Applicant
Verification:
City of Santa Clarita
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conservation organization (e.g., Friends of Santa Clara River) to be used in restoration projects. The Applicant shall provide the City with documentation of the seeds use.
MM BIO-2 Pre-construction Wildlife Survey. Prior to issuance of a grading permit, a qualified biologist (the Applicant shall submit the qualifications of the biologist to the City for review and approval) shall conduct a survey of the proposed impact areas and 50-foot buffer within 72 hours of the proposed activities. Any coastal whiptail, Southern California
legless lizard, California glossy snake, or Blainville’s horned lizard found would be relocated to a City-approved off-site location in suitable habitat for each species. If a San Diego desert woodrat midden is discovered during the survey, then the biologist would methodically relocate the midden material to suitable habitat (dense shrubs) within 50 feet of its location and outside of the project disturbance limits. The procedure would be implemented at a rate that would allow for the woodrat to flush from the midden. The results of the survey would be documented in a letter report to be submitted to the City.
Retain a City-
approved project
biologist
to ensure
compliance with
biological resource
mitigation measures
Prior to issuance of
grading permits
Implementation:
Applicant
Verification:
City of Santa Clarita
MM BIO-3 Biological Monitoring. Prior to the issuance of a grading permit, the Applicant shall submit the qualifications of the biologist(s) to the City for review and approval. The Applicant shall fund a City-approved Biological Monitor during project construction to monitor construction activities and to ensure compliance with all mitigation measures.
The Biological Monitor shall be present on-site during all native vegetation removal and initial ground-disturbing activities in undeveloped areas. Each day, before project activities begin, the Biological Monitor shall be responsible for conducting a pre-construction clearance survey and any wildlife (common or special-status) would be relocated off-site to a City-approved area.
With regard to the Crotch’s bumble bee only, if construction activity would impact the
6.04 acres of potential foraging and nesting habitat (native vegetation communities) during the Crotch’s bumble bee nesting period (February 1 through October 31), the Biological Monitor shall conduct a pre-construction survey for Crotch’s bumble bee within the aforementioned 6.04 acres of natural vegetation area prior to the start of ground- disturbing construction activities within that 6.04 acres occurring during the Crotch’s bumble bee nesting period (February 1 through October 31). The survey shall ensure that no nests for Crotch’s bumble bee are located within that 6.04-acre area. The pre- construction survey shall be based on recommendations described in the “Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species,” released by CDFW on June 6, 2023, or the most current at the time of construction.
The focused survey shall be performed by a Biological Monitor with a CDFW-issued Scientific Collection Permit (SCP) in surveying for bumble bees and include at least three (3) survey passes that are not on sequential days or in the same week, preferably spaced two to four weeks apart. The timing of these surveys shall coincide with the Colony Active Period (April 1 through August 31 for Crotch’s bumble bee). Surveys may occur between 1 hour after sunrise and 2 hours before sunset. Surveys shall not be conducted during wet conditions (e.g., foggy, raining, or drizzling) and surveyors shall wait at least 1 hour following rain. Surveys may be conducted earlier than April 1 if other bees or butterflies are flying in the native vegetation communities on the project site.
Surveys shall not be conducted when it is windy (i.e., sustained winds greater than 8 mph). Within non-developed habitats, the Biological Monitor shall look for nest resources Retain a City-
approved project
biologist
to ensure
compliance with
biological resource
mitigation measures
Prior to issuance of
grading permits
Implementation:
Applicant
Verification:
City of Santa Clarita
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Parties
suitable for bumble bee use. Ensuring that all nest resources receive 100 percent visual coverage, the biologist shall watch the nest resources for up to five minutes, looking for exiting or entering worker bumble bees. Worker bees should arrive and exit an active nest site with frequency, such that their presence would be apparent after five minutes of observation. If a bumble bee worker is detected, then a representative shall be identified to species. If a nest is suspected, the Biological Monitor can block the entrance of the possible nest with a sterile vial or jar until nest activity is confirmed (no longer than 30 minutes).
Identification shall include the SCP-permitted Biological Monitor netting/capturing the representative bumble bee in appropriate insect nets, per the protocol in U.S. National Protocol Framework for the Inventory and Monitoring of Bees. The bee shall be placed in a clear container for observation and photographic documentation if able. The bee shall be photographed using a macro lens from various angles to ensure recordation of key identifying characteristics. If bumble bee identifying characteristics cannot be adequately captured in the container due to movement, the container shall be placed in a cooler with ice until the bumble bee becomes inactive (generally within 15 minutes). Once inert, the bumble bee shall be removed from the container and placed on a white sheet of paper or card for examination and photographic documentation. The bumble bee shall be released into the same area from which it was captured upon completion of identification.
Based on implementation of this method on a variety of other bumble bee species, they become active shortly after removal from the cold environment, so photography must be performed quickly.
If Crotch’s bumble bee nests are not detected, no further mitigation would be required.
The mere presence of foraging Crotch’s bumble bees would not require implementation of additional minimization measures because they can forage up to 10 kilometers from their nests. If nest resources occupied by Crotch’s bumble bee are detected within the construction area, no construction activities shall occur within 100 feet of the nest, or as determined by the SCP-permitted Biological Monitor through evaluation of topographic features or distribution of floral resources. The nest resources shall be avoided for the duration of the Crotch’s bumble bee nesting period (February 1 through October 31).
Outside of the nesting season, it is assumed that no live individuals would be present within the nest as the daughter queens (gynes) usually leave by September, and all other individuals (original queen, workers, males) die.
A written survey report shall be submitted to the City within 30 days of the pre- construction survey. The report shall include survey methods, weather conditions, and survey results, including a list of insect species observed and a figure showing the locations of any Crotch’s bumble bee nest sites or individuals observed. The survey report shall include the qualification/resume of the SCP-permitted Biological Monitor for identification of photo vouchers, detailed habitat assessment, and photo vouchers. If Crotch’s bumble bee nests are observed, the survey report shall also include recommendations for avoidance, and the location information shall be submitted to the California Natural Diversity Database (CNDDB) at the time of, or prior to, submittal of the survey report.
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MM BIO-4 Demarcation of Disturbance Limits. Prior to commencement of earthwork in the undeveloped portion of the project site, the construction limits shall be clearly demarcated (e.g., installation of flagging or temporary high-visibility construction fence), as recommended by the Biological Monitor. All construction activities including equipment staging and maintenance shall be conducted within the marked disturbance limits to prevent inadvertent disturbance to sensitive vegetation communities outside the limits of work. The flagging shall be maintained throughout construction.
Retain a City-
approved project
biologist to ensure
compliance with
biological resource
mitigation measures
Prior to issuance of
grading permits,
during construction
Implementation:
Applicant and
Construction
Contractor
Verification:
City of Santa Clarita
MM BIO-5 Stormwater Pollution Prevention Plan. Prior to issuance of a grading permits for construction activity that would require more than one acre of earthwork, the project developer shall develop a Stormwater Pollution Prevention Plan (SWPPP) that provides for require erosion and sediment control Best Management Practices (BMPs) to be implemented during construction activities. The SWPPP shall be submitted to the City for review and approval prior to the issuance of a grading permit. For construction activities on individual lots that are less than one acre in size, a site-specific listing of BMPs shall be prepared using appropriate and feasible measures included in the primary SWPPP document and shall be submitted to the City for review and approval prior to the issuance of a grading permit. The site-specific SWPPP shall include measures including, but not be limited to: (1) the regular use of water trucks or other means of site irrigation to minimize fugitive dust during earthmoving and prevent fugitive dust from escaping the property boundary; (2) prohibition of vehicle fueling on-site; and (3) requirement that secondary containment be used for the temporary use all hazardous materials during construction activities and such containment shall be located as far as feasible from jurisdictional resources. Subsequent to approval by the City, the requirements of the SWPPP shall be implemented prior to and during construction activities, as specifically required in the SWPPP.
At the culvert in the northwest portion of the project site, a silt fence barrier shall be constructed around it prior to the start of construction activities. Wooden posts supporting the silt fence shall be spaced 2 to 3 feet apart and driven securely into the ground; a minimum of 18 to 20 inches deep. The bottom edge of the silt fence is required to extend across the bottom of the trench and the trench shall be backfilled and compacted to prevent stormwater and sediment from discharging underneath the silt fence. Silt fences shall be inspected weekly and immediately after storm events to ensure they are intact and that there are no gaps where the fence meets the ground or tears along the length of the fence. If gaps or tears are found during the inspection, the fabric is required to be repaired or replaced immediately.
Retain a City-
approved project
biologist to ensure
compliance with
biological resource
mitigation measures
Prior to issuance of
grading permits
Implementation:
Applicant
Verification:
City of Santa Clarita
MM BIO-6 Invasive Plant Species Prevention. The project shall not include invasive plant species listed on the California Invasive Plant Council inventory in project landscaping palettes.
The City shall review and approve project landscape palettes to ensure that invasive plant species are excluded. In addition, to prevent the spread of invasive plant species during construction and until the establishment of common landscaped areas associated with the project (for a period of up to 5 years):
• All equipment shall be washed prior to entering and prior to leaving the project site in an upland location where any seed material from invasive species will be contained.
Prevent spread of
invasive plant species
to ensure compliance
with biological
resource mitigation
measures
Prior to issuance of
grading permits,
during construction
Implementation:
Applicant
Verification:
City of Santa Clarita
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• All vegetative material removed from the project impact footprint shall be transported in a covered vehicle and will be disposed of at a certified disposal site.
MM BIO-7 Exterior Permanent Lighting. To address indirect impacts to special-status wildlife due to lighting, exterior lighting associated with final project development shall be designed to be minimal (only as needed for security and safety) to lessen the attraction of birds, bats, and other sensitive wildlife species.
Design exterior lights
to be minimal
Prior to approval of
building permits
Implementation:
Applicant
Verification:
City of Santa Clarita
MM BIO-8 Nesting Bird Avoidance. Project construction shall be conducted in compliance with the conditions set forth in the MBTA and California Fish and Game Code to protect active bird/raptor nests. To the maximum extent feasible, vegetation removal shall occur during the non-breeding season for nesting birds (generally late September to early March) and nesting raptors (generally early July to late January) to avoid impacts to nesting birds and raptors. If the project requires that work be initiated during the breeding season for nesting birds (March 1–September 30) and nesting raptors (February 1–June 30), in order to avoid direct impacts on active nests, a pre-construction survey shall be conducted in the study area (defined as a 500-foot buffer around the project site) by qualified biologists (someone who has more than 3 years of experience conducting nesting bird surveys in the project region) for nesting birds and/or raptors within 3 days prior to project activities. If the biologist does not find any active nests within or immediately adjacent to the impact areas, the vegetation clearing/construction work shall be allowed to proceed.
If the biologist finds an active nest within or immediately adjacent to the construction area and determines that the nest may be impacted or breeding activities substantially disrupted, the biologist shall delineate an appropriate buffer zone around the nest, depending on the sensitivity of the species and the nature of the construction activity.
To protect any nest site, the following restrictions to construction activities shall be required until nests are no longer active, as determined by a qualified biologist:
1) clearing limits shall be established within a buffer around any occupied nest; and 2) access and surveying shall be restricted within the buffer of any occupied nest, unless otherwise determined by a qualified biologist. The buffer shall be up to 300 feet for non- raptor nesting birds and up to 500 feet for nesting raptors, based upon the biologist’s determination of potential effect of project activities on the nest. Construction can proceed into the buffer when the qualified biologist has determined that the nest is no longer active.
Conduct vegetation
removal and site
distance between
September 30 and
January 31. If this is
not possible, conduct
preconstruction
nesting bird and
raptor surveys.
During construction
activities on the
project site, between
February 1 and
September 30.
Implementation:
Applicant and
Construction
Contractor
Verification:
City of Santa Clarita
MM BIO-9 Protected Tree Replacement. The Applicant would comply with the City of Santa Clarita Oak Tree Ordinance and would obtain an oak tree permit prior to the issuance of the grading permit for the project. Conditions of the oak tree permit may include the payment of a fee, planting of replacement trees on the project site, or donation of boxed trees to the City or other approved public agency to be used elsewhere in the city.
The nine trees to be removed shall be replaced by a tree of the same species at a ratio determined by the Urban Forestry Division of the City of Santa Clarita, with a minimum of 55 replacement trees required. All replacement trees shall be at least a 24‐gallon specimen in size and measure 2 inches or more in diameter, as measured from Obtain an oak tree
permit, and submit
quarterly tree
inspection reports
prepared by a City-
approved oak tree
expert
Prior to issuance of
grading permits, and 2
years following
planting of
replacement trees
Implementation:
Applicant
Verification:
City of Santa Clarita
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approximately 4 feet above the base. Replacement trees shall be certified as being grown from a seed source collected in Los Angeles County.
For replacement trees planted on the project site, the Applicant shall be responsible for submitting quarterly tree inspection reports to the City prepared by a certified oak tree expert that shall be required to document the condition of the trees. The inspection and reporting would be required for 2 years following the planting of the replacement trees.
Any tree that fails during the 2-year period would be replaced by a 24‐gallon specimen of the same species and then monitored for an additional 2 years.
Cultural Resources
MM CR-1 Archaeological Monitoring. Prior to ground-disturbing activities, the Applicant and/or subsequent responsible parties should retain a Principal Investigator/Archaeologist, meeting the Secretary of the Interior’s Standards, and with experience in California prehistoric and historic resources (experience within Los Angeles County preferred), to complete the following: compose a Cultural Resource Monitoring and Inadvertent Discovery Plan (Plan), manage archaeological monitoring, and address any inadvertent discoveries identified during project implementation. The Plan shall cover both development of the 35.2-acre project site as well as any necessary off-site improvements (e.g., transportation and infrastructure improvements) associated with the project. Proof of retainment of the Principal Investigator/Archaeologist should be provided to the City prior to the granting of a grading permit. The purpose of the Plan is to outline archaeological monitoring protocols and a program of treatment and mitigation in the case of an inadvertent discovery of archaeological resources during ground-disturbing phases and to provide for the proper identification, evaluation, treatment, and protection of any archaeological resources in accordance with CEQA throughout the duration of the project. Existence and importance of adherence to this Plan should be stated on all project site plans intended for use by those conducting the ground-disturbing activities.
The Principal Investigator/Archaeologist should manage archaeological monitoring conducted by archaeological technicians during initial ground disturbances. Initial excavation is defined as initial construction-related earth moving of sediments from their place of deposition. As it pertains to archaeological monitoring, this definition excludes movement of sediments after they have been initially disturbed or displaced by project- related construction. The retained Principal Investigator/Archaeologist should oversee and establish monitoring efforts as needed (increase, decrease, or discontinue monitoring frequency) based on the observed potential for construction activities to encounter archaeological deposits or material. The archaeological monitor should be responsible for maintaining daily monitoring logs. The requirement for archaeological monitoring should be noted on all construction plans to ensure implementation. Upon completion of all ground-disturbing activities, an archaeological monitoring report should be prepared within 60 days following completion of ground disturbance and submitted to the City for review. This report should document compliance with approved cultural resource mitigation, all monitoring efforts, and include an appendix with daily monitoring logs. The final report should be submitted to the City and the SCCIC.
Retain a qualified
archaeologist, prepare
required Plan, and
conduct monitoring
Prior to
commencement of
construction,
monitoring to occur
during construction
Implementation:
Applicant
Verification:
City of Santa Clarita
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Parties
MM CR- 2 Worker Environmental Awareness Program (WEAP) Training. All construction personnel and monitors who are not trained archaeologists should be briefed regarding unanticipated discoveries prior to the start of ground-disturbing activities. A basic presentation should be prepared and presented by a qualified archaeologist to inform all personnel working on the project about the archaeological sensitivity of the area.
The purpose of the WEAP training is to provide specific details on the kinds of archaeological materials that may be identified during construction of the project and explain the importance of and legal basis for the protection of significant archaeological resources. Each worker should also be instructed on the proper procedures to follow in the event that archaeological resources or human remains are uncovered during ground- disturbing activities. These procedures include work curtailment or redirection, and the immediate contact of the on-call archaeologist and if appropriate, tribal representative.
Necessity of training attendance should be stated on all project site plans intended for use by those conducting the ground-disturbing activities.
Retain a qualified
archaeologist to
create a Worker
Environmental
Awareness Program
Prior to
commencement of
construction
Implementation:
Applicant
Verification:
City of Santa Clarita
MM CR-3 Inadvertent Discovery Clause. In the event that potential prehistoric or historic-era archaeological resources (sites, features, or artifacts) are exposed during construction activities for the project, all construction work occurring within 50 feet of the find shall immediately stop and the Principal Investigator/Archaeologist notified immediately in order to assess of the discovery and determine whether additional study is warranted.
Depending upon the nature of the discovery, the Principal Investigator/Archaeologist may simply record the find and allow work to continue. If the discovery proves potentially significant under CEQA, additional work such as subsurface testing may be warranted.
If the discovery is determined significant under CEQA and avoidance is not feasible, data recovery shall be required. If archaeological resources are discovered or are suspected to be of Native American origin, each of the consulting tribes for the project should also be notified.
In the event that human remains are inadvertently encountered during construction activities, the remains and associated resources shall be treated in accordance with state and local regulations that provide requirements with regard to the accidental discovery of human remains, including California Health and Safety Code Section 7050.5, PRC Section 5097.98, and State CEQA Guidelines Section 15064.5(e). In accordance with these regulations, if human remains are found, the County Coroner must be immediately notified of the discovery. No further excavation or disturbance of the project site or any nearby area (within 100 feet of the find) reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined if the remains are potentially human in origin. If the County Coroner determines that the remains are, or are believed to be, Native American, he or she is required to immediately notify the NAHC. The NAHC must immediately notify those persons it believes to be the most likely descendant from the deceased Native American. The most likely descendant should then complete their inspection and determine, in consultation with the property owner, the treatment and disposition of the human remains.
Immediately cease
work in the vicinity of
an archaeological
resource find and
retain a qualified
archaeologist to
assess the find.
During ground-
disturbing activities
Implementation:
Applicant
Verification:
City of Santa Clarita
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Parties
Geology and Soils
MM GEO-1 Structural Engineering and Setback Requirements. Prior to issuance of a grading permit, the Applicant shall consult a qualified structural engineer regarding the design of structural components (i.e., floor slab support) of the building to reduce adverse impacts associated with fault rupture, strong seismic ground shaking, ground failure, and liquefaction. Design elements of structures for human occupancy should include a setback of 75 feet from the San Gabriel Fault, and pipelines (including gas, water, storm drain, and sewer) shall be constructed to allow flexure (Allan E. Seward Engineering Geology, Inc. 2007).
During construction of the proposed project, the developer shall implement all recommendations provided in the project-specific geotechnical study, including, but not limited to, removal of unsuitable soils and uncertified fills, and over-excavation and recompacting of soils within the project site. Typical hillside grading development and grading ground improvement shall be implemented to withstand the anticipated ground shaking and static and seismic-induced settlement.
Retain a City-
approved structural
engineer to ensure
compliance with
engineering
requirements
Prior to issuance of
building permits and
during construction
Implementation:
Applicant
Verification:
City of Santa Clarita
MM GEO-2 Paleontological Resource Monitoring. The developer shall implement the following:
a. Retain a Qualified Professional Paleontologist: A Project Paleontologist, defined as one who meets the Society of Vertebrate Paleontology standards for a qualified professional paleontologist, should be retained to carry out all regulatory compliance measures and protocols related to paleontological resources.
b. Conduct Worker Training: The Project Paleontologist should develop WEAP training to educate the construction crew on the legal requirements for preserving fossil resources, as well as the procedures to follow in the event of a fossil discovery. This training program should be given to the crew before ground-
disturbing work begins and should include handouts to be given to new workers as needed.
c. Monitor for Paleontological Resources: Full-time monitoring should be required in areas mapped as Holocene and late Pleistocene young alluvium, undivided (Qya) when ground-disturbing activities impact previously undisturbed sediments greater than or equal to 5 feet below ground surface, or in areas mapped as Pleistocene to late Pliocene Saugus Formation, undivided (QTs) (regardless of depth). Monitoring should not be required when ground- disturbing activities impact only artificial fill, previously disturbed sediments, and areas mapped as Qya at depths less than 5 feet below ground surface.
