Checklist Form, Item c, has 2 determinations selected (Less than Significant, No Impact).
outdated older AQMP (1987, Figure E-1). APCD does not distinguish subregional airsheds within the South Central Coast Air Basin (SCAAB). Please remove reference.
different thresholds under the VCAP CD and would thus be required to under go project-specific evaluation to determine s pecific impacts to air quality, which would occur during the permitting process for that project ”. APCD would like to note that resid ential projects are not under the permitting authority of APCD, as permits are only issued to stationary sources such as commercial or industrial projects. As such, projects would only go through a project-specific evaluation if they are required to comply with CEQA with the City of Simi Valley. APCD is not part of this internal review. This would not include any specific projects contained in the project that would be claiming a CEQA exemption (infill development, existing facilities, affordable housing, etc.).
APCD believes this statement is misleading.
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may aid the City ’s 2030 General Plan’s policies (NR-9.3) listed in order to “ensure air quality impacts are reduced ” (MND, Page 42). These programs can be recommended as standard conditions of approval for the individual projects listed in the project as they undergo a permitting review.
APCD’s Incentive Programs reduce air pollutants that are harmful to human health and the environment. The incentive programs include EV vehicle infrastructure grant funding, replacing fossil-fueled vehicles with cleaner technology, and electric lawn mower trade-ins. More information can be found here on our District Incentive Programs Website Page.
APCD would also like to no te that General Plan Policies NR-9.4, -9.5, and -9.6 are enforceable only by recommending standard conditions of approval that are consistent with APCD Rules 50, Opacity, Rule 51, Nuisance, and Rule 55, Fugitive Dust. A copy of the standard template for this condition is found below. It is recommended to be used for all incoming projects contained in the project that will have construction operations and related air emissions.
FUGITIVE DUST
Purpose: To ensure that fugitive dust and particulate matter that may result from site preparation and construction activities are minimized to the greatest extent feasible.
Requirement: The Permittee shall comply with the provisions of applicable VCAPCD Rules and Regulations, which include, but are not limited to, Rule 50 (Opacity), Rule 51 (Nuisance), and Rule 55 (Fugitive Dust).
Documentation: The Permittee shall ensure compliance with the following provisions:
I. The area disturbed by clearing, grading, earth moving, or excavation operations shall be minimized to prevent excessive amounts of dust;
II. Pre-grading/excavation activities shall include watering the area to be graded or excavated before commencement of grading or excavation operations. Application of water should penetrate sufficiently to minimize fugitive dust during grading activities; III. All trucks shall cover their loads as required by California Vehicle Code §23114.
IV. Fugitive dust throughout the site shall be controlled by the use of a watering truck or equivalent means (except during and immediately after rainfall). Water shall be applied to all unpaved roads, unpaved parking areas or staging areas, and active portions of the construction site. Environmentally safe dust control agents may be used in lieu of watering.
V. Graded and/or excavated inactive areas of the construction site shall be monitored at least weekly for dust stabilization. Soil stabilization methods, such as water and roll compaction, and environmentally safe dust control materials, shall be periodically applied to portions of the construction site that are inactive for over four days.
VI. Signs shall be posted onsite limiting traffic to 15 miles per hour or less.
VII. All clearing, grading, earth moving, or excavation activities shall cease during periods of high winds (i.e., wind speed sufficient to cause fugitive dust to be a nuisance or hazard to adjacent properties). During periods of high winds, all clearing, grading, earth moving, 562
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and excavation operations shall be curtailed to the degree necessary to prevent fugitive dust created by onsite activities and operations from being a nuisance or hazard, either offsite or onsite.
Timing: Throughout the grading and construction phases of the project.
Reporting and Monitoring: Construction and Grading permits are issued by P ublics Works Agency and inspector shall perform periodic site in spections throughout the construction period.
Monitoring and Enforcement of dust-related provisions shall also be conducted by APCD staff on a complaint-driven basis.
Greenhouse Gas Emissions Section
is incorrect. APCD does not have regulatory authority over GHGs , th is is regulated by the California Air Resources Board (CARB). To clarify, we permit stationary business for their criteria pollutants (PM, ozone by way of ROC and NOx, etc.) and toxic air contaminants, not GHGs such as methane (CH4) and carbon dioxide (CO2).
“transportation corridors, including SR 118 and arterial roads such as Los Angeles Avenue ”, APCD strongly advises consideration of proximity of proposed housing to high traffic roads. The CARB has recommended a buffer distance of 500 feet between sensitive land uses and sources of TACs (CARB 2005 Land Use Handbook) , such as high quality transit corrido rs. According to CARB, air pollution studies indicate that living close to high traffic and the associated emissions may lead to adverse health effects beyond those associated with regional air pollution in urban areas. Many of these epidemiological studie s have focused on children. A number of studies identify an association between adverse non-cancer health effects and living or attending school near heavily traveled roadways. These studies have reported associations between residential proximity to high traffic roadways and a variety of respiratory symptoms, asthma exacerbations, and decreases in lung function in children. According to the CDC, a growing body of evidence demonstrates that minority populations and persons of lower socioeconomic status expe rience higher residential exposure to traffic and traffic -related air pollution than non -minorities and persons of higher socioeconomic status (CDC, Residential Proximity to Major Highways 2010).
Thank you for the opportunity to comment on the project’s MND. You may reach me at nicole@vcapcd.,org should you have any questions.
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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
September 23, 2021
Mrs. Monica Dionne
City of Simi Valley
2929 Tapo Road
Simi Valley, CA 93063
[email protected]
Subject: Mitigated Negative Declaration for the City of Simi Valley General Plan Amendment to Update the Housing Element for the 2021-2029 Planning Period (GPA-2021-0001), SCH No. 2021080508, Ventura County
Dear Mrs. Dionne:
The California Department of Fish and Wildlife (CDFW) has reviewed the Mitigated Negative Declaration (MND) for the City of Simi Valley’s (City) General Plan Amendment to Update the Housing Element for the 2021-2029 Planning Period (GPA-2021-0001) Project (Project). Thank you for the opportunity to provide comments and recommendations regarding those activities detailed 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 & Game Code. CDFW understands that future development projects may be tiered off this environmental document. Future development projects, as detailed in the General Plan, will be collectively referred to as “Projects” or “Project(s).” This is not to say that each comment below is relevant to each of the Projects discussed in the General Plan, but that the comments listed below should be considered when a specified project may impact any of the biological resources discussed below.
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 & Game Code, §§ 711.7, subdivision (a) & 1802; Public 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 (Public Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish & Game Code, including lake and streambed alteration regulatory authority (Fish & Game Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take”, as defined by State law, of any DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 564
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species protected under the California Endangered Species Act (CESA) (Fish & Game Code, § 2050 et seq.), or State-listed rare plant pursuant to the Native Plant Protection Act (NPPA; Fish & Game Code, §1900 et seq.), CDFW recommends the Project proponent obtain appropriate authorization under the Fish & Game Code, as necessary.
Project Description and Summary
Objective: The Project involves a comprehensive update to the 2013-2021 Housing Element (Chapter four) of the City’s General Plan. The Housing Element of the General Plan addresses the Cities approach to community development, safety, environmental justice, and map amendments/zone changes. To comply with State law, the City's Housing Element must be updated every eight years to ensure the City's policies and programs can accommodate estimated housing growth allocation identified by the State-determined Regional Housing Needs Assessment. The Housing Element will address how the City will meet its housing needs, including provision of adequate housing for residents of all income levels.
Location: City of Simi Valley (Citywide), Ventura County.
Comments and Recommendations
CDFW offers the comments and recommendations below to assist the City in adequately identifying, avoiding, and/or mitigating Projects (as detailed in the General Plan) significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.
Additional comments or other suggestions may also be included to improve the document.
Comment #1: Impacts to Streams
Issue: CDFW is concerned that Projects may support streams subject to notification under Fish & Game code section 1600 et seq.
Specific impacts: Projects may result in the loss of streams and associated watershed function and biological diversity. Grading and construction activities will likely alter the topography and hydrology of streams.
Why impacts would occur: Ground disturbance activities (e.g., grading, filling, water diversions, and dewatering) would physically remove or otherwise alter existing streams or their function and associated riparian habitat. Downstream waters and associated biological resources beyond a Project(s) development footprint may also be impacted by Project(s) related releases of sediment and altered watershed effects.
Evidence impacts would be significant: Projects may substantially adversely affect the existing stream pattern of the site through the alteration or diversion of a stream, which absent specific mitigation, could result in substantial erosion or siltation on-site or off-site.
Recommended Potentially Feasible Mitigation Measure(s):
Mitigation Measure #1: Projects may result in the alteration of streams. For any such activities, the Project(s) applicant (or “entity”) must provide written notification to CDFW pursuant to section 1600 et seq. of the Fish & Game Code. Based on this notification and other information, DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 565
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CDFW determines whether a Lake and Streambed Alteration (LSA) Agreement with the applicant is required prior to conducting the proposed activities. An LSA notification package may be obtained by accessing CDFW’s web site at
https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS.
CDFW’s issuance of an LSA Agreement for Project(s) that are subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. As a Responsible Agency, CDFW may consider the CEQA document of the Lead Agency for a Project(s). To minimize additional requirements by CDFW pursuant to section 1600 et seq. and/or under CEQA, project specific CEQA documents should fully identify the potential impacts to the stream or riparian resources and provide adequate avoidance, mitigation, monitoring and reporting commitments for issuance of the LSA Agreement.
Recommendation #1: Any LSA Agreement issued for Projects by CDFW may include additional measures protective of streambeds on and downstream of the Project(s). The LSA Agreement may include further erosion and pollution control measures. To compensate for any on-site and off-site impacts to riparian resources, additional mitigation conditioned in an LSA Agreement may include the following: avoidance of resources; on-site or off-site habitat creation, enhancement, or restoration; and/or protection and management of mitigation lands in perpetuity.
Comment #2: Impacts to Special-Status Plant Species
Issue #1: Collectively, the Projects may result in a significant cumulative impact to special- status plants and habitat communities.
Issue #2: The Projects may contribute to increased habitat fragmentation and loss of native habitats.
Specific impact: CDFW considers plant communities, alliances, and associations with a statewide ranking of S1, S2, S3, and S4 as sensitive and declining at the local and regional level (Sawyer et al. 2008). An S3 ranking indicates there are 21-80 occurrences of this community in existence in California, S2 has 6-20 occurrences, and S1 has less than 6 occurrences. The Projects may have direct or indirect effects to these sensitive species.
Why impact would occur: The implementation of Projects may include grading, vegetation clearing for construction, road maintenance, and other activities that may result in direct mortality, population declines, or local extirpation of sensitive plant species and habitat fragmentation.
Evidence impact would be significant: Impacts to special-status plant species should be considered significant under CEQA unless they are clearly mitigated below a level of significance. Inadequate avoidance, minimization, and mitigation measures for impacts to these sensitive plant species will result in a Project(s) 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 in local or regional plans, policies, or regulations, or by CDFW or U.S. Fish & Wildlife Service (USFWS). Additionally, plants that have a California Native Plant Society (CNPS) California Rare Plant Rank (CRPR) of 1A, 1B, 2A, and 2B are rare throughout their range, endemic to California, and are seriously or DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 566
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moderately threatened in California. All plants constituting CRPR 1A, 1B, 2A, and 2B meet the definitions of CESA and are eligible for State listing. Impacts to these species or their habitat must be analyzed during preparation of environmental documents relating to CEQA, as they meet the definition of rare or endangered (CEQA Guidelines, § 15380). Please see CNPS Rare Plant Ranks website (https://www.cnps.org/rare-plants/cnps-rare-plant-ranks) for additional rank definitions.
Recommended Potentially Feasible Mitigation Measure(s):
Mitigation Measure #1: CDFW recommends including avoidance, minimization, and/or mitigation measure language articulating the need to perform focused surveys for sensitive/rare plants on-site and disclosing the results prior to the implementation of Projects. Based on the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW, 2018)
(https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959), a qualified biologist should “conduct surveys in the field at the time of year when species are both evident and identifiable.
Usually this is during flowering or fruiting.” Final CEQA documentation, for a specified Project(s), should provide a thorough discussion on the presence/absence of sensitive plants on-site and identify measures to protect sensitive plant communities from Project-related direct and indirect impacts.
Mitigation Measure #2: In 2007, the State Legislature required CDFW to develop and maintain a vegetation mapping standard for the state (Fish & Game Code, § 1940). This standard complies with the National Vegetation Classification System, which utilizes alliance and association-based classification of unique vegetation stands. CDFW utilizes vegetation descriptions found in the Manual of California Vegetation (MCV), found online at http://vegetation.cnps.org/. To determine the rarity ranking of vegetation communities on a specific Project site(s), the MCV alliance/association community names should be provided as CDFW only tracks rare natural communities using this classification system.
Mitigation Measure #3: CDFW recommends the General Plan be conditioned to provide mitigation ratios ranging from 5:1 – 10:1 (depending on the sensitivity of the species). This should be for the number of plants replaced to number impacted, including acres of habitat created to acres of habitat impacted. Rare plants are habitat specialists that require specific conditions to persist such as vegetation composition (species abundance, diversity, cover), soils, substrate, slope, hydrology, and pollinators. Accordingly, mitigation for impacts to rare plants should also include habitat.
Mitigation Measure #4: The General Plan should provide species-specific measures for on-site mitigation. Each species-specific mitigation plan should adopt an ecosystem-based approach and be of sufficient detail and resolution to describe the following at a minimum: 1) identify the impact and level of impact (e.g., acres or individual plants/habitat impacted); 2) location of on- site mitigation and adequacy of the location(s) to serve as mitigation; 3) assessment of appropriate reference sites; 4) scientific [Genus and species (subspecies/variety if applicable)] of plants being used for restoration; 5) location(s) of propagule source; 6) species-specific planting methods (i.e., container or seed); 7) measurable goals and success criteria for establishing self-sustaining populations (e.g. percent survival rate, absolute cover); 8) long-term monitoring, and; 9) adaptive management techniques.
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Recommendation #1: CDFW recommends the City perform a Regional Landscape Interconnectivity Assessment and incorporate the findings into the General Plan to avoid habitat fragmentation.
Comment #3: Survey Protocols for Special-Status Wildlife
Issue: Projects proposed to occur within the geographical limits of the Project(s) may impact special-status species.
Specific impacts: Several special-status-species may occur on or within the vicinity of Projects.
Without recent protocol surveys, these species may be directly or indirectly impacted. Projects may remove suitable and indirect effects such as noise, dust, and artificial lighting may also adversely impact special status species.
Why impacts would occur: Project(s)-activities have the potential to impact special status wildlife species, which have been documented to occur in the region (CDFW 2021). Protocol surveys are necessary to identify listed species and supporting habitat necessary for their survival.
Evidence impact would be significant: Ground-clearing and construction-activities could lead to the direct mortality of a listed species or Species of Special Concern (SSC). The loss of occupied habitat could yield a loss of foraging potential, nesting sites, basking sites, or refugia and would constitute a significant impact absent appropriate mitigation. CDFW considers impacts to CESA-listed and SSC a significant direct and cumulative adverse effect without implementing appropriate avoidance and/or mitigation measures.
Recommended Potentially Feasible Mitigation Measure(s):
CDFW recommends that Projects follow appropriate survey protocol for a given species. The survey(s) should be performed based on the species found, or likely to occur, on a respective Project site(s).
The following mitigation measures are suggested for impacts to special-status reptiles:
Mitigation Measure #1: To mitigate impacts to special-status reptiles, CDFW recommends focused surveys for species likely to occur within a Project(s) area. Surveys should typically be scheduled during the summer months (June and July) when these animals are most likely to be encountered. To achieve 100 percent visual coverage, CDFW recommends surveys be conducted with parallel transects at approximately 20 feet apart and walked on-site in appropriate habitat suitable for each species. Suitable habitat consists of areas of sandy, loose, and moist soils, typically under the sparse vegetation of scrub, chaparral, and within the duff of oak woodlands.
Mitigation Measure #2: In consultation with a qualified biologist familiar with the life history of the respective reptile, a relocation plan (Plan) should be developed. The Plan should include, but not be limited to, the timing and location of the surveys that will be conducted for the species, identify the locations where more intensive survey efforts will be conducted (based on high habitat suitability); identify the habitat and conditions in any proposed relocation site(s); the methods that will be utilized for trapping and relocating the individuals; and the DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 568
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documentation/recordation of the number of animals relocated. CDFW recommends the City coordinate with CDFW and/or U.S. Fish and Wildlife Service (USFWS) prior to any ground disturbing activities within potentially occupied habitat.
The following mitigation measures are suggested for impacts to bats:
Mitigation Measure #1: The MND and/or subsequent CEQA documents should provide a discussion of potential impacts to bats, which may occur as a result from the construction and/or operation of Projects. The language should adequately disclose potential impacts and identify appropriate avoidance and mitigation measures.
Mitigation Measure #2: Measures to mitigate impacts to bats should include pre-construction surveys to detect species, use of bat roost installations, and preparation of a bat protection and relocation plan to be submitted to CDFW for approval prior to commencement of Project(s) activities, as necessary.
Comment #4: Monarch Butterfly
Issue: Project(s) activities have the potential to impact overwintering monarch butterflies (Danaus plexippus), which is an Endangered Species Act (ESA) candidate listed species and has been documented to occur in throughout the region (CDFW 2021).
Specific impact: Without appropriate avoidance and minimization measures for monarch butterflies, potential significant impacts associated with tree trimming, vegetation removal, and ground disturbance activities could occur. Potential impacts include roost destruction, inadvertent entrapment, reduced reproductive success, reduction in health and vigor of eggs and/or larvae, and direct mortality of individual monarchs.
Why impacts would occur: Project(s) activities have the potential to impact monarch butterflies, which have been documented to occur in the region. Protocol surveys are necessary to identify the presence of monarch butterflies and supporting habitat necessary for their survival. A lack of protocol surveys will likely result in avoidable, direct and/or indirect impacts to monarch butterflies.
Evidence impact would be significant: During the last decade, overwintering monarch populations have decline by nearly 90-percent (Jepsen et al, 2015). Habitat loss and fragmentation is among the primary threats to the population (USFWS 2020). Ground clearing and construction activities could exacerbate this issue and lead to the direct mortality of monarch butterflies. Habitat loss could lead to a loss of foraging potential, nesting sites, or refugia and would constitute a significant impact absent appropriate mitigation. CDFW considers impacts to rare species a significant direct and cumulative adverse effect without implementing appropriate avoidance and/or mitigation measures. Project(s) activities have the potential to significantly impact the species by reducing possible roosting habitat.
Recommended Potentially Feasible Mitigation Measure(s)
To evaluate potential impacts of the Project(s) to special-status species, CDFW recommends including the following mitigation measures and requiring them as conditions for Project(s) DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 569
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approval.
Mitigation Measure #1: Monarch Butterfly Habitat Assessment CDFW recommends that a qualified biologist conduct a habitat assessment, within 30 days of Project(s) implementation, to determine if the Project(s) area or its immediate vicinity contain habitat suitable to support monarchs.
Mitigation Measure #2: Monarch Butterfly Surveys
If suitable habitat is present, CDFW recommends assessing presence of monarchs by conducting protocol surveys consistent with USFWS recommendations (see www.fs.fed.us/wildflowers/pollinators/monarch_butterfly/documents/monarch- monitoring_en.pdf).
Mitigation Measure #3: Monarch Butterfly Take Avoidance If monarch butterflies are detected within or in the vicinity of Project(s) areas, The City will consult CDFW and USFWS, prior to Project(s) implementation to discuss how to implement ground-disturbing activities and avoid take.
Comment #5: Impacts to Non-Game Mammals and Wildlife
Issue: Wildlife may move through Project(s) sites during the daytime or nighttime. CDFW is concerned that any wildlife potentially moving through or seeking temporary refuge on the Projects sites may be directly impacted during Project(s) activities and construction.
Specific impacts: Project(s) activities and construction-equipment may directly impact wildlife and birds moving through or seeking temporary refuge on site. This could result in wildlife and bird mortality. Furthermore, depending on the final fencing design, Projects may cumulatively restrict wildlife movement opportunity.
Why impacts would occur: Direct impacts to wildlife may occur from: ground disturbing activities (e.g., staging, access, excavation, grading); wildlife being trapped or entangled in construction materials and erection of restrictive fencing; and wildlife could be trampled by heavy equipment operating on Projects site(s).
Evidence impact would be significant: Mammals occurring naturally in California are considered non-game mammals and are afforded protection by State law from take and/or harassment (Fish & Game Code, § 4150; Cal. Code of Regs, § 251.1).
Recommended Potentially Feasible Mitigation Measure(s): CDFW recommends the following four mitigation measures to avoid and minimize direct impacts to wildlife during Project(s) construction and activities.
Mitigation Measure #1: If fencing is proposed for use during construction or during the life of the Project(s), fences should be constructed with materials that are not harmful to wildlife.
Prohibited materials include, but are not limited to, spikes, glass, razor, or barbed wire. Fencing should also be minimized so as not to restrict free wildlife movement through habitat areas.
Mitigation Measure #2: To avoid direct mortality, a qualified biological monitor should be on site prior to and during ground and habitat disturbing activities to move out of harm’s way DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 570
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special status species or other wildlife of low mobility that would be injured or killed by grubbing or Project(s)-related construction activities. Salvaged wildlife of low mobility should be removed and placed onto adjacent and suitable (i.e., species appropriate) habitat out of harm’s way.
It should be noted that the temporary relocation of on-site wildlife does not constitute effective mitigation for the purposes of offsetting Program impacts associated with habitat loss.
Mitigation Measure #3: Grubbing and grading should be done to avoid islands of habitat where wildlife may take refuge and later be killed by heavy equipment. Grubbing and grading should be done from the center of the Project(s) site, working outward towards adjacent habitat off site where wildlife may safely escape.
Additional Recommendations
Alternatives. CDFW recommends the City consider an alternative that would fully avoid or minimize impacts to streams, sensitive plants and wildlife.
Mitigation and Monitoring Reporting Plan. 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). A final MMRP shall reflect results following additional plant and wildlife surveys and the Project’s final on and/or off-site mitigation plans.
Filing Fees
Projects, as proposed in the General Plan, would 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 Lead Agency 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
We appreciate the opportunity to comment on the Project and 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)]. If you have any questions or comments regarding this letter, please contact Baron Barrera, Environmental Scientist, at [email protected] or (858) 354-4114.
Sincerely,
Erinn Wilson-Olgin
Environmental Program Manager I
South Coast Region
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ec: CDFW
Steve Gibson, Los Alamitos – [email protected] Baron Barrera, Los Alamitos – [email protected] Emily Galli, Fillmore – [email protected]
Susan Howell, San Diego – [email protected]
Cindy Hailey, San Diego – [email protected]
CEQA Program Coordinator, Sacramento – [email protected] State Clearinghouse, Office of Planning and Research – [email protected] Chris Delith, United States Fish & Wildlife Service – [email protected] Irma Muñoz, Santa Monica Mountains Conservancy – [email protected] Katherine Pease, Heal the Bay – [email protected]
Snowdy Dodson, Los Angeles/Santa Monica Mountains Chapter, California Native Plant Society – [email protected]
Frances Alet, The Calabasas Coalition - [email protected] References:
California Department of Fish and Wildlife [CDFW]. March 20,2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (see https://www.wildlife.ca.gov/Conservation/Plants).
[CDFWb] California Department of Fish and Wildlife. 2020. Scientific Collecting Permit.
Available from: https://wildlife.ca.gov/Licensing/Scientific-Collecting#53949678 [CDFWc] California Department of Fish and Wildlife. 2021. Submitting Data to the CNDDB.
Available from: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data [CNPS] California Native Plant Society. 2020. Rare Plant ranks. Available from:
https://www.cnps.org/rare-plants/cnps-rare-plant-ranks. [CNPS] California Native Plant Society. 1998. Statement Opposing Transplantation as Mitigation for Impacts to Rare Plants. Available from:
https://www.cnps.org/wpcontent/uploads/2018/04/transplanting2.pdf Coop et al. 2020. Wildfire Driven Forest Conversion in Western North American Landscapes. Bioscience 70(8):659-673. Available from:
https://doi.org/10.1093/biosci/biaa061
Godefroid, S., et al. 2011. How successful are plant species reintroductions? Biological Conservation 144: 672-682.
Issac Brown Ecology Studio and Los Angeles Sanitation and Environment (LASAN). 2018. 2018 Biodiversity Report. County of Los Angeles. Measurement of the Singapore Index of Cities’ Biodiversity and Recommendations for a Customized Los Angeles Index.
Available from:
https://www.laCountysan.org/cs/groups/public/documents/document/y250/mdi0/~edisp/c nt024743.pdf
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Jepsen, S., D. F. Schweitzer, B. Young, N. Sears, M. Ormes, and S. H. Black. 2015.
Conservation Status and Ecology of Monarchs in the United States. 36pp.
NatureServe, Arlington, Virginia, and the Xerces Society for Invertebrate Conservation, Portland, Oregon.
Lucas, E. 2020. Recreation-related disturbance to wildlife in California – better planning for and management of recreation are vital to conserve wildlife in protected areas where recreation occurs. California Fish and Wildlife, Recreation Special Issue 2020: 29-51.
National Research Council. 1995. Science and the Endangered Species Act. Washington, DC:
The National Academies Press. https://doi.org/10.17226/4978.
Pelton, E., Jepsen, C. Schultz, C. Fallon, and S.H. Black. 2016. State of the Monarch Butterfly Overwintering Sites in California. 40+vi pp. Portland, Oregon: The Xerces Society for Invertebrate Conservation. www.xerces.org
Sawyer, J.O., Keeler Wolf, T., and Evens J.M. 2008. A manual of California Vegetation, 2nd ed.
ISBN 978 0 943460 49 9.
Thorne, J.H., Boyton, R.M., Holguin, A.J., Stewart, J.A.E., and Bjorkman, J. 2016. A climate change vulnerability assessment of California’s terrestrial vegetation. Final Report to:
California Department of Fish and Wildlife. Information Center for the Environment University of California, Davis. Available from:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=116208&inline
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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
Attachment A: Draft Mitigation and Monitoring Reporting Plan
CDFW recommends the following language to be incorporated into a future environmental document for the Project. A final MMRP shall reflect results following additional plant and wildlife surveys and the Project’s final on and/or off-site mitigation plans.
Biological Resources (BIO)
Mitigation Measure (MM) or Recommendation (REC) Timing Responsible Party Mitigation
Measure #1 -
Impacts to
Streams
Projects may result in the alteration of streams. For any such activities, the Project(s) applicant (or “entity”) must provide written notification to CDFW pursuant to section 1600 et seq. of the Fish & Game Code. Based on this notification and other information, CDFW determines whether a Lake and Streambed Alteration (LSA) Agreement with the applicant is required prior to conducting the proposed activities. An LSA notification package may be obtained by accessing CDFW’s web site at
https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS.
CDFW’s issuance of an LSA Agreement for Project(s) that are subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. As a Responsible Agency, CDFW may consider the CEQA document of the Lead Agency for a Project(s).
To minimize additional requirements by CDFW pursuant to section 1600 et seq. and/or under CEQA, project specific CEQA
documents should fully identify the potential impacts to the stream or riparian resources and provide adequate avoidance, mitigation, Prior to
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 574
813
Mrs. Monica Dionne
City of Simi Valley
September 23, 2021
monitoring and reporting commitments for issuance of the LSA Agreement.
Mitigation
Measure #2 -
Impacts to
Streams
Any LSA Agreement issued for Projects by CDFW may include additional measures protective of streambeds on and downstream of the Project(s). The LSA Agreement may include further erosion and pollution control measures. To compensate for any on-site and off-site impacts to riparian resources, additional mitigation conditioned in an LSA Agreement may include the following:
avoidance of resources; on-site or off-site habitat creation, enhancement, or restoration; and/or protection and management of mitigation lands in perpetuity.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #3 -
Impacts to
Sensitive or
Special Status
Plant Species
CDFW recommends including avoidance, minimization, and/or mitigation measure language articulating the need to perform focused surveys for sensitive/rare plants on-site and disclosing the results prior to the implementation of Projects. Based on the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW, 2018) (https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959), a qualified biologist should “conduct surveys in the field at the time of year when species are both evident and identifiable. Usually this is during flowering or fruiting.” Final CEQA documentation, for a specified Project, should provide a thorough discussion on the presence/absence of sensitive plants on-site and identify measures to protect sensitive plant communities from Project(s)- related direct and indirect impacts.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #4 -
Impacts to
Sensitive or
Special Status
Plant Species
In 2007, the State Legislature required CDFW to develop and maintain a vegetation mapping standard for the state (Fish & Game Code, § 1940). This standard complies with the National Vegetation Classification System, which utilizes alliance and association-based classification of unique vegetation stands.
CDFW utilizes vegetation descriptions found in the Manual of California Vegetation (MCV), found online at
Prior to
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 575
814
Mrs. Monica Dionne
City of Simi Valley
September 23, 2021
http://vegetation.cnps.org/. To determine the rarity ranking of vegetation communities on a specific Project site(s), the MCV alliance/association community names should be provided as CDFW only tracks rare natural communities using this
classification system.
Mitigation
Measure #5 -
Impacts to
Sensitive or
Special Status
Plant Species
CDFW recommends the General Plan be conditioned to provide mitigation ratios ranging from 5:1 – 10:1 (depending on the sensitivity of the species). This should be for the number of plants replaced to number impacted, including acres of habitat created to acres of habitat impacted. Rare plants are habitat specialists that require specific conditions to persist such as vegetation composition (species abundance, diversity, cover), soils, substrate, slope, hydrology, and pollinators. Accordingly, mitigation for impacts to rare plants should also include habitat.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #6 -
Impacts to
Special Status
Plant Species
The General Plan should provide species-specific measures for on-site mitigation. Each species-specific mitigation plan should adopt an ecosystem-based approach and be of sufficient detail and resolution to describe the following at a minimum: 1) identify the impact and level of impact (e.g., acres or individual plants/habitat impacted); 2) location of on-site mitigation and adequacy of the location(s) to serve as mitigation; 3) assessment of appropriate reference sites; 4) scientific [Genus and species (subspecies/variety if applicable)] of plants being used for restoration; 5) location(s) of propagule source; 6) species-specific planting methods (i.e., container or seed); 7) measurable goals and success criteria for establishing self-sustaining populations (e.g. percent survival rate, absolute cover); 8) long-term monitoring, and; 9) adaptive management techniques.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #7 -
Impacts to
Special Status
Plant Species
CDFW recommends the City perform a Regional Landscape
Interconnectivity Assessment and incorporate the findings into the General Plan for the purpose of avoiding habitat fragmentation.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 576
815
Mrs. Monica Dionne
City of Simi Valley
September 23, 2021
Mitigation
Measure #8 -
Impacts to
Special Status
Reptiles
To mitigate impacts to special-status reptiles, CDFW recommends focused surveys for species likely to occur within a Project(s) area.
Surveys should typically be scheduled during the summer months (June and July) when these animals are most likely to be encountered. To achieve 100 percent visual coverage, CDFW recommends surveys be conducted with parallel transects at approximately 20 feet apart and walked on-site in appropriate habitat suitable for each species. Suitable habitat consists of areas of sandy, loose, and moist soils, typically under the sparse vegetation of scrub, chaparral, and within the duff of oak woodlands.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #9 -
Impacts to
Special Status
Plant Species
In consultation with a qualified biologist familiar with the life history of the respective reptile, a relocation plan (Plan) should be developed. The Plan should include, but not be limited to, the timing and location of the surveys that will be conducted for the species, identify the locations where more intensive survey efforts will be conducted (based on high habitat suitability); identify the habitat and conditions in any proposed relocation site(s); the methods that will be utilized for trapping and relocating the individuals; and the documentation/recordation of the number of animals relocated. CDFW recommends the City coordinate with CDFW and/or U.S. Fish and Wildlife Service (USFWS) prior to any ground disturbing activities within potentially occupied habitat.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #10 -
Impacts to Bats
The MND and/or subsequent CEQA documents should provide a discussion of potential impacts to bats, which may occur as a result from the construction and/or operation of Projects. The language should adequately disclose potential impacts and identify appropriate avoidance and mitigation measures.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #11 -
Impacts to Bats
Measures to mitigate impacts to bats should include pre- construction surveys to detect species, use of bat roost installations, and preparation of a bat protection and relocation plan to be submitted to CDFW for approval prior to
commencement of Project(s) activities, as necessary.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 577
816
Mrs. Monica Dionne
City of Simi Valley
September 23, 2021
Mitigation
Measure #12 -
Impacts to
Monarch
Butterflies
CDFW recommends that a qualified biologist conduct a habitat assessment, well in advance of Project(s) implementation, to determine if the Project(s) area or its immediate vicinity contain habitat suitable to support monarchs.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #13 -
Impacts to
Monarch
Butterflies
If suitable habitat is present, CDFW recommends assessing presence of monarchs by conducting surveys following
recommended protocols or protocol-equivalent surveys.
Recommended protocols vary by species.
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #14 -
Impacts to
Monarch
Butterflies
Detection of special-status species within or in the vicinity of the Project(s) area, warrants consultation with CDFW and U.S. Fish and Wildlife Service (USFWS) to discuss how to implement ground-disturbing activities and avoid take
Prior to
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #15 -
Impacts to Non-
Game Mammals
If fencing is proposed for use during construction or during the life of the Project, fences should be constructed with materials that are not harmful to wildlife. Prohibited materials include, but are not limited to, spikes, glass, razor, or barbed wire. Fencing should also be minimized so as not to restrict free wildlife movement through habitat areas.
Prior to/After
Project
construction
and activities
Lead Agency/
Applicant
Mitigation
Measure #16 -
Impacts to Non-
Game Mammals
To avoid direct mortality, a qualified biological monitor should be on site prior to and during ground and habitat disturbing activities to move out of harm’s way special status species or other wildlife of low mobility that would be injured or killed by grubbing or Project(s)-related construction activities. Salvaged wildlife of low mobility shall be removed and placed onto adjacent and suitable (i.e., species appropriate) habitat out of harm’s way. It should be noted that the temporary relocation of on-site wildlife does not constitute effective mitigation for the purposes of offsetting Program impacts associated with habitat loss.
Prior to/After
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 578
817
Mrs. Monica Dionne
City of Simi Valley
September 23, 2021
Mitigation
Measure #17 -
Impacts to Non-
Game Mammals
Grubbing and grading should be done to avoid islands of habitat where wildlife may take refuge and later be killed by heavy equipment. Grubbing and grading should be done from the center of the Project(s) site, working outward towards adjacent habitat off site where wildlife may safely escape.
Prior to/After
Project
construction
and activities
Lead Agency/
Applicant
DocuSign Envelope ID: B15DE660-B738-4B71-A1F4-CCB530CA5562 579
818
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1 Whitney Luxenberger
From: Eric Chen
Sent: Tuesday, August 24, 2021 11:20 AM
To: Whitney Luxenberger
Subject: FW: Opposition To Upzoning Walnut Hills Site
From:
Sent: Tuesday, July 27, 2021 3:13 PM
To: Eric Chen <[email protected]>
Cc: ; Sean Gibson <[email protected]>;
Subject: Opposition To Upzoning Walnut Hills Site
Good Afternoon, Mr. Chen and Members of the Simi Valley City Council, Re: Our Opposition To Upzoning Walnut Hills Site
I wish to advise both you and the Simi Valley City Council that we are opposed to the possible up-zoning of the Walnut Hills site. This site is located on the Northerly top part of MAP 150 of the SIMI VALLEY DRAFT HOUSING ELEMENT 2021 and referenced in the subject report on Page 4-82 and elsewhere. Per the Housing Element, this site is vacant and designated as Low-Density Residential. The Walnut Hills site is surrounded by vacant lots, designated as Open Space (maximum 1 unit per 40 acres) and Low-Density Residential (up to 3.5 units per acre) to the north, single-family Low-Density Residential to the east, Medium Density detached single-family to the south, and Low Density detached single-family to the West. These parcels are designated to address the need for moderate to above moderate-income housing units.
Our home, located at , Simi Valley, CA 93063-1066, is just to the West of the Walnut Hills site. We have an apparent interest in the subject property remaining zoned as RL, which is consistent with the zoning in the neighborhood as most of the neighboring properties are zoned RL and RE. To up-zone, it would create an inconsistent spot zone in our area. As such, we are genuinely concerned that to up-zone this property will have a detrimental effect on our neighborhood and affect our property value and our neighbors.
We recently purchased the property at Lemon Drive at great expense and have extensively repaired and remodeled it, hoping that our investment is as safe as possible.
Our granddaughter Morgan who lives with her husband Brice at the subject site is soon expecting their first child, our great-grandchild. We hope for their sake, and their neighbor’s sake, that the entire neighborhood remains as it currently is zoned and does not have greater density housing permitted.
Additionally, the list of properties in the draft document includes many properties that apply to affordable housing due to their current zoning. Many are more centrally located, on a main street with nearby shopping without the need to travel very far, thus avoiding the carbon emissions caused by driving an unnecessary distance. 581
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2 We sincerely hope that you understand our concerns and will not up-zone the Walnut Hills site.
Thank you for your consideration,
Michael Greenhut
Attention: This message is private and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.
