TDM program.  Pomona General Plan Policy 7D.P68, to revise parking standards to encourage and facilitate alternative transportation modes by reducing parking standards for mixed-use and transit oriented developments, reducing parking space footprints by accommodating a variety of vehicles, providing preferential parking for those who carpool, and the provision of bicycle parking for large developments.

Exemption Checklist
Transportation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 123 It was determined in the GPU EIR that implementation of the GPU would not interfere with or alter air traffic patterns in or near Pomona, as there are no airports in the City. Therefore, any changes to air traffic patterns would be less than significant.

The GPU EIR states that implementation of the GPU would not substantially increase hazards due to design features or incompatible uses due to the programmatic natures of the plans. Adherence to the City’s design standards and GPU policies would ensure future facilities improve safety for applicable modes of transportation. Likewise, implementation of the GPU and CSP would not result in inadequate emergency access as these two plans do not inherently represent project-specific components. Projects processed under the GPU and CSP would be required to meet all applicable local and state regulatory standards for adequate emergency access (including the Uniform Building Code, California Building Code, Uniform Fire Code, and applicable PMC and Fire Code requirements).

Therefore, impacts to design hazards and emergency access were determined to be less than significant.

Implementation of the GPU and CSP would be expected to enhance alternative transportation. The GPU includes a range of policies aimed at enhancement of neighborhood connectivity for bicycles, pedestrians, and neighborhood electric vehicles. In addition, the GPU EIR states that the City will consider reducing parking ratios and promoting alternative transportation demand management tools, especially in TOD districts. Therefore, impacts to alternative transportation would be less than significant.

Project-Specific Impacts
The analysis contained within this section is based on the Enclave on Towne Focused Traffic Study prepared by Ganddini Group, dated February 27, 2024 (Appendix H). The traffic study includes the non-CEQA analysis (i.e., Level of Service [LOS] analysis). a. Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Roadway, Transit, Bicycle, and Pedestrian Facilities
The proposed project would be served by existing roadways, transit, and pedestrian facilities.

Regional access to the project site would be provided via I-10. Local access to the project site is provided via North Towne Avenue or San Bernardino Avenue. Primary vehicular access to the project site would be provided via one driveway on San Bernardino Avenue. In addition, emergency vehicle access to the project site would be provided via one driveway on North Towne Avenue.

Pedestrian access to the project site would be provided via the existing sidewalks on North Towne Avenue and San Bernardino Avenue. Currently, there are no bicycle lanes in the project vicinity. Two Foothill Transit bus stops are located approximately 1,290 feet northeast of the project site along North Town Avenue and provide access to Route 292. The project site is also accessible from two Foothill Transit bus stops located near the intersection of San Bernardino Avenue and North San Antonio Avenue, approximately 1,600 feet east of the project site, and provides access to Route 292. The proposed project would not interfere with existing public transit, bicycle, or pedestrian facilities or impede the construction of new facilities or the expansion of such facilities in the future.

Therefore, impacts on transit, bicycle, and pedestrian facilities would be less than significant.

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Study Area for LOS Analysis
The scope and fundamental assumptions of the project-specific LOS analysis were determined in coordination with the City of Pomona engineering staff. Based on the study intersections identified in the scoping agreement, the study area consists of two study intersection within the City of Pomona jurisdiction:

1. North Towne Avenue (North-South [NS]) at San Bernardino Avenue (East-West [EW])

2. Palomares Street (NS) at San Bernardino Avenue (EW)
It should be noted that none of these intersections were included in the City’s GPU EIR TIA.

Consequently, the proposed project would not generate trips to intersections evaluated in the GPU EIR traffic report and therefore would not have the potential to result in any significant traffic effects at those intersections.

Analysis Scenarios
The following scenarios are analyzed for typical weekday AM and PM peak hour conditions in accordance with City of Pomona Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (October 2020) (hereafter, “City of Pomona Guidelines”).  Existing Conditions
 Opening Year (2026) Without Project Conditions
 Opening Year (2026) With Project Conditions
Analysis Methodology
T

RANSPORTATION EFFECTS
The Highway Capacity Manual (HCM), 7th Edition methodology was used to assess LOS for signalized and unsignalized study intersections within the study area. The HCM analysis methodology describes the operation of an intersection using a range of LOS from LOS A (free-flow conditions) to LOS F (severely congested conditions), based on the corresponding control delay experienced per vehicle for unsignalized intersections. Based on the performance standards established by the City of Pomona’s General Plan, the acceptable LOS for intersections in the City is D or better. Signaled intersections require improvements if one or more of the following conditions are met:
 Any study intersection that is operating at a LOS 'A', 'B', 'C' or 'D' for any study scenario without project traffic in which the addition of project traffic causes the intersection to degrade to a LOS 'E' or 'F' shall mitigate that impact so as to bring the intersection back to at least LOS 'D'.  Any study intersection that is operating at a LOS 'E' or 'F' for any study scenario without project traffic shall mitigate any impacts so as to bring the intersection back to the overall level of delay established prior to project traffic being added.

Unsignalized intersections will require improvements if the addition of project related traffic causes the intersection to move from a LOS 'D' or better to a LOS 'E' or worse. In addition, if the project contributes additional traffic to an intersection that is already projected to operate at an LOS 'E' or 'F' with background traffic and one or both of the following conditions are met the intersections will
require improvements:

Exemption Checklist
Transportation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 125  The project adds ten or more trips to any approach.
 The intersection meets the peak hour traffic signal warrant after the addition of project traffic.

PROTECTED LEFT TURN PHASING WARRANT
The need for installation of protected left turn phasing is evaluated based on the following guidance from Section 4D.19 of the California Manual on Uniform Traffic Control Devices (CA MUTCD):
 Delay - Left-turn delay of one or more vehicles, which were waiting at the beginning of the green interval and are still remaining in the left turn lane after at least 80% of the total number of cycles for one hour.
 Volume - At new intersections where only estimated volumes are available, the following criteria may be used. For pretimed signal or a background-cycle-controlled actuated signal, a left turn volume of more than two vehicles per approach per cycle for a peak hour; or for a traffic- actuated signal, 50 or more left turning vehicles per hour in one direction with the product of the turning and conflicting through traffic during the peak hour of 100,000 or more.