Monitoring should be conducted by a paleontological monitor who meets the standards of the SVP and should be supervised by the Project Paleontologist, who may periodically inspect construction activities to adjust the level of monitoring in response to subsurface conditions. Monitoring efforts can be increased, reduced, or ceased entirely if determined adequate by the Project Paleontologist in consultation with the Applicant and the City. Paleontological monitoring should include inspection of exposed sedimentary units during active excavations within sensitive geologic sediments. The monitor should have authority to temporarily divert activity away from exposed fossils to Prepare and
implement a
Paleontological
Resources Monitoring
and Mitigation Plan
Prior to and during
construction activities
Implementation:
Applicant
Verification:
City of Santa Clarita
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Responsible
Parties
evaluate the significance of the find and, should the fossils be determined significant, professionally and efficiently recover the fossil specimens and collect associated data. The monitor should record pertinent geologic data and collect appropriate sediment samples from any fossil localities. Recovered fossils should be prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological repository (e.g., Natural History Museum of Los Angeles County).
d. Prepare a Paleontological Resources Monitoring Report: Upon conclusion of ground-disturbing activities, the Project Paleontologist overseeing paleontological monitoring should prepare a final paleontological resources monitoring report that documents the paleontological monitoring efforts for the project and describes any paleontological resources discoveries observed and/or recorded during the life of the project. If paleontological resources are curated, the final report and any associated data pertinent to the curated specimen(s) should be submitted to the designated repository. A copy of the final report should be filed with the City.
Hazards and Hazardous Materials
MM HAZ-1 Soil Management Plan. The developer and/or project contractor shall prepare and implement a Soil Management Plan for the removal of any identified contaminated soils and their transportation off-site. The Soil Management Plan shall be prepared in coordination with the City and the Los Angeles County Fire Department (as the Certified Unified Program Agency) and in accordance with all relevant and applicable federal, state, and local laws and regulations that pertain to the transportation and disposal of hazardous materials and waste. The Soil Management Plan shall:
• describe the methodology to identify and manage (reuse or off-site disposal) contaminated soil during soil excavation and/or construction; and • provide protocols for confirmation sampling, segregation and stockpiling, profiling, backfilling, disposal, guidelines for imported soil, and backfill approval from the DTSC Information Advisory on Clean Imported Fill Material.
The Soil Management Plan shall be implemented during project construction.
Prepare and
implement a Soil
Management Plan
Prior to and during
construction activities
Implementation:
Applicant and
Construction
Contractor
Verification:
City of Santa Clarita
Noise
MM NOISE-1 Noise Abatement during Construction of Light Manufacturing Lot. The following noise control and/or sound abatement measures shall be implemented during construction of Lot 5, which is the lot that is planned for the light manufacturing land use:
A. Site Preparation:
1. To the extent practicable, earthwork on the east side of the existing hill on Lot 5 shall start as far east and possible and proceed in an east-to-west direction to take advantage of the distance between the site preparation activity and the Action Family Rehab facility and the sound-blocking effects of the unworked terrain that should naturally occlude line-of-sight between this construction process and this noise-sensitive land use to the northwest.
Approach earthwork
as prescribed on the
light manufacturing
lot; install specified
noise barriers during
construction
During construction,
specifically during the
site preparation,
grading, and paving
phases of the light
manufacturing lot
Implementation:
Applicant and
Construction
Contractor
Verification:
City of Santa Clarita
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Consistent with acoustical principles for noise reduction afforded by such natural features, this line-of-sight occlusion should yield the needed decibel reduction at this receptor and result in 8-hour Leq exposure levels that are compatible with FTA guidance (80 dBA).
2. Should line-of-sight occlusion not be feasible per A.1 above, then along or within the property line where the project site adjoins the Action Rehab facility, a 20-foot-tall temporary barrier shall be installed made of typical outdoor-appropriate plywood sheeting, acoustical sound blankets, or other materials (having sound transmission class [STC] 20 or better) to ensure line-of-
sight occlusion between operating project construction equipment and the Action Family Rehab land use.
B. Grading and Paving: An appropriate temporary barrier shall also be constructed prior to the grading and paving phases and shall remain in place until these phases of the construction are completed. The grading and phasing barrier shall be at least a 12-foot- tall temporary barrier made of typical outdoor-appropriate plywood sheeting, acoustical sound blankets, or other materials (having sound transmission class [STC] 20 or better) along or adjacent to the property line where the project site adjoins the Action Family Rehab facility,
Tribal Cultural Resources
MM TCR-1 Tribal Monitoring. The project developer shall retain a professional Tribal Monitor procured by the Fernandeño Tataviam Band of Mission Indians and San Fernando Band of Mission Indians (Tribes) to observe all ground-disturbing activities including, but not limited to, clearing, grubbing, grading, excavating, digging, trenching, plowing, drilling, tunneling, quarrying, leveling, driving posts, auguring, blasting, stripping topsoil or similar activity. Tribal Monitoring Services shall continue until confirmation is received from the project developer, in writing, that all scheduled activities pertaining to Tribal Monitoring are complete. If the project’s scheduled activities require the Tribal Monitor to leave the project for a period of time and return, confirmation shall be submitted to the Tribes by the project developer, in writing, upon completion of each set of scheduled activities and reasonable notice shall be submitted to the Tribes by project developer, in writing, prior to the start of each set of scheduled activities. If tribal cultural resources are encountered, the Tribal Monitor will have the authority to request that ground-disturbing activities cease within 60 feet of discovery and a qualified archaeologist meeting Secretary of Interior standards retained by the project developer as well as the Tribal Monitor shall assess the find.
Tribal Monitor
procured by the
Fernandeño Tataviam
Band of Mission
Indians and San
Fernando Band of
Mission Indians
(Tribes) to observe all
ground-disturbing
activities
Prior to and during
construction
Implementation:
Applicant
Verification:
City of Santa Clarita
MM TCR-2 Disposition and Treatment of Inadvertent Discoveries of Tribal Cultural Resources.
The City of Santa Clarita and/or developer shall, in good faith, consult with the Fernandeño Tataviam Band of Mission Indians and San Fernando Band of Mission Indians on the disposition and treatment of any Tribal Cultural Resource encountered during all ground disturbing activities.
Fernandeño Tataviam
Band of Mission
Indians and San
Fernando Band of
Mission Indians
should Tribal Cultural
Resources be
encountered
During ground-
disturbing activities
Implementation:
Applicant
Verification:
City of Santa Clarita
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A-1
October 8. 2024
Justin Sauder
Associate Planner
City of Santa Clarita, Planning Division
23920 Valencia Boulevard, Suite 302
Santa Clarita, California 91355
Re: Response to Comments Received on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the Riverview Development Project
Dear Justin,
In accordance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines, the City of Santa Clarita (City) prepared a Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed Riverview Development Project (project), located at 22500 Soledad Canyon Way (Assessor’s Parcel Number [APN] 2836-011-018). The project site is south of Soledad Canyon Road and encompasses 35.2 acres. If approved by the City, the project would result in the construction and operation of 318 single-family residential units and a 126,790-square-foot light manufacturing facility and associated parking.
On June 25, 2024, the City distributed a Notice of Intent (NOI) to the public and interested agencies and circulated the Draft IS/MND for public review. The NOI indicated the Draft IS/MND was available for review and comment for a total of 30 days (June 25, 2024, through July 16, 2024), and announced that a public hearing on the project would be held by the Monrovia Planning Commission on July 16, 2024.
Attachment A provides responses to the individual comments received during the public comment period.
During the public review period, the City received six comment documents (letters and emails) on the Draft IS/MND. The comment documents included comment letters from California Department of Fish and Wildlife (CDFW), Department of Toxic Substances Control (DTSC), Los Angeles County Sheriff’s Department, Los Angeles County Sanitation Districts (LASAN), Lozeau Drury LLP, and South Coast Air Quality Management District (SCAQMD). Subsequently, on September 23, 2024, Lozeau Drury LLP submitted a letter withdrawing their previous comments of July 16, 2024, and recommending approval of the project. The comment documents, excluding the Lozeau Drury LLP communications, are included as Attachment B to this letter.
The City, as the Lead Agency, is required to consider agency and public comments on a CEQA document as part of the decision process to approve a project. According to State CEQA Guidelines 15073.5(b), the two conditions which require an IS/MND to be recirculated are as follows:
(1) A new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or
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2 (2) The lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required.
In accordance with the State CEQA Guidelines 15073.5(c), recirculation is not required under the following circumstances:
(1) Mitigation measures are replaced with equal or more effective measures pursuant to Section 15074.1.
(2) New project revisions are added in response to written or verbal comments on the project’s effects identified in the proposed negative declaration which are not new avoidable significant effects.
(3) Measures or conditions of project approval are added after circulation of the negative declaration which are not required by CEQA, which do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect. (4) New information is added to the negative declaration which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration.
In response to the comments, several areas of the IS/MND have been expanded and/or clarified. As allowed in the State CEQA Guidelines 15073.5(c)(4), new information has been added to the IS/MND which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration. These clarifications and additions are shown in the Final IS/MND in strikeout (strikeout; for removed text) and underline (underline; for added text). In addition, two biological resource mitigation measures have been revised/replaced with equal or more effective measures pursuant to the State CEQA Guidelines Section 15073.5(c)(1). These revisions are made specifically to Mitigation Measures MM-BIO-1 (Pre- Construction Rare Plant Survey and Conservation) and MM-BIO-3 (Biological Monitoring). The revisions made to these mitigation measures provide for additional and more substantial monitoring efforts that are not required by CEQA. These efforts do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect. They have been determined to be equal to and/or more effective in avoiding potentially significant biological resource impacts that were identified in the Draft IS/MND. Attachment C presents the additional information used to develop the Final IS/MND.
None of the comments received during the comment period present new information pertaining to environmental issues that would result in significant changes to the environmental analysis conclusions contained in the Draft IS/MND. Specifically, no new significant effects have been identified nor has the City determined that proposed mitigation measures or project revisions would not reduce potential effects to less than significant; all potential impacts can be reduced to less than significant. Therefore, none of the conditions for recirculation of the IS/MND, as specified above in State CEQA Guidelines 15073.5(b), have been met. Lastly, no evidence has been provided demonstrating that the IS/MND was inadequate.
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3 While neither CEQA nor the State CEQA Guidelines requires detailed responses to the comments received during the public review period for a draft IS/MND, the comment and response table included as Attachment A provides responses to the individual comments for the City’s consideration during the deliberation regarding the proposed project.
Sincerely,
Bobbette Biddulph, Senior Project Manager
SWCA Environmental Consultants
Attachments:
Attachment A. Response to Comments Received on the June 2024 Draft IS/MND Attachment B. Comments Received on the June 2024 Draft IS/MND Attachment C. Additional Information Developed to Support the Final IS/MND
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ATTACHMENT A
Response to Comments Received on the June 2024 Draft IS/MND Riverview Development Project
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Response to Comments Received on June 2024 Draft IS/MND Comment Summary Response
Comment Document 1: Department of Toxic Substances Control (DTSC) (July 3, 2024) DTSC states that, if the proposed project requires buildings or other structures to be demolished, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos-containing materials, and polychlorinated biphenyl caulk.
DTSC recommends for the removal, demolition, and disposal of any of these chemicals to be conducted in compliance with California environmental regulations and policies.
Buildings and other structures and built surfaces (e.g., pavement) planned for demolition require an asbestos-containing material survey, in accordance with the local South Coast Air Quality Management District Rule 1403 requirements and the U.S.
Environmental Protection Agency National Emission Standards for Hazardous Air Pollutants regulations for asbestos. A lead-based paint survey will also be required to evaluate the applicability of the lead in construction standard Title 8 California Code of Regulations Section 1532.1, which applies to all construction work including renovation and demolition activities where an employee may be occupationally exposed to lead. In addition, other hazardous materials which may be present within buildings also require proper clean-up, handling, and disposal in accordance with Universal Waste Rules.
While these are standard requirements, the City will also provide for a condition of approval stating these requirements to ensure the proposed development complies with these standards.
DTSC recommends that all imported soil and fill material be tested to ensure that they meet screening levels outlined in the Preliminary Endangerment Assessment Guidance Manual. DTSC’s Information Advisory Clean Imported Fill Material Fact Sheet and the Human and Ecological Risk Office webpage are also listed as additional reference materials.
The project would require approximately 500,000 cubic yards of cut and approximately 420,000 cubic yards of fill. Grading would consist of lowering the isolated hill area at the western part of the site and raising most of the remaining site. While existing site soils are planned to be used to the extent feasible, implementation of Mitigation Measure MM GEO-1 would result in over-excavation and replacement of soils to specified depths that would ensure only engineered fill would be used within the project site to address expansive soils. Through a condition of approval, the City will require that imported soil and fill material be tested to ensure that they meet screening levels outlines in the Preliminary Endangerment Assessment Guidance Manual noted by DTSC.
Comment Document 2: Los Angeles County Sanitation Districts (LASAN) (July 10, 2024) The comment letter notes that LASAN received the NOI for the IS/MND for the project and that previous comments submitted by LASAN in correspondence dated September 15, 2023, and enclosed a copy of those previous comments.
This comment is introductory in nature and does not require a response. The comments from the September 15, 2023 letter are also responded to herein to provide a thorough record.
LASAN notes that in Section 1.4.5 Utility and Drainage Improvements, Page 9, the second paragraph states incorrectly, “Prior to issuance of the first building permit, the site would be required to be annexed into the County Sanitation District, per Development Review Committee Comments.” LASAN clarifies that the parcel is already annexed into the Santa Clarita Valley Sanitation District.
This error has been corrected in the Final IS/MND. This change does not affect the environmental analysis contained in the document.
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Comment Summary Response
The proposed project is located approximately 0.5 mile from the Saugus Water Reclamation Plant, which is owned and operated by LASAN. As such, the MND should consider and evaluate, if necessary, any potential impacts on the proposed project.
As decided by the California Supreme Court, CEQA generally does not require the analysis of the existing environment, in this case the Saugus Water Reclamation Plant, on the project nor the future users or residents [California Building Industry Association v. Bay Area Air Quality Management District (S213478, December 17, 2015)]. An agency must analyze how environmental conditions might adversely affect a project's residents or users only where the project itself might worsen existing environmental hazards in a way that will adversely affect them. This is not the case for the project under consideration. No revisions to the IS/MND are necessary as a result of this comment.
All other information concerning LASAN facilities and sewerage service contained in the document is current.
As LASAN concurs with the analysis contained in the IS/MND, no revisions or further response is required.
In the September 15, 2023, attachment to the July 10, 2024, letter, LASAN notes that wastewater flow from the proposed project would discharge to the LASAN’s Soledad Canyon Trunk Sewer. As such, LASAN advises that direct connections to the trunk sewer that are 6 inches or less in diameter require a Trunk Sewer Connection Permit issued by LASAN. Direct connections to the trunk sewer that are 8 inches or larger in diameter require submittal of Sewer Plans for review and approval by LASAN.
This comment is noted and will be provided to the project developer. This comment does not conflict with the information presented in the Draft IS/MND. No revisions to the IS/MND are necessary as a result of this comment.
In the September 15, 2023, attachment to the July 10, 2024, letter, LASAN provides information regarding LASAN’s wastewater treatment facilities. Specifically, the comments states that the Santa Clarita Valley Joint Sewerage System has a capacity of 28.1 million gallons per day (mgd) and processes an average recycled flow of 18.4 mgd.
This comment does not conflict with the information presented in the Draft IS/MND. No revisions to the IS/MND are necessary as a result of this comment.
In the September 15, 2023, attachment to the July 10, 2024, letter, LASAN determines that the proposed project is expected to increase average wastewater flow to 89,402 gallons per day.
This comment provides additional information about LASAN’s calculations related to anticipated wastewater flows anticipated by the project. This information does not conflict with the information provided in the IS/MND regarding anticipated wastewater flows. As noted in the IS/MND, it is not anticipated that the project would require the construction of new wastewater treatment facilities, as the system has sufficient capacity to accommodate additional growth. This is affirmed by the will-serve letter received from the LASAN and included as Appendix K to the IS/MND and this subsequent comment letter.
In the September 15, 2023, attachment to the July 10, 2024, letter, LASAN states the City is required to pay connection fees to LASAN, to be determined by LASAN based on the project’s anticipated impact to the sewerage system.
This comment is noted and will be provided to the project developer.
In the September 15, 2023, attachment to the July 10, 2024, letter, LASAN advises the City that the comments made do not constitute a guarantee of wastewater service but show that LASAN intends to provide this service up to legally permitted levels, consistent with the Southern California Association of Governments regional growth forecast.
This comment is noted and will be provided to the project developer.
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Comment Document 3: California Department of Fish and Wildlife (CDFW) (July 11, 2024) CDFW states that the project may result in temporal or permanent loss of suitable nesting and foraging habitat for Crotch’s bumble bee (Bombus crotchii). The comment goes on to state that the Draft IS/MND relies on limited surveys outside the time frame (April to August) for highest detection probability and does not discuss the moderate potential for Crotch’s bumble bee to be foraging and/or nesting within the project site.
CDFW does not provide evidence or definitive proof that this impact will occur. Helix Environmental Planning conducted surveys for the species in 2024 using CDFW’s guidelines within the recommended survey period, and the results were negative1 (see Attachment C). Therefore, the species is expected to be absent from the project site.
The surveys completed for the project found few small mammal burrows, but no perennial bunch grasses or thatched annual grasses, underbrush piles, old bird nests, and dead trees or hollow logs were observed. As such, nesting opportunities were very low on the project site.
The project would impact 6.04 acres of vegetation communities (Eriogonum fasciculatum var. foliolosum-Hesperoyucca whipplei Association; Artemisia californica, Artemisia californica- Eriogonum fasciculatum Association; Adenostoma fasciculatum- Eriogonum fasciculatum Association) that support floral resources that are known to be used by the species, with Eriogonum fasciculatum being associated as a nectar source.
However, based on surveys in the Santa Clarita Valley over the past 2 years, there is evidence that the species has a strong preference for sage (Salvia ssp.) and deerweed (Acmispon glaber)
2 (see Attachment C). A few white sage (Salvia apiana) were observed but did not rise to the level to be included as co-dominant in any of the associations. The project is within a region that has abundant natural open space areas in the hills surrounding the Santa Clarita Valley that support floral resources used by the species. Some of these areas are managed by Mountains Recreation and Conservation Authority, Angeles National Forest, and State Parks. As such, the loss of 6.04 acres of foraging habitat is not expected to be significant.
CDFW states that ground-disturbing activities may cause death or injury of adults, eggs, and larva; burrow collapse; nest abandonment; and reduced nest success for Crotch’s bumble bee. The comment goes on to request that a mitigation measure should be incorporated in the Draft IS/MND to include focused surveys to confirm presence/absence of Crotch’s bumble bee on the project site prior to project activities.
CDFW does not provide evidence that this impact is likely, or that such an impact would be significant. Helix Environmental Planning conducted surveys for the species in 2024 using CDFW’s guidelines within the recommended survey period, and the results were negative
3 (see Attachment C). As such, the species is expected to be absent from the project site.
While there is no evidence of a potentially significant impact and the City maintains the impact would be less than significant without mitigation, Mitigation Measure MM-BIO-3 has been revised in the Final IS/MND to provide preconstruction surveying and monitoring for the Crotch’s bumble bee prior to ground disturbance.