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1 Whitney Luxenberger
From: Bill Bell
Sent: Saturday, September 25, 2021 7:33 AM
To: planningcomments
Subject: 2021 housing update / Attn. Sean Gibson
9/23/2021
City of Simi Valley Planning Commission
Sean Gibson
Environmental Services/Planning Division
Sent via email: [email protected]
Re: The 2021 Housing Element Update
Planning Commission Members,
My name is Bill Bellefontaine and our family members are lifelong members of our Community here in Simi Valley. We’ve owned an approximate 12.55 acre property located at 3799 Walnut St. for quite some time are having a tough time selling the property because of the physical constraints of the property. We heard about the City’s endeavor to provide approximately 2,800 new homes over the next 8 years through the Housing Element Update and would like to take part in that process if we can. The problem we have with our property is that about 10 ½ acres is not developable because it is subject to the Hillside Performance Standards 584
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2 Ordinance and there is a fault line that runs through the majority of the property leaving only about 1.92 acres developable.
We concur with Staff’s recommendation to rezone our property to Residential Medium (5 units/acre) which would allow for 16 units to be built on the remaining developable portion of 1.92 acres (southeast area of the property).
Even though the Draft Staff Report shows that the Potential Capacity could be 31 units (page H3-33, 3799 Walnut Ave.) with the new proposed zoning of RM (5units/acre), our parcel is governed by the Hillside Performance Standards limiting the # of units that can be built. We went through the expense of having a slope analysis map done which shows that only 16 units could be built on the 12.55 acre parcel if rezoned to RM.
Slope % Area Density Units
Less than 10% 3.10 acres 5 / acre 15.50
10-15% .34 acres 2 / acre .68
15-20% 1.17 acres 1/4 acres .29
More than 20% .19 acres 1 / 40 acres .19
16.67…rounding down with a Total of 16 units
The rezoning of our property to RM would be consistent with the neighboring single-family homes and would be consistent with the current General Plan.
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3 I’ve attached a copy of the Simi Valley Housing Element Cycle 6 Sites Inventory – Walnut Hills Area Map showing our parcel location, Group WHBRM-1. Again, only the southeastern area of the property is developable.
Sincerely,
Bill Bellefontaine
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1 Whitney Luxenberger
From: Veronica Solis
Sent: Tuesday, September 28, 2021 4:32 PM
To: Alexandra Clingman
Cc: Whitney Luxenberger; Stephanie Yates
Subject: RE: Attendee Zoom Link September 29, 2021 Planning Commission Meeting.
Hi Alexandra!
Thank you so much for responding so quickly! I would like to attend and not speak. I just wanted my thoughts to be noted that I would like the zoning to stay as it is. I believe moving it to a higher residential density would be very disruptive and cause unnecessary undesirable activity and hardships to our existing peaceful community.
Thank you,
Veronica Solis (formerly Hamilton)
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1 Whitney Luxenberger
From: Cindy Pain
Sent: Wednesday, September 29, 2021 9:38 AM
To: City Clerk; Eric Chen; planningcomments
Cc: Mitchell Tsai; Brandon Young; Greg Sonstein
Subject: SWRCC - City of Simi Valley’s 6th Cycle RHNA Housing Element Update Attachments: 20210927_SimiValleyHEU_ComLtr_Signed_Complete.pdf Dear Lucy Blanco and Eric Chen,
Please find the attached comment letter in regards to City of Simi Valley’s 6th Cycle RHNA Housing Element Update, along with the following Exhibits:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A)
Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B) Air Quality and GHG Expert Matt Hagemann CV (Exhibit C)
Best Regards,
--
Cindy Pain
Paralegal
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P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
VIA E-MAIL
September 29, 2021
Lucy Blanco
City Clerk
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93063
Em: [email protected]
Eric Chen
Associate Planner
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93063
Em: [email protected]
Em: [email protected]
RE: City of Simi Valley’s 6th Cycle RHNA Housing Element Update.
Dear Commissioners and Eric Chen,
On behalf of the Southwest Regional Council of Carpenters (“Commenter” or “Carpenter”), my Office is submitting these comments on the City of Simi Valley’s (“City”) Initial Study/Mitigated Negative Declaration (SCH 2021080508) and on the 6th Cycle RHNA Housing Element Update for the September 29, 2021 Planning Commission Meeting (“Project”).
The Southwest Carpenters is a labor union representing 50,000 union carpenters in six states and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.
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City of Simi Valley – 6th Cycle RHNA Housing Element Update September 29, 2021
Individual members of the Southwest Carpenters live, work and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.
Commenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.
Commenters incorporates by reference all comments raising issues regarding the EIR submitted prior to certification of the EIR for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has objected to the Project’s environmental documentation may assert any issue timely raised by other parties).
Moreover, Commenter requests that the Lead Agency provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
The City should require the use of a local skilled and trained workforce to benefit the community’s economic development and environment. The City should require the use of workers who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program or who are registered apprentices in an apprenticeship training program approved by the State of California.
Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized 590
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economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.
Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to delivering emissions reductions and moving California closer to its climate targets.
1 Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.
2 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/wp- content/uploads/2020/09/Putting-California-on-the-High-Road.pdf 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve 591
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Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3 In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”
4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. .
As the California Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.6
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to
Supporting Budget Actions, available at http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf. 4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-ca.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf.
5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs- housing.pdf
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those held by local residents.7 Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:
In nearly bu ilt-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.
The City should consider utilizing skilled and trained workforce policies and requirements to benefit the local area economically and mitigate greenhouse gas, air quality and transportation impacts.
Sincerely,
______________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C). 7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.
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EXHIBIT A
594
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1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.
Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3
1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 595
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2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:
Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.”6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.
Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7 In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- specific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the
4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 596
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3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9 Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86. 597
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4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.
Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).
Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.
14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 598
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5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
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EXHIBIT B
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SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist
Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on more than ten cases involving exposure to air contaminants from industrial sources.
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Professional H
istory:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science , 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113–125.
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.
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Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds , 70, 000527- 000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
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Chollack,
T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).
Rosenfeld, P. E. ( 1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.
Presentations:
Rosenfeld,
P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water .
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E . (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting , Lecture conducted from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting . Lecture conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P . (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant . The 23 rd Annual International Conferences on Soils Sediment and Water . Platform lecture conducted from University of Massachusetts, Amherst MA.
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Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water . Lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting . Lecture conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006 . Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility . APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D . (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.
Paul Rosenfeld Ph.D . (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference . Lecture conducted from Hilton Hotel, Irvine California.
Paul Rosenfeld Ph.D . (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D . (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants . Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D . (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference .
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D . (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust .
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
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Paul Rosen
feld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association . Lecture conducted from Radison Hotel, Sacramento, California.
Rosenfeld, P. E ., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants .. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D . (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E . and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association . Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association . Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conferenc e. Lecture conducted from Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. ( October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.
Rosenfeld, P.E. ( 2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E ., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings . Lecture conducted from Bellevue Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E. , C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E. , C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington. 606
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Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.
Rosenfeld, P.E. , C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America . Lecture conducted from Anaheim California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
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Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019
Depositio
n and/or Trial Testimony:
In the Uni
ted States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.
Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112 th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017
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Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.
Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
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In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
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EXHIBIT C
611
850
1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and H
ydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010
– 2014;
• Senior Environmental Analyst, Komex H2O
Science, Inc. (2000 ‐‐ 2003);
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• Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities. • Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
• Expert witness on two cases involving MTBE litigation. • Expert witness and litigation support on the impact of air toxins and hazards at a school. • Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Senior researcher in the develop ment of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
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• Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. 3 614
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• Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Sou rce Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
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• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Ag ency Source Water Agreement under the Clean Water Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents. 5 616
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Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.
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Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
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Hagemann, M.F ., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F ., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.
Hagemann, M.F., 1994. Groundwater Characterization and Cleanup a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M. F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 8 619
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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐ 2011.
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1 Whitney Luxenberger
From: Cassandra Douglas
Sent: Wednesday, September 29, 2021 10:42 AM
To: planningcomments
Subject: Housing Element Comments
My name is Cassandra Douglas. I am a Simi Valley resident.
I care deeply about this city and the Housing Element is an opportunity to commit ourselves to racial equity through housing that is both inclusive and affordable.
We must plan for a growing and diverse community.
I have the following suggestions regarding the Housing Element:
According to Table H4-7 in Simi Valley's housing element draft (see attached), over 54% of Simi Valley renters are cost-burdened (pay more than 30% of their income in rent), and over 28% are severely cost-burdened, paying more than half their income in rent. This is money that they could be spending in local shops, at the grocery store, education supplies, or sports programs for their kids, etc. Therefore, the city should take this opportunity to meaningfully plan for more affordable housing for local families and workers.
Figure H-7 is a map of the Opportunity Sites. These sites are clearly not evenly distributed throughout our town and are clustered where high-density zoning already exists. This does not "affirmatively further fair housing." The Fair Housing Analysis on pages H4-30 of the housing element states that "Racial/ethnic dissimilarity indices have increased since 1990, indicating that segregation in [Simi Valley] has worsened." White residents also tend to be located in neighborhoods with high incomes, better quality schools, and low-density zoning. Simi Valley should identify strategies to provide opportunities for people of various income levels to live in each area of town. Most of the Opportunity Sites have buildings on them already, many of which are currently in operation.
The city should be very clear about the likelihood of these businesses or residences being sold and/or demolished for redevelopment. If there is a low likelihood of redevelopment, then the city should identify more sites.
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2 1. We noticed there were a lot of areas identified in the Patri cia area that would potentially be rezoned for higher density, however many of the sites already have homes built on them, have we talked to the landowners about upcoming plans to redevelop? Otherwise, we are rezoning without any actual plan for those sites to be redeveloped.
2. This also applies to some of the Church properties that were identified for rezoning, have we spoken to the Churches and their plans for building housing on their properties? In regards to height limits, for mixed-use overlay zoning, in order to achieve at least 35 units per acre, we would like to see the height limit increased to 4 or 5 stories. If we look at mixed-use buildings that have shops or restaurants on the street level, limiting that building to 3 stories only allows for two levels of potential housing which isn’t adding very much housing stock.
I look forward to seeing adjustments made to the Housing Element Plan.
Thank You,
Cassandra Douglas - Simi Valley Resident and Lead for Ventura County YIMBY 622
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1 Whitney Luxenberger
From: Joy
Sent: Wednesday, September 29, 2021 10:51 AM
To: planningcomments
Subject: housing elements comments
Again it seems the govt and contractors are being pitted against the taxpayers of this city and the neighborhoods in which they live.
I can only fight for one parcel and that is the Walnut parcel. This is exhausting to say the least. We have been fighting the zoning change on this for years now. How many times do we have to say that this area is zoned for low density and has been for over 40 plus years. There is a reason for this. The plots are large here and the typography of the land is NOT conducive of being packed in here like sardines. There is a fault line running through this property. It is on a hill that either needs a 30 foot wall to hold up the dirt to level it off or the hill must be torn down. It is in a fire area. Really, why do we have to go over this again? Why are the hills being allowed to be built on when the population of this valley does not want this? Why are you not upholding the hill codes of not building on them?
This property has been sold many times over these years because each time the owner has found out that there are limits on what can be built here.
This zoning change is only being brought up, once again, to appease a contractor and not to take into consideration the people who actually live in this area. Do not change the zoning on this property.
Bill and Joy Lomenick
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1 Whitney Luxenberger
From: Roshawn Helmandi
Sent: Wednesday, September 29, 2021 11:51 AM
To: Eric Chen; planningcomments
Subject: Housing Element Meeting (Heyneman Lane Property) Attachments: 2021-09-28 Planning Commission ltr Kathy Messano.pdf Hello Mr. Chen,
I hope all is well. Please find a letter I received for today's meeting attached to this email. This letter is from Kathy Messano (Trustee for Heyneman Family Trust).
Also, I would like to speak today to voice my support for the housing element update.
Thank you,
Roshawn Helmandi
"Go into the world and do well. But more importantly
, go into t
he world and do good"
Disclaimer: Our company accepts no liability for the content of this email, or for the consequences of any actions taken on the basis of the information provided, unless that information is subsequently confirmed in writing. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.
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1 Whitney Luxenberger
From: Aubri Lancaster
Sent: Wednesday, September 29, 2021 2:04 PM
To: planningcomments
Subject: Housing Element Comments
I'm writing in support of more affordable and inclusive housing options. Growing up in Simi I have watched the majority of the people I grew up with move out of town because there's so little affordable housing. When we were young there wasn't much available in our price range to live on our own, so people left. Now as prices continue to rise I see more people leaving to find affordability. The people moving in are primarily single family homes that have spread further and further away from the center of town and are not invested in the security of housing for others. Please take to heart the needs of ALL Simi citizens and not just those who leverage their wealth to push out more of our neighbors.
I support mixed use, apartments, town homes, duplexes, triplexes, quadraplexes, and whatever else we can do to fill the massive gap our town has in affordable inclusive housing.
Thank you for your time.
Aubri Lancaster
Life long Simi resident
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1 Whitney Luxenberger
From: Lizzy Whitlock
Sent: Wednesday, September 29, 2021 2:57 PM
To: planningcomments
Subject: 09-29-21 Meeting - Housing Element Comments
Hello all,
My Name is Elizabeth Whitlock and I am a Simi Simi Valley resident.
I feel that our city must plan for a growing and diverse community by committing ourselves to racially equitable housing opportunities rooted in inclusivity and affordability. Otherwise this city, that we all care deeply about, will not have sustaining economic vitality in the years to come. According to Table H4-7 in Simi Valley's housing element draft , over 54% of Simi Valley renters are cost-burdened (pay more than 30% of their income in rent), and over 28% are severely cost- burdened, paying more than half their income in rent. This is money that they could be spending in local shops, at the grocery store, education supplies, or sports programs for their kids, etc.
Therefore, the city should take this opportunity to meaningfully plan for more affordable housing for local families and workers.
Figure H-7 is a map of the Opportunity Sites. These sites are clearly not evenly distributed throughout our town and are clustered where high-density zoning already exists. This does not "affirmatively further fair housing." The Fair Housing Analysis on pages H4-30 of the housing element states that "Racial/ethnic dissimilarity indices have increased since 1990, indicating that segregation in [Simi Valley] has worsened." White residents also tend to be located in neighborhoods with high incomes, better quality schools, and low-density zoning. Simi Valley should identify strategies to provide opportunities for people of various income levels to live in each area of town. Most of the Opportunity Sites have buildings on them already, many of which are currently in operation.
The city should be very clear about the likelihood of these businesses or residences being 633
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2 sold and/or demolished for redevelopment. If there is a low likelihood of redevelopment, then the city should identify more sites.
1. We noticed there were a lot of areas identified in the Patri cia area that would potentially be rezoned for higher density, however many of the sites already have homes built on them, have we talked to the landowners about upcoming plans to redevelop? Otherwise, we are rezoning without any actual plan for those sites to be redeveloped.
2. This also applies to some of the Church properties that were identified for rezoning, have we spoken to the Churches and their plans for building housing on their properties? In regards to height limits, for mixed-use overlay zoning, in order to achieve at least 35 units per acre, we would like to see the height limit increased to 4 or 5 stories. If we look at mixed-use buildings that have shops or restaurants on the street level, limiting that building to 3 stories only allows for two levels of potential housing which isn’t adding very much housing stock.
I look forward to seeing adjustments made to the Housing Element Plan.
Thank You Kindly,
Elizabeth Whitlock
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1 Whitney Luxenberger
From: Max Ghenis
Sent: Wednesday, September 29, 2021 3:14 PM
To: planningcomments
Subject: Housing Element Comments
Dear Planning Commissioners,
Please prioritize mixed-use dense development on realistic infill sites in your Housing Element. Many Opportunity Sites are on parcels that are already developed and therefore are unlikely to produce the needed housing. Expanding the list of sites and raising height and density limits on allowed sites would make it more likely that Simi Valley meets its housing goals, and in the process make our community more affordable, inclusive, and sustainable.
Thank you,
Max Ghenis
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1 Whitney Luxenberger
From: Jennifer Coile
Sent: Wednesday, September 29, 2021 3:17 PM
To: planningcomments
Cc: Ellen Brokaw; Linda Braunschweiger
Subject: Housing Element Comments
Attachments: Comment Letter to SV.PC hrg Draft HE Sept 29-2021HFW.finl..pdf Dear Mr. Chen,
On behalf of House Farm Workers!, I am enclosing a letter of comments on the Simi Valley Housing Element for
tonight's meeting.
Regards,
Jennifer Coile
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1 HOUSE FARM WORKERS!
Promoting safe, decent, and affordable housing
for Ventura County farm workers since 2004.
P.O. Box 402, Santa Paula, CA 93061 | (805) 921-0430 | [email protected] | www.housefarmworkers.org
September 27, 2021
Mr. Eric Chen, Associate Planner, City of Simi Valley
Sent via email to [email protected]
Re: Housing Element Comments
Planning Commission Public Hearing September 29, 2021
As a follow up to our letter of March 10, 2021, the Board of Directors of House Farm Workers! strongly requests that you include the following additions to the description of special needs population-Farmworkers and two programs in the Draft Housing Element (HE).
1. Page 24, Special Needs - Farmworkers
Please add (excerpt from the HE of the County of Ventura):
“Official counts of farmworkers significantly underestimate the true numbers, with undocumented and poor residents most likely to be undercounted. Farmworkers are notoriously difficult to count due to their mobility, the shared and substandard housing available to them, their fear of authorities, and their lack of involvement in a foreign and unfamiliar culture. Of the 22,694 farmworkers in the County reported in the 2017 NASS, 10,529 (46%) worked 150 days or more, and 12,165 (54%) worked less than 150 days.
A Farm Labor study conducted by the University of California in Davis, estimates an even higher number of farmworkers in Ventura County. The study utilized wage and tax data from the California Employment Development Department, and estimated that Ventura County employed approximately 36,500 farmworkers in 2012. Therefore, depending on the data source, the estimated number of farmworkers in Ventura County ranges from 18,000 to 36,500 persons. Based on information received from the Ventura County Agricultural Commissioner and the local House Farm Workers! Task Force, the higher end of the range is more accurate and should be used for estimating farmworker housing needs.” 637
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2 Background for recommendation: We note that the comment letter from the State Department of Housing and Community Development (HCD) regarding an analysis of special housing needs stated: “ The element includes data and analysis for persons with special needs. However, to better formulate policies and programs, it should also identify and analyze elderly households by tenure (renters and owners) and permanent and seasonal farmworkers at a county level. HCD will send data under separate cover.” We haven’t seen the data sent by HCD but we suggest consistency with the countywide data which HCD has already approved within the 2021-2029 Draft Housing Element of the County of Ventura.
2. Page 4-25, Special Needs Housing – Farmworkers – Resources Available
The first sentence reads: “Although farmworkers comprise a small proportion of the City’s population, the City will implement zoning ordinance amendments that allow Supportive Housing by right in zones where multi-family and mixed-use developments are permitted, when the development meets certain conditions, as detailed in Program 13.” Program 13 on page 4-111, Zoning Ordinance Amendments, includes eight amendments responding to recent changes in State law. “Supportive Housing” (AB 2162) may not be as relevant to farmworker housing as “Housing for Agricultural Employees.”
3. Page 4-102, Goal HE-4: Special Needs Groups. Programs to meet the special needs of target groups are available.
Please add: Policy HE 4.11 Countywide Farmworker Housing Study. Work with the County of Ventura and allied groups to plan and implement a countywide survey of farmworkers and associates, then utilize the survey results to develop targeted programs and strategies to address farmworkers needs and support agricultural businesses with a stable and healthy workforce.
Background for recommendations: Although the Simi Valley Draft HE notes that the City has limited farmworker jobs or residents within the city boundaries, this past year has highlighted the dire need for decent affordable housing for farm workers, essential workers contributing to a major sector of the Ventura County economy. When communities of color living in crowded conditions were hit hardest, the pandemic has reinforced the fact that a safe and secure national food supply requires a stable, healthy, trained workforce who live in quality affordable housing.
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3 HOUSE FARM WORKERS!
Promoting safe, decent, and affordable housing
for Ventura County farm workers since 2004.
P.O. Box 402, Santa Paula, CA 93061 | (805) 921-0430 | [email protected] | www.housefarmworkers.org
Since two Ventura County farmworker housing studies were published in 2002 , House Farm Workers! (HFW!) has been advocating for more farm worker homes.
But much has changed in the housing market, agricultural labor force, and County economy in the last 20 years. We need updated information in order to appropriately address farm worker housing needs.
The County of Ventura is taking the lead role in implementing the Farmworker Housing Study which is included in their Draft Final 2021-29 Housing Element, to be submitted to the California Department of Housing and Community Development in a few weeks. Initial grants totaling $100,000 have been awarded to HFW! and the County for this work. The cities of Camarillo, Oxnard, and Santa Paula have included participation in the study in the programs of their Draft HEs.
The Study will provide statistically valid numbers of farmworkers living in every jurisdiction, including Simi Valley. Anecdotal evidence leads House Farm Workers! to believe that a substantial number of farmworkers live in Simi Valley and commute to their jobs.
The County of Ventura will convene advocacy groups and agricultural organizations to plan, fund, and implement the countywide survey of farmworkers, employers, and housing providers to further define housing conditions, needs and barriers. An Advisory Council for the Study will be formed in the next few months and you will be invited to name a representative to participate in the Council.
4. Page 4-106, Program 6: Affordable Housing Development.
Please add to Objectives and Timeframe:
• Continue to make a regular contribution to support the Housing Trust Fund Ventura County (HTFVC), a local countywide nonprofit organization that provides short term, pre-development, acquisition, and construction funding to developers of affordable housing.
• Support creation of a county-wide dedicated source of funding for affordable housing.
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4 • Encourage the donation of land to the Housing Trust Fund VC/Housing Land Trust VC for the development of affordable housing.
Background for Recommendation: The City of Simi Valley had contributed financially to the HTFVC over the years, which has resulted in important affordable housing projects.
Thank you for considering these recommendations.
Sincerely,
Ellen Brokaw, HFW! Board of Directors
Linda Braunschweiger, Vice Chair of HFW! Board of Directors 640
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1 Whitney Luxenberger
From: Douglas Baker
Sent: Wednesday, September 29, 2021 3:29 PM
To: planningcomments
Subject: Housing Element Written Comments
My name is Douglas Baker.
Simi Valley is my hometown and I care deeply about this city. The Housing Element is an opportunity to commit ourselves to equity through housing that is both inclusive and affordable. We must plan for a growing and diverse community.
I have the following suggestions regarding the Housing Element:
According to Simi Valley's housing element draft (see attached), over 54% of Simi Valley renters are cost-burdened (pay more than 30% of their income in rent), and over 28% are severely cost- burdened, paying more than half their income in rent. This is money that they could be spending in local shops, at the grocery store, education supplies, or sports programs for their kids, etc.
Therefore, the city should take this opportunity to meaningfully plan for more affordable housing for local families and workers.
Opportunity sites are not evenly distributed throughout our town and are clustered where high-density zoning already exists. This does not "affirmatively further fair housing." The Fair Housing Analysis of the housing element states that "Racial/ethnic dissimilarity indices have increased since 1990, indicating that segregation in Simi Valley has worsened." White residents also tend to be located in neighborhoods with high incomes, better quality schools, and low-density zoning. Simi Valley should identify strategies to provide opportunities for people of various income levels to live in each area of town.
Most of the Opportunity Sites have buildings on them already, many of which are currently in operation.
The city should be very clear about the likelihood of these businesses or residences being sold and/or demolished for redevelopment. If there is a low likelihood of redevelopment, then the city should identify more sites.
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2 In regards to height limits, for mixed-use overlay zoning, in order to achieve at least 35 units per acre, I would like to see the height limit increased to 4 or 5 stories. If we look at mixed-use buildings that have shops or restaurants on the street level, limiting that building to 3 stories only allows for two levels of potential housing which isn’t adding very much housing stock.
I look forward to seeing adjustments made to the Housing Element Plan.
Thank You,
Douglas Baker
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S-2
GPA20210001,ZS20210005 PC Staff Report Supplemental #3(sy) Corrected Page 25 of Planning Commission Staff Report
EXHIBIT A
(continued)
General Plan Amendment No. GPA-2021-0001
The Simi Valley Official General Plan Land Use Map is hereby amended as follows:
L-1. General Plan Land Use Change from Residential Medium Density (3.6 – 5 du/ac) to Residential High Density
(10.1 – 20 du/ac).
L-2. General Plan Land Use Change from Office Commercial (.5 FAR) to Mixed Use (Up to 1.5 FAR).
APN Symbol on Map Existi ng Land Use New Land Use
638-0-030-34 A Medium Density High Density
638-0-310-05 B Office Commercial Mixed Use
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1 Whitney Luxenberger
From: Reese Holland
Sent: Wednesday, September 29, 2021 3:43 PM
To: planningcomments
Subject: Housing Element Comments
Hello! In addition to public comments during the meeting, I want to share the following thoughts on the Housing Element for Simi Valley.
1) Never saw myself able to live equitably in Simi Valley. While I'm a lifetime resident of Simi Valley, I never saw a point in time where I could afford to live on my own in Simi Valley, and certainly not to get housing meaningful enough to raise a family on a single income. - This is a two-part problem on the lack of above-poverty jobs available in Simi Valley, and the cost of rent and housing being exorbitantly high compared to incomes.
- Part of this is the county's demand for housing and rent to be based on a terrible model, that Simi has never seemed to attempt to work around or request exemption for in order to meet workforce housing demands. 2) First party workforce housing should be handled first-party by Simi Valley, not 3rd party with developers who refuse to build anything that is primarily for very-low and low income workers. - This means forming a first-party Simi Valley housing development solution, and giving opportunities for local contractors and semi-skilled to skilled workers to work directly for the city. - This means we don't need to negotiate with 3rd parties to get the work we need completed, and can cut through red tape and approvals faster than the current lengthy process that keeps us from meeting needs and demands in a timely manner.
- This means deprioritizing luxury and high-income housing. We will not lose out on tax and other income if people live in housing that is below their expected income, as it means they have more free assets to make larger purchases locally. The caveat is that we want to be sure that workforce-level earners can get housing instead of being out-rented by higher income earners.
3) With all the Assembly Bills passed recently, we need to use every tool available to make better use of the space we have already built up in Simi Valley.
- This means incentivizing more efficient use of space for housing per area of land like building up further (3-4 floor minimum) instead of keeping a two-floor limit.
- We need to expand on existing homes and property where the owners are open to it, helping them build ADUs, Junior ADUs, and expand their home to a second floor with the intent to rent the newly-added half. 4) A malignant factor in housing is the companies who aren't in Simi Valley, have no loyalty to Simi Valley, and buy up housing before actual prospective homeowners get a chance. Heavy fees and taxes are needed to either edge them out, or generate enough income to cover building more housing to compensate for what non-local landlords own to rent out.
- Companies such as Greystone have a pleasant veneer, but their goal of buying houses and making them perpetually rent-ownly is a form of landlordism that hurts the working class and even above-average earners. - Places that are owned specifically for rentals (such as a perpetual AirBnB) rob Simi Valley residents of the opportunity to find long-term housing opportunities, in exchange for private profits by the landlord. 5) On a more personal note, I have observed a great deal of deflection based on false premises and people who have less time and investment in Simi Valley.
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2 - Anyone who opposes building taller and denser workforce housing in Simi Valley because the city will "lose its charm
/ character" is not a worker that needs housing, and should not be recognized for this concern. This is often tied with segregationist language such as "not wanting Simi Valley to be like San Fernando Valley" which is not a concern for the people that actually need housing in Simi Valley. - Anyone who associates an increase in dense workforce housing with crime is ignoring Simi Valley's elevated police budget, and ignores that increasing equitable conditions historically reduce crime rather than elevating it. - Anyone who is concerned that their view will be blocked by taller housing, that higher-stories mean peeping Toms will be looking in their backyard, and that it means there will be more traffic, do have legitimate concerns--but instead of negotiating and discussing solutions for this, often just go into full shutdown and opposition. Any change does warrant concern, but the lack of changes that have left Simi Valley without necessary housing opportunities is the most critical priority to address today.
Thank you,
Reese Holland
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GPA-2021-0001: Draft Housing Element
Update for the 2021-2029 Planning Period
Final Initial Study – Mitigated Negative Declaration
prepared by
City of Simi Valley
Department of Environmental Services, Planning Division 2929 Tapo Canyon Road
Simi Valley, California 93063
Contact: Stratis Perros, Environmental Services Director prepared with the assistance of
Rincon Consultants, Inc.
180 North Ashwood Avenue
Ventura, California 93003
October 2021
EXHIBIT 6
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This report prepared on 50% recycled paper with 50% post-consumer content. 649
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Table of Contents
Final Initial Study – Mitigated Negative Declaration i
Table of Contents
Initial Study – Mitigated Negative Declaration ...................................................................................... 1
1. Project Title ......................................................................................................................... 1
2. Lead Agency Name and Address ......................................................................................... 1
3. Contact Person and Phone Number ................................................................................... 1
4. Project Location .................................................................................................................. 1
5. Project Sponsor’s Name and Address ................................................................................. 1
6. Description of Project ......................................................................................................... 3
7. Location of Prior Environmental Document(s) .................................................................22
8. Other Public Agencies Whose Approval is Required ........................................................22
9. Native American Tribal Consultation ................................................................................22 Environmental Factors Potentially Affected .........................................................................................23 Determination ......................................................................................................................................23 Environmental Checklist .......................................................................................................................25 1 Aesthetics ..........................................................................................................................25 2 Agriculture and Forestry Resources ..................................................................................37 3 Air Quality .........................................................................................................................39 4 Biological Resources ..........................................................................................................45 5 Cultural Resources ............................................................................................................61 6 Energy ...............................................................................................................................69 7 Geology and Soils ..............................................................................................................73 8 Greenhouse Gas Emissions ...............................................................................................83 9 Hazards and Hazardous Materials ....................................................................................87 10 Hydrology and Water Quality ...........................................................................................97 11 Land Use and Planning ....................................................................................................105 12 Mineral Resources ..........................................................................................................107 13 Noise ...............................................................................................................................111 14 Population and Housing ..................................................................................................119 15 Public Services .................................................................................................................123 16 Recreation .......................................................................................................................129 17 Transportation ................................................................................................................131 18 Tribal Cultural Resources ................................................................................................135 19 Utilities and Service Systems ..........................................................................................139 20 Wildfire............................................................................................................................145 21 Mandatory Findings of Significance ................................................................................149 651
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ii
References ..........................................................................................................................................151 Bibliography ................................................................................................................................151 List of Preparers ..........................................................................................................................152 Tables
Table 1 Simi Valley Zoning Designations ......................................................................................... 7 Table 2 Simi Valley RHNA Allocation for 2021-2029 by Income Category ....................................10 Table 3 Opportunity Areas and Potential Units Overview ............................................................12 Table 4 Candidate Housing Sites Inventory List .............................................................................15 Table 5 Health Effects Associated with Non-Attainment Criteria Pollutants ................................41 Table 6 Vibration Damage Potential ............................................................................................113 Table 7 Vibration Annoyance Potential .......................................................................................113 Figures
Figure 1 Regional Project Location ................................................................................................... 2 Figure 2 Opportunity Areas.............................................................................................................13 Figure 3 Example Scenic Vistas in Simi Valley .................................................................................27 Figure 4 Example Viewshed From Topo Canyon Road Looking South across Simi Valley ..............27 Appendices
Appendix A Responses to Comments on the Draft IS-MND
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Initial Study – Mitigated Negative Declaration
Final Initial Study – Mitigated Negative Declaration 1
Initial Study – Mitigated Negative Declaration
1. Project Title
GPA-2021-0001: General Plan Amendment to Update the Housing Element for the 2021-2029 Planning Period for Selected Sites Located Citywide and Internal Consistency of the General Plan (2021-2029 Housing Element).
2. Lead Agency Name and Address
City of Simi Valley
Department of Environmental Services, Planning Division 2929 Tapo Canyon Road
Simi Valley, California 93063
3. Contact Person and Phone Number
Stratis Perros, Environmental Services Director
805-583-6769
4. Project Location
Simi Valley is a suburban community in southeastern Ventura County, north of the San Fernando Valley in the greater Los Angeles area of southern California (Figure 1). The Ronald Reagan Freeway (State Route [SR] 118) bisects the city and the Santa Monica Mountains National Recreation Area is nearby, to the south. Simi Valley is in a crescent-shaped valley surrounded by the steep hills of the Santa Susana Mountains to the north and east (which separate Simi Valley from the Santa Clarita Valley to the north and the San Fernando Valley to the east), the Simi Hills to the south (which separate Simi Valley from the Conejo Valley), and the Las Posas Valley to the west.
5. Project Sponsor’s Name and Address
City of Simi Valley
Department of Environmental Services, Planning Division 2929 Tapo Canyon Road
Simi Valley, California 93063
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City of Simi Valley
GPA-2021-0001: Draft Housing Element Update for the 2021-2029 Planning Period
2 Figure 1 Regional Project Location
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6. Description of Project
Introduction
The project consists of a comprehensive update to the 2013-2021 Housing Element, which comprises Chapter 4 of the Simi Valley 2030 General Plan (adopted in 2012). The 2013-2021 Housing Element was adopted in February 2014 and was designed to bring the Housing Element into compliance with State law in place at that time as part of the fifth cycle of Regional Housing Needs Assessment (RHNA) allocations. The General Plan Program Environmental Impact Report (2012 EIR) was completed in June 2012. The General Plan and environmental documents are available for download on the City of Simi Valley, Environmental Services Department website.1 State law requires that housing elements shall be updated every eight years (California Government Code sections 65580 to 65589.8). The proposed update, the 2021-2029 Housing Element, identifies sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups defined under state law (California Government Code Section 65583), analyzes governmental constraints to housing maintenance, improvement, and development, addresses conservation and improvement of the condition of existing affordable housing stock, and outlines policies that promote housing opportunities for all persons. The current project updates the City of Simi Valley Housing Element as part of the sixth cycle planning period, which spans October 2021 through October 2029.
The update to the Housing Element will comply with State legislation passed since adoption of the 2030 General Plan in 2012. The 2021-2029 Housing Element update will reflect current conditions and include the following: 2
▪ Housing: An introduction and overview of the 2021-2029 Housing Element update process and legal requirements, including data sources used to compile the Housing Element and its relationship to other General Plan Elements. This section also details the extent of public participation in the development of the Housing Element. ▪ Housing Needs Assessment: A discussion of the city’s demographic and economic characteristics, along with growth projections for southern California, housing growth forecasts compared to recent population and housing growth; and current housing stock in the city. This section also includes an assessment of populations with special housing needs. ▪ Housing Constraints: An analysis of market, regulatory, and environmental constraints on housing production, cost, and maintenance.
▪ Housing Resources: An evaluation of housing resources, available land suitable for residential development, and estimated capacity in identified Opportunity Areas where the City’s RHNA could be met. This section also discusses financial and administrative resources and opportunities for energy conservation.
▪ Housing Plan: This section details the goals and policies of the 2021-2029 Housing Element, a list of the programs that will help achieve these goals and policies, and a summary of objectives with general timeframes in which those objectives might be achieved, along with the agency responsible for implementing the program.
1 https://www.simivalley.org/departments/environmental-services/planning-division/documents-applications-and-development- activity/general-plan
2 https://www.simivalley.org/departments/environmental-services/2021-housing-element-update 655
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4 Project Background and History
The City began preparing the 2021-2029 Housing Element in early 2021 when it initiated Planning Commission, task force, and public outreach meetings that extended from February to April 2021.
During these meetings, the City and local stakeholders considered strategies for meeting the sixth cycle RHNA allocation. The public review period for the draft 2021-2029 Housing Element began June 1, 2021 on the City’s website and at local venues as detailed in the Draft 2021-2029 Housing Element.3 Public meetings occurred from February 3, 2021 to June 9, 2021 and were advertised through social media, television, newspaper ads, and other means as detailed on page 4-3 of the Draft 2021-2029 Housing Element Update.
As part of the sixth cycle housing element update, cities are required to identify housing sites that provide the development capacity to accommodate build out of the City’s RHNA allocation at all income levels. Simi Valley is faced with limited opportunities to provide affordable housing due to historic land use patterns, high land and housing costs, and scarcity of vacant land. To accommodate the City’s RHNA need for all income levels, future housing development would occur through a variety of methods, and as detailed in the Housing Plan section of the 2021-2029 Housing Element.
This will include development on vacant parcels, infill development in existing residential and commercial areas, development of accessory dwelling units (ADU), and development on City-owned parcels such as those near the Metrolink Station. Housing elements are also required to consider ways to promote access to housing that is attainable for residents at all income levels, beyond focusing solely on opportunities for production of new units.
The 2021-2029 Housing Element establishes objectives, policies, and programs to help the City of Simi Valley meet state-mandated goals. The City’s implementation of these policies and programs includes a future technical update to the other elements of the 2030 General Plan and the rezoning of some sites in the inventory (as described in the section “Candidate Housing Sites Inventory” of this IS-MND) to meet the City’s RHNA obligation. Pursuant to Government Code Section 65583(c)(1), these actions will be accomplished within three years of the City’s adoption of the 2021-2029 Housing Element. As required by Government Code Section 65583(c), the 2021-2029 Housing Element provides a timeline for processing each of the amendments to the 2030 General Plan, Chapter 16 of the Simi Valley Municipal Code (SVMC), and other land use documents that implement the 2021-2029 Housing Element. In addition to the Housing Element, other 2030 General Plan elements that are being updated to maintain internal consistency include the Safety and Noise Element and the Land Use Element, which will also be assessed in this Initial Study – Mitigated Negative Declaration (IS-MND) to ensure new policies do not result in direct or indirect impacts.