TRAFFIC SIGNAL WARRANT
The need for installation of a traffic signal at currently unsignalized study intersections is evaluated based on review of the traffic signal warrants contained in the CA MUTCD. As noted in the CA MUTCD, the satisfaction of a traffic signal warrant or warrants shall not in itself require the installation of a traffic control signal. Since this analysis contains measured volumes and forecasts for the AM and PM peak hours, the peak hour volume (Warrant 3) is evaluated first. If the peak hour volume warrant is satisfied, then further evaluation of Warrants 1 (Eight Hour Vehicular Volume) and Warrant 2 (Four Hour Vehicular Volume) may be conducted.

Project Trip Generation
The project trip generation is based upon trip generation rates obtained from the Institute of Transportation Engineers (ITE) Trip Generation Manual (11 th Edition, 2021). Trip generation rates for
Land Use Code 215 – Single-Family Attached Housing were used for the project. The number of trips forecast to be generated by each proposed land use is determined by multiplying the trip generation rates by the land use quantity. The project is forecast to generate approximately 324 daily trips, including 22 trips during the AM peak hour and 26 trips during the PM peak hour.

LOS Impact Analysis
E

XISTING CONDITIONS
The study intersections currently operate within acceptable LOS D or better during the peak hours.

The need for installation of protected left turn phasing was evaluated at the study intersection of North Towne Avenue and San Bernardino Avenue. San Bernardino currently provides permissive signal phasing in the east-west direction at its intersection with North Towne Avenue. Under existing conditions, installation of protected left turn phasing for eastbound/westbound left turn lanes at the signalized intersection of North Towne Avenue and San Bernardino Avenue is not warranted based on the CA MUTCD guidelines for existing peak hour volumes. In addition, based on review of existing conditions and the CA MUTCD traffic signal warrants, installation of a traffic signal is not recommended at the intersection of Palomares Street and San Bernardino Avenue.

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OPENING YEAR (2026) WITHOUT PROJECT CONDITIONS
Opening Year (2026) Without Project volume forecasts were developed by adding ambient growth to Existing volumes. To account for ambient growth on roadways, existing volumes were increased by a growth rate of two percent per year over a two-year period. This equates to a total growth factor of approximately 1.04. The ambient growth was conservatively applied to all movements at the study intersections. The study intersections are forecast to operate within acceptable LOS D or better during the peak hours for Opening Year (2026) Without Project conditions.

O
PENING YEAR (2026) WITH PROJECT CONDITIONS
Opening Year (2026) With Project volumes were developed by adding project generated trips to the Opening Year (2026) Without Project forecast volumes. The study intersections are forecast to operate within LOS D or better during the peak hours for Opening Year (2026) With Project Conditions. In addition, installation of protected left turn phasing for eastbound/westbound left turn lanes at the signalized intersection of North Towne Avenue and San Bernardino Avenue is not warranted based on the CA MUTCD guidelines for existing peak hour volumes. Furthermore, the intersection of Palomares Street and San Bernardino Avenue is not forecast to satisfy the CA MUTCD peak hour volume warrant (Warrant 3) for Opening Year (2026) With Project conditions.

As discussed above, the operational traffic would not cause a measurable transportation effect to the circulation system per LOS analysis. The project would not preclude implementation of any plans or policies regarding existing or proposed bicycle or pedestrian facilities in Pomona. As such, the project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and impacts would be less than significant.
b. Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
As established by the City of Pomona Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (2020), certain types of projects, because of their size, nature, or location, are exempt from the requirement of preparing a VMT analysis. The City guidelines provide the following three screening steps: Transit Priority Area (TPA) Screening, Low VMT Area Screening and Project Type Screening. The proposed project does not satisfy TPA Screening or Low VMT Area Screening. However, the proposed project satisfies the City-established project type screening criteria based on the Substantial Evidence Memorandum for Vehicle Miles Traveled Screening Criteria Analysis. Substantial Evidence Memorandum for Vehicle Miles Traveled Screening Criteria Analysis states that 150 single-family units or less, 200 multi-family units or less, 80,000 sf of office use or less, and 150,000 sf of general light industrial use or less would be screened from conducting a detailed VMT analysis and presumed to have a less-than-significant impact absent substantial evidence to the contrary in the City of Pomona provided that that each land use will be operating as a single use only on a subject property and not in a mixed-use scenario.

The project consists of 45
attached single-family units; therefore, the proposed project satisfies the City established project type screening criteria based on the Substantial Evidence Memorandum for Vehicle Miles Traveled Screening Criteria Analysis.

As discussed in the preceding analysis, the project would not conflict with the surrounding circulation system, including roadway and transit facilities. Rather, the adjacent Foothill Transit Route 292 would encourage project residents to use transit options as an alternative means of transportation, which would help lower the project’s VMT. Furthermore, based on the project’s trip Exemption Checklist
Transportation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 127 distribution, the project is forecast to contribute fewer than 50 or more weekday peak hour trips to a CMP-monitored intersection and fewer than 150 weekday peak hour trips to a mainline freeway monitoring location. Therefore, a CMP impact analysis is not required for the proposed project.

Pursuant to the CMP guidelines, the proposed project is forecast to generate approximately 16 daily transit trips, including one transit trip during the AM peak hour and one transit trip during the PM peak hour, based on CMP transit trip estimation procedures. Based on the relatively low project- generated transit trip estimate, the project is expected to have a negligible impact on transit service capacity.
c. Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? The GPU EIR determined that the roadway network changes proposed as part of the GPU did not include any identified hazardous design features, and that the GPU would not incorporate any design features that could increase traffic hazards.

Project Design Features
As shown on the project site plans (Appendix A), primary vehicular access to the project site would be provided via one driveway on San Bernardino Avenue. The project would construct the following improvements for vehicular site access in accordance with City of Pomona design standards:
 Project Driveway (NS) at San Bernardino Avenue (EW) - #1  Install southbound stop control.
 Construct the southbound approach to consist of one shared left/right turn lane.  Modify the eastbound approach to add a two-way left turn lane and maintain one shared through/right turn lane.
 Maintain the existing westbound approach to consist of one left turn lane a shared through/right turn lane.