In conclusion, the project would not create a significant impact related to the Crotch’s bumble bee. While this impact would be less than significant prior to mitigation, the City is revising Mitigation Measure MM-BIO-3 in the Final IS/MND to provide assurances that
1 Helix Environmental Planning. 2024. Summary of the 2024 Crotch’s Bumble Bee Focused Survey Results for the Riverview Project. Memorandum from L. Singleton (Senior Project Manager, Helix Environmental Planning) to P. Vanek (Integral Communities). August 26, 2024. 2 Dudek. 2024. Dudek Response to California Department of Fish and Wildlife Comment for the Riverview Development Project, Mitigated Negative Declaration (SCH#2024061060). Memorandum from M. Cady (Senior Biologist, Dudek) to D. Peterson (Senior Planner, City of Santa Clarita). September 16, 2024. 3 Helix Environmental Planning. 2024. Summary of the 2024 Crotch’s Bumble Bee Focused Survey Results for the Riverview Project. Memorandum from L. Singleton (Senior Project Manager, Helix Environmental Planning) to P. Vanek (Integral Communities). August 26, 2024.
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preconstruction surveying and monitoring would be integrated into the construction process.
CDFW requests that the Draft IS/MND be amended to provide a discussion on habitat suitability for Crotch’s bumble bee within and adjacent to the project site. The comment also recommends two potentially feasible mitigation measures:
1) The project proponent shall retain a qualified entomologist with the appropriate handling permits to conduct focused surveys. Focused surveys shall follow CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023). Focused surveys shall also be conducted throughout the entire project site during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the City prior to implementing project ground-disturbing activities. 2) If Crotch’s bumble bee is detected the project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to California Fish and Game Code 2080 et seq). The project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The project proponent shall provide a copy of a fully executed take authorization to the City prior to implementing project ground-disturbing activities and vegetation removal.
Additional information has been added to the IS/MND to address the Crotch’s bumble bee. Helix Environmental Planning conducted surveys for Crotch’s bumble bee in July and August 2024 using CDFW’s guidelines within the recommended survey period, and the results were negative4 (see Attachment C). As such, the species is expected to be absent from the project site and would not be impacted by the project. Regardless, Mitigation Measure MM-BIO-3 has been revised as discussed above.
CDFW states that project ground-disturbing activities would result in loss of suitable habitat, loss of population, and direct mortality of slender mariposa lily (Calochortus clavatus var. gracilis). The comment goes on to state that the protocol surveys and seed collection proposed by Mitigation Measure MM-BIO-1 is not sufficient to adequately offset project-related impacts, as it does not include specific performance standards and actions pertaining to management of mitigation actions. CDFW also expresses concern that the Draft IS/MND does not provide a justification as to why a count of 20 individuals is the used as the minimum threshold. CDFW recommends that additional compensatory mitigation should be provided if any individual slender mariposa lily is observed.
The density of the shrub vegetation in the area with suitable habitat for the species (limited to the knoll on the western end of the site) is expected to limit the number of individuals that could be impacted.5 CDFW’s own micro-habitat description for the species describes it occurring on shaded foothill canyons and often on grassy slopes within other habitats, which are not present in the site. 6 Slender mariposa lily is not a
listed species, so impacts are considered by the loss to the species as a whole and not on the individual level. The California Natural Diversity Database (CNDDB) has records of the species throughout the Santa Clarita Valley, with locations that have hundreds of individuals. Therefore, the loss of a few individuals would not reduce the number of individuals such that the species population would be compromised, and thus, the loss would be considered a less-than-significant impact under CEQA.
As stated in the State CEQA Guidelines Section 15065 (Mandatory Findings of Significance), the significance of the impacts are considered in the following context: (1) substantially degrade the quality of the environment, (2) substantially reduce the habitat of a fish or wildlife species, (3) cause a fish or wildlife population to drop below self-
4 Helix Environmental Planning. 2024. Summary of the 2024 Crotch’s Bumble Bee Focused Survey Results for the Riverview Project. Memorandum from L. Singleton (Senior Project Manager, Helix Environmental Planning) to P. Vanek (Integral Communities). August 26, 2024. 5 Dudek. 2024. Dudek Response to California Department of Fish and Wildlife Comment for the Riverview Development Project, Mitigated Negative Declaration (SCH#2024061060). Memorandum from M. Cady (Senior Biologist, Dudek) to D. Peterson (Senior Planner, City of Santa Clarita). September 16, 2024. 6 California Department of Fish and Wildlife. 2024. California Natural Diversity Database (CNDDB); RareFind query for Calochortus clavatus var. gracilis. Available at:
https://apps.wildlife.ca.gov/rarefind/view/RareFind.aspx. Accessed September 2024.
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sustaining levels, (4) threaten to eliminate a plant or animal community, or (5) reduce the number or restrict the range of a rare or endangered plant or animal. The small amount of potential habitat for the species that the project would impact is not expected to meet any of those findings. As such, Mitigation Measure MM-BIO-1 as originally drafted provides an equivalent compensation for the loss of those individuals.
However, in response to the CDFW’s comment and direction, MM-BIO-1 has been revised in the Final IS/MND to first require the project to replace those specimens that may be lost through planting replacements within the project site. However, if that is not reasonably possible, the project may still rely on seed collection as an equivalent alternative. The threshold of 20 individuals has also been removed.
CDFW states that the mitigation measures proposed in the Draft IS/MND may not be sufficient to minimize project impacts on California Species of Special Concern (SSC).
Specifically, CDFW requests that SSC should be allowed to move out of harm’s way on their own accord rather than actively relocated and that additional compensatory mitigation be incorporated if SSC presence is confirmed.
The species discussed above are not listed as SSC. Mitigation Measure MM-BIO-2, which provides a preconstruction survey where any special-status species found would be relocated out of harm’s way, and MM-BIO-3, which provides Biological Monitoring during initial vegetation removal and grading, provide sufficient mitigation by avoiding and minimizing direct impacts to individuals of the species that may be present.
Acquisition of, maintenance of, and establishing an endowment over, mitigation lands for the handling of potentially a few individuals is not proportionate to the impact, as the level of impact that would occur to the population of the species is negligible based upon presence of vast amount of open space in the region that is expected to provide suitable habitat for those species. Therefore, introduction of the suggested mitigation measures is not appropriate mitigation under CEQA, and Mitigation Measures MM-BIO-2 and MM- BIO-3, as written, adequately mitigate impacts to the species.
Comment Document 4: South Coast Air Quality Management District (SCAQMD) (July 11, 2024) The SCAQMD identifies concerns about the potential health impacts of siting the proposed manufacturing uses near existing and new sensitive land uses since the operation could generate and attract heavy-duty diesel-fueled trucks that emit diesel particulate matter (DPM). Additionally, the SCAQMD states that the proposed residential uses are located north of the Southern Pacific Railroad line and recommends following California Air Resources Board (CARB) and SCAQMD land use guidance to ensure that sensitive receptors are not heavily affected by warehouse truck activities and other sources of emissions.
LSA prepared a Health Risk Assessment (HRA)
7 (Appendix A of the IS/MND), which
includes an operational health risk analysis to estimate the increased health risk levels for people living and working near the project site associated with toxic air contaminants (TACs), consistent with SCAQMD guidelines. The purpose of the HRA is to document the increased cancer and noncancer health risk levels from project-related emissions of TACs on existing nearby sensitive receptors, including residents and workers. The methodology for the operational HRA is described on pages 10 through 14 of the HRA.
As stated on page 10, the operational HRA evaluates the potential health risk associated with diesel-powered trucks and equipment (diesel forklifts, two yard trucks, and a 500-horsepower [HP] backup generator). A multi-pathway assessment was conducted to evaluate the project’s emissions following the modeling techniques recommended by the State Office of Environmental Health Hazard Assessment (OEHHA) and the SCAQMD. The HRA was conducted using three models: (1) California Emissions Factor Model, Version 2021 (EMFAC2021) for on-road vehicle emissions factors and percentages of fuel type within the overall vehicle fleet; (2) the EPA AERMOD air dispersion model to determine how the TACs would move through the atmosphere after release from sources both on site and on surrounding roadways; and (3) CARB’s HARP2 model to translate the pollutant concentrations from AERMOD into individual health risks at any sensitive receptor locations surrounding the project site.
The results of the operational HRA are provided in Table C of the HRA. As
7 LSA. 2024. Health Risk Assessment for the Riverview Development Project. Santa Clarita, California.
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demonstrated in Table C, all health risk levels to nearby receptors from operation- related emissions of TACs would be below the SCAQMD’s HRA thresholds. No significant health risk would occur from project operation emissions. Therefore, identification and analysis of mitigation measures is not required.
Additionally, consistent with the California Building Industry Association v. Bay Area Air Quality Management District (62 Cal.4th 369) decision, CEQA does not require an analysis of how existing environmental conditions would impact a project’s future users or residents. As such, an analysis of the Southern Pacific Railroad line is not required under CEQA. No additional analysis is necessary.
The SCAQMD states that even though Mitigation Measure AIR-1 would reduce the impacts to a less-than-significant level, the mitigation measure should be revised to ensure the use of the cleanest technology, which currently is Tier 4 equipment, as it is available and feasible to reduce the impacts from the construction activities further.
As discussed in the Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development8 (Appendix A of the Draft IS/MND), a localized significance threshold (LST) analysis was prepared for the proposed project. Based on the results of the LST analysis, the proposed project would result in an exceedance of the SCAQMD LST for particulate matter less than 10 microns in diameter (PM10) during project construction but would not result in an exceedance of the SCAQMD LST during project operation. However, as stated by the SCAQMD, proposed projects whose calculated emission budgets for the proposed construction or operational activities are above the LST emission levels found in the LST lookup tables should not assume that the project would necessarily generate adverse impacts. Detailed emission calculations and/or air dispersion modeling may demonstrate that pollutant concentrations are below recommended thresholds. As such, the HRA (Appendix A of the IS/MND) also included a project-specific construction health risk analysis, which evaluates construction-period health risk to off-site receptors. The results of the construction HRA are provided in Table B of the HRA. As demonstrated in Table B, with implementation of Mitigation Measure MM AIR-1, the mitigated cancer risk at the maximally exposed sensitive receptor would not exceed the SCAQMD’s cancer risk threshold of 10 in one million.
Therefore, with implementation of MM AIR-1, construction of the proposed project would not result in localized concentrations of PM
10 that would exceed SCAQMD risk
thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations. Additionally, no significant health risk would occur from project construction emissions. As such, identification and analysis of additional mitigation, including the use of Tier 4 equipment, would not be required to reduce emissions to a less than significant level.
The SCAQMD suggests several strategies to reduce future resident exposure to DPM including building filtration systems. However, the SCAQMD states that the presumed effectiveness and feasibility of any filtration units should be carefully evaluated in more detail prior to assuming that they would sufficiently alleviate exposures to diesel particulate matter emissions.
As stated on page 11 of the HRA (Appendix A of the IS/MND), the health risk analysis assumes that sensitive receptors would be subject to DPM 24 hours per day, 350 days per year. As stated on page 11, the analysis does not include indoor adjustments for residents, which is conservative as typical people spend the majority of their time indoors versus remaining outdoors 24 hours per day, 350 days per year. As such, filtration units were not considered in the analysis. As demonstrated in Table C of the HRA, all health risk levels to nearby receptors from operation-related emissions of TACs would be below the SCAQMD’s HRA thresholds. Since the analysis conservatively did not include indoor adjustments for residences, the interior spaces of the project would also not exceed any CEQA thresholds; therefore, interior mitigation measures, such as
8 LSA. 2024. Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development Project. Santa Clarita, California.
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enhanced filters would not be required. As discussed on page 17 of the HRA, with implementation of Mitigation Measure MM AIR-1, all health risk levels to nearby receptors from project-related emissions of TACs would be well below the SCAQMD’s HRA thresholds. As such, no significant health risk would occur from project-related emissions and no additional mitigation would be required.
The SCAQMD states the proposed project would require the use of a new 500-HP diesel backup generation; therefore, air permits from the SCAQMD would be required.
The SCAQMD also states that the Final IS/MND should include a discussion about any new stationary and portable equipment requiring SCAQMD air permits and identify SCAQMD as a Responsible Agency for the proposed project. Additionally, the SCAQMD states that the Final IS/MND should also include calculations and analyses for construction and operation emissions for the new stationary and portable sources, as this information would also be relied upon as the basis for the permit conditions and emission limits for the air permit(s).
As discussed on page 2 of the Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development and page 4 of the HRA (Appendix A of the Draft IS/MND), the analysis assumes that the proposed project would include two electric forklifts, two diesel forklifts, and two yard trucks and the installation of a 500 HP diesel backup generator. Additionally, as discussed on pages 10 and 11 of the Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development, the California Emissions Estimator Model (CalEEMod) was used to calculate the long- term operational emissions associated with the project. CalEEMod assumed the use of the onsite equipment associated with the proposed, including two electric forklifts, two diesel forklifts, and two yard trucks; and that this equipment would run 8 hours per day, 260 days per year. In addition, CalEEMod included the use of a 500-HP diesel backup generator for up to 50 hours per year. The long-term operation emissions associated with the proposed project (including use of the forklifts, yard trucks, and backup generator) are shown in Table E of the Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development.
Further, as discussed on page 10 of the HRA, the operational HRA evaluated potential health risk to people living and working near the proposed project associated with the exhaust of diesel-powered trucks and equipment (including the diesel forklifts, yard trucks, and backup generator). The health risk impacts associated with operation of the proposed project (including use of the forklifts, yard trucks, and backup generator) are shown in Table C of the HRA. As such, the calculations and analyses associated with the use of the stationary sources and portable equipment were included in the Air Quality, and Greenhouse Gas Technical Memorandum for the Riverview Development, HRA, and IS/MND. No additional analysis is necessary.
Additionally, comments regarding SCAQMD permits are noted. The proposed project would be required to comply with all applicable SCAQMD rules and permitting requirements prior to operating. Additional text has been added to the Final IS/MND to acknowledge that the SCAQMD would be a responsible agency if a permit is required for any new stationary or portable equipment requiring a SCAQMD permit.
Comment Document 5: Los Angeles County Sheriff’s Department (July 16, 2024) The Santa Clarita Valley Sheriff’s Department (Sheriff’s Department) states that the project would result in an increase in the population of the Station’s service area which would generate an increased demand for law enforcement services. As such, the Sheriff’s Department concludes that the applicant would be required to pay a law enforcement facilities mitigation fee, as well as all other applicable development fees associated with the project. The Sheriff’s Department also clarifies that the law enforcement facilities mitigation fee would ensure additional funding for facility space, and additional personnel resources and assets to address the needs of the project.
This comment does not conflict with the information presented in the IS/MND. As noted on page 76 of the IS/MND, the project would add approximately 1,272 residents to the City’s population and could place increased demand on police protection services. The requirement for the law enforcement facilities mitigation fee will be provided to the project developer.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Response to Comments Received on the Draft Initial Study/Mitigated Negative Declaration for the Riverview Development Project A-12
Comment Summary Response
The Sheriff’s Department notes that the travel distance from the Sheriff’s Department to the project site was incorrectly indicated as 1.4 miles within the Draft IS/MND and is, rather, approximately 2.9 miles.
This error has been corrected in the Final IS/MND; the actual distance travelling by road is approximately 2.5 miles. The prior measurement of 1.4 miles was a direct line measurement site-to-site. This change does not affect the environmental analysis contained in the document.
The Sheriff’s Department notes that it provides eight Special Protection Requirements and Recommendations for the project, including the incorporation of Crime Prevention through Environmental Design in the project design plans, limiting the height of hedge- type plants around security gates, installing motion sensors and gate hardware, the development of traffic and security plans which address vandalism and burglaries, the establishment of a Construction Traffic Management Plan to address construction- related traffic congestion and emergency access issues, providing easily visible numerical addresses on building corners, installing a fence adjacent to the Southern Pacific Railroad tracks, and for the City to consider how to minimize the traffic congestion impacts of the manufacturing use.
Development of the Riverview project would comply with applicable regulatory requirements related to security and safety during construction and operation.
Development would also include low-level exterior lighting, way-finding signage, and Crime Prevention through Environmental Design concepts to enhance safety and security.
Vehicular access to the project site would be provided via four new access points, one of which would provide emergency access only, and one existing access point at Commuter Way and Soledad Canyon Road. These driveways would be constructed to City of Santa Clarita design standards, which would allow for access of emergency vehicles. As described in Section XVII of the IS/MND, Transportation, project-generated traffic would not substantially adversely affect the performance of nearby roadways, including Golden Valley Road. Therefore, emergency service response times and disaster evacuation routes would not be affected. Also, prior to operation, the project would receive all required permits and certificates for occupancy and operation, including those issued by the City Department of Building and Safety. Therefore, there would be no impact related to emergency access, and no mitigation measures are necessary.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview
ATTACHMENT B
Comments Received on June 2024 Draft IS/MND
Riverview Development Project
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205))
SENT VIA ELECTRONIC MAIL
July 03, 2024
Justin Sauder
Associate Planner
City of Santa Clarita, Planning Division
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
[email protected]
RE: MITIGATED NEGATIVE DECLARATION FOR THE RIVERVIEW DEVELOPMENT PROJECT DATED JUNE 25, 2024, STATE CLEARINGHOUSE NUMBER 2024061060 Dear Justin Sauder,
The Department of Toxic Substances Control (DTSC) received a Mitigated Negative Declaration (MND) for the Riverview Development Project (Project). The proposed project will construct 318 residential units (122 detached single-family condos and 196 attached townhomes and an approximate 127,000 square-foot light manufacturing industrial building. The Project also includes a community recreation area, and other on- site improvements including on-site parking and landscaping. The Project site is approximately 35.2 acres in size on a property formerly occupied by the Saugus Speedway and is directly adjacent to the existing Santa Clarita Metrolink Station.
After reviewing the Project, DTSC recommends and requests consideration of the following comments:
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
July 3, 2024
1. If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC's Preliminary Endangerment Assessment (PEA) Guidance Manual.
2. DTSC recommends that all imported soil and fill material should be tested to assess any contaminants of concern meet screening levels as outlined in the PEA Guidance Manual. Additionally, DTSC advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing fill is necessary. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material are suitable for the intended land use. The soil sampling should include analysis based on the source of the fill and knowledge of the prior land use. Additional information can be found by visiting DTSC’s Human and Ecological Risk Office (HERO) webpage.
DTSC appreciates the opportunity to comment on the MND for the Riverview Development Project. Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please respond to this letter or via email for additional guidance.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
July 3, 2024
Sincerely,
Tamara Purvis
Associate Environmental Planner
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
cc: (via email)
Governor’s Office of Planning and
Research State Clearinghouse
[email protected]
Bobbette Biddulph
Senior Project Manager
SWCA Environmental Consultants
[email protected]
Dave Kereazis
Associate Environmental Planner
HWMP-Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
Scott Wiley
Associate Governmental Program Analyst
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) DOC 7265483.SCV
July 10, 2024
Ref. DOC 7256553
VIA EMAIL [email protected]
Mr. Justin Sauder, Associate Planner
City of Santa Clarita, Planning Division
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
Dear Mr. Sauder
Second Response to Riverview Development Project
The Los Angeles County Sanitation District s (Districts) received a Notice of Intent (NOI) to Adopt a Mitigated Negative Declaration (MND) for the subject project located in the City of Santa Clarita on June 27, 2024.
Previous comments submitted by the Districts i n correspondence dated September 15, 2023 (copy enclosed), still apply to the subject project with the following updated information:
1. Section 1.4.5 Utility and Drainage Improvements, Page 9: The second paragraph states “Prior to issuance of the first building permit, the site would be required to be annexed into the County Sanitation District, per Development Review Committee Comments .” Please note that the parcel is already annexed into the Santa Clarita Valley Sanitation District.
2. The proposed project is located approximately one -half mile from the Saugus Water Reclamation Plant , which is owned and operated by the Districts. As such, the MND should consider and evaluate, if necessary, any potential impacts on the proposed project.
3. All other information concerning Districts’ facilities and sewerage service contained in the document is current.
If you have any questions, please contact the undersigned at (562) 908-4288, extension 2742, or [email protected].
Very truly yours,
Patricia Horsley
Environmental Planner
Facilities Planning Department
PLH:ts
Enclosure
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) DOC 7026107.DSCV A Century of Service
September 15, 2023
Ref. DOC 7026091
VIA EMAIL [email protected]
Mr. Reece LaBounty
Project Coordinator
Alliance Land Planning & Engineering, Inc.