Required Environmental Justice goals and policies are integrated into the Community Development and Mobility and Infrastructure Elements.
The Housing Element, which integrates/updates supporting socioeconomic, demographic, and household data, is specifically intended to accommodate the City’s RHNA allocation of 2,793 dwelling units. This allocation will be met with the following resources:
3 The 2021 Draft Housing Element can be found at
https://www.simivalley.org/home/showpublisheddocument/24082/637582249710100000 656
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▪ Pending, Approved, and Under Construction Residential Projects: Table H-40 in the 2021-2029 Housing Element lists 1,257 dwelling units approved, pending approval, or under construction, divided into the following categories:
191 very low/low income dwelling units
156 moderate income dwelling units
910 market-rate dwelling units
▪ ADUs are built on properties with existing single family or multi-family residences and are limited in terms of square footage and location. Recent trends in Simi Valley indicate that an average of 50 ADUs were built annually since 2018 due to streamlined permitting processes and other requirements that came about because of State legislation enacted in 2017. Following this trend, the City estimates that ADUs would add 400 dwelling units to housing inventory by 2029. ▪ Opportunity Areas/Sites Inventory: Several areas are identified as being able to accommodate the remaining RHNA of 1,136 dwelling units plus nearly a 45 percent buffer, for a total of 4,049 potential units. These include vacant or underutilized properties that offer opportunities for infill and intensification, and those with economically or physically obsolete development. The final Opportunity Areas were determined capable of accommodating the following number of units, as detailed in Table 3:
Three opportunity areas that could accommodate 860 lower income household units with their current zoning
One opportunity area (Old Town) that could accommodate 239 lower-income household units with a zoning change from Residential Medium (RM) to Residential Very High (RVH) density and Mixed-Use (MU)
One opportunity area (Patricia Avenue/Heywood Street Area) that could accommodate 411 lower-income household units and 92 moderate to above moderate-income household units, 503 units total, with a zoning change from Residential High (RH) to RVH density One opportunity area (Apricot Road) that could accommodate 69 lower-income household units and 272 moderate to above moderate-income household units, 341 units total, with a zoning change from Residential Very Low (RVL), RM, and Residential Moderate (RMod) to RH density
One opportunity area (Church on Royal Avenue) that could accommodate 42 lower-income household units and 38 moderate to above moderate-income household units, 80 units total, with a zoning change from Commercial (CO) and RM to CO(MU) and RH density One opportunity area (Heyneman Lane) that could accommodate 29 moderate to above moderate-income household units with a zoning change from Residential Low (RL) to RM density
Two opportunity areas (Walnut Hills and Oak Road) that could accommodate 95 total moderate to above moderate-income household units with a zoning change from RL to RM and RM to RMod densities.
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6 Environmental Setting
Population
The 2021 California Department of Finance Population and Housing Estimates indicate the population of Simi Valley was 124,468 as of January 1, 2021, an increase of less than 1 percent since 2010 (when the population was 124,237) and an increase of about 12 percent since 2000 (when the population was 111,339) (U.S. Census, 2011-2012; California Department of Finance [DOF] 2021).
Despite relatively flat trends in population growth over the last 10 years, the Southern California Association of Governments (SCAG) 2016-2040 Regional Transportation Plan/Sustainable Communities Survey (RTP/SCS) Final Growth Forecast by Jurisdiction estimates that Simi Valley’s population will increase by 17,923 persons to 142,400 by 2040, approximately 15 percent since 2010 (SCAG 2016).
Housing
As of 2018, the City’s housing stock totaled 43,469 dwelling units, with 34,921 single-family units comprising approximately 80 percent of that total; 7,787 multi-family homes comprising approximately 18 percent of that total; and 761 mobile homes comprising approximately two percent of that total. Most structures were built between 1960 to 1989. Based on the characteristics of the city’s housing stock, Simi Valley has a need for continued code enforcement, property maintenance, and housing rehabilitation programs to stem housing deterioration.
Candidate Housing Sites
The candidate housing sites include 121 parcels totaling 191.25 acres. This would meet the total RHNA allocation of 2,793 units, through 1,257 pending and approved projects, 400 projected ADUs, and 2,392 units that could accommodate housing on the opportunity area sites, for a total of 4,049 potential housing units. This exceeds the RHNA allocation by 1,256 units or approximately 45 percent.
This IS-MND evaluates the potential for future development of 1,367 dwelling units on the sites that will be rezoned to accommodate increased density. Rezoning will include changing the intensity of development allowed on sites identified as having the potential to meet most of the RHNA allocation. Sites zoned for residential development will be rezoned for residential development at an increased intensity, as described in the section “Candidate Housing Sites Inventory” of this IS- MND. City zoning designations are listed in Table 1. Some sites zoned for commercial use (retail and restaurant) will be rezoned with a mixed-use overlay that will allow the integration of residential units within the commercial complex. This could appear as multi-story buildings with shops and offices on the first floor and residential units on the upper floors, depending on development proposals. Many sites will include lower, moderate, and upper-income-level housing units to ensure that housing types are distributed throughout the city and to provide an integrated approach to the provision of housing for residents of all income categories.
The candidate housing sites inventory includes properties dispersed throughout the community to minimize the potential for adverse changes in neighborhood character and aesthetics and reduce the potential for adverse impacts to the environment. Opportunity areas where the rezone sites occur are described in detail on pages 4-78 through 4-84 of the Draft 2021-2029 Housing Element.
An overview of the sites appears in Figure 2 below. The 2021-2029 Housing Element will also reduce impacts by placing housing near public transportation and recreation opportunities. 658
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General Plan
The City of Simi Valley General Plan was last updated in 2012 and serves as the major framework for directing growth within the city. The 2030 General Plan presents a comprehensive approach to accommodate the city’s growing needs and includes goals and policies in the following elements:
▪ Community Development
▪ Housing
▪ Mobility and Infrastructure
▪ Natural Resources
▪ Community Services
▪ Safety and Noise
Municipal Code
The SVMC includes the Development Code (Title 9) and the Zoning Map; these identify the City’s allowed land uses and establish development standards for each zone. The Development Code carries out the policies of the City of Simi Valley General Plan by classifying and regulating the uses of land and structures in Simi Valley. The Development Code is adopted to protect and to promote the public health, safety, and general welfare of residents and businesses in the city. The Development Code applies to all land uses, subdivisions, and development in Simi Valley. The Zoning Designations that concern the 2021-2029 Housing Element are described briefly in Table 1.
Table 1 Simi Valley Zoning Designations
Zone Description
RVL – Residential Very Low
Density
The RVL zoning district is intended to provide for a semi-rural single-family residential environment with relatively large lots. The minimum lot area in this zoning district is 20,000 square feet, and the maximum residential density is one dwelling per lot.
RL – Residential Low Density The RL zoning district is intended to provide for a suburban single-family residential environment with a range of parcel sizes, but with generally low density and some clustering of parcels. The residential density in this zoning district may range from 2.1 to 3.5 dwelling units per acre. The maximum density is one dwelling per lot.
RM – Residential Medium
Density
The RM zoning district is intended to provide for a suburban single-family residential environment with a range of parcel sizes and some clustering of parcels. The residential density in this zoning district may range from 3.6 to 5.0 units per acre. The maximum density is one dwelling per lot.
RMod – Residential Moderate
Density
The RMod zoning district is intended to provide for moderate density detached single- family or multi-family dwellings. The residential density in this zoning district may range from 5.1 to 10.0 units per acre.
RH – Residential High Density The RH zoning district is intended for areas of more compact multi-family residential developments, such as townhouses, garden apartments, and other multiple-unit dwellings. The residential density in this zoning district may range from 10.1 to 20 units per acre.
RVH – Residential Very High
Density
The RVH zoning district is intended to provide for areas of relatively high density, with compact multi-family residential development near district of community shopping centers. The residential density in this zoning district may range from 20.1 to 35.0 units per acre.
MH – Mobile Home District The MH zoning district is intended to accommodate mobile home parks, to expand the range of housing opportunities available in the community. The residential density in this zoning district may range from 0 to 8 units per acre. 659
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8 Zone Description
CO – Commercial Office The CO zoning district is intended to provide areas for business and professional offices, related services, and other uses compatible with and especially sensitive to the surrounding land uses.
CPD - Commercial Planned
Development
The CPD zoning district is intended to encourage the development of attractive, innovative, and efficient commercial sites containing a broad range of retail, office, and service commercial uses.
LI – Light Industrial The LI zoning district is intended to provide areas for a variety of light manufacturing, service, technical research, and related business office uses, operating under performance standards that result in very few outside impacts Overlay Districts
A – Farm Animal Overlay The Farm Animal overlay zoning district identifies areas within the city where farm animals may be raised and maintained in large, discrete areas that avoid the common incompatibility problems associated with animal keeping on isolated and dispersed parcels.
CZ – Conditional Zoning The Conditional Zoning designations identify site-specific design criteria for specific parcels. These parcels are identified on the Zoning Map by the designation of (CZ) after the zoning. A listing of all the Conditional Zoning designations is attached to the Zoning Maps and identifies each property by the Assessor Parcel Number along with a description of the requirements for that property.
FC – Freeway Combining
Overlay District
The FC overlay is intended to regulate residential development along the freeway corridor to minimize the number of people impacted by the negative elements of the freeway. The FC overlay zone is established in recognition of the fact that residential development near SR 118 requires special consideration in construction and design to provide acoustic and visual protection for residents of dwellings to be constructed within the freeway impacted area and enhance the appearance of the freeway corridor through the city.
LAAPO – Los Angeles Avenue
Planning Overlay
The purpose of the LAAPO zoning district is to encourage and facilitate the redevelopment of existing commercial structures along both sides of Los Angeles Avenue between approximately Erringer Road and Simi Village Drive, as defined by the Zoning Map (reference Section 9-20.030). This zone is established to promote investment in the renovation of this aging business district. The overlay zone prescribes the boundaries of the area within which a specialized set of development standards shall apply. The goal is to achieve high quality, pedestrian-oriented development through innovative application of the Citywide Design Guidelines. This zone in no way modifies the land uses permitted by the underlying zoning. See Figure 2-3 in the SVMC Section 9-28.070 for the boundaries of the LAAPO District.
MU – Mixed-Use Overlay The purpose of the MU Overlay District designation is to create opportunities within the city to provide for a compatible mix of land uses, including residential, retail, and offices. The Mixed-Use Overlay allows properties to be developed with commercial retail or offices uses on the ground floor and housing on the second floor or above; a mix of differing land uses distributed horizontally on a site; or a single land use, as designated on the Community Subareas and Districts Maps (refer to Figures 2-4, 2-5, and 2-6). Mixed-Use developments strengthen the City's economic base, foster pedestrian-oriented activity, and reduce the need for automobile travel by providing a variety of goods, services, and jobs within walking distance of residences. The MU Overlay prescribes the boundaries of the area within which a specialized set of design standards and guidelines shall apply. The goal is to achieve high quality, pedestrian- oriented development through innovative application of the Citywide Design Guidelines, Residential Design Guidelines, and Landscape Design Guidelines. This zone in no way modifies the land uses permitted by the underlying zoning, except that properties that are developed for a mixture of commercial and residential uses 660
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Zone Description
(rather than a single-use development) must meet the standards for the Mixed-Use Overlay District, which are listed in SVMC Section 9-44.105. Single-use developments must meet development standards prescribed for that land use type (i.e., commercial retail development must meet all required commercial development standards).
SP – Specific Plan The Specific Plan designation indicates that the land is controlled by a formally adopted Specific Plan that may impose zoning or development standards that are more or less restrictive than those specified by the SVMC. Standards or regulations not addressed by the Specific Plan shall comply with the standards and regulations of the SVMC.
Source: SVMC Section 9 Development Code
Regional Housing Needs Assessment
The RHNA is a State Housing law requirement that is part of the periodic process of updating local general plan housing elements. It is a process that determines existing and projected housing need (i.e., RHNA allocation) for all jurisdictions in the State (including cities and unincorporated county areas) with the intent to provide opportunities for a mix of unit types, tenure, and affordability; and help achieve greenhouse gas (GHG) emission reductions from cars and light trucks. The RHNA allocation process is conducted by the State and regional planning agencies every eight years. Simi Valley is a member city of the Southern California Association of Governments (SCAG), which allocates a fair share of the total RHNA housing needed for each income category (as determined by the State) to the cities and unincorporated areas in in the SCAG region, which consists of Imperial, Riverside, San Bernardino, Orange, Los Angeles, and Ventura counties. The RHNA quantifies the housing need in each jurisdiction for all economic segments of the community across four income categories: very low, low, moderate, and above moderate. Each jurisdiction must demonstrate in its Housing Element that it can accommodate the assigned RHNA at all income levels. This may include the identification of current vacant land that can accommodate residential use or infill sites that permit residential development. If the City cannot identify enough sites/parcels appropriately zoned to accommodate RHNA allocations, then the City must identify additional candidate housing sites.
The DOF’s population estimates and the RHNA are also used for regional transportation planning purposes. Senate Bill (SB) 375 integrates RHNA with the Regional Transportation Plan (RTP) and Sustainable Communities Strategy (SCS). In the past, the RHNA was undertaken independently from the RTP. The California Legislature passed SB 375 in 2008 as the land use and transportation planning component of the State’s effort to reduce vehicle miles traveled (VMT) to achieve the GHG emission reduction goals of the Global Warming Solutions Act of 2006 (Assembly Bill [AB] 32). The law recognizes the importance of planning for housing and land use in creating sustainable communities where residents of all income levels have access to jobs, services, and housing by using transit, walking, or bicycling.
State housing law also requires that the RHNA process be consistent with the following objectives:
▪ Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties within the region in an equitable manner, which shall result in all jurisdictions receiving an allocation of units for low- and very low-income households ▪ Promoting infill development and socioeconomic equity, protecting environmental and agricultural resources, and encouraging efficient development patterns ▪ Promoting an improved intraregional relationship between jobs and housing 661
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10 ▪ Allocating a lower proportion of housing need to an income category when a jurisdiction already has a disproportionately high share of households in that income category ▪ Affirmatively furthering fair housing
The RHNA allocates housing need based on future estimates of housing unit growth need over the RHNA planning period (2021-2029). The RHNA identifies the projected number of dwelling units that will be needed to accommodate estimated future growth need during the planning period at specified levels of affordability. The SVMC Section Chapter 2, Section 3-2.01 defines a dwelling unit as “each single-family dwelling and each separate habitation unit of an apartment, duplex, or multiple dwelling structure designated as a separate habitation for one or more persons, although a part of the same building or structure, and each space in a mobile home park.” ADUs and Junior ADUs are defined separately under SVMC Section 9-44.160, which indicates these structures are built on “residentially zoned lots that already contain one legally established unit, or with the construction of a new residential unit.”
On March 22, 2021, SCAG issued its final sixth cycle RHNA Allocation Plan which determined the City of Simi Valley needed to accommodate 2,793 units. Table 2 indicates the RHNA allocation by income category. These categories are determined as a percentage of county area median income (AMI), adjusted for household size. SCAG research shows that the portion of lower income households in Simi Valley is lower than Ventura County as a whole, where Simi Valley has 9.5 percent and 9.6 percent extremely low and very low-income households respectively, and the County reports 11.7 percent each. (City of Simi Valley 2021).
Table 2 Simi Valley RHNA Allocation for 2021-2029 by Income Category Income Category (% of County AMI) Number of Units Percent Extremely low (30% or less) 374 13%
Very low (31% - 50%) 375 13%
Low (51% - 80%) 493 18%
Moderate (81% - 120%) 518 18%
Above moderate (+120%) 1,033 37%
Total 2,793 100%
AMI = Area Median Income
Source: City of Simi Valley 2021
In accordance with State Housing law, local governments must be accountable for ensuring that projected housing needs can be fully accommodated during the 2021-2029 Housing Element planning period. The 2021-2029 Housing Element provides a framework for evaluating the adequacy of local zoning and regulatory actions to ensure each local government is providing sufficient appropriately designated land throughout the planning period. The City of Simi Valley can count as credit toward meeting the sixth cycle RHNA any new dwelling units approved, permitted, and/or built during the current RHNA planning period (October 2021 to October 2029).
The Housing Element must identify and analyze the City’s housing needs and establish reasonable goals, objectives, and policies based on those needs. The 2021-2029 Housing Element must also identify candidate housing sites with the potential to accommodate housing at higher densities to meet the City’s assigned total low-income RHNA (extremely low, very low, and low income) 662
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Final Initial Study – Mitigated Negative Declaration 11 category need. Pursuant to California Government Code 65583, a “default density” of 30 dwelling units per acre4 is deemed the appropriate density to accommodate Simi Valley’s housing for lower- income households (per the State’s population-based suburban category). The default density is considered by statute as appropriate to accommodate affordable housing at an acceptable density that contributes to the feasibility of lower-income housing units. As the City has limited availability of existing suitable land to accommodate future growth, it must identify adequate sites with the potential to be developed at this density to meet the RHNA need for the lower-income categories.
Pursuant to AB 2348 and AB 1397 requirements, the City of Simi Valley will be required to accommodate future growth need through the identification of sites/parcels that can be rezoned entirely or where a zoning overlay can be applied that permit residential development at specific affordability levels in compliance with State law.
Candidate Housing Sites Inventory
State Housing law requires that the 2021-2029 Housing Element demonstrates that the City has enough land adequately zoned to accommodate its required share of regional growth and lower income dwelling units. To comply with State law (California Government Code Section 65583), the City prepared an inventory of specific housing sites that are suitable for residential development that could accommodate the lower income dwelling units allocated to the City in the sixth cycle RHNA.
The 2030 General Plan comprises the elements required by Section 65100, et seq., of the California Government Code, including the Housing Element. Among other goals, the Community Development Element includes Goal LU-2, which states that “a mix of land uses is provided that meets the diverse needs of Simi Valley’s residents, offers a variety of employment opportunities, and allows for the capture of regional population and employment growth.” The Community Development Element also includes policies to promote equitable distribution of housing types for all income groups throughout the city with a focus on mixed-income developments, while preserving the scale and characters of land uses and architecture within existing neighborhoods.
Consistent with the 2030 General Plan goals and policies and in consideration of data from SCAG, the City has identified an adequate number of sites to accommodate future housing needs within all income categories, distributed throughout the city, with higher densities oriented largely in opportunity areas along transit corridors.
It is anticipated that the City will significantly expand the potential for lower-income household units by recycling sites to higher intensity uses in these areas. The recycling focuses on redesignating sites as Mixed-Use (MU) and Very High Density residential (RVHD) for lower-income household units. Both designations allow residential development from 20.1 units per acre up to 35 units per acre. Such changes in land use designations would typically result in increases in land value and enhance the feasibility of private redevelopment of properties. The 2021-2029 Housing Element details these opportunity areas in Housing Resources: Opportunity Areas/Sites Inventory, which are summarized in Table 3 and illustrated in Figure 2.
4 One acre equals 43,560 square feet.
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12 Table 3 Opportunity Areas and Potential Units Overview Area
Number of
Potential
Units Current Zoning Proposed Rezone
Sites that would accommodate lower-income household units Mountain Gate Plaza Area 552 MU N/A
Los Angeles Avenue TOD /Metrolink Area 229 LI/MU
CPD/MU
N/A
Tapo Street Corridor 79 CPD/MU N/A
Old Town Area 239 CPD/LAAPO
RM
CPD/LAAPO (MU)
RVH
Patricia Avenue/Heywood Street Area 411 RH
RH (CZ)
RVH
RVH (CZ)
Church on Royal Avenue 42 CO CO (MU)
Apricot Road 69 RH(FC) RVH(FC)
Lower-income Household Unit Total 1,621
Sites that would accommodate lower-moderate or above
moderate household units
Apricot Road 272 RVL(A)(FC)
RM(FC)
RMod(FC)
RH(FC)
RH(FC)
RH(FC)
Heyneman Lane 29 RL RM
Leeds Street 245 RVL(SP)
RVL(A)
RH(SP)
RM
Walnut Hills 69 RLD
RMD
RMD (all)
Oak Road 26 RM RMod
Patricia Avenue/Heywood Street Area 92 RH (CZ) RVH
Church on Royal Avenue 38 RM RH
Moderate to Above Moderate-income Household Unit Total 771 Total Units Accommodated by Opportunity Areas 2,392
Source: City of Simi Valley 2021, Table H-42, Table H-43, Table H-44 664
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Source: City of Simi Valley 2021
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14 As presented in Table 3, the mix of units for each income category would be distributed among these sites, in support of the 2030 General Plan Community Design Element policy LU-9.3, Housing Type Distribution, that intends to “promote an equitable distribution of housing types for all income groups throughout the City and promote mixed-income developments.” The three areas that do not require a rezone (Mountain Gate, Los Angeles Avenue/Metrolink, and Tapo Street Corridor) would provide development opportunities for increased density with mixed use development, largely near transit corridors. The proposed rezones sites would increase density in the remaining opportunity areas to accommodate a mix of lower, moderate, and market-rate units, along with a mix of uses with amenities situated within residential areas in support of multi-modal transportation, community building, and sense of place in support of the following 2030 General Plan goals and policies:
▪ Goal LU-8: City Sustained and Renewed
LU-8.5: Revitalization of Obsolete and Underused Properties LU-8.8: Affordable Housing
▪ Goal LU-9: Fair and Equitable Access
LU-9.1: Equitable Distribution of Uses
LU-9.3: Housing Type Distribution
LU-9.4: Jobs-Housing Balance
▪ Goal LU-10: Livable and Quality Neighborhoods
LU-10-5: Walkable Neighborhoods
LU-10.6: Neighborhood Connectivity
LU-10.7: Complete Streets
▪ Goal LU-11: Neighborhood Urban Form
LU-11.3: Distribution of Density
Table 4 includes a parcel-specific listing of 121 candidate housing sites available to accommodate the City’s full share of the RHNA allocation by income level during the planning period. This list includes detailed information of the opportunity areas listed above. Ultimately, the City Council will decide which sites from the candidate housing sites inventory will be identified in the 2021-2029 Housing Element, as part of the action programs to accommodate the assigned affordable housing obligations.
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Final Initial Study – Mitigated Negative Declaration 15 Table 4 Candidate Housing Sites Inventory List
Opportunity Area APN Acres Address
Mountain Gate Plaza Area 632032064 17.07 2090 First St. 632032046 14.36 1317 E. Los Angeles Ave.
Los Angeles Ave./Metrolink Area 644021007 2.73 5000 E. Los Angeles Ave. 644021006 3.55 5000 E. Los Angeles Ave.
644007052 1.06 4785 E. Los Angeles Ave.
644009132 0.98 4809 E. Los Angeles Ave.
Tapo Street Corridor 616016029 0.18 4379 Alamo St.
616016030 0.47 4387 Alamo St.
618016014 1.59 2267 Tapo St.
618016012 1.06 2295 Tapo St.
Old Town Area 631010108 1.33 E. Los Angeles Ave & Third St. 631010104 0.11 E. Los Angeles Ave & Third St.
631010112 0.09 E. Los Angeles Ave & Third St.
631014010 9.97 1636 Sinaloa Rd.
Patricia Avenue/Heywood Street Area 632035170 0.24 1280 Patricia Ave. 632035171 0.24 1292 Patricia Ave.
632035172 0.23 1296 Patricia Ave.
630222023 0.55 1335 Patricia Ave.
632002022 0.55 1355 Patricia Ave.
632002019 0.21 1377 Patricia Ave.
632002017 0.53 1391 Patricia Ave.
632008001 1.26 1312 Patricia Ave.
632008014 0.48 1336 Patricia Ave.
632002013 0.50 1453 Patricia Ave.
632002012 0.50 1467 Patricia Ave.
632002011 0.45 1479 Patricia Ave.
632002021 0.25 1367 Patricia Ave.
632003067 0.77 1511 Patricia Ave.
632003066 0.26 1874 Hubbard St.
632003047 1.04 1541 Patricia Ave.
632003028 0.48 1579 Patricia Ave.
632003027 0.13 1593 Patricia Ave.
632003055 0.17 1841 Duncan St.
632003024 0.23 1881 Duncan St.
632003051 0.22 1867 Duncan St.
632003056 0.13 1850 Duncan St.
632003060 0.21 1876 Duncan St.
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16 Opportunity Area APN Acres Address
632003068 0.22 1887 Galt St.
632003018 0.27 1611 Patricia Ave.
632003017 0.22 1621 Patricia Ave.
632006001 0.40 1624 Patricia Ave.
632006023 0.27 1644 Patricia Ave.
632006026 0.34 1746 Duncan St.
632006025 0.33 1623 Heywood St.
632006029 0.44 1680 Patricia Ave.
632006004 0.64 1715 Galt St.
632006058 0.75 1724 Rose Ln.
632006005 0.62 1710 Patricia Ave.
632006022 0.62 1730 Patricia Ave.
632005039 4.36 Not available
632002020 0.25 1363 Patricia Ave.
632008018 0.57 1364 Patricia Ave.
632002014 0.56 1439 Patricia Ave.
632006023 0.25 1644 Patricia Ave.
632003070 0.19 1859 Galt St.
632003018 0.21 1611 Patricia Ave.
632003017 0.21 1621 Patricia Ave.
632002018 0.28 1381 Patricia Ave.
632002025 0.01 Unaddressed
632003048 0.20 1855 E. Duncan St.
632003024 0.22 1881 Duncan St.
632003051 0.21 1867 Duncan St.
Church on Royal Avenue 638031005 2.40 1925 Royal Ave.
Apricot Road Area 625022024 0.54 4476 Apricot Rd.
625008105 0.53 4462 Apricot Rd.
625008106 0.26 4464 Apricot Rd.
625008119 0.26 4483 Cochran St.
625008118 0.26 4491 Cochran St.
625008117 1.03 4497 Cochran St.
625008111 0.53 4558 Apricot Rd.
618008069 0.78 Cochran St.
618008066 0.78 4071 Cochran St.
618008072 0.78 4107 Cochran St.
618008065 2.36 Unaddressed
618007017 0.78 422 E. Cochran St.
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625007506 0.54 4613 Apricot Rd.
625006208 0.57 4481 Apricot Rd.
625006209 0.55 4511 Apricot Rd.
625006210 0.57 4535 Apricot Rd.
625006211 0.28 4551 Apricot Rd.
625006212 0.28 4555 Apricot Rd.
625006214 0.56 4571 Apricot Rd.
625006215 0.55 4591 Apricot Rd.
625006207 0.57 4473 Apricot Rd.
625007505 0.53 4639 Apricot Rd.
625007503 0.27 4653 Apricot Rd.
625007504 0.81 4681 Apricot Rd.
625009119 0.69 4613 Cochran St.
625009120 0.77 4639 Cochran St.
625008112 0.80 4570 Apricot St.
625008113 0.40 4590 Apricot Rd.
625008114 0.40 4592 Apricot Rd.
625009101 0.40 4608 Apricot Rd.
625009105 1.61 4688 Apricot Rd.
625009111 0.39 4620 Apricot Rd.
625009116 0.39 4630 Apricot Rd.
625009117 0.39 4640 Apricot Rd.
625009114 0.77 4633 Cochran St.
625009106 0.29 2439 Fig St.
625009121 0.27 4669 Cochran St.
Heyneman Lane/Leeds Street Area 639001075 1.23 Not available 639001076 25.16 Not available
644008019 3.94 5121 Leeds St.
644008017 1.72 5157 Leeds St.
644008018 0.99 5135 Leeds St.
644008016 2.56 2245 Stearns St.
644008085 5.15 4832 Cochran St.
644008042 5.31 4910 Cochran St.
644008084 2.58 4868 Cochran St.
644008046 4.02 5028 Cochran St.
644008050 1.44 Unaddressed
Oak Road 637014015 3.05 1761 Oak Rd.
637014032 0.73 Unaddressed
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18 Opportunity Area APN Acres Address
Royal Area 638003034 3.85 2369 Royal Ave.
Walnut Hills 611037007 2.57 Chelmas Ct.
614001026 12.55 3799 Walnut Ave.
614001022 0.08 Walnut Ave.
614001021 12.07 Unaddressed
614001024 0.12 Unaddressed
614001025 0.16 Unaddressed
Source: City of Simi Valley 2021
Project Characteristics
Buildout Projections for Future Site Development
A “project” as defined by State CEQA Guidelines Section 15378(a) “means the whole of an action, which has a potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment.” The project includes 121 candidate housing sites/parcels for future housing development to meet the City’s total RHNA allocation of 2,793 dwelling units plus a 15 percent buffer (1,367 potential units total on the rezone sites in 10 Opportunity Areas).5 The 2021-2029 Housing Element does not propose any specific development projects on the candidate sites. Future housing development could occur on these candidate housing sites, if they are included in the 2021-2029 Housing Element, as local conditions dictate with timing at the discretion of each individual property owner and as the market allows.
This IS-MND evaluates the potential for development of 2,392 dwelling units on 121 candidate housing sites/parcels (any combination thereof) totaling approximately 191.25 acres, as detailed in Table 4. Recognizing that not all candidate housing sites will ultimately be included in the 2021-2029 Housing Element, and necessary Community Plan amendments and SVMC zone changes that may be required for the selected candidate housing sites/parcels would influence buildout projections on a site-by-site basis, this IS-MND evaluates the environmental impacts for potential development of 2,392 dwelling units constituting the full build-out of these sites, with a development footprint that includes each candidate housing site/parcel in its entirety.
The candidate housing sites are evaluated at a programmatic level based on information available to the City where reasonably foreseeable direct and indirect physical changes in the environment can be considered. A detailed analysis of each site was not conducted because the City has no information on actual projects that may be proposed on these sites and thus it would be speculative to analyze specific impacts on any given site. As such, potential changes beyond those considered here would be assessed on a project-level basis as part of the permitting and (when applicable) environmental review process when specific projects are proposed.
As part of the 2021-2029 Housing Element update, other elements of the 2030 General Plan are being updated simultaneously to ensure the 2030 General Plan complies with current state law.
These include updates to the Community Development Element policies that prioritize mixed-use development in keeping with the in-fill development focus of the 2021-2029 Housing Element and include Environmental Justice goals and policies that address the potential impacts of development
5 1,136 dwelling units is the remainder of the total RHNA (2,793 dwelling units) after accounting for the pending and approved projects (1,257 dwelling units) and the estimated ADUs (400 dwelling units). 670
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Final Initial Study – Mitigated Negative Declaration 19 to marginalized and at-risk communities. Goals and policies in the Safety and Noise Element that address updates to legislation concerning new development and wildfire risk in accord with SB 747.
These updates to the 2030 General Plan goals and policies are designed to reduce environmental risk to new development as they would target potential impacts to air quality, greenhouse gas pollutants, and wildfire risk. Therefore, these policy updates are not analyzed further in this IS-MND.
Future Development Constraints
Future housing development facilitated by the Housing Element could be constrained by market conditions or various environmental conditions or impacts. Market constraints on potential future housing development are created by environmental and regulatory frameworks that reduce the potential profitability of housing development. Environmental constraints on potential future housing development coincide with the time, effort, and costs associated with mitigating environmental impacts.
Where environmental impacts are significant and unavoidable, pursuant to State CEQA Guidelines Section 15093, the City Council would be required to balance, as applicable, the economic, legal, social, technological, or other benefits of the 2021-2029 Housing Element against its unavoidable environmental risks when determining whether to approve the Housing Element. However, as concluded throughout this IS-MND, all potentially significant environmental effects of the 2021- 2029 Housing Element would be avoided or substantially lessened through compliance with the established regulatory framework and mitigation measures specified in this IS-MND. In accordance with the State CEQA Guidelines, all later activities associated with implementation of the Housing Element will be examined in the light of this IS-MND to determine whether an additional environmental document must be prepared.
Design Review and Regulation
The SVMC Section 9-52.070, specifies that projects that require a Conditional Use Permit must undergo design review as part of the permitting process. Conditional Use Permits are intended to allow for activities and uses which may be desirable in the applicable zoning district and compatible with adjoining land uses, but whose effect on a site and its surroundings cannot be determined before being proposed for a particular location. The Citywide Design Guidelines (City of Simi Valley 2000) promote a desired level of future development quality in Simi Valley that contributes to a positive physical image and identity of non-residential development and most of the potential projects that could occur under the 2021-2029 Housing Element implementation would include design review. These ensure compatible land use forms in terms of style, massing, and landscaping for new and renovated development.
The City’s Residential Design Guidelines promote excellence in design and development of new residential projects in Simi Valley (City of Simi Valley 2001). Implementation of these guidelines contributes to a positive residential built environment and community identity through superior residential design. Section 9-30.040 of the SVMC addresses exterior light and glare for existing and new development, and SVMC Section 9-37.060.B regulates commercial and other business signage, including offices, in a way that allows for identification of the businesses while maintaining the character of residential zones. Finally, the Landscape Design Guidelines apply to the development of preliminary landscape plans for residential, commercial, and industrial projects in the City (City of Simi Valley 2015). The guidelines establish minimum landscape design standards without dictating specific planting styles, themes, or arrangements. Landscape designs are required to comply with SVMC Section 8-22.03, Division 4.304 and the most recent water conservation regulations. 671
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20 Future Development
As outlined in the 2021-2029 Housing Element and associated zoning provisions, the Housing Element will develop a RHNA implementation plan through its programs, along with CEQA mitigation measures identified in this IS-MND, the implementation of which is detailed in the Mitigation Monitoring and Reporting Program (MMRP). Future projects will be required to adhere to the mitigation stated herein for the site to develop consistent with the 2021-2029 Housing Element’s purpose and to avoid or lessen any potentially significant environmental impacts.
Future housing proposals may tier from this IS-MND or a finding may be made that sufficient environmental clearance occurred with this IS-MND (State CEQA Guidelines Sections 15152, 15162, and 15168). This IS-MND considers a series of related projects with the intent to streamline subsequent review of future housing development projects consistent with the 2021-2029 Housing Element’s intent.
Future development facilitated by the 2021-2029 Housing Element programs may be subject to subsequent environmental and other discretionary review and permitting, in accordance with the SVMC. Specifically, design review and subsequent discretionary review may be required for some actions. Subsequent environmental review may be required for discretionary actions to entitle future development projects.
Regulatory Setting
Changes in State Law
Many new state housing laws have been enacted since the last housing element update cycle. The 2021-2029 Housing Element incorporates and addresses all pertinent housing law changes through analysis or new policies or programs. The 2021-2029 Housing Element is consistent with these changes in State law, all of which are detailed in the introduction of the 2021-2029 Housing Element and are summarized below:
▪ Affordable Housing Streamlined Approval Process: Senate Bill (SB) 35 (2017), Assembly Bill (AB) 168, and AB 831 – These bills support a streamlined, ministerial review process for qualifying multifamily, urban infill projects in jurisdictions that have failed to approve housing projects sufficient to meet their state‐mandated RHNA.
▪ Additional Housing Element Sites Analysis Requirements: AB 879 (2017) and AB 1397 (2017) – These bills require additional analysis and justification of the sites included in the sites inventory of the City’s Housing Element.
▪ Affirmatively Furthering Fair Housing: AB 686 (2017) – AB 686 requires the City to administer its housing programs and activities in a manner to affirmatively further fair housing and not take any action that is inconsistent with this obligation.
▪ No-Net-Loss Zoning: SB 166 (2017) – SB 166 amended the No‐Net‐Loss rule to require that the land inventory and site identification programs in the Housing Element include sufficient sites to accommodate any unmet RHNA, should it exist. The Simi Valley sites inventory far exceeds the City’s RHNA, allowing for additional sites to be used for additional housing units as needed. ▪ Safety Element to Address Adaptation and Resilience: SB 1035 (2018) – SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the Housing Element.
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Final Initial Study – Mitigated Negative Declaration 21 ▪ By Right Transitional and Permanent Supportive Housing: AB 2162 (2018) and AB 101 (2019) – AB 2162 requires the city to change its zoning to provide a “by right” process and expedited review for supportive housing. Additionally, AB 101 requires that a Low Barrier Navigation Center development be an allowed use by right in mixed-use zones and nonresidential zones permitting multifamily uses if it meets specified requirements. ▪ Accessory Dwelling Units: AB 2299 (2016), SB 1069 (2016), AB 494 (2017), SB 229 (2017), AB 68 (2019), AB 881 (2019), AB 587 (2019), SB 13 (2019), AB 670 (2019), AB 671 (2019), and AB 3182 (2020) – The 2016 and 2017 updates to State law included changes pertaining to the allowed size of accessory, permitting ADUs by right in at least some areas of a jurisdiction, and limits on parking requirements related to ADUs. More recent bills reduce the time to review and approve ADU applications to 60 days, remove lot size and replacement parking space requirements, and require local jurisdictions to permit junior ADUs.
▪ Density Bonus: AB 1763 (2019) and AB 2345 (2020) – AB 1763 amended California’s density bonus law to authorize significant development incentives to encourage 100 percent affordable housing projects, allowing developments with 100 percent affordable housing units to receive an 80 percent density bonus from the otherwise maximum allowable density on the site. AB 2345 created additional density bonus incentives for affordable housing units provided in a housing development project. It also requires that the annual report include information regarding density bonuses that were granted.
▪ Housing Crisis Act of 2019: SB 330 – SB 330 enacts changes to local development policies, permitting, and processes that will be in effect through January 1, 2025. Recent updates to this act include the proposed SB 8 (2019), which would extend the operation of SB 330 until January 1, 2030.