The project would also comply with the following conditions as part of the City’s standard development review process:
 A construction work site traffic control plan would comply with State standards set forth in the CA MUTCD and would be submitted to the City for review and approval prior to the issuance of a grading permit or start of construction. The plan would identify any roadway, sidewalk, bike route, or bus stop closures and detours as well as haul routes and hours of operation. All construction-related trips would be restricted to off-peak hours to the extent possible.  All on- and off-site roadway design, traffic signing and striping, and traffic control improvements relating to the proposed project would be constructed in accordance with applicable State/federal engineering standards to the satisfaction of the City of Pomona Public Works Department.
 Site-adjacent roadways would be constructed or repaired at their ultimate half-section width, including landscaping and parkway improvements in conjunction with development, or as otherwise required by the City of Pomona Public Works Department.  Adequate off-street parking would be provided to the satisfaction of City of Pomona Planning and/or Public Works Department.

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 The final grading, landscaping, and street improvement plans would demonstrate that sight distance requirements are met in accordance with applicable City of Pomona/California Department of Transportation sight distance standards.

Slight Distance Analysis
Intersection sight distance analysis was prepared for the proposed project driveway at San Bernardino Avenue. Roadways are designed to provide sufficient stopping sight distance continuously along each roadway so that drivers have a view of the roadway ahead. If the available sight distance equals or exceeds the appropriate stopping sight distance for the major road, sufficient sight distance is provided to anticipate and avoid collisions. In some cases, however, vehicles traveling on the major road may need to substantially slow down or stop to accommodate vehicles entering or crossing from the minor road. Therefore, to enhance traffic operations at uncontrolled or minor street stop-controlled intersections, it is desirable to provide intersection sight distances that exceed the stopping sight distances along the major road.

The sight distance analysis was prepared based on the sight distance guidelines specified in the American Association of State Highway and Transportation Officials (AASHTO) A Policy on Geometric Design of Highways and Street (7th Edition, 2018) [“AASHTO Greenbook”]. Both stopping sight distance and intersection sight distance were evaluated. The stopping sight distances are based on passenger car operation and do not explicitly consider design for truck operations. While trucks typically require longer braking distances, they generally travel slower and truck drivers are more experienced than the average passenger car driver; therefore, separate stopping distances for trucks and passenger cars are not generally used in highway design. For intersection sight distance, AASHTO notes that the minor road design vehicle can usually be assumed to be a passenger car, except in cases where substantial volumes of heavy vehicles enter the major road, such as ramp terminals.

Based on the sight distance guidelines, there are no existing structures, objects, or landscaping that substantially obstruct the line of sight for the proposed driveways along San Bernardino Avenue and North Towne Avenue. On-street parking is permitted on the project frontage and could potentially cause temporary sight distance obstructions if vehicles park in these areas. At a minimum, on-street parking should be prohibited for 20 feet on either side of the proposed driveway per the CA MUTCD.

To enhance traffic operations and ensure vehicles traveling on San Bernardino Avenue do not have to substantially slow down or stop to accommodate vehicles exiting the project driveway along San Bernardino Avenue, the following measures are recommended to provide sufficient intersection sight distance:
 Prohibit on-parking (i.e., install red curb markings) on San Bernardino Avenue approximately 110 feet west of the project driveway.
 Prohibit on-parking (i.e., install red curb markings) on San Bernardino Avenue between project driveway and North Towne Avenue.

Off-Street Parking
Based on the project plans, the project does not appear to meet the standard off-street parking requirements per the PMC. Therefore, the project would be required to prepare a parking management plan, which would document anticipated parking demand for the project and, if necessary, measures to ensure excess parking demand does not adversely affect surrounding neighborhoods.

Exemption Checklist
Transportation

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 129 Speeding on San Bernardino Avenue
The proposed driveway along San Bernardino Avenue would be located approximately 180 feet from the curb return at the intersection of North Towne Avenue. Most, if not all, project-related vehicles are not expected to exceed the posted speed limit due to the relatively short distance between the proposed driveway along San Bernardino Avenue and North Towne Avenue. Most project-related vehicles will turn to/from the proposed driveway and turn to/from North Towne Avenue with a short straightaway between, thus limiting the ability for vehicles to substantially accelerate in between turns. In addition, vehicles entering the project site will slow down to make a right turn at the project driveway and would likely require trailing vehicles to partially slow.

Therefore, the proposed project is not anticipated to substantially contribute to any existing speeding issues on San Bernardino in front of the project site.

Based on the analysis above, the project does not include any modifications to the existing off-site transportation network that would result in potential transportation hazards not anticipated in the GPU EIR. Therefore, the project would have a less-than-significant impact. d. Would the project result in adequate emergency access? The project would not modify any existing emergency access route in a way that would result in inadequate emergency access. Proposed vehicle circulation on the project site would provide adequate width and turn radius for emergency vehicles, and project site plans would be reviewed and approved by LACoFD prior to construction. Therefore, the project’s potential impacts related to emergency access would be less than significant.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU and CSP policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site and/or cumulative impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The GPU EIR included four mitigation measures to address impacts to transportation. These mitigation measures were incorporated into the GPU policies; however, they do not apply to the project. Incorporation of project design features and enforcement of standard conditions of approval would ensure potential project impacts to transportation would be less than significant. No additional mitigation measures apply.

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Exemption Checklist
Tribal Cultural Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 131 18 Tribal Cultural Resources

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

a. Listed or eligible for listing
in the California Register of
Historical Resources, or in a
local register of historical
resources as defined in
Public Resources Code
Section 5020.1(k), or □ □ □ □ ■ □
b. A resource determined by
the lead agency, in its
discretion and supported
by substantial evidence, to
be significant pursuant to
criteria set forth in
subdivision (c) of Public
Resources Code
Section 2024.1. In applying
the criteria set forth in
subdivision (c) of Public
Resources Code Section
5024.1, the lead agency
shall consider the
significant of the resource
to a California Native
American tribe.
□ □ □ □ ■ □
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses cultural resource impacts, including potential impacts to tribal resources, on pages 4.4-1 through 4.4-24. Pomona has a long cultural history and is known to have been home to Native American groups prior to settlement by Euro-Americans. Therefore, the presence of subsurface archaeological, paleontological, and human remains may be present, and subject to direct or indirect effects of ground-disturbance activities associated with 2035 buildout under the GPU. The GPU EIR concludes that impacts to archaeological and paleontological resources or human remains would be a less than significant impact with GPU EIR Mitigation Measure CUL-2 incorporated (Policy 7F.P39).