2248 Faraday Avenue
Carlsbad, CA 92008
Dear Mr. LaBounty:
Will Serve Letter for Tentative Tract Map No. 83605
The Santa Clarita Valley Sanitation District (District) received your will serve letter request for the subject project, located in the City of Santa Clarita, on September 12, 2023. We offer the following comments regarding sewerage service:
1. The wastewater flow originating from the proposed project will discharge directly to the Districts’ Soledad Canyon Sections 1, 2, 3, and 4 Trunk Sewer, located in Soledad Canyon Road west of Commuter Way.
The Districts’ 15–inch diameter trunk sewer has a capacity of 4 million gallons per day (mgd) and conveyed a peak flow of 2.3 mgd when last measured in 2018. A 6 -inch diameter or smaller direct connection to a Districts’ trunk sewer requires a Trunk Sewer Connection Permit issued by the Districts. An 8- inch diameter or larger direct connection to a Districts’ trunk sewer requires submittal of Sewer Plans for review and approval by the Districts. For additional information, please contact the Districts’ Engineering Counter at (562) 908-4288, extension 1205, or [email protected] .
2. The District operates two water reclamation plants (WRPs), the Saugus WRP and the Valencia WRP, which provide wastewater treatment in the Santa Clarita Valley. These facilities are interconnected to form a regional treatment system known as the Santa Clarita Valley Joint Sewerage System (SCVJSS). The SCVJSS has a capacity of 28.1 mgd and currently processes an average recycled flow of 18.4 mgd.
3. The expected increase in average wastewater flow from the project, described in the application as 195 attached townhomes, 122 detached townhomes, and 68,000 square-feet of commercial buildings, is 89,402 gallons per day, after all structures on the project site are demolished. For a copy of the Districts’ average wastewater generation factors, go to www.lacsd.org, under Services, then Wastewater Program and Permits and select Will Serve Program, and click on the Table 1, Loadings for Each Class of Land Use link.
4. The District is empowered by the California Health and Safety Code to charge a fee to connect facilities (directly or indirectly) to the District’s Sewerage System or to increase the strength or quantity of wastewater discharged from connected facilities. This connection fee is used by the District for its capital facilities. Payment of a connection fee may be required before this project is permitted to discharge to the District’s Sewerage System. For more information and a copy of the Connection Fee Information Sheet, go to www.lacsd.org, under Services, then Wastewater (Sewage) and select Rates & Fees. In determining the impact to the Sewerage System and applicable connection fees, the District will determine the user category
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Mr. Reece LaBounty 2 September 15, 2023
DOC 7026107.DSCV A Century of Service
(e.g. Condominium, Single Family Home, etc.) that best represents the actual or anticipated use of the parcel(s) or facilities on the parcel(s) in the development. For more specific information regarding the connection fee application procedure and fees, the developer should contact the District’s Wastewater Fee Public Counter at (562) 908-4288, extension 2727.
5. In order for the District to conform to the requirements of the Federal Clean Air Act (CAA), the capacities of the District’s wastewater treatment facilities are based on t he regional growth forecast adopted by the Southern California Association of Governments (SCAG). Specific policies included in the development of the SCAG regional growth forecast are incorporated into clean air plans, which are prepared by the South Coast and Antelope Valley Air Quality Management Districts in order to improve air quality in the South Coast and Mojave Desert Air Basins as mandated by the CAA. All expansions of District’s facilities must be sized and service phased in a manner that will be consistent with the SCAG regional growth forecast for the counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial. The available capacity of the District’s treatment facilities will, therefore, be limited to levels associated with the approved growth identified by SCAG. As such, this letter does not constitute a guarantee of wastewater service, but is to advise the applicant that the District intends to provide this service up to the levels that are legally permitted and to in form the applicant of the currently existing capacity and any proposed expansion of District’s facilities.
If you have any questions, please contact the undersigned at (562) 908- 4288, extension 27 08 or at [email protected].
Very truly yours,
Donna J. Curry
Customer Service Specialist
Facilities Planning Department
DC:sw
cc: A. Schmidt
A. Howard
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
(858) 467-4201
www.wildlife.ca.gov
July 11, 2024
Justin Sauder
City of Santa Clarita
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
[email protected]
SUBJECT: RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION, SCH#2024061060; Los Angeles County, CA
Dear Justin Sauder:
The California Department of Fish and Wildlife (CDFW) has reviewed the Mitigated Negative Declaration (MND) from the City of Santa Clarita (City; Lead Agency) for Riverview Development Project (Project). Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.
CDFW’s Role
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State [Fish & G. Code, §§ 711.7, subdivision (a) & 1802; Pub. Resources Code, § 21070; California Environmental Quality Act (CEQA) Guidelines, § 15386, subdivision (a)]. CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect State fish and wildlife resources.
CDFW is also submitting comments as a Responsible Agency under CEQA (Pub.
Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.).
Likewise, to the extent implementation of the Project as proposed may result in “take”, Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
City of Santa Clarita
July 11, 2024
as defined by State law, of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), or CESA-listed rare plant pursuant to the Native Plant Protection Act (NPPA; Fish & G. Code, § 1900 et seq.), CDFW recommends the Project proponent obtain appropriate authorization under the Fish and Game Code.
PROJECT DESCRIPTION SUMMARY
Proponent: Forward Planning
Objective: The Project proposes the construction of 318 single-family residential units and a 126,790 square foot building for light manufacturing use. The single-family residential units would be constructed towards the center of the Project site and the manufacturing building would be constructed in the northwest corner of the Project site.
Within the residential area, community recreation amenities (i.e., dog park, pool, garden area, community lawn, etc.) would be constructed for community use. Vehicular access to the residential area of the Project site would be provided by three proposed driveways along Soledad Canyon Road. Vehicular access to the manufacturing building would be provided by a main driveway and a secondary right-turn in-and-out driveway.
Approximately 819 parking spaces would be constructed for residential use and 219 parking spaces would be constructed near the manufacturing building. Additionally, four drainage basins would be constructed on site for stormwater management.
Landscaping would occur throughout the Project site with trees, various shrubs, grasses, and ground cover. Furthermore, a 5-foot-high retaining wall is proposed along the northern side of the site, south of Soledad Canyon Road. Off-site improvements include a bus stop with a permanent shelter, a new bus turnout, new curb and gutters, base paving, and 5-foot minimum sidewalk along Soledad Canyon Road and Commuter Way. Moreover, existing Southern California Edison-owned streetlights along Soledad Canyon Road and Commuter Way would be removed and replaced with City standard streetlights. Lastly, the Project would also involve construction of a new telecommunications conduit for installation of fiber-optic cable along Soledad Canyon Road.
Project Timeline: Site preparation and grading activities will commence in late 2024 and be concluded by December 2025. Building construction would begin in 2026 and be phased over four to five years.
Location: The 35.2-acre Project site is located at 22500 Soledad Canyon Way in the City. The Project site is bound by Soledad Canyon Road to the north, Commuter Way to the east, Bouquet Canyon Road to the west, and a Southern Pacific railroad line used by Metrolink. The Assessor’s Parcel Number associated with the Project site is 2836- 011-018. The Project site is separated from the Santa Clara River by Soledad Canyon Road and was formerly occupied by the Saugus Speedway.
Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
City of Santa Clarita
July 11, 2024
Biological Setting: A general biological survey was conducted on September 23, 2022, and findings from the survey were compiled in a Biological Resources Technical Report (BRTR). Focused surveys for coastal California gnatcatcher (Polioptila californica californica; Endangered Species Act (ESA) listed-threatened species and California Species of Special Concern (SSC)) were also conducted between April and June 2023.The majority of the Project site is developed and generally flat with undeveloped hillsides in the northwestern corner of the Project site. Native vegetation within the impacted areas of the Project site includes 0.10 acre of California buckwheat (Eriogonum fasciculatum) scrub, 9.94 acres of California sagebrush (Artemisia californica) scrub, and 0.97 acre of chamise chaparral (Adenostoma fasciculatum) scrub. No special-status plants or natural communities were observed within the Project site during surveys. Additionally, no water features were identified within the Project site. Results from focused surveys indicated that no coastal California gnatcatcher were observed or audibly detected. During the general survey, a variety of common bird species were observed along with California ground squirrel (Otospermophilus beecheyi) and western fence lizard (Sceloporus occidentalis). The undeveloped areas of the Project site may provide suitable habitat for slender mariposa lily (Calochortus clavatus var. gracilis; California Rare Plant Rank (CRPR) 1B.2), Crotch’s bumble bee (Bombus crotchii; CESA candidate species), southern California legless lizard (Anniella stebbinsi; SSC), California glossy snake (Arizona elegans; SSC), Blainville’s horned lizard (Phrynosoma blainvillii; SSC), coastal whiptail (Aspidoscelis tigris stejnegeri; SSC), and San Deigo desert woodrat (Neotoma lepida intermedia; SSC). Nine mitigation measures are incorporated in the MND to avoid, minimize, and/or mitigate adverse Project impacts on slender mariposa lily, SSC, nesting birds, and oak tree replacement in compliance with the City’s tree ordinance. Additionally, mitigation measures detailing exterior lighting, invasive plant species prevention, biological monitoring, and stormwater pollution prevention are also included.
COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately avoiding and/or mitigating the Project’s impacts on fish and wildlife (biological) resources. Additional comments or other suggestions may also be included to improve the document. CDFW recommends the measures or revisions below be included in a science-based monitoring program that contains adaptive management strategies as part of the Project’s CEQA mitigation, monitoring and reporting program (Pub. Resources Code, § 21081.6; CEQA Guidelines, § 15097).
Comment #1: Impacts on Crotch’s bumble bee
Issue: The Project will impact Crotch’s bumble bee.
Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
City of Santa Clarita
July 11, 2024
Specific impacts: The Project may result in temporal or permanent loss of suitable nesting and foraging habitat of Crotch’s bumble bee. Project ground-disturbing activities may cause death or injury of adults, eggs, and larva; burrow collapse; nest abandonment; and reduced nest success.
Why impact would occur: The Project site lies within the current range of Crotch’s bumble bee based on CDFW’s Crotch’s Bumble Bee Range Dataset (CDFW 2024a). As with any flying species, Crotch’s bumble bee may fly throughout the City and utilize areas that have suitable nesting habitat and floral resources. Additionally, the BRTR notes that there is a moderate potential for Crotch’s bumble bee to occur within the Project site (page 25). The on-site vegetation provides foraging opportunities and there is limited nesting potential within the undeveloped northwestern area of the Project site.
Crotch’s bumble bee primarily nest underground in abandoned small mammal burrows but may also nest under perennial bunch grasses or thatched annual grasses, under- brush piles, in old bird nests, and in dead trees or hollow logs (Williams et al. 2014; Hatfield et al. 2018). While the Project site may provide limited nesting habitat, the possibility of Crotch’s bumble bee to be present on site cannot be completely ruled out considering that the general survey was a single survey conducted two years ago outside the timeframe (April to August) for highest detection probability. In addition to limited surveys, the MND does not discuss the moderate potential for Crotch’s bumble bee to be foraging and/or nesting within the Project site. The MND also does not provide mitigation measures directly related to Crotch’s bumble bee. A mitigation measure should be incorporated in the MND to include focused surveys to confirm presence/absence of Crotch’s bumble bee on the Project site prior to Project activities.
Without focused surveys, individual Crotch’s bumble bee and/or nesting sites may go undetected resulting in incidental take of a CESA protected species. If presence of Crotch’s bumble bee is confirmed, the Project would result in loss of confirmed habitat for this species.
Evidence impact would be significant: The California Fish and Game Commission accepted a petition to list the Crotch’s bumble bee as endangered under CESA, determining the listing “may be warranted” and advancing the species to the candidacy stage of the CESA listing process. The Project may substantially reduce and adversely modify habitat as well as reduce and potentially impair the viability of populations of Crotch’s bumble bee. The Project may also reduce the number and range of the species without considering the likelihood that special status species on adjacent and nearby natural lands may rely upon the habitat that occurs on the proposed Project site.
In addition, Crotch’s bumble bee has a State Ranking of S1/S2. This means that the Crotch’s bumble bee is considered critically imperiled or imperiled and is extremely rare (often 5 or fewer populations). Crotch’s bumble bee is also listed as an invertebrate of conservation priority under the California Terrestrial and Vernal Pool Invertebrates of Conservation Priority (CDFW 2017).
Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
City of Santa Clarita
July 11, 2024
Recommended Potentially Feasible Mitigation Measure(s):
Recommendation #1: Crotch’s Bumble Bee Discussion - The MND should be amended to provide a discussion on habitat suitability for Crotch’s bumble bee within and adjacent to the Project site. The discussion should also disclose the Project’s potential direct and indirect impacts on Crotch’s bumble bee. If the Project may impact Crotch’s bumble bee, the MND should provide measures to minimize, and/or mitigate potential impacts to Crotch’s bumble bee as well as habitat supporting the species. The discussion should be of a depth and scope that a CESA Incidental Take Permit can be issued based on the analysis provided in the MND.
Mitigation Measure #1: Crotch’s Bumble Bee Surveys - The Project proponent shall retain a qualified entomologist with the appropriate handling permits to conduct focused surveys. Focused surveys shall follow CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023). Focused surveys shall also be conducted throughout the entire Project site during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the City prior to implementing Project ground-disturbing activities.
Mitigation Measure #2: Incidental Take Permit - If Crotch’s bumble bee is detected the Project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a copy of a fully executed take authorization to the City prior to implementing Project ground-disturbing activities and vegetation removal.
Comment #2: Impacts on Slender Mariposa Lily
Issue: MM-BIO-1 does not adequately offset Project-related impacts on slender mariposa lily.
Specific impacts: Project ground-disturbing activities (i.e., grading, vegetation removal) would result in loss of suitable habitat, loss of population, and direct mortality of slender mariposa lily.
Why impact would occur: Seed collection alone is not sufficient to offset Project impacts. According to the California Natural Diversity Database, there are recorded observations of slender mariposa lily near the Project site (CDFW 2024b). Additionally, the MND also states that there is a moderate potential for slender mariposa lily to occur on the Project site (page 28). While CDFW concurs that focused surveys should be done during the appropriate bloom period for highest detection probability, we disagree that protocol surveys and seed collection makes impacts to the species less than Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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City of Santa Clarita
July 11, 2024
significant with mitigation. Compensatory mitigation should be provided if any individual slender mariposa lily is observed, especially since this rare plant is threatened in California.
CDFW is also concerned that the MND does not provide biological justification as to why a count of 20 individuals is the minimum threshold. If slender mariposa lily is observed on the Project site, there is a possibility for multiple bulbs to exist underground that may or may not have bloomed. Moreover, handing seeds to a local organization for restoration opportunities does not guarantee successful creation of a slender mariposa lily population.
As currently written, Mitigation Measure BIO-1 does not commit to mitigation that would adequately offset the direct loss of slender mariposa lily, nor does it adopt specific performance standards and actions pertaining to management of mitigation actions. The MND does not disclose where or when the seeds would be used in restoration projects.
If restoration projects do not utilize the seeds until several years after collection, they may become inviable. Moreover, the mitigation measure does not provide success criteria for these restoration projects to ensure successful mitigation is achieved. In addition to no success criteria, long-term management actions for these restoration projects is not outlined in the mitigation measure. With limited information and no enforceable actions regarding the restoration projects, the proposed mitigation would be considered deferred.
Evidence impact would be significant: Impacts on rare flora could be considered a significant effect on the environment. Plants with a CRPR of 1B are rare throughout their range, endemic to California, and are seriously or fairly threatened. Most of the plants that are ranked 1B have declined significantly over the last century. The additional threat rank of 0.1 indicates a species with over 80 percent of its occurrences threatened in California. The additional threat rank of 0.2 indicates a species with 20 to 80 percent of its occurrences threatened (CNPS 2024). Impacts to CRPR 1B plant species and their habitat meet the definition of endangered, rare, or threatened species (CEQA Guidelines, § 15380). Some CRPR 3 and 4 species meet the definitions of endangered, rare, or threatened under CEQA. Impacts to CRPR 1B plant species and their habitat may result in a mandatory finding of significance because the Project would have the potential to threaten to eliminate a plant community and substantially reduce the number or restrict the range of an endangered, rare, or threatened species (CEQA Guidelines, § 15065).
Additionally, Mitigation Measure BIO-1 is considered deferred mitigation [CEQA Guidelines, § 15126.4(a)(1)(B)]. Insufficient mitigation may result in unmitigated temporal or permanent impacts to a rare plant species. Subsequently, the Project would continue to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species by CDFW.
Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder
City of Santa Clarita
July 11, 2024
Recommended Potentially Feasible Mitigation Measure(s):
Mitigation Measure #3: MM BIO-1: Pre-Construction Rare Plant Survey and Seed Collection – The City should revise MM BIO-1 to incorporate the underlined language and omit language in strikethrough:
Prior to issuance of a grading permit, the Applicant shall have a qualified biologist (the Applicant shall submit the qualifications of the biologist to the City for review and approval) conduct a focused rare plant survey for slender mariposa lily within the undeveloped portion of the project site during the appropriate blooming period (March through June). The survey would consist of three passes, with one in April, May, and June. Reference site checks would be made for the species to determine if the species is blooming in the project vicinity. The surveys would conform to the California Native Plant Society’s Botanical Survey Guidelines (2001); CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (2018); and USFWS’ Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants (2000). The results of the surveys would be documented in a report and submitted to the City.
If the presence of slender mariposa lily is detected, Should the species be found at a count of 20 or higher, no Project activities shall commence. The Project proponent shall coordinate with CDFW to discuss avoidance of the slender mariposa lily on site. If complete avoidance is unattainable, the Project proponent shall provide compensatory mitigation to offset the Project’s impact on rare plants observed on site at no less than 2:1. The total habitat acreage within the mitigation land shall be no less than 2:1. The Project proponent shall acquire CDFW approved mitigation land that has presence of slender mariposa lily and is located in the same watershed as the Project site. The mitigation land shall also provide equivalent or greater habitat value than that of the Project site. The Project proponent shall protect replacement habitat in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage mitigation lands pursuant to Assembly Bill 1094. Recordation of the conservation easement shall occur prior to commencement of Project activities. An appropriate endowment shall also be provided for the long-term monitoring and management of mitigation lands. then construction of the occupied location shall be delayed until the individuals have gone to seed. Seeds shall be collected once the seed has matured, but prior to the seed capsules opening to disperse the seed.
Seeds shall be stored in breathable paper bags in a cool, dry, and dark place. The seeds would then be donated to a City-approved local conservation organization (e.g., Friends of the Santa Clara River) to be used in restoration projects.
Mitigation Measure #4: Habitat Management and Monitoring Plan - The Project proponent shall retain a certified botanist to draft a Habitat Management and Monitoring Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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Plan (HMMP) and submit it to the City and CDFW for review and approval prior to Project activities. The HMMP shall outline initial and long-term management and maintenance activities that would occur on mitigation lands. The HMMP shall provide measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Maintenance activities outlined in the HMMP shall include measures pertaining to control of exotic vegetation, irrigation schedule, and protection from future maintenance activities.
Comment #3: Impacts on California Species of Special Concern
Issue: The mitigation measure proposed in the MND may not be sufficient to minimize Project impacts on SSC.
Specific Impact: Direct impacts to SSC could result from Project activities (e.g., equipment staging, mobilization, and grading); ground disturbance; vegetation clearing; trampling or crushing from construction equipment, vehicles, and foot traffic. Project ground-disturbing activities such as vegetation removal will also result in habitat destruction, causing the death or injury of adults, juveniles, eggs, or hatchlings.
Why impact would occur: The MND states that southern California legless lizard, California glossy snake, Blainville’s horned lizard, coastal whiptail, and San Diego desert woodrat have a moderate to high potential to occur on the Project site during Project activities (page 29). To reduce Project impacts, Mitigation Measure BIO-2 Pre- construction Wildlife Survey and Mitigation Measure BIO-3 Biological Monitoring are incorporated into the MND. Mitigation Measure BIO-2 states that if SSC are found, they would be relocated to a City approved off-site location with suitable habitat. Injury or death of SSC may occur during the transit process when relocating a species from one area to another. With a high level of risk involved in relocating species, SSC should be allowed to move out of harm’s way on their own accord rather than actively relocated. In addition to relocation of SSC, the mitigation measures do not outline any compensatory mitigation if SSC presence is confirmed. Given that habitat loss on a local and regional scale is a major cause of population decline for these SSC, removal of confirmed SSC habitat would be considered a significant impact and should be mitigated appropriately.