▪ Surplus Land Act Amendments: AB 1486 and AB 1255 (2019) - AB 1486 refines the Surplus Land Act to provide clarity and further enforcement to increase the supply of affordable housing. AB 1255 requires the City to create a central inventory of surplus and excess public land each year.
The City is required to transmit the inventory to the California Department of Housing and Community Development (HCD) and to provide the list to the public upon request. ▪ Housing Impact Fee Data: AB 1483 (2019) – AB 1483 requires the City to publicly share information about zoning ordinances, development standards, fees, exactions, and affordability requirements.
▪ Emergency and Transitional Housing Act of 2019: AB 139 (2019) – AB 139 established new criteria for evaluating the needs of the homeless population. ▪ Standardization of Sites Inventory Analysis and Reporting: SB 6 (2019) – SB 6 requires the City to electronically submit the sites inventory to HCD starting in 2021. ▪ Evacuation Routes: SB 99 and AB 747 (2019) – AB 747 and SB 99, require the General Plan Safety Element to be updated to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios and to include information identifying residential developments in hazard areas that do not have at least two emergency evacuation routes. 673
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22 7. Location of Prior Environmental Document(s)
The Environmental Services Director for the City of Simi Valley, 2929 Tapo Canyon Road, Simi Valley, California, 93063 serves as the custodian of the 2030 General Plan, including the 2021-2029 Housing Element, and the associated environmental documents. A copy of previous environmental documents and supporting reports are available online at the City of Simi Valley, Planning Division webpage and by request: https://www.simivalley.org/departments/environmental- services/environmental-documents.
8. Other Public Agencies Whose Approval is Required
Adoption of the 2021-2029 Housing Element and the General Plan updates (Community Development, Mobility and Infrastructure, and Safety and Noise Elements) would require the following discretionary actions by the City of Simi Valley Planning Commission and/or City Council:
▪ Certification of the final environmental analysis
▪ Approval of the General Plan update and the 2021-2029 Housing Element, including related text and map amendments in other chapters that are required for internal consistency ▪ Approval of the zoning changes
HCD does not approve the City’s Housing Element. The City Council performs that task. However, the City is required to submit it to HCD for certification.
9. Native American Tribal Consultation
The City initiated the tribal consultation process, as required under Public Resources Code (PRC) Section 21080.3.1 and consistent with Assembly Bill (AB) 52 and Senate Bill (SB) 18. The City mailed consultation letters on April 27, 2021 according to SB 18, and on June 29, 2021 according to AB 52, to contacts identified by the Native American Heritage Commission that requested the City of Simi Valley notify them of projects subject to AB 52 or SB 18. As of the drafting of this report, the City has not received any responses requesting consultation. Under AB 52, Native American tribes have 30 days to respond to consultation notification and request further project information and formal consultation; under SB 18 Native American tribes have 90 days to respond requesting consultation. 674
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Final Initial Study – Mitigated Negative Declaration 23 Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
■ Biological Resources ■ Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse Gas
Emissions
□ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources □ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation ■ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire □ Mandatory Findings of Significance
Determination
Based on this initial evaluation:
□ I find that the 2021-2029 Housing Element COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. ■ I find that although the 2021-2029 Housing Element could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the 2021-2029 Housing Element MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. □ I find that the 2021-2029 Housing Element MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. 675
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Final Initial Study – Mitigated Negative Declaration 25 Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029 Housing Element:
a. Have a substantial adverse effect on a
scenic vista? □ □ ■ □
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway? □ □ ■ □
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project is
in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ ■ □
Environmental Setting
As addressed in CEQA analysis, aesthetics refers to visual concerns. Aesthetics or visual resources analysis is a process to assess the visible change and anticipated viewer response to that change.
While the conclusions of these assessments may seem subjective, value is measured based on generally accepted measures of quality, viewer sensitivity, and viewer response, supported by consistent levels of agreement in research on visual quality evaluation (BLM 1984, FHWA 2015).
Modifications in a landscape that repeat basic elements found in that landscape are said to be in harmony with their surroundings; changes that do not harmonize often look out of place and can be found to form an unpleasant contrast when their effects are not evaluated adequately. This includes the built environment and the natural landscape, and more precisely, how the built environment visually coheres with the natural environment. Terms used in visual analysis are as follows:
Viewshed
A viewshed is an area of the landscape visible from a particular location or series of points (e.g., an overlook or a trail, respectively) (FHWA 2015). A viewshed may be divided into viewing distances 677
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26 called foreground, middle ground, and background. Usually, the closer a resource is to the viewer, the more dominant it appears visually, and thus it has greater important to the viewer than something farther away. A common set of criteria identifies the foreground as 0.25 to 0.5 mile from the viewer; the middle ground is three to five miles away; and the background extends away to the horizon.
Visual Character
Natural and human-built landscape features contribute to the visual character of an area or view.
Features include geology, water features, plants, wildlife, trails and parks, and architecture and transportation elements (e.g., bridges or city skylines). The way visual character is perceived can vary based on the season, the time of day, the light, and other elements that influence what is visible in a landscape. The basic components used to describe visual character are form, line, color, and texture of landscape features (USFS 1996, FHWA 2015).
Visual Quality
Visual quality is a term that indicates the uniqueness or desirability of a visual resource, within a frame of reference that accounts for the uniqueness and “apparent concern for appearance” by viewers (e.g., residents, visitors, jurisdictions) (USDA 1978). A well-established approach to visual analysis is used to evaluate visual quality, using the concepts of vividness, intactness, and unity (FHWA 2015).
▪ Vividness describes the memorability of landscape components as they combine in striking patterns.
▪ Intactness refers to the visual integrity of the natural and human-built. ▪ Unity indicates the visual coherence and compositional harmony of the landscape as a whole.
Simi Valley is a suburban city situated in a crescent-shaped valley surrounded by the steep hills of the Santa Susana Mountains to the north and east (which separate Simi Valley from the Santa Clarita Valley to the north and the San Fernando Valley to the east), the Simi Hills to the south (which separate Simi Valley from the Conejo Valley), and the Las Posas Valley to the west. The City recognizes the natural landforms in Simi Valley as scenic resources; these include the hillsides and mountains on the horizon, but also the oak woodlands, lakes, rivers, streams, and historical areas, including those discussed in Section 5, Cultural Resources.
A viewshed is an area of land, water, and other natural environment elements visible from a public vantage point that is of particular scenic or historic value and deemed worthy of preservation against development and other changes. Most streets on the valley floor offer views of the surrounding hillsides and ridgelines, particularly major arterial roadways such as Los Angeles Avenue, Tapo Canyon Road, Sycamore Drive, and Erringer Road. Figure 3 provides examples of these views. From more elevated areas, views across the valley looking south are sweeping and feature rock formations, mature naturally occurring and landscaped trees, and the low-level suburban neighborhoods that characterize much of Simi Valley, as shown in Figure 4. SR 118 offers expansive vistas of both the natural and the built environment. Scenic view and vistas are also available from roads in Tapo Canyon and Alamos Canyon, as well as Madera Road and Olsen Road. 678
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Final Initial Study – Mitigated Negative Declaration 27 Figure 3 Example Scenic Vistas in Simi Valley
Sycamore Drive, looking north Erringer Road, looking northwest
Los Angeles Avenue, looking east Tapo Canyon Road, looking Figure 4 Example Viewshed From Topo Canyon Road Looking South across Simi Valley
The study area for aesthetics includes the areas in which the Opportunity Areas with rezone sites occur and not the entire city. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element. The City cannot assess the specific impacts of specific projects as those have yet to be proposed on the Opportunity Areas, which are largely situated in areas currently zoned for commercial, light industrial, mixed use, and 679
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28 residential uses. Project-specific impacts will be ascertained during the permitting process for those projects.
Impact Analysis
a. Would the project have a substantial adverse effect on a scenic vista? A scenic vista can generally be defined as a public viewpoint that provides expansive views of a highly valued landscape for the benefit of the public. In Simi Valley, these include Big Mountain and the Whiteface escarpment, views and vistas from the various canyons of Simi Valley, views along SR 118, and manmade landmarks such as Ranch Reservoir and Dam and the Ronald Raegan Presidential Library (City of Simi Valley 2012). The 2021-2029 Housing Element prioritizes the development of new housing on infill sites in areas with existing public transit infrastructure. The Opportunity Areas would allow for the development of new housing and greater density of housing on sites currently zoned CO, CPD, LI, MU, RH, RL, RLD, RM, RMD, and RVL. The Opportunity Areas would occur along and near SR 118, Arroyo Simi, Los Angeles Avenue, Old Town, and near open space land in the northern and southern portions of the city, areas where scenic vistas are available.
Future development projects would be required to comply with the 2030 General Plan goals and policies that address design as follows:
Goal LU-4 Development Shaped by Environmental Setting. Development is located to respect, work with, and complement the natural features of the land.
Policy LU-4.1 Preservation of Natural Features. Maintain significant natural landmarks, such as prominent ridgelines visible from the valley floor, and other natural scenic features in their natural state, to the extent feasible.
Policy LU-4.2 Incorporation of Natural Features. Integrate natural scenic features, such as mature trees, rock outcroppings, watercourses, and views into project design, except where infeasible for public safety.
Policy LU-4.4 Hillside Development. Locate and design development to maintain the existing visual character of the hillsides as a natural backdrop.
Policy LU-4.5 Hillside Grading. Minimize terrain disruption and design grading using generally accepted principles of civil engineering with the objective to blend the project into the natural topography.
Policy LU-4.7 Development Compatibility with Hillside Character. Ensure the compatibility of proposed structures with the surrounding terrain in hillside areas by using varying setbacks, building heights, building forms, and other applicable features.
Policy LU-4.8 Architecture and Building Design. Design buildings to be architecturally integrated into the terrain and blend with the natural environment.
Policy LU-4.9 Building Colors in Hillsides. Use earth tones or subdued colors for development in hillside areas with bright hues used only as accents so they will complement the natural setting.
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Final Initial Study – Mitigated Negative Declaration 29 Goal LU-7 Viewsheds. Vistas of the hillsides, valley floor, city entrance areas, recreation areas, major open space areas, and viewsheds from the hills are maintained for the public.
Policy LU-7.1 City Entries. Protect open vistas at freeway entrances to the community and along Madera Road and Tierra Rejada Road, by such means as enriched parkways, open space, height limits, and view corridors. The appearance of development along these throughways should be attractive, complement the vista, and not compete for attention.
Policy LU-7.2 Development in View Corridors. Design structures and site improvements constructed in highly visible locations to minimize their impacts on natural vistas.
Goal NR-3 Visual Resource Protection. Significant visual resources are preserved as important quality-of-life amenities for residents and as assets for recreation and tourism.
Policy NR-3.1 Maintenance of Natural Topography. Preserve hills, ridgelines, canyons, bluffs, significant rock outcroppings, and open space areas surrounding the city as a visual resource and locate buildings and utility infrastructure to minimize alteration of natural topography.
Policy NR-3.2 Provide public trails, recreation areas, and viewing areas near significant visual resources where appropriate.
Policy NR-3.3 Location and Design of Developments. Require development within visually sensitive areas to minimize impacts to scenic resources and to preserve unique or special visual features, particularly in hillside areas, through the following:
▪ Creative site planning
▪ Integration of natural features into the project
▪ Appropriate scale, materials, and design to complement the surrounding natural landscape
▪ Clustering of development to preserve open space vistas and natural features
▪ Minimal disturbance of topography
▪ Creation of contiguous open space networks
Policy NR-3.5 Development Location on Hillsides. Require development to preserve and enhance physical features by being located down and away from ridgelines.
City zoning and overlay regulations, including specific plan or community plan development regulations, that implement General Plan goals and policies intended to protect scenic vistas would also apply. These include undergoing development design review as part of the permitting process to ensure compliance with existing design standards, including Hillside Performance Standards and Landscaping Standards (Simi Valley Municipal Code [SVMC] Chapter 9-32). With adherence to General Plan goals and policies, and City design standards that address architectural style and the quality of building materials, along with landscaping, impacts to scenic vistas from development facilitated by the 2021-2029 Housing Element would be less than significant. Concurrent updates to the Community Development Element do not alter the scenic resources or visual quality goals and policies, and thus impacts to scenic vistas from updates to the General Plan would also be less than significant.
LESS THAN SIGNIFICANT IMPACT
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30 b. Would the project substantially damage scenic resources, including but not limited to, trees, - rock outcroppings, and historic buildings within a state scenic highway? SR 27 in the Santa Monica Mountains is officially designated as a State Scenic Highway for a 2.5-mile stretch in Los Angeles County, approximately 16.6 miles south of Simi Valley (California Department of Transportation [Caltrans] 2019). While SR 118 is noted in the Simi Valley General Plan as offering scenic vistas, it is not officially designated as a State scenic highway or as a local scenic highway to be protected. Therefore, the project would not damage scenic resources of any kind within a State scenic highway. Additionally, future development projects would be required to comply with the General Plan goals and policies that address design discussed under Threshold a, and these goals and policies (especially Goal NR-3, Visual Resource Protection) would help protect scenic resources.
This impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Most of the Opportunity Areas and rezone sites occur in an urbanized setting developed with retail establishments, homes, and office spaces. The Walnut Hills Opportunity Area is adjacent to open space and hillsides, but the area to its south is developed with single-family homes. Therefore, the Opportunity Areas are in urbanized areas.
The 2021-2029 Housing Element would facilitate infill on sites in the Opportunity Areas that are being rezoned to accommodate a greater density of residential development on sites currently zoned for commercial, industrial, mixed-use, and varying densities of residential uses, as listed in Table 4. Increased density would change the visual character to some degree through the introduction of horizontal and vertical (multi-story) complexes, up to three stories, in areas where mostly single-story development exists. However, all development facilitated by the 2021-2029 Housing Element would be subject to design review as part of the permitting process and would be required to comply with the 2030 General Plan goals and policies that guide scenic and visual quality, including limiting abrupt changes in height from one-story neighborhoods to taller buildings, up to three stories in height. In addition to the goals and policies listed under Threshold a, those that further address visual quality are as follows:
Goal LU-6 Open Spaces. Open space lands are preserved to maintain the visual quality of the City, provide recreational opportunities, protect the public from safety hazards, and conserve natural resources and wildlife.
Policy LU-6.5 Orientation towards Arroyo Simi. Orient new development located along the Arroyo Simi to take advantage of it as an asset and integral part of the project design.
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Final Initial Study – Mitigated Negative Declaration 31 Goal LU-10 Livable and Quality Neighborhoods. A City composed of neighborhoods with a variety of housing types, densities, and design, and that provide a mix of land uses, services, and amenities that support the needs of its residents.
Policy LU-10.1 Neighborhood Conservation. Maintain the uses, densities, character, amenities, and quality of Simi Valley’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life for residents.
Policy LU-10.2 Housing Character and Design. Locate and design new and renovated housing within existing single- and multi-family neighborhoods to maintain their distinguishing characteristics and qualities of the neighborhoods, including prevailing lot sizes; building form, scale, massing, and relationship to street frontages; architectural design; landscape; property setbacks; and comparable elements.
Goal LU-11 Neighborhood Urban Form. Residential development is provided that respects Simi Valley’s natural setting and suburban density and scale, while offering opportunities for more intensive use in key activity areas that reduce automobile use and transition smoothly to existing neighborhoods, and open spaces.
Policy LU-11.1 Placement of Residential Structures. Encourage the siting of residential units to preserve open space and natural resources while maintaining the overall density.
Goal LU-12 Neighborhood Identity. Residential neighborhoods are provided that are distinctly identified and differentiated from one another in consideration of geography, character, and lifestyle.
Policy LU-12.1 Contributing Elements for Neighborhood Identity. Locate and design new development in or abutting existing residential neighborhoods to respect boundaries defined by topography, drainage, landscape, or other natural elements that delineate and contribute to their distinct identity.
Policy LU-12.2 Identity through Design. Promote the design of new development to provide a positive sense of uniqueness to aid neighborhood identity and to be compatible with existing surrounding neighborhoods.
Goal LU-14 Single-Family Neighborhoods. The characteristics and qualities that distinguish Simi Valley’s distinct single-family residential neighborhoods, such as identity, scale, and character, are maintained.
Policy LU-14.1 Neighborhood Identity. Maintain distinguishing characteristics, such as topography, parcel size, housing scale and form, and public streetscapes that differentiate Simi Valley’s single-family neighborhoods. 683
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32 Goal LU-15 Multi-Family Neighborhoods. Multi-family residential neighborhoods that provide ownership and rental opportunities are well designed, exhibit a high quality of architecture, and incorporate amenities for their residents.
Policy LU-15.1 Character and Design. Locate and design new and renovated housing within existing multi-family neighborhoods to achieve a high level of architectural design quality, in consideration of the following principles:
▪ Design elevations of multi-family buildings facing public streets and pedestrian ways to exhibit a high level of visual interest ▪ Incorporate property setbacks, modulate building mass, and design multi- family buildings and projects in consideration of the development patterns of the surrounding neighborhood.
Goal LU-19 Mixed-Use Villages. Well-designed districts are developed containing an integrated mix of commercial, office, entertainment, and housing that enhance pedestrian activity and enable Simi Valley’s residents to live close to businesses and employment, reduce automobile use, and actively engage with each other.
Policy LU-19.1 Land Use Mix. Allow for mixed-use districts that integrate housing with retail, office, entertainment, and public uses where the housing may be developed on the upper floors of multi-use buildings or located in stand-alone buildings on a project site where other uses are also built.
Policy LU-19.2 Development Scale. Establish standards to assure that a sufficient scale and footprint of any single use is achieved in mixed-use areas to establish a cohesive environment that minimizes impacts attributable to the adjacency of differing uses. This may define minimum parcel and building sizes, number of housing units, and/or nonresidential square footage, as well as relationships and setbacks among the uses. (Imp A-1, A-2, LU-1, LU-3, LU-4, LU-16, LU-18) Policy LU-19.3 Design. Design mixed-use development projects to enhance pedestrian activity.
Policy LU-19.4 On-Site Amenities. Incorporate recreational areas and other pedestrian-scale amenities in mixed-use projects, such as benches, fountains, and landscaping, to support residents or contribute to their development within proximity of the project
Policy LU-19.5 Design Integration. Integrate residential and nonresidential portions of mixed- use buildings through architectural design, development of pedestrian walkways, and landscaping.
Policy LU-19.6 Compatibility of Residential and Nonresidential Uses. Design buildings that integrate housing with nonresidential uses to assure compatibility among uses and public safety, including separate accesses, fire suppression barriers, secured resident parking, noise insulation, and other similar elements. 684
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Final Initial Study – Mitigated Negative Declaration 33 Goal LU-24 Enhanced Community Center. Improvement of the economic vitality and cohesive use of underutilized commercial and industrial properties within the Los Angeles Avenue area, capitalizing on the potential development of a new Metrolink station.
This would reposition the area as a focal point of community identity and activity, incorporating a diversity of commercial, office, business park, and residential uses developed in a pedestrian-oriented transit village environment.
Policy LU-24.1 Mixed-Use Development. Encourage the improvement and higher economic use of properties along the Los Angeles Avenue and First Street corridors as a series of distinct centers and nodes containing a mix of retail, office, business Policy LU-24.2 Transit-Oriented Development. Promote the development of a new Metrolink transit station to serve the western portion of Simi Valley and intensify development within its proximity to foster transit use and reduce automobile trips, energy consumption, air pollution, and greenhouse gas emissions.
Incorporate retail uses in the ground floor of street-facing elevations of parking structures developed to serve transit riders and or office uses that are designed for continuity with development on adjoining parcels. (Imp A-1, A-2, A-3, LU-1, LU-3, LU-9, LU-10, LU-16, LU-18, ED-8, M-15)
Policy LU-24.3 Mountain Gate Mixed-Use Village. Promote the redevelopment of the Mountain Gate commercial center as a pedestrian-oriented mixed-use “village environment,” where buildings are clustered along and front sidewalks, plazas, and open spaces, capitalizing on the development of a Metrolink station. (Imp A-1, A-2, LU-1, LU-3, LU-4, LU-9, LU-10, LU-16, LU-18, ED-1, ED-8) Policy LU-24.4 Donville Avenue Extension. Extend Donville Avenue to connect with Easy Street, to improve traffic movement in this area. (Imp A-1, A-2, LU-4, LU-14, LU-18)
Policy LU-24.5 Streetscape Improvements. Improve sidewalks and crosswalks with distinctive paving materials and pedestrian-oriented amenities, and develop bikeways, where feasible, to improve the connectivity among properties. (Imp A-1, A-2, LU-4, LU-9, LU-14, LU-18, M-13)
Policy LU-24.6 Planned Development. Develop a master or specific plan to guide development of the Los Angeles Avenue and First Street corridors as a distinct and cohesive district that integrates a diversity of uses, promotes architectural consistency, and provides for unifying streetscape amenities and improvements. (Imp A-1, A-2, LU-4, LU-18)
Goal LU-32 General Plan and Zoning Consistency. Development proposals within the city are consistent with the General Plan Policies and Land Use Designations identified on the General Plan Land Use Map.
Policy LU-32.1 Consistency Guidelines. Require that new development proposals be consistent with General Plan policies, land use designations, and zoning 685
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34 Goal NR-2 Vegetation and Habitat Preservation. Plant and wildlife habitat are preserved and enhanced and wildlife movement corridors are protected.
Policy NR-2.1 Tree Preservation. Encourage the preservation of trees and native vegetation in development projects. Require that new development utilize creative land planning techniques to preserve any existing healthy, protected trees to the greatest extent possible.
City zoning and overlay regulations, including specific plan or community plan development regulations, that implement General Plan goals and policies intended to protect visual quality would also apply to all development implemented under the 2021-2029 Housing Element. These include undergoing development design review as part of the permitting process to ensure compliance with existing design standards. Furthermore, City design guidelines and landscaping guidelines would apply to such development.
These regulations and processes would apply to any projects developed in the Opportunity Areas, minimizing visual quality impacts. Furthermore, because new development would likely include increased landscaping associated with residential projects, including trees, ornamental shrubs, and other features to enhance shared open space areas, visual quality could be improved in both urbanized and non-urbanized areas where Opportunity Areas occur and no conflict with design guidelines or zoning codes would occur.
Changes to the General Plan implemented as part of the 2021-2029 Housing Element update would increase forestation and continue to support enhancements to the city’s visual quality and would not adversely impact visual quality or conflict with zoning codes. Development proposals on the rezone sites in the Opportunity Areas would be subject to City review that would include the evaluation of project design and potential impacts on visual quality on the site and in the area where the specific project is being proposed. With adherence to design requirements as indicated in the SVMC and the policies outlined in the City’s General Plan, impacts to visual quality would be less than significant and development projects implemented under the 2021-2029 Housing Element would have less than significant impacts.
LESS THAN SIGNIFICANT IMPACT
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
For purposes of this analysis, light refers to light emissions (brightness) generated by a source of light. Stationary sources of light include exterior parking lot and building security lighting; moving sources of light include the headlights of vehicles driving on roadways near the project site.
Streetlights and other security lighting also serve as sources of light in the evening hours.
Glare is defined as focused, intense light emanated directly from a source or indirectly when light reflects from a surface. Daytime glare is caused in large part by sunlight shining on highly reflective surfaces at or above eye level. Reflective surfaces are associated with buildings that have expanses of polished or glass surfaces, light-colored pavement, and the windshields of parked cars.
Increased development in the city would increase potential light and glare sources. Glare could be generated by sunlight reflecting off metal or glass surfaces of cars parked in lots with insufficient sources of shade; or from building surfaces including walls or other exterior surfaces painted bright white and roofs with metallic or otherwise light-colored or reflective surfaces. Glare could also occur if broad expanses of glass, such as those used in commercial storefronts, were installed in buildings 686
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Final Initial Study – Mitigated Negative Declaration 35 with west- or east-facing orientations. The 2030 General Plan has goals and policies in place to reduce light and glare impacts, as follows:
Goal LU-5 Land Use Compatibility. New development is located and designed to assure a compatible relationship with adjoining uses.
Policy LU-5.8 Lighting Impacts. Lighting Impacts. Design, locate, and direct lighting and signs so that they do not result in excessive spillover, illumination, and glare for adjacent uses.
Goal LU-6 Open Spaces. Open space lands are preserved to maintain the visual quality of the City, provide recreational opportunities, protect the public from safety hazards, and conserve natural resources and wildlife.
Policy LU-6.4 Night Sky. Reduce the impacts of ambient outdoor lighting on the darkness of the night sky.
All development would be subject to Section 9-30.040, Exterior Light and Glare, of the SVMC, which limits the direction of exterior lighting systems to prevent light from spilling onto adjacent lots, limits the height of light fixtures, and requires a photometric plan for buildings with outside parking and lighting. Additionally, Section 9-37.060.B regulates commercial and other business signage, including offices, in a way that allows for identification of the businesses while maintaining the character of residential zones. Finally, the City’s Landscape Design Guidelines state that more than 50 percent of a parking lot area needs to be shaded within 15 years of planting the trees. New development under the 2021-2029 Housing Element and updated General Plan would be required to undergo design review as part of the permitting process to ensure individual projects adhere to the requirements of the SVMC that regulate light and glare, the General Plan goals and policies, and the City’s design guidelines to ensure impacts from new development on the night sky views would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 37 2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029 Housing Element:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest
use? □ □ □ ■
Environmental Setting
Ventura County has a long history of agricultural production, and farming in the county continues to contribute to the nation’s food supply and be a vital aspect of the setting in which Simi Valley is situated(City of Simi Valley 2012). Although agricultural production in Ventura County has remained stable in terms of production, agricultural use of land in Simi Valley is no longer a significant factor in the local economy or in the Opportunity Areas. Vacant parcels and some outlying areas are used for grazing, dry farming, and some irrigated agriculture. Significant conflicts exist between agriculture and urban uses that can impact long-term agricultural use of areas adjacent to developed areas, including dust from cultivation, pesticide use, and other. 689
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38 Most of Simi Valley is categorized as “Urban and Built-Up Land” and “Other Land” by the California Department of Conservation (City of Simi Valley 2012). The city does not have land classified as Prime Farmland or Farmland of Statewide Importance within the Planning Area, and no land is subject to Williamson Act Contracts. The city does contain land designated as Unique Farmland and Farmland of Local Important in the southwestern portion of the city and in the northern hillsides, respectively.
The study area for agriculture and forestry resources includes the areas in which the Opportunity Areas with rezone sites occur and not the entire city. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element.
Impact Analysis
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
The 2030 General Plan EIR states that no impact to agricultural or forestry resources would occur from implementation of the General Plan because there are no areas of the city zoned for agricultural use, nor are there any current Williamson Act contracts in Simi Valley. This would hold true for the 2021-2029 Housing Element and General Plan update. Figure 4.2-1 of the City’s General Plan EIR shows that the core of Simi Valley is designated as “Urban and Built-Up” land, with most of the immediately surrounding area designated as “Other” land, an indication that the area is undeveloped open space. Two Opportunity Areas are on land classified as “Other,” but none are within or adjacent to Prime Farmland, Unique Farmland, Farmland of Statewide Importance, land under a Williamson Act Contract, or forest land. The only land classified as Unique Farmland within the city limits is north of Bard Reservoir, which has a land use designation as Open Space and is zoned RPD-Residential Planned Development. The Opportunity Areas are not situated in this area, and the 2021-2029 Housing Element does not propose development in that area. Therefore, the 2021-2029 Housing Element and General Plan update would not convert important farmland to non-agricultural use, convert forest land to non-forest use, or conflict with existing Williamson Act contracts. As such, no impact to agricultural or forestry resources would occur with implementation of the 2021-2029 Housing Element and General Plan update.
NO IMPACT
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Air Quality
Final Initial Study – Mitigated Negative Declaration 39 3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Conflict with or obstruct implementation
of the applicable air quality plan? □ □ ■ □
b. Provide directly or indirectly for
increased population growth above that
forecasted in the most recently adopted
AQMP will have a significant cumulative
adverse air quality impact? □ □ ■ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ □ ■
Environmental Setting
Simi Valley is in southeastern Ventura County, which is part of the South Central Coast Air Basin (the Basin), in the inland portion of the Oxnard Plain Airshed, approximately 25 miles from the Pacific Ocean. The city experiences the mild Mediterranean climate typical of southern California. The city is surrounded by the Santa Susana Mountains to the north and northeast, Big Mountain to the north, and the Simi Hills to the South. Average temperatures in the valley are an 88.2°F high and a
40.7°F low. Precipitation averages 14.37 inches per year, with most rainfall occurring from late October through early April. Prevailing daytime winds are from the west to west-southwest with average wind speeds of approximately eight miles per hour, although periodic episodes of Santa Ana wind conditions occur, which blow very dry winds through the valley from north to northeast with sustained velocities of more than 17 miles per hours and gusts in excess of 30 miles per hour (City of Simi Valley 2012).
Overview of Air Pollution
The federal and State Clean Air Acts (CAA) mandate the control and reduction of certain air pollutants. Under these laws, the U.S. Environmental Protection Agency (U.S. EPA) and the California Air Resources Board (CARB) have established the National Ambient Air Quality Standards (NAAQS) and the California Ambient Air Quality Standards (CAAQS) for “criteria pollutants” and other pollutants. Some pollutants are emitted directly from a source (e.g., vehicle tailpipe, an exhaust stack of a factory, etc.) into the atmosphere, including carbon monoxide, volatile organic 691
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40 compounds (VOC)/reactive organic gases (ROG),6 nitrogen oxides (NOX), particulate matter with diameters of ten microns or less (PM10) and 2.5 microns or less (PM2.5), sulfur dioxide, and lead.
Other pollutants are created indirectly through chemical reactions in the atmosphere, such as ozone, which is created by atmospheric chemical and photochemical reactions primarily between ROG and NOX. Secondary pollutants include oxidants, ozone, and sulfate and nitrate particulates (smog).
Air pollutant emissions are generated primarily by stationary and mobile sources. Stationary sources can be divided into two major subcategories:
▪ Point sources occur at a specific location and are often identified by an exhaust vent or stack.
Examples include boilers or combustion equipment that produce electricity or generate heat. ▪ Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products.
Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and can also be divided into two major subcategories:
▪ On-road sources that may be legally operated on roadways and highways ▪ Off-road sources include aircraft, ships, trains, and self-propelled construction equipment Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles or when wildfires release fine particulate matter.
Air Quality Standards and Attainment
The Ventura County Air Pollution Control District (VCAPCD) is required to monitor air pollutant levels to ensure that the NAAQS and CAAQS are met and, if they are not met, to develop strategies to meet the standards. Table 5 lists nationally recognized criteria pollutants and provides a brief description of their health effects. The General Plan EIR notes that air quality has improved throughout the Basin since the 1980s and cites decreases in the percentage of days the region exceeded national and state pollutant standards for ozone (City of Simi Valley 2012). CARB’s Ambient Air Quality Standards Designation Tools shows Ventura County, including Simi Valley, as in non-attainment for federal ozone standards but in attainment for PM2.5 and PM10 standards, and in non-attainment for State ozone and PM10 standards, but in attainment for PM2.5 (CARB 2021).
6 CARB defines VOC and ROG similarly as, “any compound of carbon excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,” with the exception that VOC are compounds that participate in atmospheric photochemical reactions. For the purposes of this analysis, ROG and VOC are considered comparable in terms of mass emissions, and the term ROG is used in this IS-MND.
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Final Initial Study – Mitigated Negative Declaration 41 Table 5 Health Effects Associated with Non-Attainment Criteria Pollutants Pollutant Adverse Effects
Ozone (1) Short-term exposures: (a) pulmonary function decrements and localized lung edema in humans and animals and (b) risk to public health implied by alterations in pulmonary morphology and host defense in animals; (2) long-term exposures: risk to public health implied by altered connective tissue metabolism and altered pulmonary morphology in animals after long-term exposures and pulmonary function decrements in chronically exposed humans; (3) vegetation damage; and (4) property damage.
Carbon monoxide (CO) Reduces oxygen delivery leading to: (1) aggravation of chest pain (angina pectoris) and other aspects of coronary heart disease; (2) decreased exercise tolerance in persons with peripheral vascular disease and lung disease; (3) impairment of central nervous system functions; and (4) possible increased risk to fetuses.
Nitrogen dioxide (NO2) (1) Potential to aggravate chronic respiratory disease and respiratory symptoms in sensitive groups; (2) risk to public health implied by pulmonary and extra-pulmonary biochemical and cellular changes and pulmonary structural changes; and (3) contribution to atmospheric discoloration.
Sulfur dioxide (SO2) (1) Bronchoconstriction accompanied by symptoms that may include wheezing, shortness of breath, and chest tightness during exercise or physical activity in persons with asthma.
Suspended particulate
matter (PM10)
(1) Excess deaths from short-term and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease (including asthma).1 Suspended particulate
matter (PM2.5)
(1) Excess deaths from short- and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes, including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children, such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease, including asthma.
Lead (1) Short-term overexposures: lead poisoning can cause (a) anemia, (b) weakness, (c) kidney damage, and (d) brain damage; (2) long-term exposures: long-term exposure to lead increases risk for (a) high blood pressure, (b) heart disease, (c) kidney failure, and (d) reduced fertility.
Source: United States Environmental Protection Agency 2018 Impact Analysis
Air Pollutant Emission Thresholds
VCAPCD has adopted guidelines for quantifying and determining the significance of air quality emissions in its Ventura County Qir Quality Assessment Guidelines (VCAPCD 2003). The significance thresholds as they apply to Simi Valley are as follows:
▪ Ozone. Any General Plan Amendment or revision (including Housing Element updates) that would provide directly or indirectly for increased population growth above that forecasted in the most recently adopted AQMP will have a significant cumulative adverse air quality impact. ▪ Criteria Pollutants. A project that may cause an exceedance of any ambient air quality standard (state or federal) or may make a substantial contribution to an existing exceedance of an air quality standard will have a significant adverse air quality impact. “Substantial” is defined as making measurably worse an existing exceedance of a state or federal ambient air quality 693
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42 standard. For example, a project that directly or indirectly produces large quantities of carbon monoxide (CO) could cause an exceedance of the state or federal CO standards. Such a determination may require the use of an appropriate air quality model.
Methodology
The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element. Because specific projects are not known at this time, the City cannot assess the specific impacts of development on the Opportunity Areas, which are largely situated in areas currently zoned for commercial, light industrial, mixed use, and residential uses. Therefore, air quality modeling was not produced for this assessment, and will be required for environmental assessments conducted for specific development proposals as part of the permitting process for those projects. Instead, the VCAPCD thresholds for General Plan evaluation was used, where potential population growth determines the potential impact. a. Would the project conflict with or obstruct implementation of the applicable air quality plan? b. Would the project provide directly or indirectly for increased population growth above that forecasted in the most recently adopted AQMP will have a significant cumulative adverse air quality impact?
The VCAPCD Air Quality Management Plan considers regional population forecasts developed by SCAG to determine the degree of impact under a General Plan update. Because the 2021-2029 Housing Element is a policy document and does not directly implement any development projects, it does not generate air quality impacts in and of itself. Rather it facilitates development throughout the city, including on the rezone sites listed in Table 4, and anticipates growth that could occur if full future build out of the rezone sites in the Opportunity Areas were to occur. As discussed in Section 14, Population and Housing, development on the rezone sites could introduce up to 7,033 new residents to Simi Valley, bringing the total population to 131,501, 5,499 persons less than the SCAG estimate for the year 2035.
The population increase that could result from implementation of the 2021-2029 General Plan is within the most recent growth projections of SCAG for Simi Valley. As such, the growth forecast is also within the population growth parameters considered in the AQMP, which is updated by the Ventura County APCD to manage air emissions in the County of Ventura in accordance with local, State, and federal standards.
Projects that are proposed under the 2021-2029 Housing Element would be held to different thresholds depending on the characteristics of each project. For example, residential projects are not under the permitting authority of VCAPCD, as permits are only issued to stationary sources such as commercial or industrial projects. However, even if a project were not subject to VCAPCD review or thresholds, it would still under the VCAPCD and would thus be required to undergo project- specific evaluation by the City to determine if it were subject to VCAPCD review and/or CEQA. If any project is determined to be subject to VCAPCD review, the City will work with the applicant and VCAPCD to facilitate that review. specific impacts to air quality, which This evaluation would occur during the development review and permitting process for that each project. As the criteria needed to assess these impacts is only available to the City upon submittal of a specific project proposal, any quantitative analysis would be speculative at this time. All projects would be required to conform to 694
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Final Initial Study – Mitigated Negative Declaration 43 local, State, and federal regulations governing air quality. Furthermore, the 2030 General Plan has policies to ensure air quality impacts are reduced, as follows:
Policy LU-24.2 Transit-Oriented Development. Promote the development of a new Metrolink transit station to serve the western portion of Simi Valley and intensify development within its proximity to foster transit use and reduce automobile trips, energy consumption, air pollution, and greenhouse gas emissions.
Incorporate retail uses on the ground floor of street-facing elevations of parking structures developed to serve transit riders and or office uses that are designed for continuity with development on adjoining parcels.
Policy M-1.1 Comprehensive Mobility System. Establish a diverse transportation system that provides mobility options for the community, including adequate roads, transit service, bike paths, pedestrian walkways, and commuter rail services Policy M-1.2 Integrated Multi-Modal System. Provide an integrated transportation system that supports the land use plan set forth in the Land Use Element.