Pursuant to the requirements of SB 18, the City notified six Native American tribes of the proposed GPU and accompanying plans. No requests for consultation were received (page 4.4-18 of the GPU EIR). The GPU EIR includes the following GPU policies to ensure project impacts to tribal cultural resources would be less than significant:

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132
 Pomona General Plan Policy 7F.P36, to require consultation with California Native American tribes prior to the adoption or amendment of the General Plan or Specific Plans for the purpose of preserving, or mitigating impacts to, cultural places located on land within the City’s jurisdiction that may be affected by the proposed Plan adoption or amendment, per SB 18.  Pomona General Plan Policy 7F.P39, to require that for proposed developments with the potential to adversely impact cultural resources, notification be sent to cultural organizations, including Native American organizations (adopted into the General Plan based on Mitigation Measure CUL-2).

Therefore, Native American outreach procedures were completed by the City for the GPU areas. The GPU EIR concludes that implementation of the GPU policies would ensure impacts to archaeological and Native American cultural resources would be less than significant.

Project-Specific Impacts
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or, b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 2024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significant of the resource to a California Native American tribe.

As discussed in the GPU EIR, archaeological and tribal cultural materials associated with occupation of the City are known to exist throughout the City and have the potential to provide important scientific information regarding history and prehistory. The GPU EIR identified impacts to unrecorded subsurface cultural resources as less than significant with mitigation incorporated.

The project site is relatively flat, vacant, and undeveloped, and currently contains a telecommunications tower on the northeast portion of the site and a paved parking lot. The project site is within a highly urbanized area and contains a recently demolished building on the southeast corner of the project site. Therefore, no tribal consultation was warranted since there is no evidence to suggest that the project site is sensitive for tribal cultural resources based on prior development, disturbance, and existing conditions on the project site and vicinity.

Though unanticipated, project construction activities (such as excavation, grading, and site preparation) have the potential to impact previously unidentified tribal cultural resources.

Potentially significant impacts would occur if the implementation of the project would result in construction activities that would damage previously unidentified significant tribal cultural resources. The project would comply with the City’s standard conditions pertaining to tribal cultural resources should such resources, previously unknown, be encountered during ground disturbing construction activities. The City’s standard conditions include procedures to halt work until found resources are appropriately handled, assessed, and/or recorded by qualified personnel to prevent damage to found resources. Therefore, the project would have a less-than-significant impact on tribal cultural resources.

Exemption Checklist
Tribal Cultural Resources

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 133 Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts to tribal cultural resources that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigate potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts to tribal cultural resources that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts proposed under the project that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to tribal cultural resources found all impacts to be less than significant with the incorporation of Mitigation Measure CUL-2. Mitigation Measure CUL-2 was incorporated into the GPU as Policy 7F.P39. No additional mitigation measures contained in the GPU EIR apply to impacts to tribal cultural resources.

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Exemption Checklist
Utilities and Service Systems

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 135 19 Utilities and Service Systems

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Would the project:
a. Require or result in the
construction of new or
expanded water,
wastewater treatment or
stormwater drainage,
electric power, natural gas,
or telecommunications
facilities, the construction
of which could cause
significant environmental
effects? □ □ □ □ □ ■
b. Have sufficient water
supplies available to serve
the project and reasonably
foreseeable future
development during
normal, dry and multiple
dry years? □ □ □ □ □ ■
c. Result in a determination
by the wastewater
treatment provider which
serves or may serve the
project that it has adequate
capacity to serve the
project’s projected demand
in addition to the provider’s
existing commitments?
□ □ □ □ □ ■
d. Generate solid waste in
excess of State or local
standards, or in excess of
the capacity of local
infrastructure, or otherwise
impair the attainment of
solid waste reduction
goals?
□ □ □ □ □ ■
e. Comply with federal, State,
and local management and
reduction statutes and
regulations related to solid
waste? □ □ □ □ □ ■
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City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses impacts on utilities and service systems on pages 4.14-1 through 4.14-20. This discussion addresses the issues of water supply, wastewater, and solid waste and recycling.

Water Supply
The City’s Public Works Department provides water service for Pomona. Approximately 68 percent of the City’s water is supplied from groundwater sources. Imported water from the Metropolitan Water District of Southern California via the Three Valleys Municipal Water District makes up 16 percent of the City’s supply, 15 percent from local surface water from the San Antonio and Evey Canyon watersheds, and the remaining one percent from recycled water that is non-potable.

The City’s 2010 Urban Water Management Plan (UWMP) concludes that the City will have adequate water supply, with normal conservation efforts, to meet demand through 2035 in average year, single dry year, and multiple dry year scenarios. According to the GPU EIR, development facilitated by the GPU is expected to increase the City’s population to 197,400 by 2035, in line with SCAG growth forecasts for Pomona. The 2010 UWMP anticipates the service population to be 216,899 in 2035, which is 19,500 people greater than the population increase anticipated as a result of implementing the GPU EIR (216,899 – 197,400 = 19,499). Therefore, the GPU EIR concludes that water supplies would be adequate to serve population growth facilitated by the GPU and that impact on water supply would be less than significant.

Wastewater
Wastewater service in Pomona is provided by the City’s Public Works Department. Wastewater from the City’s system is treated and disposed of by the Pomona Water Reclamation Plant (PWRP), operated by the Los Angeles County Sanitation District (LACSD). Sewage effluent from the neighboring cities of La Verne and Claremont is also treated at the PWRP, which has a design capacity of 15 million gallons per day (mgd). In 2012, the average daily flow to the plant was approximately 8.4 mgd, leaving approximately 6.6 mgd in available capacity. Though implementation of the GPU would result in an increase in wastewater generation, maximum wastewater generation as a result of the GPU was estimated to generate 3.1 mgd. The GPU EIR concludes that the PWRP has capacity to accommodate the additional wastewater through the existing treatment infrastructure and that expansion would not be required. In addition, the GPU EIR specifies adherence to Pomona General Plan Policy 7E.P33, which requires all new development or expansion of existing facilities bear the cost of expanding the wastewater disposal system to handle the increased loads anticipated by development, to ensure GPU impacts are less than significant. Therefore, project impact on wastewater treatment facilities associated with increased growth in the City would be less than significant.

Stormwater Runoff
As discussed in the GPU EIR, new development under implementation of the GPU would continue to comply with all provisions of the NPDES program, as enforced by the RWQCB, discussed in Section 10, Hydrology and Water Quality. The GPU EIR states future projects under the GPU would be required to comply with all applicable wastewater discharge requirements issued by the SWRCB and RWQCB. Therefore, implementation of the GPU would not violate applicable wastewater treatment requirements of the RWQCB with respect to discharges to the sewer system or stormwater system in Pomona.