Evidence impact would be significant: A California Species of Special Concern is a species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
1) if the species is extirpated from the State or, in the case of birds, is extirpated in its primary season or breeding role;
2) if the species is listed as threatened or endangered under ESA-, but not CESA-, threatened, or endangered;
3) if the species meets the State definition of threatened or endangered but has not Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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formally been listed;
4) if the species is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status; and, 5) if naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for CESA threatened or -endangered status (CDFW 2024c).
CEQA provides protection not only for CESA-listed species, but for any species including but not limited to SSC that can be shown to meet the criteria for State listing.
These SSC meet the CEQA definition of rare, threatened, or endangered species (CEQA Guidelines, § 15380). The MND does not provide mitigation for potential impacts on SSC. Inadequate avoidance, minimization, and mitigation measures for impacts to sensitive or special status species will result in the Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special- status species by CDFW.
Recommended Potentially Feasible Mitigation Measure(s)
Mitigation Measure #5: MM BIO-2: Pre-Construction Wildlife Survey – The City should revise MM BIO-2 to incorporate the underlined language and omit language in strikethrough:
Prior to issuance of a grading permit, a qualified biologist (the Applicant shall submit the qualifications of the biologist to the City for review and approval) shall conduct a survey of the proposed impact areas and 50-foot buffer within 72 hours of the proposed activities. Any coastal whiptail, Southern California legless lizard, California glossy snake, or Blainville’s horned lizard found shall be passively ushered out of harm’s way to an area that is unaffected by the Project. If the Project requires SCC to be removed, disturbed, or otherwise handled, the qualified biologist shall obtain all appropriate permits and prepare a species-specific list (or plan) of proper handling and passive relocation protocols. The list (or plan) of protocols shall be implemented during Project construction and activities/biological construction monitoring. The City/qualified biologist may coordinate with CDFW to prepare a passive relocation plan and shall be submitted to CDFW for review and comment prior to implementing Project ground-disturbing activities. would be relocated to a City-approved off-site location in suitable habitat for each species. If a San Diego desert woodrat midden is discovered during the survey, then the qualified biologist shall erect a fence with a 50-foot buffer around the midden. Adequate space should be provided for sufficient foraging habitat at the discretion of the qualified biologist in coordination with CDFW. If young are present, no work shall occur within the fenced area until the young have left the nest. If the woodrat midden cannot be left in place, the qualified biologist shall prepare a list (or plan) of proper handling and relocation Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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protocols. The plan shall be submitted to CDFW for review and comment prior to Project ground-disturbing activities. would methodically relocate the midden material to suitable habitat (dense shrubs) within 50 feet of its location and outside of the project disturbance limits. The procedure would be implemented at a rate that would allow for the woodrat to flush from the midden. The results of the survey would be documented in a letter report to be submitted to the City.
Mitigation Measure #6: Compensatory Mitigation - For SSC that have been confirmed and/or are expected to occur within the Project site, the Project proponent shall provide compensatory mitigation for temporary and permanent loss of any habitat supporting SSC. There shall be no net loss of habitat supporting SSC [CEQA Guidelines, § 15370(e)]. Compensatory mitigation shall be provided within the Project boundary at no less than 2:1. Mitigation shall provide appropriate habitat (depending on the species), refugia, and habitat structures that supports that species (e.g., woody material, rocks, brush piles, pools, burrows). Any proposed mitigation area/plan shall include a discussion on the territory size; nesting, breeding, foraging, and refuge locations; invasive, non-native plant and wildlife species present; food availability; and how all life cycle functions will be mitigated. Any mitigation plan for SSC shall be distributed and approved by CDFW prior to Project activities. The replacement habitat shall be protected in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity, which should include an appropriate endowment to provide for the long-term management of mitigation lands.
Additional Comments
Data. CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database [i.e., CNDDB], which may be used to make subsequent or supplemental environmental determinations [Pub.
Resources Code, § 21003, subd. (e)]. Accordingly, please report any special status species detected by completing and submitting CNDDB Online Field Survey Form (CDFW 2024d).The Project proponent should ensure that data was submitted data properly, with all data fields applicable filled out, prior to finalizing/adopting the environmental document. The data entry should also list pending development as a threat and then update this occurrence after impacts have occurred. The Project proponent should provide CDFW with confirmation of data submittal.
Mitigation and Monitoring Reporting Plan. CDFW recommends updating the MND’s proposed Biological Resources Mitigation Measures to include mitigation measures recommended in this letter. Mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments [Pub. Resources Code, § 21081.6; CEQA Guidelines, § 15126.4(a)(2)]. As such, CDFW has provided comments and recommendations to assist the City in developing mitigation measures that are (1) consistent with CEQA Guidelines section 15126.4; (2) specific; (3) detailed (i.e., responsible party, timing, specific actions, location), and (4) clear for a measure to be fully enforceable and implemented successfully via mitigation monitoring and/or Docusign Envelope ID: 0E433554-1B95-4A5E-B414-1FE7BE5AABBE
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reporting program (Pub. Resources Code, § 21081.6; CEQA Guidelines, § 15097). The City is welcome to coordinate with CDFW to further review and refine the Project’s mitigation measures. Per Public Resources Code section 21081.6(a)(1), CDFW has provided the City with a summary of our suggested mitigation measures and recommendations in the form of an attached Draft Mitigation and Monitoring Reporting Plan (MMRP; Attachment A).
Filing Fees
The Project, as proposed, could have an impact on fish and/or wildlife, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the City and serve to help defray the cost of environmental review by CDFW.
Payment of the fee is required in order for the underlying Project approval to be operative, vested, and final (Cal. Code Regs, tit. 14, § 753.5; Fish & Game Code, § 711.4; Pub. Resources Code, § 21089).
Conclusion
CDFW appreciates the opportunity to comment on the Project to assist the City in adequately analyzing and minimizing/mitigating impacts to biological resources. CDFW requests an opportunity to review and comment on any response that the City has to our comments and to receive notification of any forthcoming hearing date(s) for the Project [CEQA Guidelines, § 15073(e)].
Questions regarding this letter or further coordination should be direct to Julisa Portugal, Environmental Scientist, at [email protected] or (562) 330-7563.
Sincerely,
Jennifer Turner
For Victoria Tang
Environmental Program Manager
South Coast Region
EC: California Department of Fish and Wildlife
Jennifer Turner
Steve Gibson
Frida Diaz-Barriga
Cindy Hailey
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References:
[CDFW] California Department of Fish and Wildlife. 2017. California Terrestrial and Vernal Pool Invertebrates of Conservation Priority. Available at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=149499&inline [CDFW] California Department of Fish and Wildlife. 2023. Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species. Available at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline [CDFW] California Department of Fish and Wildlife. 2024a. Crotch’s Bumble Bee Range – CDFW [ds3095]. Available at: https://data.ca.gov/dataset/crotchs-bumble-bee- range-cdfw-ds3095
[CDFW] California Department of Fish and Wildlife. 2024b. California Natural Diversity Database. Available at: https://wildlife.ca.gov/Data/CNDDB [CDFW] California Department of Fish and Wildlife. 2024b. Threatened and Endangered Species. Available at: https://wildlife.ca.gov/Conservation/CESA [CDFW] California Department of Fish and Wildlife. 2024d. Submitting Data to the CNDDB. Available at: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. [CNPS] California Native Plant Society. 2024. California Rare Plant Ranks. Available at:
https://www.cnps.org/rare-plants/california-rare-plant-ranks Hatfield, R., Jepsen, S., Foltz Jordan, S., Blackburn, M., Code, Aimee. 2018. A Petition to the State of California Fish and Game Commission to List Four Species of Bumblebees as Endangered Species.
Williams, P. H., R. W. Thorp, L. L. Richardson, and S.R. Colla. 2014. Bumble bees of North America: An Identification guide. Princeton University Press, Princeton, New Jersey. 208pp
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Attachment A: Draft Mitigation and Monitoring Reporting Plan
CDFW recommends the following language to be incorporated into a future environmental document for the Project.
Biological Resources (BIO)
Mitigation Measure (MM) or Recommendation (REC) Timing Responsible Party
MM-BIO-1 –
Crotch’s Bumble
Bee Surveys
The Project proponent shall retain a qualified entomologist with the appropriate handling permits to conduct focused surveys. Focused surveys shall follow CDFW’s Survey
Considerations for California Endangered Species Act
Candidate Bumble Bee Species. Focused surveys shall
also be conducted throughout the entire Project site during the appropriate flying season to ensure no missed
detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the City prior to implementing Project ground-
disturbing activities.
Prior to Project
activities
Project
Proponent/
Qualified
Entomologist
MM-BIO-2 –
Incidental Take
Permit
If Crotch’s bumble bee is detected the Project proponent shall coordinate with CDFW and obtain appropriate take
authorization from CDFW (pursuant to Fish & Game Code,
§ 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a
copy of a fully executed take authorization to the City prior to implementing Project ground-disturbing activities and vegetation removal.
Prior to Project
activities
Project
Proponent
MM-BIO-3- MM
BIO-1
Prior to issuance of a grading permit, the Applicant shall have a qualified biologist (the Applicant shall submit the qualifications of the biologist to the City for review and Prior to
issuance of
grading permits
Project
Proponent/
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approval) conduct a focused rare plant survey for slender mariposa lily within the undeveloped portion of the project site during the appropriate blooming period (March through June). The survey would consist of three passes, with one in April, May, and June. Reference site checks would be made for the species to determine if the species is
blooming in the project vicinity. The surveys would
conform to the California Native Plant Society’s Botanical Survey Guidelines (2001); CDFW’s Protocols for
Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (2018); and
USFWS’ Guidelines for Conducting and Reporting
Botanical Inventories for Federally Listed, Proposed and Candidate Plants (2000). The results of the surveys would be documented in a report and submitted to the City.
If the presence of slender mariposa lily is detected, no Project activities shall commence. The Project proponent shall coordinate with CDFW to discuss avoidance of the
slender mariposa lily on site. If complete avoidance is unattainable, the Project proponent shall provide
compensatory mitigation to offset the Project’s impact on rare plants observed on site at no less than 2:1. The total habitat acreage within the mitigation land shall be no less than 2:1. The Project proponent shall acquire CDFW
approved mitigation land that has presence of slender
mariposa lily and is located in the same watershed as the Project site. The mitigation land shall also provide
equivalent or greater habitat value than that of the Project site. The Project proponent shall protect replacement
habitat in perpetuity under a conservation easement
Qualified
Biologist
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dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage
mitigation lands pursuant to Assembly Bill 1094.
Recordation of the conservation easement shall occur
prior to commencement of Project activities. An
appropriate endowment shall also be provided for the long- term monitoring and management of mitigation lands.
MM-BIO-4-
Habitat
Management and
Monitoring Plan
The Project proponent shall retain a certified botanist to draft a Habitat Management and Monitoring Plan (HMMP)
and submit it to the City and CDFW for review and
approval prior to Project activities. The HMMP shall outline initial and long-term management and maintenance
activities that would occur on mitigation lands. The HMMP shall provide measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Maintenance activities
outlined in the HMMP shall include measures pertaining to control of exotic vegetation, irrigation schedule, and
protection from future maintenance activities.
Prior to Project
activities
Project
Proponent/
Certified
Botanist
MM-BIO-5- MM-
BIO-2
Prior to issuance of a grading permit, a qualified biologist (the Applicant shall submit the qualifications of the
biologist to the City for review and approval) shall conduct a survey of the proposed impact areas and 50-foot buffer within 72 hours of the proposed activities. Any coastal whiptail, Southern California legless lizard, California glossy snake, or Blainville’s horned lizard found shall be passively ushered out of harm’s way to an area that is
unaffected by the Project. If the Project requires SCC to be removed, disturbed, or otherwise handled, the qualified biologist shall obtain all appropriate permits and prepare a species-specific list (or plan) of proper handling and
Prior and during
Project activities
Qualified
Biologist/
Project
Proponent
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passive relocation protocols. The list (or plan) of protocols shall be implemented during Project construction and
activities/biological construction monitoring. The
City/qualified biologist may coordinate with CDFW to
prepare a passive relocation plan and shall be submitted to CDFW for review and comment prior to implementing
Project ground-disturbing activities. If a San Diego desert woodrat midden is discovered during the survey, then the qualified biologist shall erect a fence with a 50-foot buffer around the midden. Adequate space should be provided
for sufficient foraging habitat at the discretion of the qualified biologist in coordination with CDFW. If young are present, no work shall occur within the fenced area until the young have left the nest. If the woodrat midden cannot be left in place, the qualified biologist shall prepare a list (or plan) of proper handling and relocation protocols. The plan shall be submitted to CDFW for review and comment
prior to Project ground-disturbing activities.
MM-BIO-6 –
Compensatory
Mitigation
For SSC that have been confirmed and/or are expected to occur within the Project site, the Project proponent shall provide compensatory mitigation for temporary and
permanent loss of any habitat supporting SSC. There shall be no net loss of habitat supporting SSC. Compensatory
mitigation shall be provided within the Project boundary at no less than 2:1. Mitigation shall provide appropriate
habitat (depending on the species), refugia, and habitat structures that supports that species (e.g., woody material, rocks, brush piles, pools, burrows). Any proposed
mitigation area/plan shall include a discussion on the
territory size; nesting, breeding, foraging, and refuge locations; invasive, non-native plant and wildlife species Prior to Project
activities
Project
proponent
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present; food availability; and how all life cycle functions will be mitigated. Any mitigation plan for SSC shall be distributed and approved by CDFW prior to Project
activities. The replacement habitat shall be protected in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity, which should include an appropriate endowment to provide for
the long-term management of mitigation lands.
REC 1 – Crotch’s
Bumble Bee
Discussion
The MND should be amended to provide a discussion on
habitat suitability for Crotch’s bumble bee within and
adjacent to the Project site. The discussion should also disclose the Project’s potential direct and indirect impacts on Crotch’s bumble bee. If the Project may impact Crotch’s bumble bee, the MND should provide measures to
minimize, and/or mitigate potential impacts to Crotch’s bumble bee as well as habitat supporting the species. The discussion should be of a depth and scope that a CESA
Incidental Take Permit can be issued based on the
analysis provided in the MND.
Prior to adopting
CEQA
document
Lead Agency
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SENT VIA E-MAIL: July 11, 2024
[email protected]
Justin Sauder, Associate Planner
City of Santa Clarita, Planning Division
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
Mitigated Negative Declaration (MND) for the Proposed
Riverview Development Project (Proposed Project)
(SCH No.: 2024061060)
South Coast Air Quality Management District (South Coast AQMD) staff appreciate the opportunity to review the above-mentioned document. The City of Santa Clarita is the California Environmental Quality Act (CEQA) Lead Agency for the Proposed Project. To pr ovide context, South Coast AQMD staff has provided a brief summary of the project information and prepared the following comments, which are organized by topic of concern.
South Coast AQMD Staff’s Summary of Project Information in the MND Based on the information provided in the MND, the Proposed Project includes constructing 318 single-family units and a 126,790-square-foot light industrial building on a 35.2-acre property.1 The Proposed Project is located at 22500 Soledad Canyon Way in Santa Clarita .2 The proposed project site would be split into five planning areas (PAs), where PAs 1, 2, 3, and 4 are dedicated to residential development, while PA 5 is for a light manufacturing building.3 The light industrial building would provide 18 dock doors and generate approximately 609 average daily truck trips.4 According to aerial photographs, South Coast AQMD staff found that the nearest sensitive receptor is within 100 feet northwest of the Proposed Project site. The site preparation and grading are expected to begin in late 2024 and conclude by December 2025, with building construction commencing in 2026 and lasting for over four to five years.5
South Coast AQMD Staff’s Comments on the MND
Recommendation on Siting New Sensitive Land Uses (Residential Areas)
The Proposed Project is located within the land use and zoning designation of Mixed-Use Corridor (MXC), 6 which allows the use of the proposed property. 7 However, South Coast AQMD is concerned about the potential health impacts of siting the manufacturing building that generates
1 MND. Page 1.
2 Ibid.
3 Ibid. Pages 5 and 7.
4 Appendix A - Health Risk Assessment. Page 12.
5 Ibid. Page 10.
6 Ibid. Page 4.
7 Ibid. Page 20.
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2 609 daily truck trips8 that are in close proximity to existing and new sensitive land uses since the operation generates and attracts heavy-duty diesel-fueled trucks that emit Diesel Particulate Matter (DPM). Based on the aerial photographs, South Coast AQMD staff found that the nearest existing sensitive receptor is within 100 feet northwest of the Proposed Project site at 22722 Soledad Canyon Road. Also, according to the IS-MND, Figure 3. Site Plan, it is estimated that the loading docks/truck idling would be less than 500 feet from existing and proposed residential areas.
When the health impacts from the Proposed Project are added to the existing background, both existing and new residents living in the surrounding communities will likely face even great er exposure to air pollution and bear a disproportionate burden of increasing health risks. Moreover, the proposed high-density residential area will be north of the Southern Pacific Railroad line.
Consequently, the lead agency is recommended to follow CAR B and South Coast AQMD land - use guidance to ensure that sensitive receptors are not heavily affected by the warehouse truck activities and other sources of emissions. This guidance includes:
1) The CARB’s Air Quality and Land Use Handbook: A Community Health Perspective9 is a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision -making process with additional guidance on strategies to reduce air pollution exposure near high-volume roadways available in CARB’s technical advisory.10
2) The South Coast AQMD’s Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning 11 includes suggested policies that local governments can use in their General Plans or through local planning to prevent or reduce potential air pollution impacts and protect public health. It is recommended that the Lead Agency review this Guidance Document as a tool when making local planning and land use decisions.
By adherin g to these essential guidance documents and implementing proactive Mitigation Measures (MMs), the Lead Agency can avoid, eliminate , or reduce the adverse impacts of warehouse and truck activities on public health, ensuring that vulnerable communities are adequately protected from disproportionate exposure to air pollution.
Recommend Revision to Air Quality Mitigation Measure
In the air quality section of the MND, the Proposed Project’s regional and localized construction and operational emissions have been quantified and compared to South Coast AQMD Air Quality Significance Threshold s,12 and the results are presented in Table 7. 13 However, the localized
8 Appendix A - Health Risk Assessment. Page 12.
9 CARB’s Air Quality and Land Use Handbook: A Community Health Perspective can be found at:
http://www.arb.ca.gov/ch/handbook.pdf.
10 CARB’s technical advisory can be found at: https://www.arb.ca.gov/ch/landuse.htm. 11 South Coast AQMD. 2005. Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning.
Available at: http://www.aqmd.gov/docs/default-source/planning/air-quality-guidance/complete-guidance-document.pdf. 12 South Coast AQMD Air Quality Significance Thresholds. Available at: https://www.aqmd.gov/docs/default- source/ceqa/handbook/south-coast-aqmd-air-quality-significance-thresholds.pdf. 13 Ibid. Page 24.
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3 construction emissions show an exceedance for PM10. The mitigation measure MM AIR-114 is proposed with “all off-road diesel-powered construction equipment of 50 hp or more used for the project construction at a minimum meets the California Air Resources Board Tier 2 emis sions standards equipped with level 3 diesel particulate filters .” The MND concludes that with the implementation of MM AIR -1, the Proposed Project -related emissions would be less than significant.15 Even though the implementation of MM AIR -1 could reduce the impacts, South Coast AQMD staff recommends that the Lead Agency revise the MM AIR-1 to ensure the use of the cleanest technology, which currently is Tier 4 equipment, as it is available and feasible to reduce the impacts from the construction activities further.
Health Risk Reduction Strategies
Many strategies are available to reduce exposures, including, but not limited to, building filtration systems with MERV 13 or better, or in some cases, MERV 15 or better is recommended, building design, orientation, location, vegetation barriers, landscaping screening, etc. Enhanced filtration units are capable of reducing exposures. However, enhanced filtration systems have limitations.