Policy M-1.3 Complete Streets. Accommodate and balance the needs of all users of the transportation system including pedestrians, bicyclists, transit users, freight, and motor vehicle drivers through all phases of transportation and development projects so that all users can travel safely within the various public rights-of-way
Policy M-2.4 Regional Traffic Mitigation. Participate in programs (Congestion Management Program, Growth Management Program, etc.) to reduce regional traffic congestion.
Policy NR-9.1 Regional Cooperation. Ensure that air quality standards are consistent with the Countywide recommendations of the Ventura County Air Pollution Control District, which are intended to reduce air quality impacts. In addition, cooperate with the Southern California Association of Government’s efforts to implement provisions of the region's Air Quality Management Plan.
Policy NR-9.2 Truck Deliveries. Encourage local businesses to alter truck delivery schedules for off-peak delivery times.
Policy NR-9.3 Improved Technology. Promote and implement state and federal regulations that improve transportation technology, vehicle mileage performance, and cleaner fuels.
Policy NR-9.4 Contractors. Require that government contractors minimize greenhouse gas emissions in building construction, operations, etc. For example, contractors can use low or zero-emission vehicles and equipment.
Policy NR-9.5 Dust and Particulate Control. Adopt procedures to regulate and minimize particulate emissions from paved and unpaved roads, parking lots, and building construction activities.
Policy NR-9.6 Construction and Operation. Evaluate development project applications using the procedures and thresholds established in the most recent version of the Ventura County Air Quality Assessment Guidelines as published by the Ventura County Air Pollution Control District and ensure that projects incorporate all applicable construction and operation mitigation measures contained therein. 695
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44 Because potential population growth associated with the 2021-2029 Housing Element is within current SCAG and VCAPCD projections and therefore would not increase population growth beyond what is forecasted in the most recently adopted AQMP, implementation of the 2021-2029 Housing Element would not conflict with the Ventura County Air Quality Management Plan and impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project expose sensitive receptors to substantial pollutant concentrations? The 2021-2029 Housing Element would implement residential development throughout the city on Opportunity Areas. These would include increased density and infill on sites currently zoned for commercial, light industrial, and residential. Potential pollutants would include those that occur throughout the city. The VCAPCD defines typical sensitive receptors as residences, schools, playgrounds, childcare centers, athletic facilities, hospitals, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. Each of these land use types is present in Simi Valley, with some being proximate to the rezone sites.
Residential development does not usually produce substantial pollutants and thus implementation of projects under the 2021-2029 Housing Element would not expose sensitive receptors to these pollutants in substantial measure. Nonetheless, individual projects could expose occupants of residential uses to industrial pollution if infill development occurred coincidental with industrial uses, and sensitive users could be exposed to higher levels of pollutant concentrations. Individual projects would undergo project-specific City review to determine if nearby uses would expose residential uses to source pollutants in excessive amounts. Furthermore, all projects would be required to align with 2030 General Plan policies that support reduced air quality impacts, including exposure to excessive pollutant concentrations, including the following:
Policy LU-20.7 Buffering from Adjacent Properties. Ensure that business and industrial park developments are positive additions to the City’s community setting, incorporating adequate landscaped buffers to minimize any negative impacts to surrounding neighborhoods and development, and controlling on-site lighting, noise, odors, vibrations, toxic materials, truck access, and other elements that may impact adjoining non-business-park and non-industrial uses.
Adherence to City regulations and General Plan goals and policies listed above would reduce impacts to less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The Ventura County AQMP identifies uses that may require mitigation due to substantial odor, including industrial production and agricultural uses. Residential land uses are not identified as uses that create objectionable odors. Therefore, the project would not generate any objectionable odors and there is no potential for a significant impact to the environment from the creation of objectionable odors affecting a substantial number of people. There would be no impact.
NO IMPACT
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Final Initial Study – Mitigated Negative Declaration 45 4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ ■ □ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ ■ □
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ ■ □
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ ■ □
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ ■ □
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
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46 Environmental Setting
Simi Valley is a crescent-shaped valley bounded by the steep hills of the Santa Susana Mountains to the north and east, and the Simi Hills the south and west of the City. To protect the nearby canyon and hillside areas from development and urban sprawl, the City adopted the City Urban Restriction Boundary (CURB) in 1998. Specifically, the CURB protects existing agricultural, open space, viewsheds, wildlife areas, and watershed land.
Vegetation Communities
Simi Valley comprises four main vegetation communities: annual grassland, chaparral, coastal sage scrub, and riparian woodland, including undeveloped open space and developed areas within the urbanized city. Annual grassland is a dense to sparse cover of nonnative annual grasses and native annual forbs in small patches around the city’s boundary. Chaparral is a fire-adapted community that is widespread upland vegetation throughout the state and is generally composed of hard- stemmed shrubs with leaves that avoid desiccation during the dry season. Chaparral is restricted to the steeper, rockier, higher elevation slopes that bound the southern portion of the city. Coastal sage scrub is a native scrub-type community found throughout lower elevations of Southern California, and typically consists of low-growing, drought-tolerant shrubs adapted to dry habitat.
Coastal Sage scrub can be found in the foothill areas in the northern portion of the City, as well as along the western border and near the chaparral community in the south (City of Simi Valley 2012).
Regional riparian woodlands occur near perennial or intermittent streams along canyon and valley bottoms (National Park Service 2015). Riparian woodland is sparsely located in the city, along Arroyo Simi and near Sinaloa Lake in the west, and in pockets near the eastern border. Although riparian woodland is not the dominant vegetation community within the city, it is considered a high biological resource, as it provides water resources, suitable nesting and foraging opportunities, and live-in refuge and migratory habitat for sensitive resident and migratory wildlife species (City of Simi Valley 2012).
Wildlife
Urban wildlife lives in and migrates through Simi Valley and species are typical of those found in other cities. Regional wildlife found outside of the city boundary is extremely diverse. Together, the creek channels, open upland areas north of the City, Los Padres National Forest, Sespe Condor Sanctuary, and the Santa Monica Mountains National Recreation Area offer habitat and movement corridors for larger species. Several species of mammals, birds, amphibians, and reptiles are found in the surrounding area. Federal and state-special status bird species, such as the rufous-crowned sparrow (Aimophila ruficeps) and burrowing owl (Athene cunicularia), can be found in habitat near the city. Additionally, snakes, toads, frogs, lizards, and salamanders are primarily found in the Arroyo Simi, which courses east to west through the city (City of Simi Valley 2012).
The study area for biological resources includes the areas in which the Opportunity Areas with rezone sites occur and not the entire city. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element. The City cannot assess the specific impacts of specific projects as those have yet to be proposed on the rezone sites in the Opportunity Areas, which are largely situated in areas currently zoned for commercial, light industrial, mixed use, and residential uses. Project-specific impacts will be ascertained during the permitting process for those projects.
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Final Initial Study – Mitigated Negative Declaration 47 Impact Analysis
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Simi Valley is largely built out, with open space areas its perimeter. Wildlife corridors can be found along the perimeter of the Simi Valley, and within the southwestern portion of the city. They often overlap land designated as open space. Notable terrestrial communities include cismontane alkali marsh, southern mixed riparian forest, southern willow scrub, and valley oak woodland, considered to be sensitive (City of Simi Valley 2012). These habitats, found mostly in the northern and western edges of the city, provide important foraging, dispersal, and migratory corridors for common and special-status species in Simi Valley and the surrounding region.
Special-status species are those plants and animals listed, proposed for listing, or candidates for listing as Threatened or Endangered by the United States Fish and Wildlife Service (USFWS) under the Federal Endangered Species Act. Several sensitive plant species are known to occur or have the potential to occur in the habitats described above, including Lyon’s pentachaeta and round-leaved filaree. Similarly, numerous special-status bird, mammal, fish, and reptile species are found in these habitats, including Southern California rufous-crowned sparrow and burrowing owls, San Diego desert woodrat, arroyo chub and tidewater goby, western pond turtle, and the California red-legged frog. Additionally, the sparsely vegetated and undeveloped land at the base of the Santa Susana Mountains and Simi Hills within the northern and southern portions of the City provide high quality foraging for sensitive raptors in the county, such as the California condor (City of Simi Valley 2012).
Goals and policies in the 2030 General Plan designed to avoid impacts to the unique sensitive biological resources of the planning area include the following:
Goal LU-4 Development Shaped by Environmental Setting. Development is located to respect, work with, and complement the natural features of the land.
Policy LU-4.1 Preservation of Natural Features. Maintain significant natural landmarks, such as prominent ridgelines visible from the valley floor, and other natural scenic features in their natural state, to the extent feasible.
Policy LU-4.2 Incorporation of Natural Features. Integrate natural scenic features, such as mature trees, rock outcroppings, watercourses, and views into project design, except where infeasible for public safety
Goal LU-6: Open Spaces. Open space lands are preserved to maintain the visual quality of the City, provide recreational opportunities, protect the public from safety hazards, and conserve natural resources and wildlife.
Policy LU-6.1 Scenic and Natural Areas. Provide for the preservation of significant scenic areas and corridors, plant and animal habitat, riparian areas, and significant geologic features within the City.
Policy LU-6.2 Mature Trees. Continue to sustain mature trees, which are an integral part of the City’s character.
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48 Goal NR-1: Natural Resource Conservation. Natural resources of importance to the City of Simi Valley and its Planning Area are conserved, enhanced, and protected.
Policy NR-1.1 Open Space Preservation and Buffer Zone. Protect, conserve, and maintain the open space, hillside, and canyon areas that provide a buffer zone around the City’s urban form, serve as designated habitat for sensitive species, and provide recreation opportunities for residents and visitors.
Policy NR-1.6 Open Space for Wildlife Habitat. Preserve open space in its natural form.
Prioritize preservation of open space that can support Sensitive, Endangered, and Protected species, as defined by the county, state, and federal governments, as part of a contiguous system that allows the movement of wildlife from one habitat area to another.
Policy NR-1.7 Tools to Preserve Open Space. Maximize the protection of open space through the following actions:
▪ City land use, development, and zoning regulations
▪ Fee-title dedications associated with new private developments ▪ Mitigation requirements for loss of habitat areas
▪ Development agreements that maintain open space in private developments
▪ Establishment of conservation easements
▪ Easement acquisition that retains open space
▪ Tax sale, donation, life estate, eminent domain, and leaseback arrangements
Policy NR-1.9 Restoration of Degraded Areas. Require replanting of vegetation and remediation of associated erosion in conjunction with requested land use approvals in hillside areas.
Goal NR-2: Vegetation and Habitat Preservation. Plant and wildlife habitat are preserved and enhanced and wildlife movement corridors are protected.
Policy NR-2.5 Wetland and Sensitive Habitat Mitigation. Conserve wildlife ecosystems, wetlands, and sensitive habitat areas in the following order of protection preference: (1) avoidance; (2) on-site mitigation; and (3) off-site mitigation.
Where avoidance is not possible, require provision of replacement habitat through restoration and/or habitat creation to mitigate the loss of wetland and/or sensitive habitat. Off-site replacement habitat should be at a minimum of 5:1 replacement ratio or as recommended by the California Department of Fish and Game.
Policy NR-2.6 Site Assessments. Require assessment by a qualified professional for development applications that may adversely affect sensitive biological or wetland resources, including occurrences of special-status species, occurrences of sensitive natural communities, and important wildlife areas and movement corridors. Ensure that individual projects incorporate measures to reduce impacts to special-status species, sensitive natural communities, and important 700
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Final Initial Study – Mitigated Negative Declaration 49 wildlife areas and movement corridors according to Simi Valley’s environmental review process.
The Opportunity Areas proposed in the 2021-2029 Housing Element consist mostly of infill development in areas already developed with urban uses. They are generally located away from riparian and other sensitive habitats (see Threshold 4.b below). Adherence with the 2030 General Plan goals and policies listed above would minimize impacts from potential direct effects to special- status species as they would ensure development in the Opportunity Areas would avoid or mitigate impacts to environmentally sensitive areas, thus protecting sensitive species. Furthermore, future development proposed under the 2021-2029 Housing Element would be required to comply with federal and State regulations, such as the California Fish and Game Code and Migratory Bird Treaty Act, that protect sensitive species and their habitats and be subject to the Mature Tree Preservation Ordinance (Chapter 9-38) and the Hillside Performance Standards (Chapter 9-32) in the SVMC designed to minimize biological resource impacts.
On undeveloped parcels or parcels with mature trees and nesting bird habitat, impacts could occur and thus projects proposed on Opportunity Areas meeting this description would be subject to Mitigation Measure BIO-1, Preconstruction Biological Survey, and Mitigation Measure BIO-2, Nesting Bird Protection. Mitigation measures BIO-3 through BIO-9 are required to avoid potential impacts to biological resources In the Walnut Hills and Heyneman Lane Opportunity Areas.
Mitigation Measures
BIO-1 Pre-Construction Biological Survey
Projects proposed on undeveloped lots shall be subject to a pre-construction biological survey.
Within 48 hours of ground disturbance and vegetation removal, a qualified biologist shall conduct a pre-construction survey for potential rare, listed, or other special-status wildlife species. The survey shall include all proposed work areas, access routes, and staging areas plus a 50-foot buffer where accessible. If special-status species are observed during the survey, they shall be relocated by the qualified biologist to nearby suitable habitat, but far enough where they will not re-enter the project site. If a threatened or endangered species is observed, consultation with the appropriate regulatory agency shall be conducted prior to removing the species and work will not commence until approved by the regulatory agency.
BIO-2 Nesting Bird Protection
If construction requires any vegetation trimming or tree removal during the nesting bird season (February 1 to August 31), pre-construction surveys shall be conducted by a qualified biologist not more than one week before construction to determine the presence or absence of nesting birds on the project site. The survey shall be repeated if a lapse occurs in construction activity of two weeks or more. If active nests are found, the qualified biologist shall establish an appropriate buffer, accounting for species sensitivity and the physical location of the nest (line of sight to the work area) to comply with California Fish and Game Code Sections 3503 and 3503.5. In no case shall the buffer be smaller than 50 feet for passerine species and 200 feet for raptor species. To prevent encroachment, the established buffer(s) shall be clearly marked using high-visibility material.
Encroachment into the buffer shall be prohibited unless approved by the qualified biologist with adequate restrictions, protections, and/or monitoring to ensure that impacts to the nest are avoided. The established buffer(s) shall remain in effect until the young have fledged or the nest is abandoned.
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50 With implementation of mitigation measures BIO-1 and BIO-2 and adherence to General Plan policies and SVMC regulations, impacts arising from implementation of the 2021-2029 Housing Element and General Plan update on urbanized rezone sites that have mature trees would be less than significant with mitigation incorporated.
Walnut Hills and Heyneman Lane Opportunity Areas Mitigation Measures In the Walnut Hills and Heyneman Lane Opportunity Areas, impacts could be greater to sensitive species and their habitats and to riparian habitat and wetlands, since this area is undeveloped and could support a variety of biological resources, including sensitive species. Although biological surveys have been completed for parts of these areas under previous proposals, any development in the Walnut Hills and Heyneman Lane Opportunity Areas proposed under the 2021-2029 Housing Element would be subject to the following mitigation measures.
BIO-3 Indirect Impacts to Vegetation Communities
The following best management practices (BMP) shall be implemented to minimize indirect impacts to special-status vegetation communities for projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas.
1. Landscaping Plan. Landscape plans shall be consistent with the City of Simi Valley’s General Plan and Municipal Codes, the City of Simi Valley Citywide Design Guidelines, and the goals of the City of Simi Valley VISION 2020 report. Landscape plans shall be reviewed by a qualified botanist to recommend appropriate provisions to minimize the spread of invasive plant species as defined by the County of Ventura, and listed by the California Invasive Plant Council (www.cal- ipc.org) and California Native Plant Society (www.cnps.org) within the project area. Provisions may include:
a. Installation of container plants and/or hydro-seeding areas adjacent to existing, undisturbed native vegetation areas with native plant species common within temporary impact areas b. Review and screening of proposed plants to identify and avoid potential invasive species and weed removal during the initial planting of landscaped areas. Recommended perennial plants and quick germinating erosion control plant species native to the coastal scrub vegetation within the project area include coastal sagebrush (Artemisia californica), Eastern Mojave buckwheat (Eriogonum fasciculatum var. fasciculatum), golden yarrow (Eriophyllum confertiflorum), California poppy (Eschscholzia californica), deerweed (Acmispon glaber), white sage (Salvia apiana), and black sage (Salvia mellifera).
2. Fire. Maintain a minimum of 100 feet between built structures and coastal scrub habitat based on Cal Fire requirements for defensible space.
3. Minimize Construction Impacts: To prevent inadvertent disturbance to areas outside the limits of work, the construction limits shall be clearly demarcated (e.g., installation of flagging or temporary high visibility construction fence) prior to ground disturbance activities and all construction activities, including equipment staging and maintenance shall be conducted within the marked disturbance limits.
4. Invasive Weeds. The spread of invasive weeds shall be minimized through revegetation of temporarily disturbed areas. Temporarily disturbed areas shall be revegetated with a native seed mix and/or container plants. A qualified biologist/restoration ecologist shall review the revegetation plan prior to implementation. Revegetated areas shall be monitored and maintained for three years or until native vegetation has been established. Maintenance shall 702
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Final Initial Study – Mitigated Negative Declaration 51 include removal of non-native weed species and remedial measures as determined during routine monitoring.
BIO-4 Direct Impacts to Special-Status Plants
For projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas, rare plant surveys for rare plant species likely to occur on project sites where there is no existing development shall be conducted within suitable habitat (e.g., coastal scrub and grassland habitats) for these species no more than one year prior to commencement of construction activities. Surveys shall occur at the appropriate time to capture the characteristics necessary to identify the taxon. Surveys shall be conducted consistent with CNPS protocols and by a qualified botanist knowledgeable of the local flora. Since yearly variation in weather may result in fewer specimens being observed, the locations of plants considered will be cumulative (i.e., all known plant locations over the course of the various surveys, will be noted). For direct impacts to special-status plant species, one or a combination of the following strategies shall be implemented:
a. Agency Consultation. If special-status plant species are present and would directly or indirectly be impacted by the proposed project activities, the applicant shall consult with the CDFW to determine the recommended course of action.
b. Avoidance and Minimization. Impacts to special-status plant populations should be avoided to the greatest extent possible and minimized where avoidance is not feasible. Where project impacts cannot be avoided, mitigation is required and is discussed further below. c. Salvage. If impacts to special-status plants cannot be avoided, and it is feasible to effectively salvage, a qualified ecologist shall develop a restoration and mitigation plan based on the life history of the species impacted, and in coordination with CDFW to mitigate project impacts. The plan shall include at minimum: (a) collection/salvage measures for plants or seed banks, to retain intact soil conditions and maximize success likelihood; (b) details regarding storage of plants or seed banks; (c) location of the proposed recipient site, and detailed site preparation and plant introduction techniques details for top soil storage, as applicable; (d) time of year that the salvage and replanting or seeding will occur and the methodology of the replanting; (e) a description of the irrigation, if used; (f) success criteria; and (g) a detailed monitoring program, commensurate with the plan’s goals.
BIO-5 Indirect Impacts to Special-Status Plants
In addition to Mitigation Measure BIO-3, the following BMPs shall be implemented for projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas to minimize indirect impacts to special-status plant species:
a. Minimize Impacts. To the extent feasible, impacts to known special-status plant populations identified in the project area (e.g., two slender mariposa lily individuals and one Catalina mariposa lily individual;) should be minimized. The full extent of the occurrence of a special status plant species within the survey area shall be recorded and mapped with the number of individuals for each occurrence documented. The outer extent of each occurrence of special- status plants, including a 50-foot buffer (to minimize potential indirect effects due to fugitive dust and accidental intrusion into the area) should be flagged and avoided during project- related activities.
b. Standard Dust Control Measures. Standard dust control measures as per the Ventura County Air Pollution Control District shall be implemented to reduce impacts on nearby plants and 703
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52 wildlife. Measures include controlling speed to 15 mph or less on unpaved roads, replacing ground cover in disturbed areas as quickly as possible, frequently watering active work sites, installation of shaker plates, and suspending excavation and grading operations during periods of high winds.
c. Minimize Spills of Hazardous Materials. All vehicles and equipment shall be maintained in proper condition to minimize the potential for fugitive emissions of motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials. Hazardous spills shall be immediately cleaned up and the contaminated soil shall be immediately cleaned up and the contaminated soil shall be properly handled or disposed of at a licensed facility. Servicing of construction equipment shall take place only at a designated staging area.
BIO-6 Direct Impacts to Special-Status Amphibian and Reptile Species For projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas, a qualified biologist shall be present during ground-disturbing activities immediately adjacent to or within any grassland and coastal scrub habitat that could support populations of special-status amphibian and reptile species to monitor vegetation removal and topsoil salvaging and stockpiling. The qualified biologist shall possess an appropriate California scientific collecting permit to handle special-status species likely to occur in the project area. If special-status species (e.g., California glossy snake, coast horned lizard, silvery legless lizard, coastal whiptail, coast patch-nosed snake, and western spadefoot) are detected in the work area during the surveys, the authorized biologist shall capture and relocate individuals to nearby undisturbed areas with suitable habitat outside of the construction area, but as close to their origin as possible. All wildlife moved during project activities shall be documented by the biologist on site and a report shall be provided to the City of Simi Valley Planning Division.
BIO-7 Burrowing Owl
For projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas, preconstruction surveys for burrowing owl shall be conducted in accordance with CDFW guidelines. Preconstruction surveys shall include the project footprint and appropriate buffer as required in the most recent guidelines. Focused surveys only need to be conducted where suitable burrow resources are present. The surveys shall be conducted no more than 30 days prior to initiation of ground disturbance or site mobilization activities within 500 feet from suitable burrowing owl habitat (e.g., grassland and/or disturbed land) where legal access to conduct the surveys exists. If burrowing owls are not detected during the clearance survey, no additional mitigation is required. If an active (as determined by positive focused surveys) burrowing owl burrow is located within 500 feet from any project work area or disturbance area, a Burrowing Owl Relocation and Mitigation Plan shall be prepared and implemented following approval from the CDFW. The plan shall include the following:
1. Avoidance and minimization measures, including at a minimum:
a. Non-Disturbance Buffer. Fencing or flagging shall be installed at a 250-foot radius from the occupied burrow to create a buffer area where no work activities may be conducted. The non-disturbance buffer and fence line may be reduced to 160 feet if all Project-related activities that might disturb burrowing owls would be conducted during the nonbreeding season (i.e., conducted September 1 through January 31). 704
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Final Initial Study – Mitigated Negative Declaration 53 b. Monitoring. If construction activities occur within 500 feet of the occupied burrow during the nesting season (February 1–August 31), a qualified biologist shall monitor to determine if these activities have potential to adversely affect nesting efforts and shall implement measures to minimize or avoid such disturbance.
c. Relocation Plan. Relocation plan if construction activities occur during the non-breeding season (occupied burrows may not be disturbed during the nesting season (February 1 to August 31) to avoid take under the Migratory Bird Treaty Act and California Fish and Game Code) describing the following:
1. Detailed methods and guidance for passive relocation of burrowing owls.
2. Monitoring and management of the replacement burrow site(s), and provide a reporting plan; the objective shall be to manage the sites for the benefit of burrowing owls, with the specific goals of maintaining the functionality of the burrows for a minimum of two years and minimizing weed cover.
3. Ensure that a minimum of two suitable, unoccupied burrows are available off site for every burrowing owl or pair of burrowing owls to be passively relocated.
BIO-8 Coastal California Gnatcatcher
For projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas, during the year prior to initiation of construction activities for each construction phase, a focused coastal California gnatcatcher survey shall be conducted in accordance with USFWS protocol (USFWS 1997). If focused surveys are negative, no additional mitigation is required. If focused surveys are positive, consultation with USFWS shall occur and/or an incidental take permit (ITP) shall be obtained from the USFWS. Occupied habitat shall be mitigated at a minimum 1:1 ratio for temporary impacts, 2:1 ratio for permanent impacts, or as specified by the resources agencies (e.g., within an ITP).
Avoidance and minimization measures shall be implemented in accordance with provisions of the ITP and shall include, at a minimum:
a. Environmental awareness training for all construction personnel to educate personnel about coastal California gnatcatcher, protective status avoidance measures to be implemented by all personnel, including the avoidance of nesting bird season to the greatest extent feasible and minimization of vegetation impacts within suitable coastal scrub habitat b. Removal of suitable coastal scrub vegetation outside of the coastal California gnatcatcher breeding season (February 15 through August 31)
c. Establishment of environmentally sensitive areas around coastal California gnatcatcher nest locations (500-foot avoidance buffer or as approved by USFWS and CDFG) by a qualified biologist prior to the start of any ground or vegetation-disturbing activities, which shall be maintained and avoided during construction activities and until the nest is determined to no longer be active by a biologist
d. Presence of a qualified biological monitor during initial grading activities, adjacent to environmentally sensitive areas, and as needed to document compliance with the conditions of the ITP, the biological monitor will have the authority to stop work as needed to avoid direct impacts to coastal California gnatcatcher
e. Should an active gnatcatcher nest be observed during construction activities, activities shall cease until the nest is determined to no longer be active. 705
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54 BIO-9 Indirect Impacts to Special Status Wildlife Species For projects proposed in the Walnut Hills and Heyneman Lane Opportunity Areas, in addition to those listed above, the following BMPs shall be implemented to minimize indirect impacts to special-status wildlife species. BMPs shall be implemented to minimize indirect impacts to special- status species.
a. Workers Environmental Awareness Program (WEAP) Training. Before commencement of construction, a qualified Biologist shall provide environmental training to educate all on-site personnel, including construction personnel, contractors, and monitors, on special-status biological resources that may be encountered on the project site. Personnel shall be reminded that harassment, handling, or removal of wildlife and/or other special-status resources from the project site is prohibited by law without appropriate notifications and permitting. Personnel shall be instructed on actions to take should a special-status species be identified within an immediate work area (e.g., work will cease until the project biologist is notified and provides further instructions).
b. Mark/Flag Special-Status Biological Resources. The qualified Biologist shall review and/or designate the vegetation removal area in the field with the contractor in accordance with the final plan. Any construction activity areas immediately adjacent to special-status biological resources may be flagged or temporarily fenced by the monitor, at their discretion. c. Biological Monitoring. The qualified Biologist shall be present during vegetation clearing, grubbing, and grading. Biological monitors shall visit the site periodically during construction to ensure that biological measures are being implemented and may also be required when work is conducted close to an established avoidance buffer.
d. Flush Special-Status Species. The qualified Biologist shall flush special-status species (i.e., non- nesting avian or other mobile species) from occupied habitat areas immediately prior to vegetation removal activities.
e. Avoid Wildlife Entrapment:
1. Backfill Trenches. At the end of each workday, check that all potential wildlife pitfalls (trenches, bores, and other excavations) have been backfilled, covered, or sloped to allow wildlife egress. Should wildlife become trapped, a qualified biologist shall remove and relocate it.
2. Avoid entrapment of nesting or migratory birds. All pipes or other construction materials or supplies shall be covered or capped in storage or laydown areas at the end of each workday. No pipes or tubing of sizes or inside diameters ranging from 1 to 10 inches shall be left open either temporarily or permanently.
f. Monitoring Reports. Biologist shall record any inadvertent impacts to special status biological resources outside the designated construction zone in periodic monitoring reports. g. Trash. All food-related trash items (such as wrappers, cans, bottles, and food scraps) shall be disposed of in closed containers and removed daily from the project site. Special attention should also be given to leaving no microtrash (screws, nuts, bolts, washers, etc.) at the job site. h. Lighting. Lighting along the perimeter of natural areas shall be shielded and oriented to limit light shine into the natural areas.
i. Pets. No pets shall be allowed within the project site, to prevent harassment and mortality to potential special-status species during construction.
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Final Initial Study – Mitigated Negative Declaration 55 With incorporation of these mitigation measures into any development projects in the Walnut Hills and Heyneman Lane Opportunity Areas, impacts on sensitive biological resources would be reduced to less than significant.
LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Plant communities are considered sensitive biological resources if they have limited distributions, high wildlife value, include sensitive species, or are particularly susceptible to disturbance. Riparian habitats in Simi Valley include cismontane alkali marsh, southern mixed riparian forest, southern willow scrub, and valley oak woodland, which can be found in the foothill areas outside of city limits, as well as in the northern and western areas of the city (City of Simi Valley 2012). The 2030 General Plan contains the following goals and policies that mitigate potential impacts to riparian habitat and sensitive natural communities:
Goal NR-1 Natural Resource Conservation. Natural resources of importance to the City of Simi Valley and its Planning Area are conserved, enhanced, and protected.
Policy NR-1.1 Open Space Preservation and Buffer Zone. Protect, conserve, and maintain the open space, hillside, and canyon areas that provide a buffer zone around the City’s urban form, serve as designated habitat for sensitive species, and provide recreation opportunities for residents and visitors.
Policy NR-1.6 Open Space for Wildlife Habitat. Preserve open space in its natural form.
Prioritize preservation of open space that can support Sensitive, Endangered, and Protected species, as defined by the county, state, and federal governments, as part of a contiguous system that allows the movement of wildlife from one habitat area to another.
Policy NR-1.7 Tools to Preserve Open Space. Maximize the protection of open space through the following actions:
▪ City land use, development, and zoning regulations
▪ Fee-title dedications associated with new private developments ▪ Mitigation requirements for loss of habitat areas
▪ Development agreements that maintain open space in private developments
▪ Establishment of conservation easements
▪ Easement acquisition that retains open space
▪ Tax sale, donation, life estate, eminent domain, and leaseback arrangements
Policy NR-1.9 Restoration of Degraded Areas. Require replanting of vegetation and remediation of associated erosion in conjunction with requested land use approvals in hillside areas.
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56 Goal NR-2 Vegetation and Habitat Preservation. Plant and wildlife habitat are preserved and enhanced and wildlife movement corridors are protected.
Policy NR-2.5 Wetland and Sensitive Habitat Mitigation. Conserve wildlife ecosystems, wetlands, and sensitive habitat areas in the following order of protection preference: (1) avoidance; (2) on-site mitigation; and (3) off-site mitigation.
Where avoidance is not possible, require provision of replacement habitat through restoration and/or habitat creation to mitigate the loss of wetland and/or sensitive habitat. Off-site replacement habitat should be at a minimum of 5:1 replacement ratio or as recommended by the California Department of Fish and Game.
Policy NR-2.6 Site Assessments. Require assessment by a qualified professional for development applications that may adversely affect sensitive biological or wetland resources, including occurrences of special-status species, occurrences of sensitive natural communities, and important wildlife areas and movement corridors. Ensure that individual projects incorporate measures to reduce impacts to special-status species, sensitive natural communities, and important wildlife areas and movement corridors according to Simi Valley’s environmental review process.
Opportunity Areas listed under the 2021-2029 Housing Element Update do not occur adjacent to or near the riparian habitats described above. The Opportunity Area most proximal to a riparian community is the Walnut Hills Opportunity Area. This Opportunity Area is located downslope of cismontane alkali marsh, southern willow scrub, and southern coast live oak riparian forest and, as such, development would have no impact to the communities discussed above. In addition to the goals and policies in the City’s General Plan, future development implemented under the 2021-2029 Housing Element and General Plan update would adhere to the FESA, the California ESA, National Plant Protection Act, and the California Fish and Game Code. Adherence to these policies and regulations would ensure that project impacts to riparian habitat and other sensitive natural communities would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Wetlands in Simi Valley are associated with springs, streams, rivers, lakes, reservoirs, and most notably the Arroyo Simi which traverses the city from east to west. The eastern most Opportunity Area, located east of Yosemite Avenue (see Figure 2), is on a hydrological feature that could be a wetland. Other Opportunity Areas are near or adjacent to the Arroyo Simi or other hydrological features. Development construction could result in indirect impacts pertaining to water quality in nearby wetlands and those that may occur downslope or downstream of construction zones. These impacts are discussed in Section 10, Hydrology and Water Quality, of this IS-MND.
The 2030 General Plan contains goal and policies aimed at protecting and maintaining wetlands in Simi Valley, as discussed under Threshold b, above. Because no specific development proposals are included in the 2021-2029 Housing Element or General Plan update, specific impacts to wetlands cannot be ascertained at this time. All development implemented under the 2021-2029 in areas 708
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Final Initial Study – Mitigated Negative Declaration 57 where potential wetlands could be affected will be required to undergo a project-level analysis, as required under CEQA.
Policy NR-2.6 of the 2030 General Plan would determine the presence or absence of wetlands and other federally regulated waters as described in Section 404 of the Clean Water Act (CWA).
Development facilitated by the 2021-2029 Housing Element would be required to adhere to local, State, and federal regulations regarding protected wetlands. Wetland areas have the potential to support riparian and streambed species and habitats, which are regulated by the California Department of Fish and Wildlife (CDFW). Depending on the acreage of project disturbance, individual development facilitated by the 2021-2029 Housing Element would be required to obtain either a Nationwide or Individual permit from the United States Army Corps of Engineers (USACE), pursuant to CWA Section 404, prior to obtaining a grading permit. This would require developers to obtain a Water Quality Certification from the Los Angeles Water Quality Control Board (RWQCB) pursuant to CWA Section 401. Further discussion on project impacts to water quality are discussed in Section 10, Hydrology and Water Quality.
All potential projects implemented under the 2021-2029 Housing Element would be required to comply with local, State, and federal policies aimed at protecting wetlands. This and adherence to the goals and policies in the General Plan, would reduce impacts to state or federally protected wetlands to less than significant levels.
LESS THAN SIGNIFICANT IMPACT
d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Wildlife corridors are generally defined as connections between habitat patches that allow for physical and genetic exchange between otherwise isolated animal populations. Such linkages may serve a local purpose, such as between foraging and denning areas, or they may be regional in nature, allowing movement across the landscape. Some habitat linkages may serve as migration corridors, wherein animals periodically move away from an area and then subsequently return.
There are no known nursery sites in Simi Valley. Nearby landscapes that contribute to wildlife corridors are concentrated primarily in large, contiguous open space areas with native habitats such as those located in the Los Padres National Forest, Sespe Condor Sanctuary, and Santa Monica Mountains National Recreation Area that surround the city, as illustrated in Figure 4.4 in the City’s General Plan EIR. (City of Simi Valley 2012). The Opportunity Areas do not occur near or adjacent to these habitats and are mostly in developed areas. While the Walnut Hills and Heyneman Lane Opportunity Areas are in or near undeveloped land zoned as open space, the immediately adjacent neighborhoods have little to no vegetation cover and serve as barriers to movement in their own right. Additionally, most of the surrounding areas for both the Walnut Hills and Heyneman Lane Opportunity Areas are developed with residential land uses. Implementation of projects on the Opportunity Areas listed under the 2021-2029 Housing Element would not interfere with wildlife corridors or wildlife nursery sites. Therefore, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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58 e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Implementation of the 2021-2029 Housing Element would be subject to all applicable local policies and regulations related to the protection of important biological resources. Construction activities of projects facilitated by the Housing Element Update could result in direct or indirect impacts to mature trees. Coast live oaks, valley oaks, and other oak tree species, as well as historic or mature trees, occur throughout both developed and undeveloped areas of the city (City of Simi Valley 2012). The following 2030 General Plan goals and policies would mitigate impacts to biological resources, including trees:
Goal LU-4 Development Shaped by Environmental Setting. Development is located to respect, work with, and complement the natural features of the land.
Policy LU-4.1 Preservation of Natural Features. Maintain significant natural landmarks, such as prominent ridgelines visible from the valley floor, and other natural scenic features in their natural state, to the extent feasible.
Policy LU-4.2 Incorporation of Natural Features. Integrate natural scenic features, such as mature trees, rock outcroppings, watercourses, and views into project design, except where infeasible for public safety
Goal LU-6 Open Spaces. Open space lands are preserved to maintain the visual quality of the City, provide recreational opportunities, protect the public from safety hazards, and conserve natural resources and wildlife.
Policy LU-6.1 Scenic and Natural Areas. Provide for the preservation of significant scenic areas and corridors, plant and animal habitat, riparian areas, and significant geologic features within the City.
Policy LU-6.2 Mature Trees. Continue to sustain mature trees, which are an integral part of the City’s character.
Goal NR-1 Natural Resource Conservation. Natural resources of importance to the City of Simi Valley and its Planning Area are conserved, enhanced, and protected.
Policy NR-1.1 Open Space Preservation and Buffer Zone. Protect, conserve, and maintain the open space, hillside, and canyon areas that provide a buffer zone around the City’s urban form, serve as designated habitat for sensitive species, and provide recreation opportunities for residents and visitors.
Policy NR-1.6 Open Space for Wildlife Habitat. Preserve open space in its natural form.
Prioritize preservation of open space that can support Sensitive, Endangered, and Protected species, as defined by the county, state, and federal governments, as part of a contiguous system that allows the movement of wildlife from one habitat area to another.
Policy NR-1.7 Tools to Preserve Open Space. Maximize the protection of open space through the following actions:
▪ City land use, development, and zoning regulations
▪ Fee-title dedications associated with new private developments ▪ Mitigation requirements for loss of habitat areas
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Final Initial Study – Mitigated Negative Declaration 59 ▪ Development agreements that maintain open space in private developments
▪ Establishment of conservation easements
▪ Easement acquisition that retains open space
▪ Tax sale, donation, life estate, eminent domain, and leaseback arrangements
Policy NR-1.9 Restoration of Degraded Areas. Require replanting of vegetation and remediation of associated erosion in conjunction with requested land use approvals in hillside areas.