Exemption Checklist
Utilities and Service Systems

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 137 Solid Waste and Recycling
The City’s Public Works Department provides trash, recycling, and special pickup services for residents. Waste is collected by franchise commercial waste haulers and conveyed to the West Valley Materials Recovery Facility (MRF) in Fontana and the Athens Services MRF in Industry. There are four landfills that serve Pomona (Puente Hills, Olinda Alpha, El Sobrante, and Mid-Valley Sanitary), which have a combined estimated available daily capacity of 33,823 tons per day.

Implementation of the GPU would generate approximately 177 tons of solid waste per day.

Therefore, the landfills that serve Pomona were determined to have capacity to accommodate the additional waste. Furthermore, based on the City’s 2011 waste diversion rate of 70.4 percent, actual solid waste disposal resulting from the GPU EIR would be approximately 54 tons/day. The GPU EIR concludes that impact on waste management and recycling would be less than significant.

Project-Specific Impacts
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? Water Supply
The GPU EIR demonstrates that anticipated water demand in this area has been accounted for in the City’s 2010 UWMP and that development occurring under the GPU would not require any changes in existing water supplies. Because the project would be within the maximum buildout as anticipated under the GPU EIR, it is not anticipated that the City would need new or expanded entitlements to serve the project. The City reviewed the existing water and sewer infrastructure in the project area and concluded that water and wastewater service for the project would be provided by the City.

According to the 2020 UWMP, the 2020 water demand for the City was an estimated 19,472 acre- feet per year (AFY), or approximately 17.4 million gallons per day (mgd). The City’s water demand is forecast to increase to 28,135 AFY, or approximately 25 mgd (City of Pomona 2021). According to CalEEMod results, the project would result in a water demand of 1.7 million gallons per year, or approximately 4,658 gallons per day. Therefore, the project’s water demand of 4,658 gallons per day would account for approximately 0.1 percent of the forecast water demand increase of 4.8 mgd between 2015 and 2035. Furthermore, Pomona’s water supply reliability analysis concluded that water supplies will exceed demands under all hydrologic scenarios with the implementation of additional supplies from recycled water and treated groundwater, more water efficient equipment, and conservation measures. Therefore, existing water infrastructure and supplies would be adequate to serve the anticipated residents of the project, and the project’s impact on water supply would be less than significant.

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c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
The PWRP has approximately 6.6 mgd capacity to accommodate additional wastewater from projects resulting from the GPU. The project applicant would be required to bear the cost of expanding the wastewater disposal system if existing systems on the project are inadequate for conveying anticipated wastewater generated by residents of the project. Conservatively assuming that wastewater generation is 100 percent of water demand, the project would generate an estimated 4,658 gallons of wastewater per day (Appendix B), which is approximately 0.1 percent of the PWRP’s 6.6 mgd capacity. Therefore, existing wastewater infrastructure would be adequate to serve the anticipated residents of the proposed building, and the project’s impact on wastewater systems would be less than significant.

As discussed in Section 10, Hydrology and Water Quality, the project, as designed, would increase the amount of impervious surface on the project site due to the proposed building footprints, and pedestrian and vehicle circulation pathways. The project also includes landscaped and common open space areas throughout the site. Project construction activities would implement BMPs to prevent substantial erosion or siltation on- or off-site, and the project site would be fully developed with no bare dirt left exposed. Because the project would generate a higher peak stormwater runoff flowrate than the existing condition of the site, the project also includes the installation of a stormwater infiltration trench system on-site. Therefore, the project would not require the construction of new or expanded off-site facilities for stormwater drainage and would have a less than significant impact related to stormwater runoff.
d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e. Would the project comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
The four landfills that serve Pomona have sufficient capacity to accommodate solid waste from full buildout under the GPU, according to the GPU EIR. Diversion of solid waste from the project site into the recycling stream would substantially reduce the project’s impact on landfill capacity.

According to CalEEMod results for the project (Appendix B), the project would generate approximately 33.2 tons of solid waste per year, or approximately 0.09 tons per day. This represents approximately 0.003 percent of the estimated available daily capacity at the four landfills that serve the City (33,823 tons) and approximately 0.05 percent of the 177 tons of waste anticipated to be generated from projects implemented under the GPU. Assuming the City’s 2011 waste diversion rate of 70.4 percent applies to waste generated from the project, the project would generate approximately tons of solid waste per day, which would account for approximately 0.2 percent of the 54 tons of waste resulting from projects implemented under the GPU. Therefore, the project would not result in greater impacts on landfill capacity or regulatory compliance related to solid waste than anticipated in the GPU EIR, and project impact on solid waste and recycling would be less than significant.

Exemption Checklist
Utilities and Service Systems

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 139 Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigates potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The conclusion of the GPU EIR relating to utilities and service systems found all impacts to be less than significant. There are no mitigation measures contained in the GPU EIR that apply to impacts to utilities and service systems.

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Exemption Checklist
Wildfire