For example, in a study that South Coast AQMD conducted to investigate filters, 16 a cost burden is expected to be within the range of $120 to $240 per year to replace each filter panel. The initial start-up cost could substantially increase if an HVAC system needs to be installed and if standalone filter units are required. Installation costs may vary and include costs for conducting site assessments and obtaining permits and approvals before filters can be installed. Other costs may include filter life monitoring, annual maintenance, and training for conducting maintenance and reporting. In addition, because the filters wo uld not have any effectiveness unless the HVAC system is running, there may be increased energy consumption that the Lead Agency should evaluate in the Final MND. It is typically assumed that the filters operate 100 percent of the time while residents are indoors, and the environmental analysis does not generally account for the times when the residents have their windows or doors open or are in common space areas of the project. These filters have no ability to filter out any toxic gases. Furthermore, when used filters are replaced, replacement has the potential to result in emissions from the transportation of used filters at disposal sites and generate solid waste that the Lead Agency should evaluate in the Final MND. Therefore, the presumed effectiveness and feasibility of any filtration units should be carefully evaluated in more detail prior to assuming that they will sufficiently alleviate exposures to diesel particulate matter emissions.
South Coast AQMD Rules, Permits, and Responsible Agency
Based on the information in Appendix A – Air Quality and Greenhouse Gas Analysis, the Proposed Project would require the use of a new 500-horsepower diesel backup generator .17 Hence, air permits from South Coast AQMD will be required, and the role of South Coast AQMD would change from a Commenting Agency to a Responsible Agency under CEQA. In addition, if South Coast AQMD is identified as a Responsible Agency, per CEQA Guidelines Secti ons15086, the
14 Ibid. Page 26.
15 Ibid. Page 25.
16 This study evaluated filters rated MERV 13 or better. Available at:
http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/aqmdpilotstudyfinalreport.pdf. Also, see South Coast AQMD's 2012 Peer Review Journal article at https://onlinelibrary.wiley.com/doi/10.1111/ina.12013. 17 Appendix A. Air Quality and Greenhouse Gas Analysis. Page 2.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Justin Sauder July 11, 2024
4 Lead Agency is required to consult with South Coast AQMD. In addition, CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of evaluating the applications for air permits. For these reasons, the Final MND should include a discussion about any new stationary and portable equipment requiring South Coast AQMD air permits and identify South Coast AQMD as a Responsible Agency for the Proposed Project.
The Final MND should also include calculations and analyses for construction and operation emissions for the new stationary and portable sources, as this information will also be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385 for questions regarding what types of equipment would require air permits. For more general information on permits, please visit South Coast AQMD’s webpage at http://www.aqmd.gov/home/permits.
Conclusion
The Lead Agency is recommended to revise the CEQA analysis to address the aforementioned comments and provide the necessary evidence to sufficiently support the conclusions reached. If the requested information and analysis are not included in the final CE QA document, either the Final MND or other type of CEQA document, the Lead Agency should provide reasons for not doing so. Pursuant to California Public Resources Code Section 21092.5(b) and CEQA Guidelines Section 15074, prior to approving the Proposed Project, the Lead Agency shall consider the MND for adoption together with any comments received during the public review process and notify each public agency when any public hearings are scheduled. Please provide South Coast AQMD with written responses to all comments contained herein prior to the adoption of the Final MND.
When responding to issues raised in the comments, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided. In addition, if the Lead Agency decides to adopt the Final MND, please provide South Coast AQMD with notice of any scheduled public hearing(s).
Thank you for the opportunity to provide comments. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter.
Please contact Danica Nguyen, Air Quality Specialist, at [email protected] should you have any questions.
Sincerely,
Sam Wang
Sam Wang
Program Supervisor, CEQA-IGR
Planning, Rule Development & Implementation
SW:DN
LAC240626-01
Control Number
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) (j1ViW4W:T1=LIFE
COUNTYOFLosANGELES
R0BE1?TG.LUNA,SFII1?IFF
July16,2024
Mr.DavidPeterson,SeniorPlanner
CityofSantaClarita
DepartmentofCommunityDevelopment
23920ValenciaBoulevard,Suite302
SantaClarita,California91355
DearMr.Sauder:
SANTACLARITARIVERVIEWDEVELOPMENTPROJECT
(MASTERCASENO.21-205)
NOTICEOFINTENTTOADOPTANINITIALSTITDY/
MITIGATEDNEGATIVEDECLARATION
REVIEWCOMMENTS
ThankyouforinvitingtheLosAngelesCountySheriff’sDepartment (Department)toreviewandcommentontheJune2024NoticeofIntentto AdoptanInitialStudy/MitigatedNegativeDeclaration(IS/MND),fortheSanta ClaritaRiverviewDevelopmentProject(Project).
TheproposedProjectislocatedwithintheserviceareaoftheDepartment’s SantaClaritaValleySheriff’sStation(Station).Itislikelytheconstructionof theproposedProjectwillimpactthecurrentlevelofserviceprovidedbythe Stationforthepotentialincreaseinpopulationandthereforemayrequirea reevaluationwithyourcityofthelawenforcementservicescontractonce completed.
PleaseseetheattachedreviewcommentsprovidedbyourStation(see correspondencedatedJuly16,2024,fromCaptainJustinDiez).
Also,forfuturereference,theDepartmentprovidesthefollowingupdated addressandcontactinformationforallrequestsforreviewscomments,law documents,andotherrelatedcorrespondence:
211WESTTEMPLESTREET,LosANGELES,CAJIFoRA90012
7add€,z/ie
c—1850
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Mr.Peterson-2-July16,2024
TraceyJue,BureauDirector
FacilitiesPlanningBureau
LosAngelesCountySheriff’sDepartment
211WestTempleStreet
LosAngeles,California90012
Attention:PlanningSection
Shouldyouhaveanyquestionsregardingthismatter,pleasecontactme,at (323)626-5657,oryourstaffmaycontactMs.BeeBeePee,ofmystaff,at (323)526-5697.
Sincerely,
ROBERTG.LUNA,SHERIFF
TraceyJue,BureauDirector
FacilitiesPlanningBureau
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SH-AD-32A
(3123)
COUNTY
OF
LOS
ANGELES
SHERIFF’S
DEPARTMENT
“/1
Tradilion
of
Service
Since
1850
DATE:
July
16,
2024
FILE
NO:
OFFICE
CORRESPONDENCE
FROM:
IN
DIEZ,
CAPTAIN
TO:
TRACEY
JUE,
BUREAU
SANTA
CLARITA
VALLEY
DIRECTOR
FACILITIES
STATION
PLANNING
BUREAU
SUBJECT:
REVIEW
COMMENTS
ON
THE
INITIAL
STUDY/MITIGATED
NEGATIVE
DECLARATION
FOR
SANTA
CLARITA
RIVERVIEW
DEVELOPMENT
PROJECT
(MASTER
CASE
21-205)
Santa
Clarita
Valley
Sheriffs
Station
(Station)
reviewed
the
Initial
Study/Mitigated
Negative
Declaration
(IS/MND),
dated
June
2024,
for
the
Santa
Clarita
Riverview
Development
Project
(Project).
The
project
proposes
to
construct
318
residential
units
(122
detached
single-family
condos
and
196
attached
townhomes,
22 of
which
are
identified
as
affordable)
and
an
approximately
127,000
square-foot
light
manufacturing
industrial
building.
The
project
also
includes
a
community
recreation
area,
and
other
on-site
improvements
including
on-site
parking
and
landscaping.
The
project
site
is
approximately
35.2 acres
in
size
on
a
property
formerly
occupied
by
the
Saugus
Speedway
and
is
directly
adjacent
to
the
existing
Santa
Clarita
Metrolink
Station.
The
site
is
zoned
Mixed
Use
Corridor
and
is
within
the
Jobs
Creation
Overlay
Zone
and
the
Alquist
Priolo
Fault
Zone.
According
to
Section
XV
Public
Services
for
Police
Service
of
the
JS/MND
pages
74 and
76,
the
proposed
Project
is
expected
to
have
less
than
significant
impact
on
law
enforcement
services
provided
by
the
Station.
However,
the
proposed
Project
will
increase
current
residents,
employees
and
visitors,
daytime,
and
nighttime
population
of
the
Station’s
service
area,
which
will
generate
an
increased
demand
for
law
enforcement
services.
To
date,
the
Station
is
currently
understaffed.
However,
assigning
additional
law
enforcement
personnel
to
the
Station
to
meet
an
acceptable
service
ratio
will
require
modification
of
the
law
enforcement
services
contract,
for
additional
support
personnel
and
equipment
assets.
The
Project
Applicant
will
be
required
to
pay
all
applicable
development
fees
associated
with
the
Project,
such
as
a
law
enforcement
facilities
mitigation
fee,
as
applicable.
In
addition,
according
to
the
IS/MND
page
76 Police
Protection,
‘The
project
would
not
result
in
the
construction
or
expansion
of
police
facilities,
as
the
current
staffing
and
facilities
are
expected
to
be
sufficient
to
serve
the
project.
Therefore,
the
project
would
not
result
in
substantial
adverse
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) RiverviewDevelopmentProject-2-Jti)y18,2024
physicalimpactsassociatedwiththeprovisionofneworphysicallyaltered policefacilities.Assuch,impactswouldbelessthansignificant,andno mitigationmeasuresarenecessary.”TheStationwouldliketoclarifythat thelawenforcementfacilitiesmitigationfeewouldensureadditionalfunding forfacilityspace,andadditionalpersonnelresourcesandassetstoaddress theneedsasaresultoftheexpansionandwillneedtobereviewedbyyour CityandourContractLawEnforcementBureauincoordinationwithour Station.
TheStationwouldalsoliketonotethatthetraveldistancefromtheStation totheProjectSiteisapproximately2.9miles,not1.4milesasindicatedon SectionXVPublicServicesPoliceProtectionoftheIS/MNDpage76.
TheStationremainsconcernedthatcontinuedgrowthandintensificationof multi-uselanduseswithintheserviceareawillultimatelycontributeto significantcumulativeimpactsfromthisProjectandotherdevelopments previouslyapprovedwithintheCityonourdepartmentresourcesand operations.Itisreasonabletoexpectthat,althoughplanned,continued developmentwithinthecitywillleadtoasignificantincreaseinthedemand forlawenforcementservicesandfacilities.Meetingsuchdemandsrequires additionalresources,includingpatroldeputies,othersworndeputies, supportpersonnel,andattendantassets,suchaspatrolvehicles,support vehicles,communicationsequipment,weaponry,office
furnishings/equipment,etc.Resourcesshouldbeevaluatedasprojectsare completed.
TheProjectApplicantwillberequiredtopayallapplicabledevelopment feesassociatedwiththeProject,suchasthelawenforcementfacilities mitigationfee,asapplicable.
Also,theStationreviewedtheconceptdrawingsFigure3and4toprovide thefollowingcomments:
1.SpecialProtectionRequirementsorRecommendations:
a.TheDepartmentrecommendsthattheprinciplesofCrime
PreventionthroughEnvironmentalDesign(CPTED)are
incorporatedinthedesignplans.ThegoalofCPTEDisto
reduceopportunitiesforcriminalactivitiesbyemploying
physicaldesignfeaturesthatdiscourageanti-socialbehavior, whileencouragingthelegitimateuseofthesite.Theoverall
tenetsofCPTEDincludedefensiblespace,territoriality,
surveillance,lighting,landscaping,andphysicalsecurity.The Stationrecommendsinstallationofsecuritycamerastoreduce
opportunitiesforcriminalactivities,wherefeasible.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) Riverview
Development
Project
-3-
July
16,
2024
b.
The
proposed
Project
will
benefit
from
a
landscaping
maintenance
program
that
would
minimize
opportunities
for
individuals
to
hide.
The
Station
also
recommends
limiting
the
height
of
hedge-type
plants
around
security
gates
to
allow
visibility
from
the
street
and
trees
should
not
block
line
of
sight
of
building
addresses
from
street
patrol
car
height.
c.
The
installation
of
security
cameras
for
avideo
monitoring
system
and
building
lights
with
motion
sensors
is
beneficial,
where
feasible.
Appropriate
gate
hardware
such
as
keypad/keycard
access,
automatic
gate
closers,
and
tire
spike
strips
can
be
implemented
where
feasible
to
limit
unauthorized
access
and
for
easy
monitoring.
In
addition,
the
proposed
locations
of
exterior
building
security
cameras
shall
be
considered
in
areas
where
law
enforcement
can
adequately
identify
vehicle
license
plates
upon
entry/exit
into
the
proposed
Project
with
adequate
lighting
to
enhance
visibility.
Installation
of
security
cameras
inside
the
building
at
each
level’s
entry/exit
points,
at
the
elevators,
and
at
the
stairwells
can
be
considered
where
feasible.
d.
Effective
traffic
and
security
plans
be
developed
to
address
potential
issues
from
vandalism
and
burglaries
at
the
proposed
Project
site,
in
coordination
with
all
jurisdictional
approvals.
e.
A
Construction
Traffic
Management
Plan
should
also
be
established
as
part
of
the
proposed
Project
to
address
construction-related
traffic
congestion
and
emergency
access
issues.
Iftemporary
lane
closures
are
necessary
for
the
installation
of
utilities,
emergency
access
should
be
maintained
at
all
times.
Flag
persons
and/or
detours
should
be
provided
as
needed
to
ensure
safe
traffic
operations,
and
construction
signs
should
be
posted
to
advise
motorists
of
reduced
construction
zone
speed
limits.
f.
Provide
numerical
address
on
the
corner
of
the
building
that
can
be
easily
viewed
from
the
street.
g.
Where
feasible,
install
afence
or
CMU
wall
on
the
backside
of
the
property
adjacent
to
the
railroad
tracks
at
a
height
high
enough
so
that
itis
not
scalable
for
easy
access
into
the
proposed
property.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) RiverviewDevelopmentProject-4-Ju)y18,2024
h.Cityconsidertypesoflightmanufacturingandthevehicular
trafficassociatedwithittominimizetrafficcongestionand/or opportunitiesforvehiclecollisionsonSoledadCanyonRoad.
Atthistime,theStationhasnofurthercommentsontheproposedProject.
However,theStationreservestherighttoamendorsupplementour assessmentuponsubsequentreviewsoftheproposedProjectonce additionalinformationbecomesavailable.
ThankyouforincludingtheStationinthereviewprocessfortheproposed Project.Shouldyouhaveanyquestionsregardingthismatter,please contactpleasecontactOperationsLieutenants,BrandonBarclayat(661)- 287-5702.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205))
ATTACHMENT C
Additional Information Developed to Support the Final IS/MND Riverview Development Project
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205))
Memorandum
HELIX Environmental Planning, Inc.
16485 Laguna Canyon Road, Suite 150
Irvine, CA 92618
949.573.9450 tel
619.462.0552 fax
www.helixepi.com
Date: August 26, 2024
To: Peter Vanek, Integral Communities
From: Lauren Singleton, Senior Biology Project Manager
Subject: Summary of the 2024 Crotch’s Bumble Bee Focused Survey Results for the Riverview Project
HELIX Project: 00357.00145.001
Message:
HELIX Environmental Planning, Inc. completed presence/absence survey for the Crotch’s bumble bee (Bombus crotchii), a candidate species under the California Endangered Species Act (CESA) for the Riverview Project (project) located in the City of Santa Clarita, Los Angeles County, California. The survey was performed in accordance with survey guidelines outlined in the California Department of Fish and Wildlife’s (CDFW) Survey Considerations for CESA Candidate Bumble Bee Species.1 Focused surveys were completed on August 23, 2024.
The initial habitat assessment and first survey were conducted on the same day, with all three surveys spaced at least two weeks apart within the Crotch’s bumble bee colony active period (April to August).
Crotch’s bumble bee surveys were conducted by slowly walking throughout suitable habitat within the project site, accounting for suitable Crotch’s bumble bee nesting locations, pollen and nectar sources, and foraging bumble bee activity. Table 1, Survey Information, details the survey dates, times, and conditions.
1 California Department of Fish and Wildlife. 2023. Survey Considerations for CESA Candidate Bumble Bee Species. June 6.
Available at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline. Accessed August 2, 2024.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205))
Memorandum to Peter Vanek Page 2 of 2
August 26, 2024
Table 1
SURVEY INFORMATION
Site
Visit
Survey
Date Biologist Time
(Start/Stop)
Weather Conditions
(Start/Stop)
HA1/1 07/19/2024 Cache Tucker2
Taylor Chase3 0745/1145 72F, wind 1-3 mph, 5% cloud cover 88F, wind 5-7 mph, 0% cloud cover
2 08/08/2024 Taylor Chase 0900/1100 82F, wind 2-3 mph, 0% cloud cover 89F, wind 3-4 mph, 0% cloud cover
3 08/23/2024 Taylor Chase 1300/1430 81F, wind 4-6 mph, 0% cloud cover 86F, wind 8-12 mph,4 0% cloud cover
1 Habitat assessment
2 Biologist attended Bombus crotchii Workshop - 2024 University of California Riverside Department of Entomology 3 Biologist attended Bombus Workshop - 2024 The Natural History Museum San Diego 4 Wind speed was below 8 mph until just before the survey was completed when winds increased speed. Flying insects were observed throughout the duration of the survey.
Approximately 12 acres of potential Crotch’s bumble bee habitat was identified on the project site, which included California buckwheat scrub, California sagebrush scrub, chamise chaparral, upland mustards, and disturbed habitat. During the first survey, suitable habitat was slowly walked and no more than three acres of suitable habitat was covered per hour per biologist. During the second and third surveys, most plants were either dead or in seed. Flowering plants within the areas identified as potential habitat were scarce (less than one percent cover). Therefore, the potential habitat was surveyed in fewer hours, with the biologist only concentrating on plants that had flowers at the time of the survey. No Bombus species were observed during the three surveys. Crotch’s bumble bee individuals or nests were not detected during the survey effort and are presumed to be absent from the project site. Multiple honey bee (Apis mellifera) hives were observed within the project site, which may outcompete bumble bees for nectar sources.
A focused survey report is currently being prepared and will be provided by September 13, 2024.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205))
MEMORANDUM
To: David Peterson, Senior Planner-City of Santa Clarita From: Michael Cady, Senior Biologist
Subject: Dudek Response to California Department of Fish and Wildlife Comments for the Riverview Development Project, Mitigated Negative Declaration (SCH#2024061060) Date: September 16, 2024
cc: Bobbette Biddulph, SWCA; Peter Vanek, Integral Communities; Carey Fernandes, Dudek; Chelsea Ohanesian, Dudek
The following is Dudek’s response to the comments California Department of Fish and Wildlife (CDFW) supplied in a letter dated July 11, 2024, after their review of the Biological Resources section of the Mitigated Negative Declaration that was prepared for the Riverview Development Project.
CDFW Comment Response
Crotch’s Bumble Bee
The Project will impact Crotch’s bumble bee. CDFW does not provide evidence or definitive proof that this impact will occur. Helix Environmental
Planning conducted surveys for the species in 2024
using CDFW’s guidelines within the recommended
survey period and the results were negative. As such,
the species is expected to be currently absent from the project site.
The Project may result in temporal or permanent loss
of suitable nesting and foraging habitat of Crotch’s
bumble bee.
The project will impact 6.04 acres of vegetation
communities (Eriogonum fasciculatum var. foliolosum-
Hesperoyucca whipplei Association; Artemisia
californica, Artemisia californica- Eriogonum
fasciculatum Association; Adenostoma fasciculatum-
Eriogonum fasciculatum Association) that support
floral resources that are known to be used by the
species, with Eriogonum fasciculatum being associated
as a nectar source. Dudek’s experience with the
species over the past two years of surveys in the Santa Clarita Valley is the species has a strong preference for sage (Salvia ssp.) and deerweed (Acmispon glaber). A
few white sage (Salvia apiana) were observed but did
not rise to the level to be included as co-dominant in
any of the asspciations. The project is within a region that has abundant natural open space areas in the hills surrounding the Santa Clarita Valley that support floral resources used by the species. Some of these areas
are managed by Mountains Recreation and
Conservation Authority, Angeles National Forest, and
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 2 CDFW Comment Response
State Parks. As such, the loss of 6.04 acres of foraging habitat is not expected to be significant.