Goal NR-2 Vegetation and Habitat Preservation. Plant and wildlife habitat are preserved and enhanced and wildlife movement corridors are protected.
Policy NR-2.1 Tree Preservation. Encourage the preservation of trees and native vegetation in development projects. Require that new development utilize creative land planning techniques to preserve any existing healthy, protected trees to the greatest extent possible.
Policy NR-2.5 Wetland and Sensitive Habitat Mitigation. Conserve wildlife ecosystems, wetlands, and sensitive habitat areas in the following order of protection preference: (1) avoidance; (2) on-site mitigation; and (3) off-site mitigation.
Where avoidance is not possible, require provision of replacement habitat through restoration and/or habitat creation to mitigate the loss of wetland and/or sensitive habitat. Off-site replacement habitat should be at a minimum of 5:1 replacement ratio or as recommended by the California Department of Fish and Game.
Policy NR-2.6 Site Assessments. Require assessment by a qualified professional for development applications that may adversely affect sensitive biological or wetland resources, including occurrences of special-status species, occurrences of sensitive natural communities, and important wildlife areas and movement corridors. Ensure that individual projects incorporate measures to reduce impacts to special-status species, sensitive natural communities, and important wildlife areas and movement corridors according to Simi Valley’s environmental review process.
In addition to the policies described above, the SVMC contains a Mature Tree Preservation Ordinance (Chapter 9-38). The ordinance applies to any tree within city limits that is considered an historic tree, mature native oak tree, mature tree, native oak tree, or a protected tree. The 2021- 2029 Housing Element does not include any components that would preclude implementation of or alter the above-described policies, or ordinance. Thus, implementation of the Housing Element Update would not conflict with any local policies or ordinances protecting biological resources, including protected trees. Impacts related to local policies or ordinances protecting biological resources would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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60 f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Habitat Conservation Plans designated under FESA Section 10(a)(1)(B), are federal planning documents designed to conserve the ecosystems upon which listed species depend, ultimately contributing to their recovery. HCPs require a “take permit” when a project will affect a species identified as listed, non-listed or eligible under the act and detail how those impacts will be minimized or mitigated; and how the HCP is to be funded. According to the 2012 General Plan EIR, no HCPs apply to Simi Valley (City of Simi Valley 2012). Therefore, no impact would occur from implementation of development under the 2012-2029 Housing Element and General Plan update.
NO IMPACT
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Cultural Resources
Final Initial Study – Mitigated Negative Declaration 61 5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029 Housing Element:
a. Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ ■ □ □
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ ■ □ □
Environmental Setting
Spanish contact with the Chumash Indians occurred in the late eighteenth century in what is now Simi Valley. The Chumash Indians are known for their well-constructed canoes, fine basket work, and one of the most complex hunter-gatherer cultures. The first Spanish settlement in Simi Valley was Rancho Simi, initially developed by Santiago Pico. Rancho Simi consisted of approximately 113,000 acres that stretched from the Santa Susana Mountains to Moorpark. Early dwellings of the Rancho Simi can be found at the Strathearn Historical Park.
Over time, the area now known as Simi Valley began to function as a community rather than a single rancho, and religious, educational, and commercial services were offered. The Southern Pacific Railroad was later built, allowing for the agricultural town of Santa Susana to be established. By the 1950s, the agricultural uses of the area began to shift to residential development due to an increase in the local population. The City of Simi Valley was incorporated in 1969 and adopted its first General Plan in 1972.
The study area for cultural and historical resources includes the areas in which the Opportunity Areas with rezone sites occur and not the entire city. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element. The City cannot assess the specific impacts of specific projects as those have yet to be proposed in the Opportunity Areas, which are largely situated in areas currently zoned for commercial, light industrial, mixed use, and residential uses. Some Opportunity Areas are in undeveloped locations (e.g., Walnut Hills).
Project-specific impacts will be ascertained during the permitting process for those projects. 713
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62 Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
An historic resource is defined as any object, building, structure, site, area, place, record, or manuscript that a lead agency determines to be historically significant (State CEQA Guidelines, Section 15064.5[a][1-3]). Specific criteria must be met for a resource to be determined historically significant, and an Historic Resources Assessment is the analysis applied to most resources 50 years or older. The 2030 General Plan prioritizes preserving cultural resources, including historical buildings and structures through the implementation of the following goals and policies:
Goal HR-1 Historic Resources. Historically significant landmarks, sites, natural features, and structures are recognized and protected.
Policy HR-1.1 Historical Resources Inventory. Contribute to the maintenance of Ventura County’s recorded inventory of historical landmarks for properties, objects, structures, and monuments having importance to the history or architecture of Ventura County. Photo documentation of inventoried historic sites or structures shall be required prior to demolition.
Policy HR-1.2 Preservation or Re-use of Historical Structures. Support the preservation of structures listed on the National Register of Historic Places, list of California Historical Landmarks, and/or the Ventura County List of Historic Landmarks.
Provide incentives, such as waivers of application fees, permit fees, and/or any liens placed by the City, to properties listed in the National or State Register or the Ventura County List of Historic Landmarks in exchange for preservation easements.
Policy HR-1.4 Adaptive Reuse. Support alternatives to demolition of historical sites or structures by promoting architecturally compatible rehabilitation or adaptive reuse.
Policy HR-1.5 Historical Elements within New Projects. If preservation and/or adaptive reuse are not feasible options, require that proposed alteration of a historical site or structure incorporates a physical link to the past within the site or structural design. For example, incorporate historical photographs or artifacts within the proposed project; or preserve the location and structures of existing pathways, gathering places, seating areas, rail lines, roadways, or viewing vantage points within the proposed site design.
Policy HR-1.6 Offer for Relocation of Designated Historic Structure. Require that prior to the demolition of a designated historic structure, developers offer the structure for relocation by interested parties.
Goal CS-2 Facilities and Programs. A diversity of arts and cultural facilities and programs are available for people of all ages to enrich the community and enhance the quality of life for residents.
Policy CS-2.8 Strathearn Historical Park and Museum. Encourage relocation of historical structures threatened with demolition to the Strathearn Historical Park and Museum and support activities, events, and historical programs occurring at the Strathearn Historical Park and Museum.
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Final Initial Study – Mitigated Negative Declaration 63 As of 2006, Simi Valley contained 28 previously recorded historic resources, including the Chumash Wilderness Park, Strathearn Historical Park, and Old Town Simi (City of Simi Valley 2012). Identified historic structures and sites that are eligible for National Register of Historic Resources listing may be vulnerable to construction associated with infill development if they are damaged by construction or if their context changes substantially. Some Opportunity Areas are located near the following historical resources: Old Town Simi, Grandma Prisbrey’s Bottle Village, Elephant Rock, Miss Bessie Printz Colony House, Saint Rose of Lima Catholic Church, Scott Ranch, and Simi Cemetery, among others. As it is possible that Opportunity Areas may have sites with historic-era resources, development facilitated by the 2021-2029 Housing Element would require evaluation for significance before project construction could begin, in accord with Public Resources Code Section 21084.1. This could include a preliminary evaluation by an architectural historian, qualified under the Secretary of the Interior’s standards, or an Historic Resources Assessment conducted by someone similarly qualified, depending on the potential degree of impact. The requirement would be determined during the permitting process, pursuant to the SVMC Cultural Heritage Ordinance (Section 2-3.5), which requires approval by the Simi Valley Cultural Heritage Board for actions that affect designated historical resources (Article 5, Section 2-3.501 et seq.). The Board determines if a site or its structures has historic, aesthetic, or special characters of public interest.
Projects implemented under the 2021-2029 Housing Element in the Opportunity Areas with rezone sites, including in the Old Town, would undergo project-level City review that would ensure adherence to these regulations and the 2030 General Plan goals and policies, reducing impacts to historic resources to less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
The planning area is considered to have a high sensitivity for cultural and Native American resources (City of Simi Valley 2012). However, most of the Opportunity Areas are situated in developed urban areas that have been previously disturbed and graded for existing development. The Walnut Hills Opportunity Area and the Opportunity Area south of Heyneman Lane include undeveloped lands, and impacts to previously unknown cultural resources in these areas are possible. Because the 2021-2029 Housing Element is a policy document and does not include specific development proposals, the City does not have information about where ground-disturbing activities could occur in these areas. Specific impacts to archaeological resources are therefore unknown at this time and would be determined by project-level analysis. Effects on archaeological resources can only be known once a specific project has been proposed because potential effects are highly dependent on the individual project site conditions and the characteristics of proposed ground-disturbing activity.
Ground-disturbing activities associated with development facilitated by the 2021-2029 Housing Element, particularly in Opportunity Areas that have not previously been developed with urban uses or that have not been studied through a cultural resources investigation, or for projects where excavation depths exceed those previously attained at that site, there is the potential for construction activities to damage or destroy previously unknown historic or prehistoric archaeological resources that may be present on or below the ground surface. Consequently, damage to or destruction of previously unknown sub-surface cultural resources could occur because of development implemented under the 2021-2029 Housing Element.
The 2030 General Plan includes the following goals and policies that require implementation programs to protect cultural resources, including requiring avoidance where feasible:
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64 Goal HR-2 Archeological and Paleontological Resources. Important archeological and paleontological resources are identified and protected within the City.
Policy HR-2.1 New Development Activities. Require that new development protect and preserve paleontological and archaeological resources from destruction and avoid and mitigate impacts to such resources. Through planning policies and permit conditions, ensure the preservation of significant archeological and paleontological resources and require that the impact caused by any development be mitigated.
Policy HR-2.2 Grading and Excavation Activities. Maintain sources of information regarding paleontological and archeological sites and the names and addresses of responsible organizations and qualified individuals who can analyze, classify, record, and preserve paleontological or archeological findings. Require a qualified paleontologist/archeologist to monitor all grading and/or excavation where there is a potential to affect cultural, archeological, or paleontological resources. If these resources are found, the applicant shall implement the recommendations of the paleontologist/archeologist, subject to the approval of the City.
Policy HR-2.4 Paleontological or Archaeological Materials. Require new development to donate scientifically valuable paleontological or archaeological materials to a responsible public or private institution with a suitable repository, located within Simi Valley or the County of Ventura, whenever possible.
The likelihood that intact archaeological resources or human remains are present in the surficial soil layer is low in Opportunity Areas that have been previously developed, but potentially high in the undeveloped Opportunity Areas.
If archaeological resources are identified, as defined by PRC Section 21083.2, the project site would require treatment in accordance with the provisions of that law, as appropriate, and the goals and policies in the City’s 2030 General Plan. This could include stopping work and evaluating the find; preserving the find; and waiting for site release by a qualified archaeologist to resume work, per the 2030 General Plan policies listed above.
To ensure construction workers are aware of potential impacts and can identify them, Mitigation Measure CUL-1 would be required for any project on sites that are currently undeveloped or where excavation would be to deeper levels than previous excavation levels, as determined during plan review. When these conditions are anticipated and the potential for discovery of unidentified cultural resources is high and where impacts could be significant if those resources go unrecognized, including on Opportunity Areas that are previously undeveloped. Furthermore, if the site is determined to be sensitive through the archaeological investigation, Mitigation Measure CUL-2 would be required to reduce impacts to less than significant.
Mitigation Measures
CUL-1 Worker Environmental Awareness Program
Prior to the start of construction on sites that are currently undeveloped or where excavation would be to deeper levels than previous excavation levels as determined during plan review, the project archaeologist or their designee shall conduct training for construction personnel regarding the appearance of fossils and the procedures for notifying paleontological staff should fossils be 716
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Final Initial Study – Mitigated Negative Declaration 65 discovered by construction staff. The WEAP shall be fulfilled at the time of a preconstruction meeting, which a qualified archaeologist shall attend. This training will include a printed handout that provides examples of potential cultural resources. The WEAP training will be repeated when construction personnel change and periodically renewed if the project has a long duration (more than three months.)
CUL-2 Archeological Resource Construction Monitoring
Prior to the issuance of a grading permit on sites that are currently undeveloped or where excavation would be to deeper levels than previous excavation levels as determined during plan review, the property owner/developer shall retain a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology (National Park Service 1983) to be present during all initial subsurface ground-disturbing construction activities. At the commencement of construction activities, an orientation meeting shall be conducted by the qualified archaeologist, construction manager, general contractor, subcontractor, and construction workers associated with ground-disturbing activities. The orientation meeting shall describe the potential of exposing archaeological resources, the types of resources that may be encountered, and directions on the steps that shall be taken if such a find is encountered.
With adherence to the 2030 General Plan policies and implementation of Mitigation Measure CUL-1 and Mitigation Measure CUL-2, impacts would be reduced to less than significant.
LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
Human burials outside of formal cemeteries often occur in prehistoric archaeological contexts.
Although much of the city is built out, the potential still exists for these resources to be present.
Excavation during construction activities in Simi Valley would have the potential to disturb these resources, including Native American burials.
The 2030 General Plan stated that the planning area (i.e., Simi Valley) is rich in subsurface archaeological resources, indicating a high level of habitation and resource use by Native Americans.
Therefore, the possibility that human remains could be found in subsurface excavations exists, particularly in undisturbed areas or in those where development occurred prior to the institution of environmental laws requiring surveys prior to construction. In addition to regulations that apply to potential archaeological resources, human burials have further specific provisions for treatment and protection of human burial remains in PRC Section 5097 and the California Health and Safety Code (Sections 7050.5, 7051, and 7054). Existing regulations address the illegality of interfering with human burial remains, and protect them from disturbance, vandalism, or destruction. PRC Section 5097.98 establishes procedures to be implemented if Native American skeletal remains are discovered, and addresses the disposition of Native American burials. This regulation protects such remains and establishes the NAHC to resolve any related disputes.
The 2030 General Plan contains a goal and policy to address the treatment of Native American remains as follows:
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66 Goal HR-2 Archeological and Paleontological Resources. Important archeological and paleontological resources are identified and protected within the City.
Policy HR-2.3 Cultural Organizations. Notify cultural organizations, including Native American organizations, of proposed developments that have the potential to adversely impact cultural resources. Allow representatives of such groups to monitor grading and/or excavation of development sites.
Most of the Opportunity Areas with rezone sites occur in urban areas previously disturbed and graded for existing development, but two include currently undeveloped lands, as discussed above, and there is potential to encounter previously undiscovered human remains. Even in previously disturbed sites, it is possible that unanticipated cultural resource remains could be encountered during construction or land modification activities associated with development projects facilitated by the 2021-2029 Housing Element.
If human remains are unearthed, the State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur until the Coroner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98. If there is a possibility that the remains are of Native American origin, Mitigation Measure CUL-3 would be required.
Mitigation Measures
CUL-3 Unanticipated Discovery of Human Remains and Associated Funerary Objects
The term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the burial of associated cultural resources (Funerary objects) with the deceased, and the ceremonial burning of human remains. These remains are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. The Native American Graves Protection and Repatriation Act guidance specifically states that the federal agencies will consult with organizations on whose aboriginal lands the remains and cultural items might be discovered, who are reasonably known to have a cultural relationship to the human remains and other cultural items. Therefore, it is appropriate to consult with local Native American groups as recommended by the California Native American Heritage Commission.
Any discoveries of human skeletal material shall be immediately reported to the County Coroner.
The monitor shall immediately divert work at a minimum of 50 feet and place an exclusion zone around the burial. The monitor shall then notify the Qualified Archaeologist and the construction manager who shall call the Coroner. Work shall continue to be diverted while the Coroner determines whether the remains are Native American. The discovery shall be kept confidential and secure to prevent any further disturbance. If the remains are Native American, the Coroner will notify the California NAHC as mandated by state law who will then appoint a Most Likely Descendent (MLD). The MLD shall provide recommendations as to the treatment and disposition of the human remains within 48 hours MLD designation. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains shall be covered with a protective casing to prevent further damage or looting. 718
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Final Initial Study – Mitigated Negative Declaration 67 If the Coroner determines the remains represent a historic non-Native American burial, the burial shall be treated in the same manner of respect with agreement of the Coroner. Reburial will be in an appropriate setting. If the Coroner determines the remains to be modern, the Coroner will take custody of the remains. Each occurrence of human remains and associated funerary objects shall be stored in accordance with methods agreed upon between the MLD and the landowner.
Implementation of Mitigation Measure CUL-4 would reduce potential impacts to human remains to a less than significant level. Potential impacts to tribal cultural resources are also discussed in Section 18, Tribal Cultural Resources of this IS-MND.
LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
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Energy
Final Initial Study – Mitigated Negative Declaration 69 6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ ■ □
Environmental Setting
California is one of the lowest per capita energy users in the United States, ranked 48th in among states, due to its energy efficiency programs and mild climate. In 2019, California consumed 662 million barrels of petroleum, 2,144 billion cubic feet of natural gas, and one million short tons of coal in 2018 (United States Energy Information Administration [EIA] 2021a). The single largest end- use sector for energy consumption in California is transportation (39.4 percent), followed by industrial (23.1 percent), commercial (18.8 percent), and residential (18.7 percent) (EIA 2021b).
Most of California’s electricity is generated in state with approximately 28 percent imported from the Northwest and Southwest in 2019; however, the state relies on out-of-state natural gas imports for nearly 90 percent of its supply (California Energy Commission [CEC] 2021a and 2021b). In addition, approximately 32 percent of California’s electricity supply comes from renewable energy sources, such as wind, solar photovoltaic, geothermal, and biomass (CEC 2021a). In 2018, Senate Bill 100 accelerated the state’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy and zero-carbon resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.
To reduce statewide vehicle emissions, California requires all motorists use California Reformulated Gasoline, which is sourced almost exclusively from in-state refineries. Gasoline is the most used transportation fuel in California with 15.3 billion gallons sold in 2019 and is used by light-duty cars, pickup trucks, sport utility vehicles, and aviation (California Department of Tax and Fee Administration 2020). Diesel is the second most used fuel in California with 4.2 billion gallons sold in 2015 and is used primarily by heavy duty-trucks, delivery vehicles, buses, trains, ships, boats and barges, farm equipment, and heavy-duty construction and military vehicles (California Energy Commission 2016).
Energy consumption is directly related to environmental quality in that the consumption of nonrenewable energy resources releases criteria air pollutant and greenhouse gas (GHG) emissions 721
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70 into the atmosphere. The environmental impacts of air pollutant and GHG emissions associated with the project’s energy consumption are discussed in detail in Section 3, Air Quality, and Section 8, Greenhouse Gas Emissions, respectively.
Projects that are proposed under the 2021-2029 Housing Element would be required to undergo project-specific evaluation to quantify specific impacts to energy consumption, which would occur during the permitting process for that project. As the criteria needed to assess these impacts are only available to the City upon submittal of a specific project proposal, any quantitative analysis would be speculative at this time. All projects would be required to conform to local, State, and federal regulations governing energy consumption reduction.
Impact Analysis
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Reasonably foreseeable development under the 2021-2029 Housing Element would consume energy during construction and operation using petroleum fuel, natural gas, and electricity, as further addressed below.
Construction
Energy use during construction associated with reasonably foreseeable development under the 2021-2029 Housing Element would be in the form of fuel consumption (e.g., gasoline and diesel fuel) to operate heavy equipment, light-duty vehicles, machinery, and generators for lighting. In addition, temporary grid power may also be provided to construction trailers or electric construction equipment. Energy use during the construction of individual projects would be temporary in nature, and equipment used would be typical of construction projects in the region. In addition, construction contractors would be required to demonstrate compliance with applicable CARB regulations that restrict the idling of heavy-duty diesel motor vehicles and govern the accelerated retrofitting, repowering, or replacement of heavy-duty diesel on- and off-road equipment.
Construction activities associated with reasonably foreseeable development under the 2021-2029 Housing Element would be required to utilize fuel-efficient equipment consistent with State and Federal regulations and would comply with State measures to reduce the inefficient, wasteful, or unnecessary consumption of energy. In addition, individual projects would be required to comply with construction waste management practices to divert 50 percent of construction and demolition debris (SVMC Section 9-35.010). Developers would be required to complete the Construction and Demolition Waste Management Plan Form and use City-approved haulers to remove mixed construction debris in accordance with the standards set by the Department of Public Works.
These practices would result in efficient use of energy during construction of future development under the 2021-2029 Housing Element. Furthermore, in the interest of both environmental awareness and cost efficiency, construction contractors would not utilize fuel in a manner that is wasteful or unnecessary. Therefore, future construction activities associated with reasonably foreseeable development under the Housing and Safety Element Update would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant. 722
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Energy
Final Initial Study – Mitigated Negative Declaration 71 Operation
Long-term operation of new projects developed in accordance with the 2021-2029 Housing Element and General Plan update would require permanent grid connections for electricity and natural gas service to power internal and exterior building lighting, and heating and cooling systems. As previously discussed, the 2021-2029 Housing Element and General Plan update would prioritize development in previously developed areas of Simi Valley already served by energy providers.
Electricity service in the city is provided by Southern California Edison and Southern California Gas Company (SoCal Gas) provides natural gas services to residents and businesses in the city.
Reasonably foreseeable development under the 2021-2029 Housing Element and General Plan update would be subject to the energy conservation requirements of the California Energy Code (Title 24, Part 6 of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings), the California Green Building Standards Code (CALGreen, Title 24, Part 11 of the California Code of Regulations). The California Energy Code provides energy conservation standards for all new and renovated commercial and residential buildings constructed in California. This Code applies to the building envelope, space-conditioning systems, and water- heating and lighting systems of buildings and appliances and provides guidance on construction techniques to maximize energy conservation. Minimum efficiency standards are given for a variety of building elements, including appliances; water and space heating and cooling equipment; and insulation for doors, pipes, walls, and ceilings. The Code emphasizes saving energy at peak periods and seasons and improving the quality of installation of energy efficiency measures. The California Green Building Standards Code sets targets for energy efficiency; water consumption; dual plumbing systems for potable and recyclable water; diversion of construction waste from landfills; and use of environmentally sensitive materials in construction and design, including ecofriendly flooring, carpeting, paint, coatings, thermal insulation, and acoustical wall and ceiling panels.
The 2021-2029 Housing Element and General Plan update would prioritize future development projects close to high quality transit areas and existing commercial/retail, recreational, and institutional land uses, which would reduce trip distances and encourage the use of alternative modes of transportation such as bicycling and walking. These factors would minimize the potential of the 2021-2029 Housing Element to result in the wasteful or unnecessary consumption of vehicle fuels. As a result, operation of reasonably foreseeable development projects under the Housing Element Update would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
In 2012, the City Council integrated the City’s environmental programs by adopting the Climate Action Plan, which is included in the 2030 General Plan as Appendix D. This plan is based on the United National Environmental Accords which provide a series of goals or “action items” that can be adopted at the local level to achieve urban sustainability, promote healthy economies, advance social equity, and protect the world’s ecosystem. The plan includes both renewable energy and energy efficiency goals, as well as the expansion of public transportation throughout the City (City of Simi Valley 2012).
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72 Proposed projects related to implementation of the 2021-2029 Housing Element would be required to comply with City and State energy efficiency regulations and standards, including CALGreen building code requirements, and compliance with these requirements would be assessed during the project permitting and review process. This would ensure that individual projects implemented under the 2021-2029 Housing Element would not conflict with renewable energy and energy efficiency plans adopted by the City. As such, reasonably foreseeable development under the 2021- 2029 Housing Element would not conflict with or obstruct a plan for renewable energy or energy efficiency, and the Safety Element and Environmental Justice updates to the 2030 General Plan would not result in development that would conflict with a plan to renewable energy and energy efficiency. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Geology and Soils
Final Initial Study – Mitigated Negative Declaration 73 7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
1. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial evidence
of a known fault? □ □ ■ □
2. Strong seismic ground shaking? □ □ ■ □
3. Seismic-related ground failure,
including liquefaction? □ □ ■ □
4. Landslides? □ □ ■ □
b. Result in substantial soil erosion or the
loss of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ ■ □
d. Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building
Code (1994), creating substantial direct
or indirect risks to life or property? □ □ ■ □
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
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74 Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
Existing Conditions
Southern California is a well-known seismically active region, and commonly experiences strong ground shaking from earthquakes along known and previously unknown active faults. There are three main types of faults throughout California: active, potentially active, and inactive. Faults that have caused displacement within the Holocene period (the last 11,000 years) are defined as active.
Potentially active faults are those that have experienced movement during the Quaternary period (last two million years), while inactive faults have not experienced movement in the last two million years.
While the City is near several regional fault systems such as the San Andres and Santa Susana Faults, the Simi-Santa Rosa Fault is a known active fault which runs east-west through the City of Simi Valley. Over the past century, Simi Valley has experienced eight earthquakes of a magnitude 5.0 or greater, none of which have occurred within the City. The Simi-Santa Rosa Fault has been designated as an Earthquake Fault Zone by the State, in which structures are prohibited per the Alquist-Priolo Special Studies Act of 1972 (City of Simi Valley 2012). The study area for geology and soils includes the areas in which the Opportunity Areas are situated and not the entire city.
Many of the geologic units in the Planning Area are fossil-bearing, but not all contain fossils of land- dwelling vertebrates. The units containing fossils of land-dwelling vertebrates include the Old Alluvium (late to middle Pleistocene), the Modelo Formation (late Miocene), and the Sespe Formation (early Miocene, Oligocene, and late Eocene), according to the 2030 General Plan EIR (City of Simi Valley 2012). These units are considered to have High Sensitivity for paleontological resources because they are known to produce vertebrate fossil remains; they are generally located in the northwest half and southwest of the city. These sensitive units are shown in relation to the Planning Area boundaries in Figure 4.5-2 of the 2030 General Plan EIR.
Impact Analysis
a.1. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? a.2. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? The City of Simi Valley is in a seismically active region of southern California. Major active faults in the area include the San Andreas and Simi-Santa Rosa faults, the latter of which traverses the city from the northeast to the southwest as depicted in Figure 4.6-2 of the City’s 2030 General Plan EIR (City of Simi Valley 2012). The Simi-Santa Rosa fault is considered to have been active within the last 11,000 years, and therefore the fault zone is classified as an Alquist-Priolo Fault Zone. Fault 726
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Final Initial Study – Mitigated Negative Declaration 75 rupturing could result in severe ground shaking. In addition to the Simi-Santa Rosa fault, there are several regional fault zones that could produce moderate to large earthquakes resulting in ground shaking within the city limits (City of Simi Valley 2012).
Development projects proposed on the Opportunity Areas as implementation of the 2021-2029 Housing Element would be subject to the 2030 General Plan goals and policies listed below and the provisions in the Chapter 8-11 of the SVMC, which include California Building Code requirements to reduce seismic impacts. Adherence to these goals, policies, and regulations would reduce potential impacts to less than significant levels.
Goal S-5 Geologic and Seismic Hazards. Adverse effects to residents, public and private property, and essential services caused by seismic and geologic hazards are minimized.
Policy S-5.1 Review Safety Standards. Regularly review and enforce all seismic and geologic safety standards, including the Building Code, in site design and building construction methods.
Policy S-5.2 Building Codes. Adopt building codes that include design and construction features that provide protection for new and renovated structures in hazard areas.
Policy S-5.3 Geotechnical Investigations. Require geotechnical investigations for applicable improvements to determine the potential for ground rupture, ground shaking, landslides, and liquefaction impacts due to seismic events, and to assess for expansive soils and subsidence problems. The report shall specify construction methods to protect existing and future residences and commercial properties from identified hazards.
The Walnut Hills Opportunity Area is within the Simi-Santa Rosa fault zone, and therefore could experience severe ground shaking, surface rupture, and translocation due to earthquakes. Building setbacks could limit or preclude development of certain parcels, but, according to a geotechnical investigation for a development proposed for part of the Walnut Hills Opportunity Area the site would be suitable for construction so long as geotechnical engineering recommendations are followed.
The SVMC adopts the most recent California Building Code in Section 8-11.01, Adoption and Amendments of the California Building Code. The City’s Hillside Performance Standards, Chapter 9- 32 of the SVMC, set forth design guidelines related to grading, slope design, ridgeline development, and requirements for geologic and soils engineering reports. All potential projects built in the Opportunity Areas would be required to comply with SVMC building regulations and engineering practices. This, and adherence to the goals and policies in the 2030 General Plan, would reduce impacts due to potential seismic ground shaking to less than significant levels.
LESS THAN SIGNIFICANT IMPACT
a.3. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction? Liquefaction is a phenomenon in which loose, saturated, granular soils behave similarly to a fluid when subjected to high-intensity ground shaking. Liquefaction occurs when three general conditions exist: shallow groundwater; low density, fine, clean sandy soils; and strong ground motion.
Liquefaction-related effects include loss of bearing strength, amplified ground oscillations, lateral 727
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76 spreading, and flow failures. As illustrated in Figure 4.6-3 of the City’s 2030 General Plan EIR, a large portion of central Simi Valley, near the Arroyo Simi and other creeks, is subject to liquefaction hazards (City of Simi Valley 2012).
Development projects proposed in the Opportunity Areas facilitated by implementation of the 2021-2029 Housing Element would be subject to the 2030 General Plan goals and policies listed below and the provisions in the Hillside Performance Standards, Chapter 9-32, and Chapter 8-11, Adoption of the California Building Code, of the SVMC, which include California Building Code requirements to reduce seismic impacts. Adherence to these goals, policies, and regulations would reduce potential impacts to less than significant levels. Goal S-5 Geologic and Seismic Hazards.
Adverse effects to residents, public and private property, and essential services caused by seismic and geologic hazards are minimized.
Policy S-5.1 Review Safety Standards. Regularly review and enforce all seismic and geologic safety standards, including the Building Code, in site design and building construction methods.
Policy S-5 Building Codes. Adopt building codes that include design and construction features that provide protection for new and renovated structures in hazard areas.
Policy S-5.3 Geotechnical Investigations. Require geotechnical investigations for applicable improvements to determine the potential for ground rupture, groundshaking, landslides, and liquefaction impacts due to seismic events, and to assess for expansive soils and subsidence problems. The report shall specify construction methods to protect existing and future residences and commercial properties from identified hazards.
New construction within liquefaction zones would be built to current building, structural, and seismic codes. In accordance with the State’s Seismic Hazard Mapping Act, development within liquefaction zones must perform site-specific geotechnical investigations prior to construction. Soil improvement requirements to mitigate liquefaction hazards on small lots could be economically infeasible but this would be determined when specific projects are proposed on individual sites.
Compliance with City and State building codes, as well as the policies within the 2030 General Plan, would reduce seismic ground shaking impacts with current engineering practices and the project would not exacerbate liquefaction potential in the area. As such, the 2021-2029 Housing Element would not directly or indirectly cause substantial adverse effects from liquefaction risk and impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.4. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
Landslides generally occur in loosely consolidated, wet soil and/or rocks on steep sloping terrain.
Areas of the City in landslide hazard zones are concentrated in the hillsides surrounding Simi Valley.
Specifically, areas north of Route 118 in the foothills of the Santa Susana Mountains and those south of Royal Avenue have experienced past landslides and are likely to experience future landslides (City of Simi Valley 2012). The Opportunity Area south of Heyneman Lane is located on a landslide hazard zone, however the area is small compared to the size of the Opportunity Area. 728
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Final Initial Study – Mitigated Negative Declaration 77 Development projects proposed on the Opportunity Areas as implementation of the 2021-2029 Housing Element would be subject to the 2030 General Plan goals and policies listed below and the provisions in Chapter 8.11 of the SVMC, which adopts the California Building Code’s requirements to reduce seismic impacts. Goals and policies of the 2030 General Plan that would apply to potential effects from landslides are as follows:
Goal LU-4 Development Shaped by Environmental Setting. Development is located to respect, work with, and complement the natural features of the land.
Policy LU-4.5 Hillside Grading. Minimize terrain disruption and design grading using generally accepted principles of civil engineering with the objective to blend the project into the natural topography.
Policy LU-4.6 Hillside Development Density. Maintain land outside the valley floor having a slope of over 20 percent as permanent open space. Commercial and industrial development shall be limited to slopes of 10 percent or less, unless otherwise allowed under the Hillside Performance Standards of the SVMC or approved by a specific plan that justifies and provides appropriate design measures for the development of these areas, in which case development shall be limited to slopes of 20 percent or less.
Goal S-5 Geologic and Seismic Hazards. Adverse effects to residents, public and private property, and essential services caused by seismic and geologic hazards are minimized.
Policy S-5.1 Review Safety Standards. Regularly review and enforce all seismic and geologic safety standards, including the Building Code, in site design and building construction methods.
Policy S-5.2 Building Codes. Adopt building codes that include design and construction features that provide protection for new and renovated structures in hazard areas.
Policy S-5.3 Geotechnical Investigations. Require geotechnical investigations for applicable improvements to determine the potential for ground rupture, groundshaking, landslides, and liquefaction impacts due to seismic events, and to assess for expansive soils and subsidence problems. The report shall specify construction methods to protect existing and future residences and commercial properties from identified hazards.
In addition to the 2030 General Plan goals and policies listed above, development in landslide hazard areas would be required to adhere to Chapter 9.32, Hillside Performance Standards, of the SVMC, as well as regulations of the California Building Code in Chapter 8.11 of the SVMC. Projects carried out under the Housing Element Update would adhere to existing regulations and would result in less than significant impacts related to landslides.
LESS THAN SIGNIFICANT IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? Simi Valley is a heavily developed city with insignificant amounts of agricultural uses within the city limits, and therefore has minimal potential for erosion or topsoil loss because of further development (City of Simi Valley 2012). The Opportunity Areas identified in the 2021-2029 Housing Element would primarily be infill development and would not rezone agricultural land. Demolition 729
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78 and construction activities would be required to comply with California Building Code Appendix Section J110, Erosion Control standards, which ensures appropriate erosion and storm water pollution control during grading and construction activities (City of Simi Valley 2012). Construction activities that occur on more than one acre are required to obtain a National Pollutant Discharge Elimination System (NPDES) Construction General Permit. NPDES requires the development of a stormwater pollution prevention plan, which includes best management practices (BMPs) to reduce erosion and topsoil loss from stormwater runoff. Additionally, development would adhere to sediment control regulations described in Section 6-12.504 of the SVMC, as well as grading and erosion controls listed in Section 9-32.110. Lastly, development would adhere to VCAPCD Rule 55 which requires BMPs such as watering disturbed soils to prevent wind-blown dust.
Adherence to applicable regulations and permits would ensure that new land uses and development do not increase the level of soil erosion or loss of topsoil within the City. Therefore, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Impacts related to landslides and liquefaction are addressed under impact discussions a.3. and a.4.; therefore, this discussion focuses on impacts related to unstable soils because of lateral spreading, subsidence or collapse. Lateral spreading occurs because of liquefaction; accordingly, liquefaction- prone areas would also be susceptible to lateral spreading. Subsidence occurs at great depths below the surface when subsurface pressure is reduced by the withdrawal of fluids (e.g., groundwater, natural gas, or oil) resulting in sinking of the ground.
Simi Valley does contain several zones of highly expansive soils located within the foothills of Simi Valley, while other areas of the city contain moderately expansive soils (City of Simi Valley 2012).
The 2021-2029 Housing Element would prioritize development of housing on infill sites in urban areas that may contain underlying expansive soils. All projects implemented under the 2021-2029 Housing Element would require geotechnical evaluation and the latest construction standards would be required for all new infill and other development, which are designed to reduce exposure to and effects of unstable soils. Implementation of these standards along with goals and policies of the 2030 General Plan that would apply to potential effects from seismic activity related to the effects of expansive soils, are as follows, would reduce potential exposure to or extent of expansive soils in the city.
Goal S-5 Geologic and Seismic Hazards. Adverse effects to residents, public and private property, and essential services caused by seismic and geologic hazards are minimized.
Policy S-5.1 Review Safety Standards. Regularly review and enforce all seismic and geologic safety standards, including the Building Code, in site design and building construction methods.
Policy S-5.2 Building Codes. Adopt building codes that include design and construction features that provide protection for new and renovated structures in hazard areas.
Policy S-5.3 Geotechnical Investigations. Require geotechnical investigations for applicable improvements to determine the potential for ground rupture, groundshaking, 730
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Final Initial Study – Mitigated Negative Declaration 79 landslides, and liquefaction impacts due to seismic events, and to assess for expansive soils and subsidence problems. The report shall specify construction methods to protect existing and future residences and commercial properties from identified hazards.
In addition to the 2030 General Plan goal and policies listed above, development would be required to adhere to minimum standards for structural design and site development outlined in the California Building Code. The California Building Code provides standards for excavation, grading, and earthwork construction; fills and embankments; expansive soils; foundation investigations; and liquefaction potential and soils strength loss. Therefore, required incorporation of soil treatment programs (replacement, grouting, compaction, drainage control, etc.) in the excavation and construction plans for a project can achieve an acceptable degree of soil stability to address site- specific soil conditions. Adherence to these requirements would achieve accepted safety standards relative to unstable geologic units or soils. In addition, although development of projects carried out under the Housing Element Update would potentially be subject to these hazards, it would not increase the potential for lateral spreading, subsidence, or collapse. Therefore, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Soils that volumetrically increase (swell) or expand when exposed to water and contract when dry (shrink) are considered expansive soils. A soil’s potential to shrink and swell depends on the amount and types of clay in the soil. Highly expansive soils can cause structural damage to foundations and roads without proper structural engineering and are generally less suitable or desirable for development than non-expansive soils because of the necessity for detailed geologic investigations and costlier grading applications.