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 141 20 Wildfire

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

a. Substantially impair an
adopted emergency
response plan or
emergency evacuation
plan?
□ □ □ □ □ ■
b. Due to slope, prevailing
winds, and other factors,
exacerbate wildfire risks,
and thereby expose project
occupants to, pollutant
concentrations from a
wildfire or the uncontrolled
spread of a wildfire? □ □ □ □ □ ■
c. Require the installation or
maintenance of associated
infrastructure (such as
roads, fuel breaks,
emergency water sources,
power lines or other
utilities) that may
exacerbate fire risk or that
may result in temporary or
ongoing impacts to the
environment?
□ □ □ □ □ ■
d. Expose people or structures
to significant risks,
including downslope or
downstream flooding or
landslides, as a result of
runoff, post-fire slope
instability, or drainage
changes?
□ □ □ □ □ ■
City of Pomona General Plan Update, Corridors Specific Plan, Active Transportation Plan, and Green Plan EIR Summary
The GPU EIR discusses wildfire impacts on pages 4.6-29 and 4.6-30 and states that parts of Pomona are susceptible to wildland fires due to its hilly terrain, dry weather conditions, and plant cover, with high fire risk areas located in mountainous areas, particularly in the southwestern corner of the City (by Phillips Ranch, Lanterman Center, and Cal Poly Pomona areas). Implementation of the GPU could lead to an increase in residential or commercial development in areas that are susceptible to City of Pomona
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wildland fires. Adherence to the following GPU policies was determined to reduce fire hazards to less than significant impacts:
 Pomona General Plan Policy 7G.P20, to require site design features, fire retardant building materials, and adequate access as conditions for approval of development or improvements to reduce the risk of fire in the City. As such, new construction is required to meet requirements of the most recent International Building Code and California Title 24 Codes.  Pomona General Plan Policy 7G.P21, to require new wood and wood shake roofing materials to be a minimum of class B rated material, requires fire-resistant materials for re-roofing projects, and requires tile roof material rated for high or very high fire threat areas.  Pomona General Plan Policy 7G.P22, which states that the City will consider future access and water supply infrastructure improvements, particularly in areas identified as high or very high fire threat areas.
 Pomona General Plan Policy 7G.P23, to require the City to develop a fire-resistant landscape program in coordination with homeowners associations throughout the City, specifically those communities located in high or very high fire threat areas.  Pomona General Plan Policies 7G.P24 and 7G.P25, which pertain to weed abatement and brush clearance programs and maintenance of low residential densities in wildfire hazard areas.

The GPU EIR concluded that impacts associated with wildfires would be less than significant following implementation of General Plan goals and policies stated above.

Project-Specific Impacts
a. Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
b. Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c. Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d. Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
The project would increase traffic at the project site and vicinity due to the addition up to 153 residents but would not result in any changes to the existing street network that could impede emergency access or evacuation. The GPU EIR includes updates for several GPU policies pertaining to disaster preparedness and emergency response and concludes that implementation of updated policies would result in a less than significant impact. The project would not inhibit the implementation of adopted Citywide emergency response or evacuation plans. As stated in the GPU EIR, the southwestern corner of the City is particularly susceptible to wildfires. The project site is flat and within an urbanized area in the northern portion of the City. There are no wildlands in the vicinity of the project site. The project site and vicinity are not identified as a Very High Fire Hazard Severity Zone (CalFire 2022; CalFire 2023). Implementation of the project would not significantly increase exposure of people or structures to a significant risk of loss, injury, or death involving Exemption Checklist
Wildfire

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 143 wildfires. The project would not require installation or maintenance of associated infrastructures to prevent wildfires. Existing project site topography would not expose people or structures to subsequent downstream flooding or landslides resulting from wildfires. Therefore, the project would have a less-than-significant impact.

Conclusion
Further environmental analysis is not required because:

1. No peculiar impacts from wildfires that are not substantially mitigated have been identified as a result of the project or its site. Application of the uniformly applied GPU policies substantially mitigate potentially significant impacts to a level of less than significant.

2. There are no potentially significant impacts from wildfires that were not analyzed as significant in the GPU EIR.

3. There are no potentially significant off-site impacts proposed under the project that were not discussed by the GPU EIR.

4. The project would not result in new cumulative impacts that were not anticipated with future buildout of the plan area analyzed in the City’s adopted GPU EIR. The GPU EIR assessed the implementation of a general plan that, by its nature, considered cumulative development anticipated with future buildout under the plan within the City’s defined plan area. To date, the City has not approved development that would conflict or deviate with the City’s 2014 GPU.

Therefore, the proposed project would not result in new cumulatively considerable impacts that were not previously considered in the City’s 2014 GPU EIR.

5. No substantial new information has been identified that results in an impact that is more severe than anticipated by the GPU EIR.

6. The GPU EIR concluded that impacts associated with wildfires would be less than significant following implementation of General Plan Policies 7G.P20 through 7G.P25. No further mitigation measures apply to this project.

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Exemption Checklist
Mandatory Findings of Significance

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 145 21 Mandatory Findings of Significance

Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniformly Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the prior EIR
Potentially
Significant
Off-site or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information

GPU EIR
Mitigation
Measures apply
to this Project
Yes No
Mandatory Findings of Significance:
a. Does the project have the
potential to substantially
degrade the quality of the
environment, substantially
reduce the habitat of a fish
or wildlife species, cause a
fish or wildlife population
to drop below self-
sustaining levels, threaten
to eliminate a plant or
animal community,
substantially reduce the
number or restrict the
range of a rare or
endangered plant or animal
or eliminate important
examples of the major
periods of California history
or prehistory? □ □ □ □ □ ■
b. Does the project have
impacts that are
individually limited, but
cumulatively considerable?
(“Cumulatively
considerable” means that
the incremental effects of a
project are considerable
when viewed in connection
with the effects of past
projects, the effects of
other current projects, and
the effects of probable
future projects). □ □ □ □ □ ■
c. Does the project have
environmental effects
which will cause substantial
adverse effects on human
beings, either directly or
indirectly □ □ □ □ □ ■
This Mandatory Findings of Significance section is not typically required under CEQA Guidelines 15183; however, the following analysis is included for informational purposes.

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Project-Specific Impacts
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? The project would not result in new or substantially greater impacts than what was analyzed in the GPU EIR. As stated in Section 4, Biological Resources, and Section 5, Cultural Resources, above, the project does not have the potential to substantially degrade the quality of the environment or reduce the habitat of a fish or wildlife species or threaten to eliminate a plant or animal community. b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects).

The GPU EIR identified significant and unavoidable cumulative impacts related to transportation (traffic generation). This impact was accounted for in the EIR and addressed by a Statement of Overriding Considerations adopted by the City; all other cumulative impacts can be reduced through mitigation measures identified in the prior EIR. Based on current knowledge of the project, there are not cumulatively relevant new or reasonably foreseeable new, development and land uses inside or outside the GPU area that was not accounted for in either the GPU EIR.

The project would, inherently, contribute to cumulative impacts considered in the GPU EIR, but in a manner anticipated and analyzed in those documents. The project would comply with all applicable mitigation measures and uniformly applied development standards to reduce impacts related to development within the site. As such, impacts associated with development of the project within the GPU area would be consistent with the analysis in the prior EIR, the project, as discussed above, would not result in new or substantially greater cumulative impacts than what was analyzed in the prior EIRs.
c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly
The project would not result in new or substantially greater adverse effects on human beings, either directly or indirectly. Please refer to the health risk analysis as described in Section 3, Air Quality.