Project ground-disturbing activities may cause death
or injury of adults, eggs, and larva; burrow collapse;
nest abandonment; and reduced nest success.
CDFW does not provide evidence that this impact is
likely, or that such an impact would be significant. Helix Environmental Planning conducted surveys for the
species in 2024 using CDFW’s guidelines within the
recommended survey period and the results were
negative.
While there is no evidence of a potentially significant impact, MM-BIO-3 will be revised per the following to
address this concern:
MM-BIO-3 Biological Monitoring. Prior to the issuance
of a grading permit, the Applicant shall submit the
qualifications of the biologist(s) to the City for review and approval. The Applicant shall fund a City-approved, Biological Monitor during Project construction to
monitor construction activities and to ensure
compliance with all mitigation measures. The Biological Monitor shall be present on site during all native
vegetation removal and initial ground disturbance
activities in undeveloped areas. Each day prior to the
commencement of activities, the Biological Monitor
shall be responsible for conducting a pre-construction
clearance survey and any wildlife (common or special-
status) will be relocated offsite to a City-approved area.
With regard to the Crotch bumble bee only, if
construction activity will impact the 6.04 acres of
potential foraging and nesting habitat(native vegetation communities) during the Crotch bumble bee nesting
period (February 1 through October 31), the Biological
Monitor shall conduct a pre-construction survey for
Crotch bumble bee within the aforementioned 6.04
acres of natural vegetation area prior to the start of
ground-disturbing construction activities within that
6.04 acres occurring during the Crotch bumble bee
nesting period (February 1 through October 31). The
survey shall ensure that no nests for Crotch bumble
bee are located within that 6.04-acre area. The pre-
construction survey shall be based on
recommendations described in the “Survey
Considerations for California Endangered Species Act
(CESA) Candidate Bumble Bee Species,” released by
the California Department of Fish and Wildlife (CDFW)
on June 6, 2023, or the most current at the time of
construction.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 3 CDFW Comment Response
The focused survey will be performed by a Biological
Monitor with a CDFW-issued Scientific Collection Permit (SCP) in surveying for bumble bees and include at least three (3) survey passes that are not on sequential days or in the same week, preferably spaced two to four
weeks apart. The timing of these surveys shall coincide with the Colony Active Period (April 1 through August
31 for Crotch bumble bee). Surveys may occur between
1 hour after sunrise and 2 hours before sunset.
Surveys will not be conducted during wet conditions
(e.g., foggy, raining, or drizzling) and surveyors will wait at least 1 hour following rain. Surveys may be
conducted earlier than April 1 if other bees or
butterflies are flying in the native vegetation
communities on the project site. Surveys shall not be
conducted when it is windy (i.e., sustained winds
greater than 8 mph). Within non-developed habitats,
the Biological Monitor shall look for nest resources
suitable for bumble bee use. Ensuring that all nest
resources receive 100% visual coverage, the biologist
shall watch the nest resources for up to five minutes,
looking for exiting or entering worker bumble bees.
Worker bees should arrive and exit an active nest site
with frequency, such that their presence would be
apparent after five minutes of observation. If a bumble bee worker is detected, then a representative shall be
identified to species. If a nest is suspected, the
Biological Monitor can block the entrance of the
possible nest with a sterile vial or jar until nest activity is confirmed (no longer than 30 minutes).
Identification will include the SCP-permitted Biological Monitor netting/capturing the representative bumble
bee in appropriate insect nets, per the protocol in U.S.
National Protocol Framework for the Inventory and
Monitoring of Bees. The bee shall be placed in a clear
container for observation and photographic
documentation if able. The bee will be photographed
using a macro lens from various angles to ensure
recordation of key identifying characteristics. If bumble bee identifying characteristics cannot be adequately
captured in the container due to movement, the
container will be placed in a cooler with ice until the bumble bee becomes inactive (generally within 15
minutes). Once inert, the bumble bee shall be removed
from the container and placed on a white sheet of
paper or card for examination and photographic
documentation. The bumble bee shall be released into
the same area from which it was captured upon
completion of identification. Based on implementation
of this method on a variety of other bumble bee
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 4 CDFW Comment Response
species, they become active shortly after removal from
the cold environment, so photography must be
performed quickly.
If Crotch bumble bee nests are not detected, no further mitigation would be required. The mere presence of
foraging Crotch bumble bees would not require
implementation of additional minimization measures
because they can forage up to 10 kilometers from their
nests. If nest resources occupied by Crotch bumble bee
are detected within the construction area, no
construction activities shall occur within 100 feet of the nest, or as determined by the SCP-permitted Biological
Monitor through evaluation of topographic features or
distribution of floral resources. The nest resources will be avoided for the duration of the Crotch bumble bee
nesting period (February 1 through October 31).
Outside of the nesting season, it is assumed that no
live individuals would be present within the nest as the daughter queens (gynes) usually leave by September,
and all other individuals (original queen, workers,
males) die.
A written survey report will be submitted to the City
within 30 days of the pre-construction survey. The
report will include survey methods, weather conditions, and survey results, including a list of insect species
observed and a figure showing the locations of any
Crotch bumble bee nest sites or individuals observed.
The survey report will include the qualification/resume of the SCP-permitted Biological Monitor for
identification of photo vouchers, detailed habitat
assessment, and photo vouchers. If Crotch bumble bee
nests are observed, the survey report will also include recommendations for avoidance, and the location
information will be submitted to the California Natural Diversity Database (CNDDB) at the time of, or prior to, submittal of the survey report.
The on-site vegetation provides foraging
opportunities and there is limited nesting potential
within the undeveloped northwestern area of the
Project site. Crotch’s bumble bee primarily nest
underground in abandoned small mammal burrows
but may also nest under perennial bunch grasses or
thatched annual grasses, underbrush piles, in old
bird nests, and in dead trees or hollow logs.
The initial survey found few small mammal burrows,
but no perennial bunch grasses or thatched annual
grasses, underbrush piles, old bird nests, and dead
trees or hollow logs were observed. As such, nesting
opportunities were considered to be very low on the
project site.
Further, Helix Environmental Planning conducted
surveys for the species in 2024 using CDFW’s
guidelines and the results were negative. As such, the
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 5 CDFW Comment Response
species is expected to be currently absent from the
project site.
While the Project site may provide limited nesting
habitat, the possibility of Crotch’s bumble bee to be
present on site cannot be completely ruled out
considering that the general survey was a single
survey conducted two years ago outside the
timeframe (April to August) for highest detection
probability.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site.
In addition to limited surveys, the MND does not
discuss the moderate potential for Crotch’s bumble
bee to be foraging and/or nesting within the Project
site.
The MND determined that the species was not
expected to nest on site and the impacts to potential
foraging habitat was not significant. This was
confirmed by the negative results of Helix
Environmental Planning’s surveys for the species in
2024 using CDFW’s guidelines and the results were
negative. As such, the species is currently absent from the project site.
The MND also does not provide mitigation measures
directly related to Crotch’s bumble bee. A mitigation
measure should be incorporated in the MND to
include focused surveys to confirm
presence/absence of Crotch’s bumble bee on the
Project site prior to Project activities.
MM-BIO-3 will be revised as outlined above.
Without focused surveys, individual Crotch’s bumble
bee and/or nesting sites may go undetected
resulting in incidental take of a CESA protected
species. If presence of Crotch’s bumble bee is
confirmed, the Project would result in loss of
confirmed habitat for this species.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site.
The Project may substantially reduce and adversely
modify habitat as well as reduce and potentially
impair the viability of populations of Crotch’s bumble
bee.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site. The project is within a
region that has abundant natural open space areas in
the hills surrounding the Santa Clarita Valley that
support floral resources used by the species. Some of
these areas are managed by Mountains Recreation
and Conservation Authority, Angeles National Forest,
and State Parks. As such, the loss of 6.04 acres of
potential foraging habitat (Eriogonum fasciculatum var. foliolosum-Hesperoyucca whipplei, Artemisia
californica- Eriogonum fasciculatum, and Adenostoma
fasciculatum-Eriogonum fasciculatum associations) is
not expected to be significant.
The Project may also reduce the number and range
of the species without considering the likelihood that
special status species on adjacent and nearby
natural lands may rely upon the habitat that occurs
on the proposed Project site.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 6 CDFW Comment Response
The MND should be amended to provide a discussion
on habitat suitability for Crotch’s bumble bee within
and adjacent to the Project site. The discussion
should also disclose the Project’s potential direct and indirect impacts on Crotch’s bumble bee. If the
Project may impact Crotch’s bumble bee, the MND
should provide measures to minimize, and/or
mitigate potential impacts to Crotch’s bumble bee as
well as habitat supporting the species. The
discussion should be of a depth and scope that a
CESA Incidental Take Permit can be issued based on
the analysis provided in the MND.
The results of Helix Environmental Planning’s 2024
surveys for the species, which were negative. MM-BIO-
3 will be revised as outlined above.
The Project proponent shall retain a qualified
entomologist with the appropriate handling permits
to conduct focused surveys. Focused surveys shall
follow CDFW’s Survey Considerations for California
Endangered Species Act Candidate Bumble Bee
Species (CDFW 2023). Focused surveys shall also be
conducted throughout the entire Project site during
the appropriate flying season to ensure no missed
detection of Crotch’s bumble bee occurs. Survey
results, including negative findings, shall be
submitted to CDFW and the City prior to
implementing Project ground-disturbing activities.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site.
If Crotch’s bumble bee is detected the Project
proponent shall coordinate with CDFW and obtain
appropriate take authorization from CDFW (pursuant
to Fish & Game Code, § 2080 et seq). The Project
proponent shall comply with the mitigation measures
detailed in the take authorization issued by CDFW.
The Project proponent shall provide a copy of a fully
executed take authorization to the City prior to
implementing Project ground-disturbing activities and
vegetation removal.
Helix Environmental Planning conducted surveys for
the species in 2024 using CDFW’s guidelines and the
results were negative. As such, the species is currently absent from the project site.
Slender Mariposa Lily
MM-BIO-1 does not adequately offset Project-related
impacts on slender mariposa lily.
Project ground-disturbing activities (i.e., grading,
vegetation removal) would result in loss of suitable
habitat, loss of population, and direct mortality of
slender mariposa lily.
The existing mitigation measure adequately mitigates
potential impact to the slender mariposa lily.
It should be noted that Table 1 (Vegetation
Communities and Land Covers in the Study Area) had
an error regarding the number of acres of the Artemisia californica Association. Dudek reran the geospatial
analysis, and it should be 0.26 acres of Artemisia
californica Association and not 5.23 acres, with a total of 6.04 acres of native vegetation communities that
could support slender mariposa lily, and not 11.01
acres. All other acre calculations in the table are
correct.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 7 CDFW Comment Response
The density of the shrub vegetation in the area with
suitable habitat for the species (limited to the knoll on the western end of the site) is expected to limit the
number of individuals that could potentially be
impacted. This determination is informed by Dudek’s
extensive experience with the species in the Santa
Clarita Valley, including on areas adjacent to the
project site. This is also based upon CDFW’s own
micro-habitat description for the species that describes it occurring on shaded foothill canyons, and often on
grassy slopes within other habitats1, which are not
present in the site. Slender mariposa lily is not a listed species, so impacts must be measured by the loss to
the species as a whole and not on the individual level.
The California Natural Diversity Database (CNDDB) has
records of the species throughout the Santa Clarita
Valley, with locations that have hundreds of individuals.
Therefore, the loss of a few individuals would not
reduce the number of individuals such that the species
population as a whole would be compromised, and
thus, the loss would be considered a less-than-
significant impact under CEQA.
As such, MM-BIO-1 as originally written provides an
equivalent compensation for the loss of those
individuals; however, MM-BIO-1 will be revised per the
following to provide additional mitigation and benefit:
1 California Department of Fish and Wildlife. 2024. California Natural Diversity Database (CNDDB); RareFind query for Calochortus clavatus var. gracilis. Accessed September 2024. https://apps.wildlife.ca.gov/rarefind/view/RareFind.aspx
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 8 MM-BIO-1 Pre-Construction Rare Plant Survey and
Conservation Seed Collection. Prior to issuance of a
grading permit, the Applicant shall have a qualified
biologist (the Applicant shall submit the qualifications of the biologist to the City for review and approval)
conduct a focused rare plant survey for slender
mariposa lily within the undeveloped portion of the
Project site during the appropriate blooming period
(March through June). The survey will consist of a
maximum of three passes, with one in from March
April, May, and to June. Reference site checks will be
made for the species to determine if the species are
blooming in the Project vicinity. If the reference site check is positive for the species, then the following
survey will determine the presence or absence of the
species within the Project. If the reference site was
positive for a species, and the survey of the Project site is negative, no further surveys would be required, and
this mitigation measure would be considered satisfied.
The surveys will conform to CNPS’ Botanical Survey
Guidelines; CDFW’s Protocols for Surveying and
Evaluating Impacts to Special Status Native Plant
Populations and Natural Communities; and USFWS’
Guidelines for Conducting and Reporting Botanical
Inventories for Federally Listed, Proposed, and
Candidate Plants. The results of the surveys will be
documented in a report and submitted to the City.
Should any of the species be found at a count of 20 or
higher, then construction of the occupied location shall be delayed, and one of the following measures will be
implemented: until the individuals have gone to seed.
Seeds shall be collected once the seed has matured, but prior to the seed capsules opening to disperse the seed.
Seeds shall be stored in breathable paper bags in a cool, dry, and dark place. The seeds will then be donated to a City-approved local conservation organization (e.g.,
Friends of the Santa Clara River) to be used in
restoration projects.
Alternative No. 1: The Project shall compensate for the loss of the species at a 1:1 ratio through the planting of replacement slender mariposa lily bulbs within the
landscaped areas of the residential portion of the
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 9 CDFW Comment Response
Project, which will be maintained by the future
homeowner’s association in perpetuity.
Alternative No. 2: If replacement slender mariposa lily bulbs cannot be reasonably located to implement the
first alternative, the Project shall compensate for the loss of discovered specimens by collecting the seeds of the onsite individuals. Seed collection and storage will be conducted by an entity with extensive experience
performing those tasks (such as S&S Seeds or the
California Botanical Garden) and approved by the City.
The Project Applicant will then work with City-approved local conservation organization (e.g., Friends of Santa Clara River) to be used in restoration projects. The
Applicant shall provide the City with documentation of
the seeds use.
Seed collection alone is not sufficient to offset
Project impacts. According to the California Natural
Diversity Database, there are recorded observations
of slender mariposa lily near the Project site (CDFW
2024b). Additionally, the MND also states that there
is a moderate potential for slender mariposa lily to
occur on the Project site (page 28). While CDFW
concurs that focused surveys should be done during
the appropriate bloom period for highest detection
probability, we disagree that protocol surveys and
seed collection makes impacts to the species less
than significant with mitigation. Compensatory
mitigation should be provided if any individual
slender mariposa lily is observed, especially since
this rare plant is threatened in
California.
Slender mariposa lily is not a listed species, so impacts should be measured by the loss to the species as a
whole and not on the individual level per CEQA. As
stated in Section 15065 (Mandatory Findings of
Significance), the significance of the impacts must be
seen in the following context: (1) substantially degrade the quality of the environment, (2) substantially reduce the habitat of a fish or wildlife species, (3) cause a fish or wildlife population to drop below self-sustaining
levels, (4) threaten to eliminate a plant or animal
community, or (5) reduce the number or restrict the
range of a rare or endangered plant or animal. The
small amount of potential habitat for the species that
the project would impact is not expected to meet any of those findings. As such, MM-BIO-1 as originally drafted provides an equivalent compensation for the loss of
those individuals. However, in response to the CDFW’s
comment and direction, MM-BIO-1 has been revised to
first require the Project to replace those specimens
that may be loss through planting replacements within
the Project site. However, if that is not reasonably
possible, the Project may still rely on seed collection, as an equivalent alternative.
CDFW is also concerned that the MND does not
provide biological justification as to why a count of
20 individuals is the minimum threshold. If slender
mariposa lily is observed on the Project site, there is a possibility for multiple bulbs to exist underground
that may or may not have bloomed. Moreover,
handing seeds to a local organization for restoration
This determination is based upon a CEQA
determination of what constitutes a significant impact, which is how non-listed species are analyzed, and not a biological determination. However, MM-BIO-1 has been
revised to mitigate impact to any individuals found and has removed the 20 individual threshold.
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Attachment: MC21-205 Riverview ISMND Response to Comments (Conformance Review - Riverview Project (Master Case 21-205)) SUBJECT: DUDEK RESPONSE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE COMMENTS FOR THE RIVERVIEW DEVELOPMENT PROJECT, MITIGATED NEGATIVE DECLARATION (SCH#2024061060) 10 CDFW Comment Response
opportunities does not guarantee successful creation
of a slender mariposa lily population.
As currently written, Mitigation Measure BIO-1 does
not commit to mitigation that would adequately
offset the direct loss of slender mariposa lily, nor
does it adopt specific performance standards and
actions pertaining to management of mitigation
actions. The MND does not disclose where or when
the seeds would be used in restoration projects. If
restoration projects do not utilize the seeds until
several years after collection, they may become
inviable. Moreover, the mitigation measure does not
provide success criteria for these restoration projects to ensure successful mitigation is achieved. In
addition to no success criteria, long-term
management actions for these restoration projects is
not outlined in the mitigation measure. With limited
information and no enforceable actions regarding the
restoration projects, the proposed mitigation would
be considered deferred.
The density of the shrub vegetation in the area with
suitable habitat for the species is expected to limit the number of individuals that could potentially be
impacted. This determination is informed by Dudek’s
extensive experience with the species in the Santa
Clarita Valley on the Newhall Ranch project. This is also based upon CDFW’s own micro-habitat description for
the species that describes it occurring on shaded
foothill canyons, and often on grassy slopes within
other habitats2, which are not present in the site.
That said, while the existing mitigation measure is
sufficient, as explained above, in response to the
CDFW’s comment and direction, MM-BIO-1 has been
revised to first require the Project to replace those
specimens that may be loss through planting
replacements within the Project site. However, if that is not reasonably possible, the Project may still rely on
seed collection, as an equivalent alternative.
Impacts on rare flora could be considered a
significant effect on the environment. Plants with a
CRPR of 1B are rare throughout their range, endemic
to California, and are seriously or fairly threatened...
Impacts to CRPR 1B plant species and their habitat
may result in a mandatory finding of significance
because the Project would have the potential to
threaten to eliminate a plant community and
substantially reduce the number or restrict the range
of an endangered, rare, or threatened species (CEQA
Guidelines, § 15065).
Slender mariposa lily is not a listed species, so impacts must be measured by the loss to the species as a
whole and not on the individual level. The
approximately 6.04 acres of potential habitat for the
species that the project would impact is not expected
to threaten to eliminate a plant community and
substantially reduce the number or restrict the range of an endangered, rare, or threatened species. The
CNDDB has records of the species throughout the
Santa Clarita Valley, with locations that have hundreds of individuals. As such, MM-BIO-1 as both originally
drafted and now revised provides sufficient mitigation
to mitigate impact to any individuals found.
Additionally, Mitigation Measure BIO-1 is considered
deferred mitigation [CEQA Guidelines, §
15126.4(a)(1)(B)]. Insufficient mitigation may result
in unmitigated temporal or permanent impacts to a
rare plant species. Subsequently, the Project would
continue to have a substantial adverse direct,
indirect, and cumulative effect, either directly or
through habitat modifications, on any species
identified as a candidate, sensitive, or special status species by CDFW.
The density of the shrub vegetation in the
approximately 6.04-acre area with suitable habitat for
the species is expected to limit the number of
individuals that could potentially be impacted. This
determination is informed by Dudek’s extensive
experience with the species in the Santa Clarita Valley.