Simi Valley does contain several zones of highly expansive soils located within the foothills of Simi Valley, while other areas of the city contain moderately expansive soils (City of Simi Valley 2012).
The 2021-2029 Housing Element would prioritize development of housing on infill sites in urban areas that may contain underlying expansive soils. All projects implemented under the 2021-2029 Housing Element would require geotechnical evaluation and the latest construction standards would be required for all new infill and other development, which are designed to reduce exposure to and effects of unstable soils. Implementation of these standards along with goals and policies of the 2030 General Plan that would apply to potential effects from seismic activity related to the effects of expansive soils, are as follows, would reduce potential exposure to or extent of expansive soils in the city.
Goal S-5 Geologic and Seismic Hazards. Adverse effects to residents, public and private property, and essential services caused by seismic and geologic hazards are minimized.
Policy S-5.1 Review Safety Standards. Regularly review and enforce all seismic and geologic safety standards, including the Building Code, in site design and building construction methods.
Policy S-5.2 Building Codes. Adopt building codes that include design and construction features that provide protection for new and renovated structures in hazard areas.
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80 Policy S-5.3 Geotechnical Investigations. Require geotechnical investigations for applicable improvements to determine the potential for ground rupture, groundshaking, landslides, and liquefaction impacts due to seismic events, and to assess for expansive soils and subsidence problems. The report shall specify construction methods to protect existing and future residences and commercial properties from identified hazards.
Development would be required to adhere to recommendations found within the geotechnical investigations, such that impacts related to geological hazards are mitigated. Additionally, development facilitated by the Housing Element Update would adhere to the City’s Building Code as well as the California Building Code, which requires the preparation of a soil investigation prior to construction and incorporation of appropriate corrective actions to prevent structural damage.
Therefore, adherence to local and State regulations would ensure that there would be minimal change in the exposure of people or structures to risks associated with expansive soils, and impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
As discussed in the City’s 2030 General Plan EIR, Simi Valley is entirely served by established wastewater conveyance and treatment services. As such, new development would connect to existing sewer lines or sewer lines that may be expanded in the future. The Housing Element Update neither requires nor proposes the use of septic tanks or alternative wastewater systems for future development. Therefore, the Housing Element Update would cause no impact related to soils incapable of adequately supporting septic tanks or alternative wastewater disposal systems.
NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The Planning Area is known to have high paleontological sensitivity in Old Alluvium, the Modelo formation, and the Sespe formation. Ground-disturbing construction activities associated with implementation of the 2021-2029 Housing Element on sites with these geologic units have the potential to destroy a unique paleontological resource directly or indirectly through inadvertent damage or destruction.
The 2030 General Plan includes goals and polices providing for the management and protection of significant paleontological resources as follows
Goal HR-2 Archeological and Paleontological Resources. Important archeological and paleontological resources are identified and protected within the City.
Policy HR-2.1 New Development Activities. Require that new development protect and preserve paleontological and archaeological resources from destruction and avoid and mitigate impacts to such resources. Through planning policies and permit conditions, ensure the preservation of significant archeological and paleontological resources and require that the impact caused by any development be mitigated.
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Final Initial Study – Mitigated Negative Declaration 81 Policy HR-2.2 Grading and Excavation Activities. Maintain sources of information regarding paleontological and archeological sites and the names and addresses of responsible organizations and qualified individuals who can analyze, classify, record, and preserve paleontological or archeological findings. Require a qualified paleontologist/archeologist to monitor all grading and/or excavation where there is a potential to affect cultural, archeological, or paleontological resources. If these resources are found, the applicant shall implement the recommendations of the paleontologist/archeologist, subject to the approval of the City.
Policy HR-2.4 Paleontological or Archaeological Materials. Require new development to donate scientifically valuable paleontological or archaeological materials to a responsible public or private institution with a suitable repository, located within Simi Valley or the County of Ventura, whenever possible.
The 2021-2029 Housing Element would prioritize development on infill sites in the city that have previously been developed and disturbed, with a few potential exceptions such the Walnut Hills Opportunity Area and the and Heyneman Lane Opportunity Areas, which are in or near undeveloped land zoned as open space. Nonetheless, there is the potential for undiscovered paleontological resources to be present below the ground surface throughout the city. There would be no impacts to paleontological resources other than during construction. Because the General Plan Update includes policies that require identification and mitigation of impacts on unique paleontological resources or sites to ensure compliance with these policies, this impact is considered less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 83 8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment? □ □ ■ □
b. Conflict with an applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases? □ □ ■ □
Environmental Setting
Gases that absorb and re-emit infrared radiation in the atmosphere are called greenhouse gases (GHG). The gases that are widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated gases such as hydrofluorocarbons and perfluorocarbons, and sulfur hexafluoride. Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. GHGs are emitted by both natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are largely by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and landfills. Different types of GHGs have varying global warming potentials (GWP), which are the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the GHG emissions, referred to as carbon dioxide equivalent (CO2e), and is the amount of a GHG emitted multiplied by its GWP. CO2 has a 100-year GWP of one. By contrast, CH4 has a GWP of 28, meaning its global warming effect is 28 times greater than that of CO2 on a molecule per molecule basis (Intergovernmental Panel on Climate Change [IPCC] 2014a).7 The accumulation of GHGs in the atmosphere regulates Earth’s temperature. Without the natural heat-trapping effect of GHGs, the Earth’s surface would be about 33 degrees Celsius (°C) cooler.
However, emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, have elevated the concentration of GHGs in the atmosphere beyond the level of naturally occurring concentrations.
7 The IPCC’s (2014a) Fifth Assessment Report determined that methane has a GWP of 28. However, modeling of GHG emissions was completed using the California Emissions Estimator Model version 2016.3.2, which uses a GWP of 25 for methane, consistent with the IPCC’s (2007) Fourth Assessment Report.
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84 Regulatory Framework
In response to climate change, California implemented Assembly Bill (AB) 32, the “California Global Warming Solutions Act of 2006.” AB 32 required the reduction of statewide GHG emissions to 1990 emissions levels (essentially a 15 percent reduction below 2005 emission levels) by 2020 and the adoption of rules and regulations to achieve the maximum technologically feasible and cost- effective GHG emissions reductions. On September 8, 2016, the Governor signed Senate Bill 32 into law, extending AB 32 by requiring the State to further reduce GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, the CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target.
The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program and the Low Carbon Fuel Standard, and implementation of recently adopted policies and legislation, such as SB 1383 (aimed at reducing short-lived climate pollutants including methane, hydrofluorocarbon gases, and anthropogenic black carbon) and SB 100 (discussed further below). The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing technology, and strategic investment to support its strategies. As with the 2013 Scoping Plan Update, the 2017 Scoping Plan does not provide project-level thresholds for land use development. Instead, it recommends local governments adopt policies and locally appropriate quantitative thresholds consistent with a statewide per capita goal of six metric tons (MT) of CO2e by 2030 and two MT of CO2e by 2050 (CARB 2017).
Impact Analysis
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
b. Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
GHG emissions are air pollutants subject to local control by the VCAPCD. As such, the City looks to the VCAPCD for guidance in the evaluation of GHG impacts. In September 2011, VCAPCD staff prepared a report entitled Greenhouse Gas Thresholds of Significance Options for Land Use Development Projects in Ventura County to establish the options for GHG significance thresholds.
The report summarizes the most prominent approaches and options either adopted or being considered by all other air districts throughout California. Similar to other air districts, VCAPCD staff members considered a tiered approach with the main components involving consistency with a locally adopted GHG reduction plan followed by a bright-line threshold for land use projects that would capture 90 percent of project GHG emissions. The South Coast Air Quality Management District (SCAQMD) also considered these strategies for land use projects. The most recent proposal issued in September 2010 included a screening threshold of 3,000 MTCO2e/year for all non- industrial projects.
The City of Simi Valley also adopted its own Climate Action Plan in 2012, as part of the General Plan Update designed to support GHG emissions reduction targets of 49 percent below 2010 levels by 2035. The CAP contains GHG reduction measures organized into four primary sectors: energy, transportation, solid waste, and water. Furthermore, the principal State plan and policy is Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006, and the follow up, Senate Bill (SB)
32. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020 and the goal of SB 32 is to reduce GHG emissions to 40 percent below 1990 levels by 2030 (CARB 2017). SB 375, signed in August 2008, enhances the State’s ability to reach AB 32 goals by directing CARB to 736
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Final Initial Study – Mitigated Negative Declaration 85 develop regional GHG emission reduction targets to be achieved from passenger vehicles for 2020 and 2035. SB 375 directs each of the State’s 18 major Metropolitan Planning Organizations (MPO) to prepare a “sustainable communities strategy” (SCS) that contains a growth strategy to meet these emission targets for inclusion in the Regional Transportation Plan (RTP). SCAG formally adopted the 2020-2045 RTP/SCS on September 3, 2020 to provide a roadmap for sensible ways to expand transportation options, improve air quality and bolster southern California’s long-term economic viability (SCAG 2020).
The 2021 Housing Element Update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021 Housing Element Update will not, in and of itself, result in impacts to energy consumption, GHG emissions, or climate change. Future development will require project- specific environmental evaluation to determine compliance with City regulations and the level of any potential environmental impacts.
The 2021-2029 Housing Element would facilitate housing in the city limits and particularly along transportation corridors, including SR 118 and arterial roads such as Los Angeles Avenue. This transit-oriented development is intended to be mixed-use and to include services that support residents within walking or cycling distance. This would reduce GHG emissions related to automobile travel. Any impacts identified for an individual project would be addressed through the project approval process, including design review and (when applicable) environmental review and mitigation measures specific to any potential impacts for that project.
As part of the General Plan update, the City has adopted a Climate Action Plan (SV-CAP) that includes a baseline GHG emissions inventory, a methodology for tracking and reporting emissions in the future, and recommendations for GHG reduction strategies as a foundation for these efforts.
The SV-CAP focuses on the various goals and policies of the 2030 General Plan relative to greenhouse gas emissions. The SV-CAP is designed to ensure that the impact of future development on air quality and energy resources is minimized and that land use decisions made by the City and internal operations within the City are consistent with adopted state legislation. The SV-CAP identifies energy reduction measures, including a requirement that new development exceed 2008 Title 24 Part 6 Energy Standards by 20 percent, and water use reduction measures to reduce water demand by 20 percent.
Development under the 2021-2029 Housing Element will be required to comply with several ordinances that implement the goals of the SV-CAP. Simi Valley has adopted an Energy Reach Code, which adopts energy efficiency performance standards that reach higher than is required by Title 24 minimums. The main focus is on efficiency measures that are simple to achieve and enforce and have the greatest influence on community sustainability. The Reach Code increases energy efficiency requirements for residential and nonresidential structures beyond Title 24, set at 10 and 15 percent respectively for new construction and substantial remodels. Chapter 9-39 of the City of Simi Valley Development Code promotes trip reduction and alternative transportation methods (e.g., carpools, vanpools, public transit, bicycles, walking, park-and ride lots, improvement in the balance between jobs and housing), flexible work hours, telecommuting, and parking management programs to address traffic increases from new development. The Water Conservation Program Ordinance (Ordinance 1142) will reduce water consumption within the City of Simi Valley through conservation, effective water supply planning, prevention of waste, and will maximize the efficient use of water within the City of Simi Valley. The Water Conservation Ordinance is designed to reduce water use in the City to at least 15 percent below the 2009 baseline. The City is an early adopter of the CALGreen Building Code, which is intended to improve sustainability of the built environment 737
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86 and reduce GHG emissions from new construction. The City’s adopting Ordinance 1167 goes further by including a CEC-approved energy reach code, additional landscape water conservation, and increased recycling.
Based on the above information, development implemented under the 2021-2029 Housing Element would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 87 9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
0.25 mile of an existing or proposed
school? □ □ ■ □
d. Be located on a site that is included on a
list of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ □ ■ □
e. For a project located in an airport land
use plan or, where such a plan has not
been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ ■ □
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88 Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
g. Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving wildland
fires? □ □ ■ □
Environmental Setting
Quantities of hazardous materials are generated, stored, or transported within Simi Valley.
Underground pipelines carry flammable and hazardous liquids, hazardous materials are used by both industrial and commercial businesses throughout the city, and freight trains traverse the area hauling various types of hazardous and explosive materials such as chlorine and natural gas.
Schools, the Police Station, all five fire stations, City Hall, the Public Services Center, utility companies, and transportation routes could be vulnerable to temporary disruptions during hazardous materials releases. Transportation related hazardous related incidents from fixed facilities (such as an accidental spill or accident at a manufacturing facility) or from pipelines, and clandestine dumping could occur. Simi Valley continues to experience clean-up of Leaking Underground Fuel Tanks and other hazardous materials sites (California Department of Toxic Substances Control 2021, State Water Resources Control Board 2021). To protect residents, the City has implemented the goals and policies found in the 2030 General Plan and adopted Part 2 of Title 24 California Building Standards Code into the SVMC.
Impact Analysis
a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Implementation of the 2021-2029 Housing Element would facilitate development of 1,367 new residential units in the 10 rezone Opportunity Areas. This would include rezoning commercial, industrial, and residential land uses to allow for increased density and mixed-use development.
Generally, residential uses may include small quantities of hazardous materials used in landscaping and common household use such as fertilizer or cleaning products.
The 2021-2029 Housing Element would facilitate the development of new housing by creating a regulatory setting in which higher density residential uses can be developed on sites currently zoned for commercial, industrial, or residential uses. It is likely that construction of new development facilitated by the 2021-2029 Housing Element would require equipment and the use of fuel and petroleum-based lubricants. Use of potentially hazardous materials during construction of future development because of the implementation of the Housing Element Update would be required to comply with local, State, and federal regulations regarding the handling of potentially hazardous materials. Likewise, the transport, use, and storage of hazardous materials during any future construction would be required to comply with applicable State and federal laws, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Material Management Act, and California Code of Regulations Title 22. 740
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Final Initial Study – Mitigated Negative Declaration 89 The Simi Valley 2030 General Plan goals and policies that govern the transport of hazardous materials are as follows:
Goal S-9 Hazardous Materials. Residents, visitors, property, and the natural environment in Simi Valley are protected by the safe and regulated use, storage, and/or transport of hazardous materials.
Policy S-9.1 Interjurisdictional Coordination. Continue to carry out inspections, emergency response, and enforcement of hazardous materials and waste compliance procedures for Simi Valley.
Policy S-9.2 Educate Residents/Businesses. Educate residents and businesses regarding methods to reduce or eliminate the use of hazardous materials, including the disposal of household hazardous materials, including medications, batteries, e- waste, biomedical waste, etc., and the use of safer nontoxic equivalents.
Policy S-9.3 Emergency Response. Maintain and enhance the City’s first responders’ ability to respond to hazardous materials incidents and releases safely and effectively.
Policy S-9.4 Hazardous Materials Regulation. Work with relevant agencies regarding enforcement of applicable laws requiring all users, producers, disposers, and transporters of hazardous materials and wastes to clearly identify the materials they store, use, produce, dispose, or transport, and to notify the appropriate City, County, State, and federal agencies in the event of a violation.
Policy S-9.5 Known Areas of Contamination. Require proponents of projects in known areas of contamination from oil operations or other uses to perform comprehensive soil and groundwater contamination assessments, in accordance with applicable standards. If contamination exceeds regulatory action levels, require the proponent to undertake remediation procedures prior to grading and development through a cleanup program under the supervision of the Ventura County Environmental Health Division, Department of Toxic Substances Control, or Regional Water Quality Control Board (depending upon the nature of any identified contamination).
Policy S-9.6 Siting of Sensitive Uses. Develop and implement strict land use controls, performance standards, and structure design standards for uses that generate, use, or store hazardous materials, including development setbacks from sensitive uses such as residential homes, schools, hospitals, daycare and eldercare facilities, high density population facilities (such as movie theaters, auditoriums, museums), and other sensitive uses.
Policy S-9.7 Phase 1 Site Assessment. Require Phase 1 site assessments for new development proposed on land that may be contaminated with hazardous materials or waste, include commercial shopping centers where residential development is allowed.
Policy S-9.8 Hazardous Waste Collection. Conduct frequent and convenient household hazardous waste collection events.
Policy S-9.9 Water Supply and Air Protection. Work with public agencies and private organizations to prevent the introduction and spread of hazardous materials in the air and water supply.
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90 Section 9-44.090-C.6 of the SVMC prohibits the handling, use, generation, or storage of hazardous materials in residences that exceed basic home use. As stated earlier, residential land use is associated with the use, transportation, storage, or generation of small quantities, if any, of hazardous materials, including household cleaners, batteries, and landscaping maintenance chemicals. Operation of new housing developed under the 2021-2029 Housing Element would likely involve an incremental increase in the use of common household hazardous materials, such as cleaning and degreasing solvents, fertilizers, pesticides, and other materials used in regular property and landscaping maintenance. Use of these materials would be subject to compliance with existing regulations, standards, and guidelines established by the federal, State, and local agencies related to storage, use, and disposal of hazardous materials and new development would be subject to the goals and policies of the 2030 General Plan, listed above. Therefore, upon compliance with all applicable local, State, and federal laws and regulations relating to environmental protection and the management of hazardous materials, potential impacts associated with the routine transport, use, or disposal of hazardous materials during construction and operation of development projects under the 2021-2029 Housing Element and General Plan update would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
As discussed above, the 2021-2029 Housing Element provides for the possible construction of new residential development in the 10 rezone Opportunity Areas, and the use and transport of hazardous materials associated with residential development occurs in small quantities such that significant impacts due to upset of hazardous materials is unlikely. Demolition of buildings whose construction predates the regulations governing lead-based paint (1978) and asbestos-containing materials (1989) would be subject to regulations guiding their removal, in accordance with California Code of Regulations Title 8, Section 1532.1 (lead) and Section 1529 (asbestos-containing materials. Furthermore, the following goal and policies within the 2030 General Plan would minimize potential impacts associated with the upset of hazardous materials:
Goal S-9 Hazardous Materials. Residents, visitors, property, and the natural environment in Simi Valley are protected by the safe and regulated use, storage, and/or transport of hazardous materials.
Policy S-9.1 Interjurisdictional Coordination. Continue to carry out inspections, emergency response, and enforcement of hazardous materials and waste compliance procedures for Simi Valley.
Policy S-9.3 Emergency Response. Maintain and enhance the City’s first responders’ ability to respond to hazardous materials incidents and releases safely and effectively.
Policy S-9.4 Hazardous Materials Regulation. Work with relevant agencies regarding enforcement of applicable laws requiring all users, producers, disposers, and transporters of hazardous materials and wastes to clearly identify the materials they store, use, produce, dispose, or transport, and to notify the appropriate City, County, State, and federal agencies in the event of a violation.
Policy S-9.8 Hazardous Waste Collection. Conduct frequent and convenient household hazardous waste collection events.
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Final Initial Study – Mitigated Negative Declaration 91 Policy S-9.9 Water Supply and Air Protection. Work with public agencies and private organizations to prevent the introduction and spread of hazardous materials in the air and water supply.
With adherence to local, state, and federal regulations applicable to the use and transport of hazardous materials, as well as the 2030 General Plan goal and policies described above, projects implemented under the 2021-2029 Housing Element would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Schools are currently in place and operational throughout the city, including within 0.25 mile of some of the Opportunity Areas. Residential uses could involve use and transport of very small quantities of hazardous materials in the form of fertilizer or household cleaning products and would therefore not emit or handle hazardous materials in such a way that it would impact those outside the home or property. However, demolition or construction activities related to the development of residential structures could result in hazardous emissions or the handling of hazardous materials within 0.25 mile of an existing or proposed school. Policy S-9.6 of the 2030 General Plan governs the siting of sensitive uses, including residences, within Simi Valley (City of Simi Valley 2021).
Goal S-9 Hazardous Materials. Residents, visitors, property, and the natural environment in Simi Valley are protected by the safe and regulated use, storage, and/or transport of hazardous materials.
Policy S-9.6 Siting of Sensitive Uses. Develop and implement strict land use controls, performance standards, and structure design standards for uses that generate, use, or store hazardous materials, including development setbacks from sensitive uses such as residential homes, schools, hospitals, daycare and eldercare facilities, high density population facilities (such as movie theaters, auditoriums, museums), and other sensitive uses.
During the permitting process for each rezone site in the Opportunity Areas, project-specific environmental assessments would determine if there were potential for hazardous materials impacts to occur within 0.25 mile of an existing school. With adherence to local, state, and federal regulations; 2030 General Plan goals and policies applicable to the use and transport of hazardous materials and siting of sensitive uses; and the findings of project-specific environmental review (when applicable), projects implemented under the 2021-2029 Housing Element would not emit hazardous emissions or handle hazardous or acutely hazardous substances or waste within 0.25 mile of an existing or proposed school. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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92 d. Would the project be located on a site that is included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The Opportunity Areas may be near hazardous land uses, including dry cleaner commercial uses, light industrial uses, and gas stations. In addition to 2030 General Plan policies described below, federal, state, and local regulations require remediation and clean-up of leaking underground storage tanks, voluntary cleanup sites, and sites with small-quantity generators of hazardous waste before development can occur.
Goal S-9 Hazardous Materials. Residents, visitors, property, and the natural environment in Simi Valley are protected by the safe and regulated use, storage, and/or transport of hazardous materials.
Policy S-9.5 Known Areas of Contamination. Require proponents of projects in known areas of contamination from oil operations or other uses to perform comprehensive soil and groundwater contamination assessments, in accordance with applicable standards. If contamination exceeds regulatory action levels, require the proponent to undertake remediation procedures prior to grading and development through a cleanup program under the supervision of the Ventura County Environmental Health Division, Department of Toxic Substances Control, or Regional Water Quality Control Board (depending upon the nature of any identified contamination).
Policy S-9.7 Phase 1 Site Assessment. Require Phase 1 site assessments for new development proposed on land that may be contaminated with hazardous materials or waste, including commercial shopping centers where residential development is allowed.
The potential for site contamination to be present can be preliminarily ascertained by a search of online hazardous materials databases such as EnviroStor.8 In addition to comprehensive soil and groundwater contamination assessments and a Phase 1 site assessment, where appropriate, project proponents would be required to undertake remediation procedures prior to grading and development if site contamination exceeds regulatory action levels. With adherence to Policy S-9.5 and Policy S-9.7, the SVMC, and associated federal and state regulations governing the location of residential uses, impacts from implementation of the 2021-2029 Housing Element and General Plan update would be less than significant.
LESS THAN SIGNIFICANT IMPACT
8 https://www.envirostor.dtsc.ca.gov/public/
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Final Initial Study – Mitigated Negative Declaration 93 e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The nearest airports are the Santa Paula Airport, approximately 17 miles northwest; Van Nuys Airport, approximately 17 miles southeast; and Camarillo Airport, approximately 18 miles southwest of Simi Valley. Los Angeles International Airport is approximately 30 miles southeast of the city. The city is outside of the airport influence area for any of these facilities. Therefore, development facilitated by the 2021-2029 Housing Element would not result in a safety hazard or excessive noise for people residing or working in the project area . There would be no impact.
NO IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Implementation of the 2021-2029 Housing Element Update could impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. For example, construction activities associated with residential development could impact evacuation protocols in such plans depending on the duration and intensity of construction. The Safety and Noise Element Update of the 2030 General Plan directs the City to accommodate safety needs when planning and approving land uses and development in Simi Valley. This would include continued interjurisdictional coordination in response to emergencies. The General Plan Update goal and policies that would ensure adequate emergency response, including evacuation, are as follows:
Goal S-1 Emergency Response. Effective emergency preparedness and rapid response to natural or human-induced disasters are provided that minimize the loss of life, damage to property, and disruptions in the delivery of vital public and private services during and following disaster.
Policy S-1.1 Multi-Hazard Mitigation Plan and NIMS Plan. Implement the strategies in the City’s Multi-Hazard Mitigation Plan and National Incident Management System (NIMS) Plan to prevent the replication of pre-disaster conditions.
Policy S-1.2 NIMS Compliance. Maintain compliance with the Federal Emergency Management Agency NIMS, which is a template for the management of incidents to reduce the loss of life and property and harm to the environment.
Policy S-1.5 Data and Information Tracking. Maintain an up-to-date Geographic Information System (GIS) database that tracks new development and structures in hazard areas to enhance the City’s capability to assess and respond to emergency incidents.
Policy S-1.6 Evacuation Planning. Coordinate evacuation planning, including evacuation routes, among emergency responders including the Ventura County Fire Protection District, Sheriff’s Department, the California Highway Patrol, and law enforcement agencies in other local jurisdictions.
Policy S-1.7 Community Information and Education. Provide community awareness information and education about potential health, natural, and human-caused hazards in Simi Valley and how to responsibly prepare for or mitigate them.
Ensure all materials are available in Spanish and other languages as requested by community members.
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94 Policy S-1.8 Identify Isolated Seniors. Identify isolated seniors who may need assistance in natural disasters such as fires, earthquakes, or floods.
Goal S-3 Public Awareness. The community is well informed regarding appropriate disaster preparation strategies and response protocols for actions before, during, and after catastrophic events.
Policy S-3.1 Educational Outreach. Sponsor and support education programs to increase awareness regarding disaster preparedness protocols and procedures and disaster risk reduction strategies to all segments of the community, including local officials, residents, businesses, property owners, and others who have interests in the City. Ensure all materials and training are available in Spanish and distributed online, in public facilities, and through public service announcements.
Goal S-7 Fire Protection. People and property in Simi Valley are protected from urban and wildfires.
Policy S-7.4 Emergency Facilities. Require new development and subdivisions to include appropriate emergency facilities and infrastructure to assist and support wildfire suppression.
Policy S-7.5 Emergency Evacuation Routes. Require new development in wildland/urban interface areas to have adequate access to existing evacuation routes.
Policy S-7.12 Emergency Evacuation Information. Develop and disseminate broadly public information regarding evacuation routes, fire safety, and low risk fire safety areas and/or emergency shelters.
Through the Emergency Services Program, the City can plan, respond, and coordinate the recovery from natural and man-made disasters. Similarly, the City of Simi Valley Multi-Hazard Mitigation Plan provides guidance for managing emergency situations associated with natural and man-made disasters. As part of the permitting process, road closures and other aspects of construction would be coordinated with the Simi Valley Fire Department, which would ensure development projects conform with the 2030 General Plan and General Plan Update’s goals and policies, emergency plans, and other resources related to evacuation and emergency response. Therefore, development facilitated by implementation of the 2021-2029 Housing Element would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 95 g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
As discussed in full in Section 20, Wildfire, implementation of the 2021-2029 Housing Element Update would not significantly increase risks related to wildfires. The Opportunity Areas described in the 2021-2029 Housing Element are primarily infill development, located on previously developed land. Even in areas near the perimeter of the community that may be in or near the wildland-urban interface, the 2021-2029 Housing Element would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. During the permitting process for each rezone site in the Opportunity Areas, project-specific environmental assessments would determine if the project would expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. For these reasons, the 2021-2029 Housing Element’s potential to expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 97 10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality? □ □ ■ □
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ ■ □
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
(i) Result in substantial erosion or
siltation on- or off-site; □ □ ■ □
(ii) Substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or off-site; □ □ ■ □
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or □ □ ■ □
(iv) Impede or redirect flood flows? □ □ ■ □
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ ■ □
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98 Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan? □ □ ■ □
Environmental Setting
Simi Valley is in the Simi Valley Groundwater Basin of the Calleguas Creek Watershed. The City imports water from its water purveyors, the Ventura County Waterworks District No. 8 and Golden State Water Company (City of Simi Valley 2020). These water companies purchase water from the Metropolitan Water District (MWD), which receives its supply from the State Water Project. The city’s storm flows and post-storm flows are carried primarily through the network of arroyos and creeks within Simi Valley, of which the Arroyo Simi is the major drainage course. Surface water quality is affected by point and nonpoint sources of discharge, such as sediment, trash, and debris.
Most of the surface waters in the Calleguas Creek Watershed are considered as impaired due to toxic pollutants, nitrogen, sediments, and algae. Overall, the Calleguas Creek Watershed is considered highly impaired; this includes the entire watershed from Simi Valley to the Pacific Ocean and Simi Valley comprises about one-third (90 square miles) of the total watershed. Cited pollutants are typical of downstream conditions (stagnant) and agricultural uses. Similarly, the groundwater quality of the Simi Valley Basin is considered unsuitable for many municipal uses due to high levels of total dissolved solids within the water.
The Ventura County Watershed Protection District (VCWPD) provides administrative services for all flood control zones throughout Ventura County, but the City of Simi Valley administers all flood zones within the city limits. In 1991, the Federal Emergency Management Agency (FEMA) mapped most of the city within the 100-year floodplain directly adjacent to the Arroyo Simi, with a one percent chance of flooding in any given year. In addition to flood hazards, the city could experience seismically induced inundation if the Bard Reservoir, Sycamore Canyon, Sinaloa Lake, or Runkle Canyon Dams were to fail, or inundation from other failure mechanisms such as catastrophic storm events and system component failure. However, each dam is a State-sized dam, and is therefore subject to regulations and annual inspections to ensure safety. State law now requires all State- regulated dam owners to update their inundation maps and emergency action plans. Should any dam fail, the city’s core and areas adjacent to Arroyo Simi would be most likely to experience inundation.
Groundwater is concentrated into basins that are the natural hydrogeological unit for delineating and describing groundwater. An aquifer is a subsurface area where water collects, concentrates, and can be extracted from the basin. Multiple aquifers may be within each basin. The Simi Valley Groundwater Basin (SV Basin) underlies Simi Valley and the 2030 General Plan EIR reported that in 2005, the SV Basin was 95 percent full. Simi Valley’s groundwater supply is considered impaired due to the presence of high levels of total dissolved solids and high chloride and nitrate concentrations, largely due to urban development and past agricultural activities (City of Simi Valley 2012) 750
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Final Initial Study – Mitigated Negative Declaration 99 Impact Analysis
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Simi Valley is under the jurisdiction of the Los Angeles Regional Water Quality Control Board (RWQCB), which is responsible for the preparation and implementation of the water quality control plan for the region. Chapter 12 of the SVMC incorporates the Ventura County Countywide Stormwater Quality Management Program's Stormwater Pollution Control Guidelines for Construction Sites, which requires owners or developers to implement stormwater pollution control requirements for construction activities. Provisions of the federal and State Clean Water Act require compliance with the National Pollutant Discharge Elimination System (NPDES) storm water permit for projects disturbing more than one acre during construction. For sites under one acre, the City requires a stormwater pollution control plan. Operators of a construction site would be responsible for preparing and implementing a stormwater pollution prevention plan that outlines project specific BMPs to control erosion, sediment release, and otherwise reduce the potential for discharge of pollutants in stormwater. Post-construction BMPs are also required by the NPDES.
Typical BMPs include covering stockpiled soils, installation of silt fences and erosion control blankets, and proper handling and disposal of wastes. The City also requires stormwater detention basins for all subdivisions and when conditions of project approval require dedication to the VCWPD (SVMC Section 9-64.040). The size of the detention basin will depend upon the size of the development and may be based on the hydrograph flood routing method. Additional detention may be required by the City Engineer to reduce the effects of runoff on downstream properties.
Compliance with these regulatory requirements would minimize impacts to water quality during the construction of future projects under the 2021-2029 Housing Element Update.
The 2030 General Plan provides polices that guide water pollution prevention, as follows:
Policy IU-3.12 Federal and County Regulations. Continue to implement the latest requirements of the National Pollutant Discharge and Elimination System (NPDES) and Ventura County Air Pollution Control District (APCD) regulations, including the use of Best Management Practices by businesses in the City.
Policy IU-4.1 Storm Drain Improvement. Upgrade existing stormwater collection and treatment facilities as necessary.
Policy IU-4.2 Adequate Drainage Facilities and Master Plan. Ensure that all new drainage facilities are adequately sized and constructed to accommodate stormwater runoff and prevent flooding. Update the City’s Master Plan of Drainage on a ten- year cycle, as practical.
Policy IU-4.3 Drainage Plans. Require developers to prepare project-specific drainage plans for proposed developments that meet integrated water quality, flow reduction, and resources management criteria, as technically feasible; define needed drainage treatment and runoff controls (BMPs) per City standards; and comply with the City’s most current National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and Master Plan of Drainage.
Policy IU-4.4 Post-Construction Runoff. Impose requirements to control post-construction stormwater runoff discharge rates and velocities to prevent or reduce downstream erosion and protect stream habitat and private property. The 751
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requirements should conform to the standards and practices outlined in the City’s most current NPDES MS4 permit and the Master Plan of Drainage.
Policy IU-4.5 Permeable Surfaces. Limit the percentage of impervious surfaces (such as asphalt) for large new or renovated development consistent with the Low Impact Development requirements for new and redevelopment projects in the City’s most current NPDES MS4 Permit.
Policy IU-4.6 Conservation of Open Space Areas. Conserve undeveloped open space areas and drainage channels as practical for the purpose of protecting water resources and water quality in the City’s watersheds.
Policy IU-4.7 Protection of Water Bodies. Require new development to protect the quality of water bodies and natural drainage systems through site design, stormwater treatment, and stormwater best management practices (BMPs) consistent with the City’s most current NPDES MS4 Permit.
Policy IU-4.8 Public Information and Participation Programs. Implement watershed awareness, stormwater pollution prevention, and water quality educational programs for City staff, community groups, schools, the public, and other appropriate groups.
Construction of reasonably foreseeable development under the 2021-2029 Housing Element could impact surface or ground water quality due to erosion resulting from exposed soils and the generation of water pollutants, including trash, construction materials, and equipment fluids.
However, compliance with the regulations described above would reduce impacts resulting from such reasonably foreseeable development to a less than significant level. Furthermore, the Housing Element Update would not introduce any features that would preclude implementation of or alter these policies and procedures and would therefore not result in development that would create impacts related to water quality. Therefore, implementation of the 2021-2029 Housing Element would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Construction activities would primarily occur as part of infill/redevelopment associated with implementation of the 2021-2029 Housing Element update. The Planning Area almost entirely overlies the SV Basin. Surface depths to water table vary from 5 to 25 feet (City of Simi Valley 2020).
Percolation of direct precipitation, inflow of minor streams, minor subsurface inflow from surrounding semi-permeable formations, and irrigation return provide recharge to the basin. Pile driving, dewatering, and other construction activities that would encounter groundwater could occur. While the insertion of support and foundation structures in groundwater-bearing soils may reduce the groundwater storage capacity of these soils, the displaced volume would not be substantial relative to the volume of the Basin. Likewise, while dewatering would remove groundwater, the volume of water removed would not likely be substantial relative to groundwater pumping for water supply. Simi Valley’s groundwater supply has been identified as impaired due to the presence of high levels of total dissolved solids and high chloride and nitrate concentrations, largely due to urban development and past agricultural activities. Accordingly, most groundwater utilized in the City of Simi Valley goes towards irrigation uses. Water needed during construction for 752
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Final Initial Study – Mitigated Negative Declaration 101 cleaning, dust control, and other uses would be nominal. Thus, construction activities would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge.
Residential projects implemented under the 2021-2029 Housing Element would utilize water from District No. 8 or the Golden State Water Company, both of which receive potable water from the MWD. 96 percent of MWD’s supply is imported from northern California via the State Water Project and the Colorado River Project (MWD 2020). The remaining 4 percent is from groundwater sources.
Future development would rely on imported water sources, with little to no use of groundwater resources. As such, there would be no substantial increased demand on the city’s groundwater supply as a result of development under the 2021-2029 Housing Element. Thus, implementation of the 2021-2029 Housing Element would not substantially deplete groundwater supplies and the impact is considered less than significant.
Intensification of development and addition of impervious surfaces as a result of implementation of the 2021-2029 Housing Element would not interfere with groundwater recharge. Recharge to the Basin is derived from percolation of rainfall and from irrigation runoff. Implementation of the 2021- 2029 Housing Element would not interfere substantially with percolation flow because the areas targeted for new development represent a small percentage of the total land area of Simi Valley and would be largely infill projects in already developed areas.
Large amounts of open space that help recharge the SV Basin would remain undeveloped with build-out of the 2021-2029 Housing Element. Thus, implementation of the 2021-2029 Housing Element would not result in substantial increases in impermeable surfaces overlying the Basin. In addition to General Plan Update Policies IU-4.5, and IU-4.6 shown above, the following polices would help to reduce any potential impacts on groundwater recharge associated with future development.
Policy NR-5.1 Permeable Surfaces. Limit the percentage of impermeable surface (such as asphalt) for new or renovated public, institutional, residential, and commercial projects
Policy NR-5.5 Arroyo Simi. Restore and protect the Arroyo Simi as a natural resource that contributes to recharge and filtration capability for the watershed.
Policy S-8.6 New Development. Ensure that new development is properly located and designed to avoid flooding, and require upgrades and improvements of the existing storm drain system for on-site retention to handle the increased runoff generated from the development site.
Policy S-8.7 Preservation of Flood Plains. Require preservation of flood plains as open space, when practical, as the preferred alternative to development or channelization in project environmental impact reports
Therefore, the 2021-2029 Housing Element would not substantially affect groundwater recharge and the impact would be considered less than significant.