References

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 147 References
Bibliography
California Air Resources Board (CARB) 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. https://sfmohcd.org/sites/default/files/20%20- %20CARB%2C%20Air%20Quality%20and%20Land%20Use%20Handbook%202005.pdf. ______. 2017. California’s 2017 Climate Change Scoping Plan. December 14, 2017. https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf (accessed August 2023).
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California Department of Conservation (DOC) 2016. California Important Farmland Finder. Available online: https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed February 2024. ______. 2019. Earthquake Zones of Required Investigation. Available online:
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California Department of Conservation, Division of Mines and Geology. 1983. Aggregate Resource Sectors. Available online:
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California Department of Forestry and Fire Protection (CalFire). 2023. California Fire Hazard Severity Zone Viewer. https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414.

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______. 2023. Fire Hazard Severity Zones in State Responsibility Area. https://calfire- forestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d89597 ab693d008. Accessed December 2023.

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California Department of Transportation (Caltrans). 2019. California State Scenic Highway System Map. Available online:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e 8057116f1aacaa. Accessed February 2024.

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California Energy Commission (CEC). 2023. 2022 California Annual Retail Fuel Outlet Report Results (CEC-A15) Energy Assessments Division. August 16, 2023. https://www.energy.ca.gov/media/3874.
______. 2024. Electricity Consumption by Entity. https://ecdms.energy.ca.gov/elecbyutil.aspx.

California Governor’s Office of Planning and Research (OPR). 2017. State of California General Plan Guidelines. Available online: https://opr.ca.gov/docs/OPR_COMPLETE_7.31.17.pdf.

Accessed January 2024.

California Native Plant Society (CNPS). 2023. Inventory of Rare and Endangered Plants. (online edition, v8-03 0.39). California Native Plant Society, Sacramento, CA. Retrieved from:
http://www.rareplants.cnps.org. Accessed February 2024. ______. 2023. Biogeographic Information and Observation System (BIOS). Available at:
http://bios.dfg.ca.gov. Accessed February 2024.

California Natural Resource Agency. 2019. “California’s Fourth Climate Change Assessment Statewide Summary Report.” January 16, 2019.
https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4- 2018-013_Statewide_Summary_Report_ADA.pdf (accessed August 2023). ______. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson- Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T.

Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://report.ipcc.ch/ar6/wg1/IPCC_AR6_WGI_FullReport.pdf (accessed August 2023). ______. 2010. Minutes for the GHG CEQA A Significance Threshold Stakeholder Working Group #15. http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf (accessed September 2021).

GEPermit. 2019. Noise Technical Report for the Beyer Community Park, San Diego, California. April.

Google Earth Pro 7.3.3.7786. December 21, 2023. Google LLC. https://www.google.com/earth/index.html. Accessed December 2023.

Federal Highway Administration (FHWA). 2011. Highway Traffic Noise Analysis and Abatement Policy and Guidance. (FHWA-HEP-10-025). December. (accessed February 2024).

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment.

November. Available at: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research- innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no- 0123_0.pdf
Ganddini Traffic Group, Inc. 2024. Enclave on Towne Focused Traffic Study. January.

Los Angeles, City of. 2012. Zoning Information (Z.I.) NO. 2427 Freeway Adjacent Advisory Notice For Sensitive Uses. November 8, 2012.
https://planning.lacity.gov/StaffRpt/InitialRpts/Freeway%20Adjacent%20Residential- %20ZI2427.pdf.

References

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 149 Los Angeles County, Airport Land Use Commission. 2015. Brackett Field Airport Land Use Compatibility Plan. Available online: https://planning.lacounty.gov/wp- content/uploads/2022/10/Brackett-Field-Airport-Land-Use-Compatibility-Plan.pdf .

Accessed February 2024.

NETR Online. 2023c. National Wetland Inventory. Available at:
http://www.fws.gov/wetlands/Data/Mapper.html. Accessed February 2024.

Office of Environmental Health Hazard Assessment (OEHHA). 2019. https://ww2.arb.ca.gov/sites/default/files/classic/toxics/healthval/contable.pdf.

Pomona, City of. n.d. General Plan and Zoning Map. Available online:
https://www.arcgis.com/apps/webappviewer/index.html?id=13bf54e995f74891bdf5b3bddf 90522a. Accessed December 2023.
______. 2010. Zoning Code. Available online:
https://library.municode.com/ca/pomona/codes/zoning. Accessed December 2023. ______. 2012b. Green Plan. November 2012. Available at:
https://www.pomonaca.gov/government/departments/water-resources- department/environmental-programs/energy-efficiency/green-plan?locale=en. Accessed December 2023.
______. 2014a. City of Pomona 2014 General Plan Update: Pomona Tomorrow. Available online:
https://www.pomonaca.gov/home/showpublisheddocument/2402/637521057423830000.

Accessed December 2023.
______. 2014b. City of Pomona General Plan Update, Corridors Specific Plan, ATP and Green Plan EIR. Available online:
https://www.pomonaca.gov/home/showpublisheddocument/2869/637539009362330000.

Accessed December 2023.
______. 2021. 2020 Urban Water Management Plan. Available online:
https://www.pomonaca.gov/home/showpublisheddocument/5870/638278730516730000.

Accessed February 2024.
______. 2023a Provided information relevant to the project including the Presidential Park Potential Local Historic District map and contributing resources. ______. 2023b Historic Designation Application: Application Submittal Checklist. Electronic resource accessed January 29, 2024, at
https://www.pomonaca.gov/home/showpublisheddocument/5651/638242523133770000 ______. 2024 Comments and map from Geoffrey Starns, Supervising Planner and Historic Preservation Supervisor, on first submission of the 1701 North Towne Avenue Cultural Resources Assessment.

Pomona Police Department (PPD). 2020. Pomona Police Department – 2020 Crime Fighting Blueprint. Available online:
https://pomona.prod.govaccess.org/home/showpublisheddocument/408/63745699732043 0000. Accessed December 2023.

Singer, B. C., W. W. Delp, D. R. Black, and I. S. Walker. 2017. Measured performance of filtration and ventilation systems for fine and ultrafine particles and ozone in an unoccupied modern City of Pomona
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California house. Indoor Air. LBNL-1006961.
https://escholarship.org/content/qt7x86h6ff/qt7x86h6ff.pdf.