This is also based upon CDFW’s own micro-habitat
description for the species that describes it occurring on shaded foothill canyons, and often on grassy slopes
2 California Department of Fish and Wildlife. 2024. California Natural Diversity Database (CNDDB); RareFind query for Calochortus clavatus var. gracilis. Accessed September 2024. https://apps.wildlife.ca.gov/rarefind/view/RareFind.aspx
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within other habitats3, which are not present in the site.
The approximately 6.04 acres of potential habitat for
the species that the project would impact is not
expected to threaten to eliminate a plant community
and substantially reduce the number or restrict the
range of an endangered, rare, or threatened species.
The CNDDB has records of the species throughout the
Santa Clarita Valley, with locations that have hundreds of individuals. As such, MM-BIO-1, as both originally
proposed and revised, provides an equivalent
compensation for the loss of those individuals.
Recommended Potentially Feasible Mitigation
Measure(s)
The density of the shrub vegetation in the area with
suitable habitat for the species is expected to limit the number of individuals that could potentially be
impacted. Acquisition of, maintenance of, and
establishing an endowment over, mitigation lands for
the loss of a few individuals is not proportionate to the impact, as the level of impact that would occur to the
population of the species as a whole is negligible.
Therefore, introduction of this new suggested
mitigation measures is not appropriate mitigation
under CEQA, and MM-BIO-1, as originally written and
revised, adequately mitigates impacts to the species.
Impacts on California Species of Special Concern (SSC)
The mitigation measure proposed in the MND may
not be sufficient to minimize Project impacts on SSC.
Injury or death of SSC may occur during the transit
process when relocating a species from one area to
another. With a high level of risk involved in
relocating species, SSC should be allowed to move
out of harm’s way on their own accord rather than
actively relocated. In addition to relocation of SSC,
the mitigation measures do not outline any
compensatory mitigation if SSC presence is
confirmed. Given that habitat loss on a local and
regional scale is a major cause of population decline
for these SSC, removal of confirmed SSC habitat
would be considered a significant impact and should
be mitigated appropriately.
These are not listed species. MM-BIO-2, which provides
a pre-construction survey where any special-status
species found will be relocated out of harm’s way, and
MM-BIO-3, which provides Biological Monitoring during
initial vegetation removal and grading, provide
sufficient mitigation by avoiding and minimizing direct impacts to individuals of the species that may be
present. Acquisition of, maintenance of, and
establishing an endowment over, mitigation lands for
the handling of potentially a few individuals is not
proportionate to the impact, as the level of impact that would occur to the population of the species as a whole is negligible based upon presence of vast amount of
open space in the region that is expected to provide
suitable habitat for those species. Therefore,
introduction of the suggested mitigation measures is
not appropriate mitigation under CEQA, and MM-BIO-2
and MM-BIO-3, as written, adequately mitigates
impacts to the species.
3 California Department of Fish and Wildlife. 2024. California Natural Diversity Database (CNDDB); RareFind query for Calochortus clavatus var. gracilis. Accessed September 2024. https://apps.wildlife.ca.gov/rarefind/view/RareFind.aspx
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CITY OF SANTA CLARITA
City Council
Regular Meeting
Joint Meeting with
Board of Library Trustees
Hereinafter the titles Mayor, Mayor Pro Tem, Councilmember, City Manager, City Attorney, and City Clerk may be used also to indicate Mayor/Chair/President, Mayor Pro Tem/Vice-Chair/Vice President, City Manager/Executive Director, City Attorney/Counsel, and City Clerk/Secretary ~Minutes~
Tuesday, October 8, 2024 6:00 PM City Council Chambers
INVOCATION
Councilmember Gibbs delivered the invocation.
CALL TO ORDER
Mayor Smyth called to order the Joint Regular meeting of the City Council and Board of Library Trustees at 6:01 p.m.
ROLL CALL
All Councilmembers were present.
FLAG SALUTE
Councilmember Gibbs led the flag salute.
EXECUTIVE MEETING
This time has been set aside for Councilmembers to review the agenda and obtain any further information that may be needed. Council will also discuss each individual item during the course of the meeting with the exception of the Consent Calendar, which may be approved in its entirety by one motion, unless there is a request to pull an item for discussion. No action will be taken on public agenda items during the Executive Meeting.
AWARDS AND RECOGNITIONS
Mayor Smyth announced that the City proclaims October 2024 as Filipino-American History Month and invited Mul Tayoba, President of the Fil-Am Association of SCV, and other representatives to the dais to accept the proclamation and take a photo.
Councilmember Gibbs proclaimed the month of October 2024 as German-American Heritage Month in Santa Clarita and invited Professor Heidi Esslinger and her students from College of the Canyons up to the dais to receive the proclamation and take a photo. 3 Packet Pg. 464
Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
Mayor Pro Tem Miranda encouraged the community to raise awareness and support loved ones who are diagnosed with cancer and metastatic breast cancer, announced that the City recognizes October 13 as National Breast Cancer Awareness Day, and proclaimed October 2024 as Breast Cancer Awareness Month. Councilmember Miranda invited his daughter, Eva Crawford, to the dais to accept the proclamation and take a photo.
PUBLIC PARTICIPATION
Addressing the Council was Donald Harlan regarding Regional Early Action Planning Grants Program funds, the Vista Canyon Water Factory, and the Tesoro Valle Project; Jeremy Sparage regarding bike lanes on Valencia Boulevard; Peggy Stabile regarding the upcoming election; James Hall regarding the Eclipse Theater LA’s future events; Dillon Negrete regarding speedbumps on Arcadia Street and developer fees; Glenda (no last name provided) regarding the Planning Commission and City Council proclamations; and Di Zimmerman regarding the upcoming election.
STAFF COMMENTS
City Manager Ken Striplin indicated that staff would reach out to Mr. Sparage to discuss the Non-Motorized Transportation Plan; commented that staff would reach out to Mr. Negrete regarding the feasibility of speed bump installation, clarified that developer fees are under the control of the state, and recommended Mr. Negrete seek more information from the school board of trustees; and spoke of a battery storage project that went through the Planning Commission as an extensively noticed and public project and shared that information involving the project is available to the public on the City’s agenda web page.
Councilmember Weste requested staff take a look at Arcadia Street.
Councilwoman McLean suggest that there may be a better way to address the safety concerns on Arcadia Street, rather than the installation of speed bumps.
COMMITTEE REPORTS/COUNCILMEMBER COMMENTS
Councilmember Weste complimented staff on the Saugus trail; she also spoke of attending the Hart Park Pow Wow, remarking that it was a great event and looking forward to the City taking over the park.
Mayor Pro Tem Miranda announced that from October 15 through October 17 the exercise staircase at Central Park will be closed a portion of each day for preparation on the River of Lights project; he also commented on the City breaking ground on two construction projects - expansion of David March Park and upgrades to Old Orchard Park.
Councilwoman McLean commented on attending the David March Park and Old Orchard Park grounding breaking events; mentioned that on September 28 the Santa Clarita Artist Association held their 2024 Annual Art Classic commenting on the talented people and remarking that the event was wonderful to attend; commented that on September 30 there were two transportation committee meetings, the Northern Corridor Cities and the San Fernando Valley Council of Governments Transportation Sub-Committee meeting, both of which advocate for safer road 3 Packet Pg. 465
Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
conditions; mentioned on October 6 the American Legion Post 507 held an awards ceremony for the California Boys and Girls State 2024, a program available to high school juniors exploring the mechanics of American government and politics, remarking that a group of students from various Santa Clarita high schools were sponsored by the post to participate in this program that sent them to Sacramento for a week and that the post is seeking sponsors for next year’s program; commented on an October 7 event at the Chabad of Santa Clarita Valley for the anniversary of the events on October 7, 2023, commented that The Signal reported Congressman Mike Garcia was in attendance and stated that Israel did not start the war, mentioned the text she sent to rabbi Mark Blazer expressing her sorrow for the lives lost in the horrendous attack last year, and wished for the terrorism to stop so everyone may live in peace.
Mayor Smyth announced the return of Pet Adoption Week, sharing that the City will cover all adoption fees for residents adopting an animal from the Castaic Animal Care Center through October 12, and invited the community to join the City on October 12 at Central Park from 9 a.m. to 12 p.m. when the center will bring some of the animals available for adoption; and spoke on the David March Park and Old Orchard Park upgrades as great additions to the community.
PUBLIC HEARINGS
ITEM 1
PROPOSED AMENDMENTS TO THE TESORO DEL VALLE PROJECT - MASTER CASE 24-176
The applicant, BLC Tesoro, LLC, is proposing amendments to the original conditions of approval, pre-annexation agreement, and community facilities district, for the Tesoro Del Valle project.
RECOMMENDED ACTION:
City Council:
1. Receive staff presentation;
2. Open the public hearing to receive testimony from the public;
3. Adopt a resolution amending the conditions of approval for the Tesoro Del Valle project;
4. Approve a modification to the Pre-Annexation Agreement between BLC Tesoro, LLC, and the City of Santa Clarita affecting the timing for the completion of the construction of the Copper Hill Bridge widening as it relates to the issuance of Certificates of Occupancy for the development;
5. Adopt a resolution approving amendments to the Joint Community Facilities Agreement and Acquisition Funding Agreement; and
6. Find the modifications to conditions of approval, the pre-annexation agreement, and community facilities district are exempt from review under the California Environmental Quality Act (CEQA) pursuant to the General Rule Exemption Section 15061(b)(3) of CEQA. 3 Packet Pg. 466
Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
Mayor Smyth opened the Public Hearing.
City Clerk Mary Cusick reported all notices required by law have been provided.
Senior Planner Dave Peterson provided the presentation.
Addressing the Council in opposition was Donald Harlan.
Councilwoman McLean spoke of a letter and photos received from Ross Pistone, inquiring whether his concerns were part of the original Tesoro or if they pertained to anything currently in front of the Council, and Mr. Peterson responded that Mr. Pistone’s concerns were related to Tesoro Highlands, the second phase of the project currently under construction. Councilwoman McLean had a follow up question as to whether the letter had anything to do with the agreement Council would amend as part of this item’s action, and Mr. Peterson confirmed it did not.
Adopted Resolution Nos. 24-65 and 24-66.
RESULT: APPROVED [UNANIMOUS]
MOVER: Laurene Weste, Councilmember
SECONDER: Bill Miranda, Mayor Pro Tem
AYES: Smyth, Miranda, Gibbs, McLean, Weste
CONSENT CALENDAR
RESULT: APPROVED [UNANIMOUS]
MOVER: Jason Gibbs, Councilmember
SECONDER: Marsha McLean, Councilmember
AYES: Smyth, Miranda, Gibbs, McLean, Weste
ITEM 2
APPROVAL OF REGULAR MEETING MINUTES – The minutes are submitted for approval.
RECOMMENDED ACTION: City Council approve the minutes of the September 24, 2024, Regular Meeting
ITEM 3
CHECK REGISTER NO. 20
Check Register No. 20 for Period 08/23/24 through 09/05/24 and 09/12/24. Electronic Funds Transfers for the Period 08/26/24 through 09/06/24.
RECOMMENDED ACTION:
City Council approve and ratify for payment the demands presented in Check Register No. 20. 3 Packet Pg. 467
Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
ITEM 4
MEMORANDUM OF UNDERSTANDING FOR RECEIPT OF REGIONAL EARLY ACTION
PLANNING GRANTS PROGRAM FUNDS
Enter into a Memorandum of Understanding with the Southern California Association of Governments for receipt of Regional Early Action Planning Grants Program Funds.
RECOMMENDED ACTION:
City Council:
.
Adopt a resolution authorizing the City Manager or designee to execute a Memorandum of Understanding, in a form approved by the City Attorney, between the Southern California Association of Governments and the City of Santa Clarita for a Subregional Partnership Program Grant for purposes of receiving grant funding to prepare objective design and development standards for multifamily and mixed-use projects.
Addressing the Council was Donald Harlan.
Adopted Resolution No. 24-67
ITEM 5
VISTA CANYON WATER FACTORY - WATER TESTING CONTRACT
Consideration to award a three- month contract to Geosyntec Consultants, Inc., for water testing services at the Vista Canyon Water Factory.
RECOMMENDED ACTION:
City Council:
1. Award a three-month contract to Geosyntec Consultants, Inc., to provide water testing services for the Vista Canyon Water Factory in the amount of $93,000, and authorize a contingency in the amount of $9,300, for a total contract amount not to exceed $102,300.
2. Appropriate a one-time funding expenditure for $102,300 from the Vista Canyon Wastewater Standby fund balance (Fund 368), effective October 2024.
3. Authorize the City Manager or designee to execute all contracts and associated documents, subject to City Attorney approval.
Addressing the Council was Donald Harlan.
ITEM 6
SECURITY SERVICES CONTRACT FOR CITY PARKS AND FACILITIES This item considers awarding a contract to Good Guard Security for security services for City parks and facilities.
RECOMMENDED ACTION:
City Council:
1. Award a two-year contract to Good Guard Security, Inc., to provide security services for the 3 Packet Pg. 468
Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
City of Santa Clarita parks and facilities in the amount of $1,910,551, and authorize a contingency in the amount of $191,055, for a total contract amount not to exceed $2,101,606.
2. Authorize the City Manager or designee to execute up to three additional one-year renewal options beginning in year three, not to exceed the annual contract amount inclusive of contingency, plus an adjustment consistent with the appropriate Consumer Price Index upon request of the contractor, and contingent upon the appropriation of funds by the City Council in the annual budget for such fiscal year.
3. Authorize the City Manager or designee to execute all contracts and associated documents, subject to City Attorney approval.
Addressing the Council was Andrea Huerta.
ITEM 7
SECURITY SERVICES CONTRACT FOR THE SANTA CLARITA PUBLIC LIBRARY This item considers awarding a contract for the purposes of security services for the Santa Clarita Public Library.
RECOMMENDED ACTION:
City Council:
1. Award a two-year contract to Good Guard Security, Inc. to provide unarmed security guard services for the Santa Clarita Public Library in the amount of $227,155 and authorize a contingency of $22,716, for a total not to exceed annual amount of $249,871.
2. Authorize the City Manager or designee to execute up to three additional one-year renewal options beginning in year three, not to exceed the annual contract amount, inclusive of contingency, plus an adjustment consistent with the appropriate Consumer Price Index, upon request of the contractor, and contingent upon the appropriation of funds by the City Council in the annual budget for such fiscal year.
3. Authorize a one-time appropriation of $87,655 in the current fiscal year and an ongoing increase in Fiscal Year 2025-2026 of $116,871 from the Public Library Fund Balance (Fund 309) to expenditure account 3097412-516101.
4. Authorize the City Manager or designee to execute all contracts and associated documents, subject to City Attorney approval.
Addressing the Council was Andrea Huerta.
PUBLIC PARTICIPATION II
No additional requests to speak were received
ADJOURN
Mayor Smyth adjourned the Regular Meeting at 7:11 p.m.
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Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
______________________________________
MAYOR
ATTEST:
______________________________________
CITY CLERK
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Minutes Acceptance: Minutes of Oct 8, 2024 6:00 PM (Consent Calendar)
Agenda Item: 4
CITY OF SANTA CLARITA
AGENDA REPORT
CONSENT CALENDAR
CITY MANAGER APPROVAL:
DATE: October 22, 2024
SUBJECT: CHECK REGISTER NO. 21
DEPARTMENT: Administrative Services
PRESENTER: Brittany Houston
RECOMMENDED ACTION
City Council approve and ratify for payment the demands presented in Check Register No. 21.
BACKGROUND
Check Register No. 21 for the Period 09/06/24 through 09/19/24 and 09/26/24 in the aggregate amount of $8,431,444.69 inclusive of Electronic Funds Transfers for the Period 09/09/24 through 09/20/24 in the aggregate amount of $944,544.78.
FISCAL IMPACT
Adequate funds are available in the budgeted expenditure accounts to support the check register payments.
ATTACHMENTS
Memo - Check Register No. 21
Check Register No. 21 (available in the City Clerk's Reading File) 4 Packet Pg. 471
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Attachment: Memo - Check Register No. 21 (Check Register No. 21)
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Attachment: Memo - Check Register No. 21 (Check Register No. 21)
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Attachment: Memo - Check Register No. 21 (Check Register No. 21)
Agenda Item: 5
CITY OF SANTA CLARITA
AGENDA REPORT
CONSENT CALENDAR
CITY MANAGER APPROVAL:
DATE: October 22, 2024
SUBJECT: RESOLUTION SUPPORTING THE DESIGNATION OF THE CITY
OF SANTA CLARITA AS A CLEAN CALIFORNIA COMMUNITY
DEPARTMENT: Neighborhood Services
PRESENTER: Darin Seegmiller
RECOMMENDED ACTION
City Council adopt a resolution supporting the designation of the City of Santa Clarita as a Clean California Community.
BACKGROUND
The Clean California Community designation is a statewide program implemented by the California Department of Transportation in August 2024. Its purpose is to establish, recognize, and reward communities that demonstrate pride in keeping their environment clean, beautiful, and litter-free.
Communities that sign the Clean California Community pledge demonstrate commitment to maintaining a clean, green, and vibrant community for the well-being of all residents. Following this, the program criteria must be met within a year from the pledge's signing date. Criteria include the following categories:
• Organizing community cleanups
• Measuring cleanup progress
• Providing community and youth education
• Maintaining trash collection infrastructure
• Increasing greenspace and beautification
• Establishing collection drives and stakeholder partnerships
The City of Santa Clarita (City) currently meets the majority of the criteria, and it is anticipated that the City will meet the minimum requirements for the designation by June 2025. 5 Packet Pg. 475
In addition to officially promoting the City as a Clean California Community committed to a zero-litter goal, this designation benefits the City by allowing it to be recognized on state websites and social media posts, state-partnered media outreach, and priority access to national grant opportunities, educational materials, and volunteer cleanup kits. Other cities that have signed the pledge include Bakersfield, Fresno, Hawthorne, Irvine, Palmdale, Riverside, San Jose, and San Leandro.
Staff recommends adopting a resolution supporting the designation of the City of Santa Clarita as a Clean California Community.
ALTERNATIVE ACTION
Other action as determined by the City Council.
FISCAL IMPACT
There is no fiscal impact.
ATTACHMENTS
Clean California Resolution
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RESOLUTION NO. 24-_______
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA,
CALIFORNIA, SUPPORTING THE DESIGNATION OF THE CITY OF SANTA CLARITA
AS A CLEAN CALIFORNIA COMMUNITY
WHEREAS, the City of Santa Clarita, (City) united by a shared vision for a cleaner, greener community, seeks to elevate our community to a healthier quality of life; and
WHEREAS, the City aspires to maintain a commitment to cleanliness and environmental stewardship; and
WHEREAS, the State of California, in its pursuit of a cleaner, greener existence, has established the Clean California Community designation as a testament to communities that exemplify these values.
NOW THEREFORE, the City Council of the City of Santa Clarita, California, does hereby resolve as follows:
SECTION 1. The City solemnly pledges to pursue the criteria of becoming a designated Clean California Community.
SECTION 2. The City solemnly pledges to uphold the principles of the Clean California Community program, dedicating ourselves to fostering a community marked by cleanliness, sustainability, and civic pride.
SECTION 3. Through our collective efforts, the City pledges to maintain a clean, green, and vibrant community for the betterment of all residents.
SECTION 4. This resolution is effective immediately upon adoption.
SECTION 5. The City Clerk shall certify to the adoption of this resolution.
PASSED, APPROVED, AND ADOPTED this __ day of ________ 2024.
______________________________
MAYOR
ATTEST:
________________________________
CITY CLERK
DATE:__________________________
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Attachment: Clean California Resolution (CLEAN CALIFORNIA COMMUNITY DESIGNATION)
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss.
CITY OF SANTA CLARITA )
I, Mary Cusick, City Clerk of the City of Santa Clarita, do hereby certify that the foregoing Resolution No. 24- was duly adopted by the City Council of the City of Santa Clarita at a regular meeting thereof, held on the __ day of ________ 2024, by the following vote:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
______________________________
CITY CLERK
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Attachment: Clean California Resolution (CLEAN CALIFORNIA COMMUNITY DESIGNATION)