South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook. April 1993.
______. 2003. Final 2003 AQMP Appendix V Modeling and Attainment Demonstrations, Final 2003 AQMP. August. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality- management-plans/2003-air-quality-management-plan/2003-aqmp-appendix- v.pdf?sfvrsn=2 (accessed May 2022).
______. 2008. Final Localized Significance Thresholds Methodology. htp://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/ghgatachmente.pdf.
______. 2009. Appendix C – Mass Rate LST Look-up Tables. October. htp://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance- thresholds/appendix-c-mass-rate-lst-look-up-tables.pdf?sfvrsn=2. ______. 2017. Final 2016 Air Quality Management Plan (AQMP). March 3, 2017. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management- plans/2016-air-quality-management-plan/final-2016-aqmp/final2016aqmp.pdf?sfvrsn=15 (accessed May 2022).
______. 2022. 2022 Air Quality Management Plan. December 2, 2022. htp://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management- plans/2022-air-quality-management-plan/final-2022-aqmp/final-2022-aqmp.pdf?sfvrsn=16. ______. 2023. South Coast AQMD Air Quality Significance Thresholds. March 2023. htp://www.aqmd.gov/docs/default-source/ceqa/handbook/south-coast-aqmd-air-quality- significance-thresholds.pdf?sfvrsn=25.
______. 2024. South Coast AQMD Modeling Guidance for AERMOD. htps://www.aqmd.gov/home/air-quality/meteorological-data/modeling-guidance (accessed February 2024). Southern California Association of Governments (SCAG). 2020.

Connect SoCal (2020 - 2045 Regional Transporta�on Plan/Sustainable Communi�es Strategy). htps://www.connectsocal.org/Pages/Connect-SoCal-Final-Plan.aspx.

Southern California Association of Governments (SCAG). 2016. Demographics and Growth Forecast Appendix. April 2016. Available online: https://scag.ca.gov/sites/main/files/file- attachments/f2016rtpscs_demographicsgrowthforecast.pdf?1606073557. Accessed January 204.
______. 2020. 2020 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS).

Demographics and Growth Forecast Appendix. September 3, 2020. Available online:
https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics- and-growth-forecast.pdf?1606001579. Accessed February 2024. ______. 2021. SCAG 6th Cycle Final RHNA Allocation Plan. Available online:
https://scag.ca.gov/sites/main/files/file-attachments/6th-cycle-rhna-final-allocation- plan.pdf?1623447417. Accessed February 2024.

References

0BExemption Checklist Pursuant to CEQA Guidelines Section15183 151 State Water Resources Control Board (SWRCB). 2024a. GeoTracker. Available online:
https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=pomona+ca.

Accessed January 2024.
______. 2024b. GeoTracker: PFAS Map. Available online:
https://gispublic.waterboards.ca.gov/portal/apps/webappviewer/index.html?id=4feba1766 c224dc99eadea06ef3bd019. Accessed January 2024.

The Engineering ToolBox. 2003a. Decibel. Available at:
https://www.engineeringtoolbox.com/decibel-d_341.html. Accessed January 2024. ______. 2003b. Propagation of Sound Outdoors – Attenuation vs. Distance. Available at:
https://www.engineeringtoolbox.com/outdoor-propagation-sound-d_64.html. Accessed January 2024.

United States Department of Agricultural, Natural Resources Conservation Service (USDA NRCS). 2023. Web Soil Survey. Available at:
https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx. Accessed February 2024.

United States Environmental Protection Agency (USEPA). 2016. Criteria Air Pollutants. Available online: https://www.epa.gov/criteria-air-pollutants. Accessed January 2024. ______. 2023a. Climate Change Indicators: Global Greenhouse Gas Emissions. Last Modified: July 21, 2023. https://www.epa.gov/climate-indicators/climate-change-indicators-global- greenhouse-gas-emissions (accessed August 2023).
______. 2023b. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2021. April 15, 2023. https://www.epa.gov/system/files/documents/2023-04/US-GHG-Inventory-2023-Main- Text.pdf. (accessed August 2023).
______. 2024a. “Criteria Air Pollutants.” https://www.epa.gov/criteria-air-pollutants (accessed February 2024).
______. 2024b. Energy Units Basics. https://www.eia.gov/kids/what-is-energy/energy-units- basics.php#:~:text=1%20gallon%20of%20finished%20motor,parts%20per%20million)%20%3 D%20138%2C500%20Btu (accessed February 2024).

United States Fish and Wildlife Service (USFWS). 2023a. Critical Habitat Portal. Available at:
http://criticalhabitat.fws.gov. Accessed February 2024. ______. 2023b. Information for Planning and Consultation (IPaC). Available at:
https://ipac.ecosphere.fws.gov/. Accessed February 2024.

United States Geological Survey (USGS). 2021. Topo View. [online map database]. https://ngmdb.usgs.gov/topoview/. Accessed February 2024.

Veneklasen Associates, Inc. 2024. 1707 Towne Site Exterior Noise and Exterior Facade Acoustical Analysis. April.

West Valley Planning Agency Airport Land Use Commission. 1981. Cable Airport Comprehensive Airport Land Use Plan. Available online:
http://www.sbcounty.gov/Uploads/lus/Airports/Cable.pdf. Accessed December 2023.

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List of Preparers
Rincon Consultants, Inc. prepared this Exemption Initial Study Checklist under contract to the City of Pomona. Vinny Tam, MURP, AICP is the Senior Planner for the City of Pomona and oversaw the project planning efforts. Persons involved in data gathering analysis, project management, and quality control include the following.

Rincon Consultants
Deanna Hansen, Principal in Charge
Ryan Luckert, Project Manager
Lauren Reese, Assistant Project Manager
Justin Ramsthaler, Environmental Planner
Michael Stewart, PE, Senior Air Quality Specialist
Aaron Rojas Jr., Air Quality and GHG Specialist
Greg Ainsworth, Natural Resources Director
Anastasia Ennis, M.S., Supervising Biologist
Amy Leigh Trost, Biologist
Kyle Pritchard, Noise Specialist
Christopher E. Duran, Cultural Resources Principal
Rachel Perzel, Architectural Historian/Cultural Resource Program Manager Andrea Ogaz, MA, RPA, Archaeologist
Ashley Losco, MHP, Architectural Historian
Ganddini Group, Inc.

Giancarlo Ganddini, PE, PTP, Principal
Tom Huang, TE, Transportation Planner