LESS THAN SIGNIFICANT IMPACT
c.(i) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
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c.(ii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Construction activities as part of infill/redevelopment associated with implementation of the 2021- 2029 Housing Element would largely occur in already developed areas, but could also involve stockpiling, grading, excavation, dredging, paving, and other earth-disturbing activities resulting in the alteration of existing drainage patterns where streams or other drainage areas exist. These types of activities would constitute a temporary alteration of drainage patterns. The 2030 General Plan includes policies designed to minimize stormwater and erosional impacts during construction, as follows:
Policy NR-5.2 Protect Open Space Areas and Water Resources. Conserve undeveloped open space areas and drainage channels for the purpose of protecting water resources in the City’s watershed. For new development and post-development runoff, control sources of pollutants and improve and maintain urban runoff water quality through stormwater protection measures consistent with the City’s National Pollution Discharge Elimination System (NPDES) Permit.
As described in Threshold a above, compliance with the SWRCB’s NPDES General Construction Activity Stormwater Permit and NPDES MS4 regulations would reduce the risk of short-term erosion resulting from drainage alterations during construction to less than significant.
Development under the 2021-2029 Housing Element would result in alterations to drainage, such as changes in ground surface permeability via paving and changes in topography by grading and excavation. Threshold a above discusses applicable regulations that would limit pollutant discharges from development carried out under the 2021-2029 Housing Element. NPDES permit requirements would be imposed on applicable projects to limit pollutant discharges. All development implemented under the 2021-2029 Housing Element would be subject to the provisions of the City’s NPDES MS4 Permit. These include provisions requiring implementation of appropriate BMPs, including a range of methods to minimize off-site erosion, including, but not limited to, hydrodynamic devices, swales/biofilters, basins, and various filters.
The 2030 General Plan policies listed above are designed to minimize post-construction erosional impacts and require implementation of BMPs, incorporation of stormwater detention facilities, design of drainage facilities to minimize adverse effects on water quality, and minimization of increase in impervious areas. Implementation of these policies would reduce the volume of sediment-laden runoff discharging from sites identified in the 2021-2029 Housing Element.
Therefore, compliance with the NPDES regulations discussed above, the CDFW regulations discussed in Thresholds c.iii and c.iv below, and implementation of the General Plan Update policies listed above would reduce the risk of erosion resulting from drainage alterations during the operation of new developments to less than significant.
LESS THAN SIGNIFICANT IMPACT
c.(iii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
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Final Initial Study – Mitigated Negative Declaration 103 c.(iv) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows? Most areas where land use changes or new development could occur under the 2021-2029 Housing Element would generally result in infill development or redevelopment. As such, implementation of the 2021-2029 Housing Element would not result in new development that would substantially alter drainage patterns because these areas are already developed with existing uses and impervious surfaces. However, development of land that may currently be vacant and covered with permeable surfaces, such as bare soil or vegetation, may occur, including in the Walnut Hills Opportunity Area and the Heyneman Lane Opportunity Area. Thus, if existing open space areas are developed, it would be expected that the natural drainage courses, particularly in hillside areas, would be altered.
Increased impervious surfaces could result in an increase of stormwater runoff in the city. This increased runoff could exceed the capacity of existing and planned infrastructure and cause downstream flooding impacts.
The 2030 General Plan policies identified in Thresholds c.i and c.ii above are designed to minimize stormwater runoff and would also apply to runoff-related flooding impacts. These policies include IU-3.12, IU-4.3, IU-4.4, IU-4.5, IU-4.6, IU-4.7, and NR-5.2 and they require preparation of a SUSMP, implementation of BMPs, incorporation of stormwater detention facilities, design of drainage facilities to minimize adverse effects on water quality, and minimization of increases in impervious areas. Implementation of these policies would also reduce the volume of runoff generated, and potential for flooding. If development proposes changes to drainages, this would occur in compliance with CDFW Streambed Alteration regulations in order to maintain drainage patterns.
The City of Simi Valley’s Drainage Guidelines require developments to detain the difference in runoff between the 10-year and 100-year storm events. Therefore, implementation of General Plan policies and compliance with SVMC and NPDES regulations, the preparation of a SUSMP, and compliance with drainage guidelines and CDFG regulations would reduce the risk of flooding resulting from drainage alterations to a less than significant level. Operation of development facilitated by the 2021-2029 Housing Element could degrade runoff water quality by contributing chemicals associated with household, commercial, transportation, and landscape uses. However, activities during operation of future development would not provide additional sources of polluted runoff apart from those described in Threshold a above. This impact would be less than significant
LESS THAN SIGNIFICANT IMPACT
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
The 2030 General Plan EIR states that most areas in Simi Valley that are within the 100-year floodplain are within and directly adjacent to the Arroyo Simi and its tributaries, most of which is open space or low-density residential or commercial areas. Implementation of residential projects under the 2021-2019 Housing Element would occur mostly as infill development in currently developed areas, except for the Walnut Hills Opportunity Area and the Heyneman Lane Opportunity Area. The Community Safety chapter of the General Plan Update has established a goal to protect human life and public and private property from the risks of flooding, including the following:
Policy S-8.1 Floodplain Requirements. Regulate new development and protect existing development within flood prone areas in accordance with City, state, and federal building codes. Follow federal requirements to reduce damage and loss 755
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due to flooding and to maintain the City’s eligibility under the National Flood Insurance Program (NFIP).
Policy S-8.2 Flood Insurance. Request assistance from state and federal governments, as necessary, to enable the City to maintain compliance with National Flood Insurance Program (NFIP) requirements.
Policy S-8.3 Flood Prevention Design. Require that new development incorporates sufficient measures to mitigate flood hazards, including the design of on-site drainage systems linking with Citywide storm drainage, gradation of the site so that runoff does not impact adjacent properties or structures on the site, and elevation of any structures above the localized flooding elevation Policy S-8.4 Critical Facilities. Prohibit the location of critical facilities within an area subject to significant inundation during any flood event unless the facility can be adequately protected from inundation, and provide for updating of critical facilities within these areas when practical
Policy S-8.6 New Development. Ensure that new development is properly located and designed to avoid flooding and require upgrades and improvements of the existing storm drain system for on-site retention to handle the increased runoff generated from the development site.
Policy S-8.7 Preservation of Flood Plains. Require preservation of flood plains as open space, when practical, as the preferred alternative to development or channelization in project environmental impact reports
Policy S-8.8 Dam Failure Warning Plan. Maintain the City’s Dam Failure Response Plan to alert affected residents, businesses, and government agencies located in potential hazard areas.
The SVMC does not allow new construction within the floodplain, as determined by permit review by the Director of Public Works who acts as the Floodplain Administrator for the City. In addition, compliance with the Flood Mitigation Strategies set forth in the Simi Valley MHMP would reduce any potential impacts for projects proposed within the Opportunity Areas that are not within the 100-year flood zone. Development facilitated by the 2021-2029 Housing Element would therefore not create a significant risk of releasing pollutants due to project inundation, and this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Potential water quality and groundwater impacts associated with the 2021-2029 Housing Element are discussed above under Thresholds a and b, and have been determined to be less than significant. The 2021-2029 Housing Element would therefore not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
Furthermore, future projects implemented under the 2021-2029 Housing Element would be required to comply with the existing regulations discussed under Impacts a. and b. of this section, including during construction and operation, and would not otherwise substantially degrade water quality. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 105 11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect? □ □ □ ■
Environmental Setting
Simi Valley encompasses approximately 42 square miles, and the City’s Sphere of Influence (SOI) is approximately 48.5 square miles. The most substantial land uses in the City’s SOI include the Simi Valley Landfill and Recycling Center located northwest of the Simi Valley and Bard Reservoir to the southwest. The city has two general areas of development: the historic valley floor, and the hillside, canyon, and specific plan areas. The City is built out in the valley floor, with remaining undeveloped land in the hillside areas. The hillside open space areas surrounding the community are expected to remain substantially unchanged as development in these areas is regulated through the City’s Hillside Performance Standards, which are designed to preserve the natural resources surrounding the community. Although residential development accounts for approximately 70 percent of the City’s total area, parks, public uses, and semi-public uses account for more than 20 percent of the area. Single-family residential land use accounts for greater than 7,250 acres, whereas multi-family land use accounts for only 352 acres, approximately 4.8 percent of the land area of single-family houses. Furthermore, the City contains only one, six-acre mixed-use project.
SR 118 bisects the northern third of the city and development occurs on both sides of the highway, including residential and commercial uses.
Impact Analysis
a. Would the project physically divide an established community? The 2021-2029 Housing Element would facilitate the development of new housing on rezoned sites in the Opportunity Areas that would largely constitute infill development when implemented. These would not involve installation of bridges, roadways, or other facilities that would physically divide an established community. Development in the Walnut Hills and Heyneman Lane Opportunity Areas would likely necessitate internal streets to allow for circulation, but these would be part of the development and would not divide existing communities. Consequently, 2021-2029 Housing Element would have no impact associated with the physical division of an established community.
NO IMPACT
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b. Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Upon its adoption by the City, the 2021-2029 Housing Element would serve as a comprehensive statement of the City’s housing policies and as a specific guide for program actions to be taken in support of those policies. The 2021-2029 Housing Element is a policy document that largely encourages housing opportunities in infill areas throughout the city. The 2030 General Plan includes goals, policies, and programs to avoid or mitigate environmental impacts, as discussed throughout this IS-MND. Implementation of the 2021-2029 Housing Element would not, therefore, conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. There would be no impact.
NO IMPACT
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Mineral Resources
Final Initial Study – Mitigated Negative Declaration 107 12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of
the state? □ □ ■ □
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan, or other land
use plan? □ □ ■ □
Existing Conditions
The Surface Mining and Reclamation Act of 1975 designated mineral resource areas into four Mineral Resource Zones (MRZ) throughout the State. The MRZ are described as follows (City of Simi Valley 2012):
▪ MRZ-1: Adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. This zone shall be applied where well-developed lines of reasoning, based upon economic geologic principles and adequate data, demonstrate that the likelihood for occurrence of significant mineral deposits is nil or slight. ▪ MRZ-2: Adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists. This zone shall be applied to known mineral deposits or where well-developed lines of reasoning, based upon economic geologic principles and adequate data, demonstrate that the likelihood for occurrence of significant mineral deposits is high.
▪ MRZ-3: Containing deposits whose significance cannot be evaluated from available data. ▪ MRZ-4: Available information is inadequate for assignment to any other MRZ zone.
Simi Valley has areas designated MRZ-1, MRZ-2, and MRZ-3, including MRZ-2 areas designated by the CDOC as an area of regional or statewide significance. Although there are two MRZ-2 areas within the Planning Area, there is significantly less within city limits, as the MRZs are in an unincorporated area south of the city, and in an open space area near the northern terminus of Black Canyon Road in the eastern portion of the city. The city’s core is designated as MRZ-1, with most of the remaining area in the city and Planning Area designated as MRZ-3 and MRZ-3a. Areas designated as MRZ-3a have been judged to have higher potential than other deposits classified as MRZ-3 (City of Simi Valley 2012).
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Impact Analysis
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? Surface Mining Resources
As discussed in the City’s 2030 General Plan EIR, there is a substantial amount of land designated as MRZ-2 within its Area of Interest, indicating significant mineral deposits either exist or are highly likely to occur. Most of this land is in the northern foothills and south-central/ southeastern portion of the Planning Area. Only a fraction of this MRZ-2 land is within the city boundary and CURB. As depicted in Figure 4.11-2, Aggregate Resource Areas, in the City’s 2030 General Plan EIR, MRZ-2 land is located within the CURB at the southern terminus of Sequoia Avenue, and within the hills behind Gonzales Road west of Black Canyon Road (City of Simi Valley 2012). In addition to these areas being designated as Open Space under the 2030 General Plan (City of Simi Valley 2012), there are no Opportunity Areas identified for rezoning within MRZ-2 land (see Figure 2). Furthermore, 2030 General Plan Policies LU-1.3, LU-3.2, LU-4.6, and NR-1.1, described below, ensure that MRZ-2 areas are not developed and that areas with mineral resources are preserved (City of Simi Valley 2012).
Policy LU-1.2 Development Location. Limit development to lands within the Simi Valley City Urban Restriction Boundary (CURB), as shown in Figure LU-1, thereby protecting existing agriculture, open space, viewsheds, wildlife, and watersheds surrounding the City from development impacts and limiting urban sprawl.
Policy LU-1.3 Development Priorities. Prioritize future growth as infill and redevelopment of existing developed areas re-using and, where appropriate, intensifying development of vacant and underutilized properties within the CURB. Allow for growth on the immediate periphery of existing development in limited designated areas, where this is guided by standards to assure seamless integration and connectivity with adjoining areas and open spaces. The Growth Diagram below illustrates the locations in which new development will be permitted.
Policy LU-3.2 Citywide Development Pattern. Provide for an overall pattern of land uses that promotes efficient development; minimizes the impact of traffic congestion; reduces transportation distances, energy consumption, air pollution, and greenhouse gas emissions; ensures compatibility between uses; protects the natural hillsides, major watercourses, and trees; enhances community livability and public health; and sustains economic vitality.
Policy LU-4.6 Hillside Development Density. Maintain land outside the valley floor having a slope of over 20 percent as permanent open space. Commercial and industrial development shall be limited to slopes of 10 percent or less, unless otherwise allowed under the Hillside Performance Standard of the Simi Valley Municipal Code approved by a specific plan that justifies and provides appropriate design measures for the development of these areas, in which case development shall be limited to slopes of 20 percent or less.
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Mineral Resources
Final Initial Study – Mitigated Negative Declaration 109 Policy NR-1.1 Open Space Preservation and Buffer Zone. Protect, conserve, and maintain the open space, hillside, and canyon areas that provide a buffer zone around the City’s urban form, serve as designated habitat for sensitive species, and provide recreation n opportunities for residents and visitors.
Due to MRZ-2 land within the Planning Area being in areas where development is not proposed under the 2021-2029 Housing Element Update and is not permissible, either due to geographic location or City policies as laid out within the 2030 General Plan, the Housing Element Update would not result in the loss of important mineral resources. Therefore, impacts would be less than significant.
Oil and Gas Wells
As discussed in the City’s 2030 General Plan EIR, both historic and active oil and gas wells are largely located within undeveloped open space in the northern portion of the City’s Planning Area. As depicted in Figure 4.11-1, Mining and Oil Permits, in the City’s 2030 General Plan EIR, this area is largely covered by oil permits, and therefore allows for oil extraction. In addition to oil permitted land located outside of the City Boundary, there are areas located within the City Boundary that allow for oil extraction. These are in the northern portion of the city, as well as in the west portion, north of Arroyo Simi.
The Walnut Hills Area Opportunity Area is on land containing an oil permit. The California Department of Conservation Geologic Energy Management Division’s Well Finder indicates that although the land once had active oil operations, there are no operational oil or gas well located on the property, as they have been plugged (CDOC 2021). Furthermore, should this location be built- out, this would represent a small portion of land within the Oil Permit area relative to the entire Planning Area. No other Opportunity Area is on land designated with an oil permit. Therefore, foreseeable build-out under the 2021-2029 Housing Element would result in less than significant impacts related to oil and gas resources. Impacts to mineral resources from development facilitated by the 2021-2029 Housing Element would be less than significant.
LESS THAN SIGNIFICANT IMPACT-
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Noise
Final Initial Study – Mitigated Negative Declaration 111 13 Noise
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies? □ □ ■ □
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or
working in the project area to excessive
noise levels? □ □ □ ■
Environmental Setting
Noise Overview
The unit of measurement used to describe a noise level is the decibel (dB). However, the human ear is not equally sensitive to all frequencies within the sound spectrum. Therefore, a method called “A weighting” is used to adjust actual sound pressure levels so that they are consistent with the human hearing response, which is most sensitive to frequencies around 4,000 Hertz (Hz) and less sensitive to frequencies around and below 100 Hz, thus filtering out noise frequencies that are not audible to the human ear. A weighting approximates the frequency response of the average young ear when listening to most ordinary everyday sounds. When people make relative judgments of the loudness or annoyance of a sound, their judgments correlate well with the A-weighted levels of those sounds.
Therefore, the A-weighted noise scale is used for measurements and standards involving the human perception of noise. In this analysis, all noise levels are A -weighted, and “dBA” is understood to identify the A-weighted decibel.
Decibels are measured on a logarithmic scale that quantifies sound intensity in a manner similar to the Richter scale used for earthqua ke magnitudes. A doubling of the energy of a noise source, such as a doubling of traffic volume, would increase the noise level by 3 dB; similarly, dividing the energy in half would result in a decrease of 3 dB (Crocker 2007). 763
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Human perception of noise has no simple correlation with sound energy: the perception of sound is not linear in terms of dBA or in terms of sound energy. Two sources do not “sound twice as loud” as one source. It is widely accepted that the average healthy ear can barely perceive an i ncrease (or decrease) of up to 3 dBA in noise levels (i.e., twice [or half] the sound energy); that an increase (or decrease) of 5 dBA (8 times [or one eighth] the sound energy) is readily perceptible; and that an increase (or decrease) of 10 dBA (10.5 times [or approximately one tenth] the sound energy) sounds twice (or half) as loud (Crocker 2007).
DESCRIPTORS
The impact of noise is not a function of loudness alone. The time of day when noise occurs, and the duration of the noise are also important. In addition, most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors has been developed. The noise descriptors used for this analysis are the one -hour equivalent noise level (L eq) and the comm unity noise equivalent level (CNEL).
▪ The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period. Typically, Leq is equivalent to a one-hour period, even when measured for shorter durations as the noise level of a 10- to 30-minute period would be the same as the hour if the noise source is relatively steady. Lmax is the highest Root Mean Squared (RMS) sound pressure level within the sampling period, and Lmin is the lowest RMS sound pressure level within the measuring period (Crocker 2007). ▪ The CNEL is a 24-hour equivalent sound level with an additional 5 dBA penalty to noise occurring during evening hours, between 7:00 p.m. and 10:00 p.m., and an additional 10 dBA penalty to noise occurring during the night, between 10:00 p.m. and 7:00 a.m., to account for the added sensitivity of humans to noise during these hours (Caltrans 2013). Quiet suburban areas typically have a CNEL in the range of 40 to 50 dBA, while areas near arterial streets are in the 50 to 70+ CNEL range.
PROPAGATION
Sound changes in both level and frequency spectrum as it travels from the source to the receiver. The most obvious change is the decrease in sound level as the distance from the source increases. The way sound reduces with distance depends on factors such as the type of source (e.g., point or line), the path the sound will travel, site conditions, and obstru ctions. Sound levels from a point source (e.g., construction, industrial machinery, ventilation units) typically attenuate, or drop off, at a rate of 6 dBA per doubling of distance. Sound from a line source (e.g., roadway, pipeline, railroad) typically attenuates at about 3 dBA per doubling of distance (Caltrans 2013).
Vibration Overview
Typical outdoor sources of perceptible groundborne vibration are construction equipment, steel- wheeled trains, and traffic on rough roads. Groundborne vibration of concern in environmental analysis consists of the oscillatory waves that move from a source through the ground to adjacent structures. While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration may also damage infrastructure when foundations or utilities, such as sewer and water pipes, physically connect the structure and the vibration source. The primary concern from vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.
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Final Initial Study – Mitigated Negative Declaration 113 Vibration Descriptors
Vibration amplitudes are usually expressed in peak particle velocity (PPV) or RMS vibration velocity.
The PPV and RMS velocity are normally described in inches per second (in./sec.). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that are experienced by buildings (Caltrans 2020).
Response to Vibration
Vibration associated with construction of the project has the potential to be an annoyance to nearby land uses. Caltrans has developed limits for the assessment of vibrations from transportation and construction sources. The Caltrans vibration limits are reflective of standard practice for analyzing vibration impacts on structures. The Caltrans Transportation and Construction Vibration Guidance Manual (Caltrans 2020) identifies impact criteria for buildings and criteria for human annoyance from transient and continuous/frequent sources: Table 6 presents the impact criteria for buildings, and Table 7 presents the criteria for humans.
Table 6 Vibration Damage Potential
Building Type Maximum PPV (in./sec.)
Historic sites and other critical locations 0.1
Historic and some old buildings 0.5
Older residential structures 0.5
New residential structures 1.0
Modern industrial/commercial buildings 2.0
PPV = peak particle velocity; in./sec. = inches per second Source: Caltrans 2020
Table 7 Vibration Annoyance Potential
Maximum PPV (in./sec.)
Human Response Transient Sources
Continuous/Frequent
Intermittent Sources
Severe/disturbing 2.00 0.70
Strongly perceptible 0.90 0.10
Distinctly perceptible 0.240 0.035
Barely perceptible 0.035 0.012
Note: Transient sources create a single isolated vibration event, such as blasting or drop balls (i.e., a loose steel ball that is dropped onto structures or rock to reduce them to a manageable size). Continuous/frequent intermittent sources include impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory compaction equipment.
PPV = peak particle velocity; in./sec. = inches per second Source: Caltrans 2020
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Vibration Propagation
Vibration energy spreads out as it travels through the ground, causing the vibration level to diminish with distance away from the source. High-frequency vibrations diminish much more rapidly than low frequencies, so low frequencies tend to dominate the spectrum at large distances from the source. Variability in the soil strata can also cause diffractions or channeling effects that affect the propagation of vibration over long distances (Caltrans 2020). When a building is exposed to vibration, a ground-to-foundation coupling loss (the loss that occurs when energy is transferred from one medium to another) will usually reduce the overall vibration level. However, under rare circumstances, the ground-to-foundation coupling may amplify the vibration level due to structural resonances of the floors and walls.
Noise and Vibration Sensitive Receptors
Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. Generally, a sensitive receiver is identified as a location where human populations (especially children, the elderly, and sick persons) are present, and where there is a reasonable expectation of continuous human exposure to noise. Noise-sensitive land uses generally include residences, hospitals, schools, churches, libraries, and parks.
Vibration-sensitive receivers, which are similar to noise-sensitive receivers, include residences and institutional uses, such as hospitals, schools, and churches. However, vibration-sensitive receivers also include buildings where vibrations may interfere with vibration-sensitive equipment that is affected by vibration levels that may be well below those associated with human annoyance (e.g., recording studies or medical facilities with sensitive equipment).
Impact Analysis
a. Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element would not, in and of itself, result in impacts from a temporary or permanent increase in ambient noise levels in the vicinity. The 2021-2029 Housing Element would, however, facilitate the development of new housing on rezoned sites in the Opportunity Areas that would largely constitute infill development when implemented. Future development projects in these Opportunity Areas would be subject to development plan review to determine potential concerns related to noise based on site-specific locations and development design. Development proposals for individual projects would be subject to adopted development guidelines, including standards that govern noise levels. Any impacts identified for an individual project would be addressed through the project approval process, including design review specific to any potential impacts for that project.
The 2030 General Plan EIR lists primary noise sources throughout the city, including roadways, highways, large trucks transporting materials to and from the city, and train noise, which is loudest near the Metrolink station (City of Simi Valley 2012).
The Safety and Noise Element of the City’s 2030 General Plan contains the following policies related to noise conditions in Simi Valley:
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Final Initial Study – Mitigated Negative Declaration 115 Policy N-1.1 Noise Standards. Require noise attenuation for all development where the projected exterior and interior noise levels exceed those shown in Table N-1 (Interior and Exterior Noise Standards [in the Safety and Noise Element), to the extent feasible.
Policy N-1.2 Noise between Adjacent Uses. Require that mixed-use and multi-family residential developments demonstrate that the design of the structure will adequately isolate noise between adjacent uses (orientation, window insulation, common wall separation, common floor/ceilings separation, etc.).
Policy N-1.3 Mixed-Use Development Standards. Require, whenever physically possible, new mixed-use developments to locate loading areas, parking lots, driveways, trash enclosures, mechanical equipment, and other noise sources away from the residential portion of the development, and apply physical construction standards (equipment, construction standards) to reduce noise between uses Policy N-1.4 Added Noise Restrictions. For development adjacent to or near the railroad tracks, apply additional restrictions of up to 10 percent more than that provided in the Noise Ordinance to reduce noise intrusions in residential districts.
Policy N-1.5 Noise Attenuation Measures. Ensure that all new development provides adequate sound insulation or other protection from existing and anticipated noise sources
Policy N-1.6 Sensitive Receptors. Incorporate ambient noise level considerations into land use decisions involving schools, hospitals, and similar noise-sensitive uses.
Policy N-2.1 State Motor Vehicle Noise Standards. Encourage the enforcement of state motor vehicle noise standards for cars, trucks, and motorcycles through coordination with the California Highway Patrol and Simi Valley Police Department.
Policy N-2.2 Roadway Noise Sensitivity Measures. Ensure the employment of noise attenuation measures in the design of roadway improvement projects consistent with funding capability. Support efforts by the California Department of Transportation and others to provide for acoustical protection of existing noise-sensitive land uses affected by these projects.
Policy N-2.3 Noise Attenuation along Major Arterials and Railroad Tracks. Require the use of walls and berms in the design of residential and other noise-sensitive land uses that are adjacent to the 118 Freeway, major arterials, and railroad tracks.
Policy N-2.4 Noise Studies for New Development. Require the preparation of noise studies, as deemed necessary by the Department of Environmental Services, for new development (especially residential projects) along the freeway corridor, major thoroughfares, and railroad tracks to ensure that adequate sound attenuation from these noise sources is provided.
Policy N-3.1 Protection from Stationary Noise Sources. Continue to enforce interior and exterior noise standards to ensure that sensitive noise receptors are not exposed to excessive noise levels from stationary noise sources, such as machinery, equipment, fans, and air conditioning equipment.
Policy N-3.2 Regulation of Sound-Amplifying Equipment. Continue to regulate the use of sound-amplifying equipment.
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Policy N-3.3 Enforcement of Hours of Construction Activity. Continue to enforce restrictions on hours of construction activity to minimize the impacts of noise and vibration from the use of trucks, heavy drilling equipment, and other heavy machinery to adjacent uses, particularly in residential areas.
Chapter 16 of the SVMC describes the noise ordinances related to operation and construction of development projects. Section 5-16.02(d) of the Municipal Code declares that the operation of engines, motors, and mechanical devices in and near residential districts between the hours of 11:00 p.m. and 7:00 a.m. on Friday or Saturday and between the hours of 10:00 p.m. and 7:00 a.m. on Sunday through Thursday, unless such device is enclosed within a sound-insulated structure so as to prevent noise and sounds from being plainly audible at a distance of 50 feet from such structure or within 10 feet of any residence, is a nuisance punishable by misdemeanor. Section 5-16.02(h) of the Municipal Code declares that the operation of any pile driver, steam shovel, pneumatic hammer, derrick, hoist, or other appliance that generates a loud or unusual noise between the hours of 7:00 PM and 7:00 AM is a nuisance punishable by misdemeanor. Additionally, Section 5-
16.02(i) of the Municipal Code declares that the erection, excavation, demolition, alteration, construction, or repair of any structure or building, other than between the hours of 7:00 AM and 7:00 PM, is a nuisance punishable by misdemeanor (City of Simi Valley 2012).
Development carried out under the 2021-2029 Housing Element would be subject to project-specific noise analysis to determine potential effects. Residential uses are not substantial generators of noise because noise from the structures themselves is self-contained, and residents are subject to City regulations that govern noise levels before 7:00 a.m. or after 11:00 p.m. Furthermore, residential land uses do not involve manufacturing, processing, or generation of large amounts of traffic which could produce substantial, temporary, or periodic increases in ambient noise.
Therefore, there impacts to the environment from a temporary or periodic increase in ambient noise levels would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Long-term operation of future housing development permitted under the 2021-2029 Housing Element would not result in any groundborne vibration or excessive groundborne noise, although construction activities may result in temporary groundborne vibration and groundborne noise levels. New development implemented under the 2021-2029 Housing Element would not exceed permitted noise levels because of existing regulations, which limit construction activities to the period from 7:00 a.m. to 7:00 p.m. Because it is a policy document, the 2021-2029 Housing Element would not, in and of itself, generate groundborne vibration or noise, but construction associated with development under the 2021-2029 Housing Element could do so if it involved pile driving or other substantial groundborne noise and vibration generating tools.
Future development projects would be subject to development plan review to determine potential concerns related to noise based on site-specific locations and development design. Development proposals for individual projects would be subject to adopted development guidelines, including standards that govern noise and vibration, as described above. Therefore, implementation of the 2021-2029 Housing Element would not result in generation of excessive groundborne vibration or groundborne noise levels and would have less than significant impacts. 768
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Final Initial Study – Mitigated Negative Declaration 117
LESS THAN SIGNIFICANT IMPACT
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
As stated in Section 9, Hazards and Hazardous Materials, there are no airports within 2.0 miles of Simi Valley and development implemented under the 2021-2029 Housing Element would therefore not expose people residing or working in those areas to excessive noise levels from airports or air traffic. There would be no impact.
NO IMPACT
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Final Initial Study – Mitigated Negative Declaration 119 14 Population and Housing
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Induce substantial unplanned population
growth in an area, either directly (e.g., by
proposing new homes and businesses) or
indirectly (e.g., through extension of
roads or other infrastructure)? □ □ ■ □
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ ■ □
Existing Conditions
Population
As discussed in the Project Characteristics section of this IS-MND, 2021 California Department of Finance Population and Housing Estimates indicate the population of Simi Valley was 124,468 as of January 1, 2021, an increase of less than 1 percent since 2010 (when the population was 124,237) and an increase of about 12 percent since 2000 (when the population was 111,339) (U.S. Census, 2011-2012; California Department of Finance [DOF] 2021). Despite relatively flat trends in population growth over the last 10 years, the SCAG 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction estimates that Simi Valley’s population will increase by 17,923 persons to 142,400 by 2040, approximately 15 percent since 2010 (SCAG 2016).
Housing Stock
As of 2018, Simi Valley’s housing stock totaled 43,469 dwelling units, with 34,921 single-family units comprising approximately 80 percent of that total; 7,787 multi-family homes comprising approximately 18 percent of that total; and 761 mobile homes comprising approximately two percent of that total. Most structures were built between 1960 to 1989. Based on the characteristics of the city’s housing stock, Simi Valley has a need for continued code enforcement, property maintenance, and housing rehabilitation programs to stem housing deterioration.
Households
A household is defined as a group of people who occupy a housing unit. A household differs from a dwelling unit because the number of dwelling units includes both occupied and vacant dwelling units. Not everyone lives in a household. Some persons live in group quarters, such as board and care facilities. Others are unhomed.
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The 2021-2029 Housing Element reports that the total number of households in Simi Valley increased by almost two percent between 2010 and 2018. Family households decreased by almost two percent during this time but continue to make up almost three-quarters of Simi Valley households. However, married families with children decreased by 14 percent, while married families without children increased by nine percent. “Other” families are family households (as defined above) but do not include a married couple. They could be siblings living together or single parents. This category of families in the city experienced a small decrease, with a decline of almost one percent since 2010.
The study area for population and housing includes only the population that would be induced by development in Opportunity Areas where the rezone sites occur and not development in the entire city. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The General Plan updates involve similar policy revisions to facilitate development described in the 2021-2029 Housing Element.
Impact Analysis
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The 2021-2029 Housing Element would allow for the rezoning of parcels associated with 12 Opportunity Areas, which are currently zoned for commercial, industrial, mixed-use, and residential uses. This would allow the development of up to 2,392 new housing units as either infill development on under-utilized parcels in many cases or new development on previously undeveloped parcels in a few cases.
The 2021-2029 Housing Element would not result in substantial environmental impacts as the Opportunity Areas are largely developed and new projects implemented under the 2021-2029 Housing Element would constitute largely infill development. Potential environmental impacts are discussed in more detail throughout this document.
SCAG estimates that the population of Simi Valley would increase to 137,000 by 2035. Full buildout of the estimated 2,392 units over the eight-year planning period would result in up to 7,033 new residents, if all units were fully occupied by the estimated household size (i.e., 2.94 persons per household; DOF 2021). This number of new residents would bring the current estimated population of Simi Valley up to 131,501, 5,499 fewer persons than the SCAG projection. Furthermore, the predicted population growth that would be induced under the 2021-2029 Housing Element (131,501) is accounted for in the City’s 2030 General Plan EIR, which evaluated the impacts of up to 134,613 persons by 2030, and 135,389 persons by 2035 (City of Simi Valley 2012). As the growth facilitated by the project would be less than SCAG’s population growth forecast and is already accounted for in potential impacts in the City’s 2030 General Plan EIR, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 121 b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The 2021-2029 Housing Element facilitates development of up to 2,392 units on the rezone sites in 12 Opportunity Areas. Project development would involve new development and redevelopment projects on infill sites and new development in two areas that are currently undeveloped.
Redevelopment projects may result in the displacement of some existing housing units and residents. However, goals, policies, and objectives included in the 2030 General Plan aim to prevent displacement and promote housing stability, as follows:
Goal LU-9 Fair and Equitable Access. Fair and equitable access to employment, housing, education, recreation, transportation, retail, and public services is provided for all residents.
Policy LU-9.1 Equitable Distribution of Uses and Amenities. Strive to ensure that uses and amenities that foster livable and complete neighborhoods such as parks and community facilities are distributed equitably throughout the City.
Policy LU-9.3 Housing Type Distribution. Promote an equitable distribution of housing types for all income groups throughout the city and promote mixed-income developments.
Policy LU-9.4 Jobs-Housing Balance. Encourage a balance between job type, the workforce, and housing development to reduce the negative impacts of long commutes and provide a range of employment opportunities for all residents.
Under the 2021-2029 Housing Element, all identified non-vacant sites are required to comply with the housing replacement requirements in California Government Code Section 65583.2(g)(3), which specifies that any multi-family residential development on a non-vacant site must replace any existing on-site housing units subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of lower or very low income, or are otherwise subject to any form of rent or price control (including any that existing on-site within the previous five years).
The 2021-2029 Housing Element facilitates development that would provide additional opportunities for housing by expanding areas where housing (including affordable housing) is allowed, and by increasing the allowable density of current residential areas. The 2021-2029 Housing Element would facilitate development that would create a net increase in the number of available housing units in the city. It is anticipated that any replacement housing need created by displacement of existing housing would be offset through implementation of the 2021-2029 Housing Element. Therefore, impacts related to displacement associated with the Housing Element Update would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 123 15 Public Services
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
a. Would the project result in substantial
adverse physical impacts associated with
the provision of new or physically altered
governmental facilities, or the need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts,
in order to maintain acceptable service
ratios, response times or other
performance objectives for any of the
public services:
1 Fire protection? □ □ ■ □
2 Police protection? □ □ ■ □
3 Schools? □ □ ■ □
4 Parks? □ □ ■ □
5 Other public facilities? □ □ ■ □
Environmental Setting
Fire Protection
The Ventura County Fire Department (VCFD) provides fire prevention, fire suppression, and emergency services in Simi Valley, using five battalions, comprising 31 fire stations, staffed 24 hours per day, 365 days per year. Battalion 4 serves Simi Valley and Moorpark, and the surrounding unincorporated areas. According to the 2019 VCFD District Snapshot, VCFD responded to 10,456 calls for service, for a mix of incidents from medical to fire (VCFD 2019). According to the VCFD, no set standard or formula for determining acceptable levels of service is in place and each department considers a variety of factors to evaluate service levels, including calls for service, population ratios, type of service calls, response times, future building, demographics, trends, and funding sources.
VCFD strives to achieve a response time between five to seven minutes for emergency calls, and nine to 12 minutes for non-emergency calls throughout the county.
Police Protection
As discussed in the City’s General Plan EIR, police services are provided Citywide by the Simi Valley Police Department (SVPD) and the SVPD patrol area covers the entire area within the Simi Valley municipal boundaries. The SVPD employs 124 sworn officers and a support staff of 65 civilians, or approximately one officer per 1,000 residents according to an estimated 2021 population of 775
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124,468 residents. The SVPD has an operations division, investigative division, support services division, and administrative division.
Schools
The Simi Valley Unified School District (SVUSD) is one of the largest school districts in Ventura County and is responsible for providing most primary and secondary education for Simi Valley residents. The SVUSD presently operates twenty-one elementary schools (grades K–6), three middle schools (grades 6–8), three high schools (grades 9–12), one continuation high school (grade 10–12), one adult school, and one independent/alternative school. The SVUSD served approximately 16,000 students 18 elementary schools, three middle schools, and four senior high schools (SVUSD 2021).
Although Simi Valley is expected to increase in population over the 2021-2029 Housing Element planning horizon, the aging adult population in the city is expected to contribute to an overall decline in total school enrollment. However, elementary enrollment is expected to increase.
Libraries
The Simi Valley Public Library provides library services for residents of Simi Valley. The Library annual report for fiscal year 2019/2020 reports 38,423 registered borrowers who attended more than 10,000 in-person programs and over 3,500 virtual programs (Simi Valley Public Library 2020).
More than 330,000 items were borrowed during over 100,000 library visits The City’s capital projects included building upgrades to include updated staffed service touchpoints and collaborative workspaces, along with many other improvements.
Impact Analysis
a.1. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
a.2. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
a.3. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered schools, or the need for new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? a.5. Would the project result in substantial adverse physical impacts associated with the provision of other new or physically altered public facilities, or the need for other new or physically altered public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects that would regulate new housing development in 776
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Final Initial Study – Mitigated Negative Declaration 125 Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts related to public services and facilities. Furthermore, as discussed in Section
4.14, Population and Housing of this IS-MND, the additional housing units that could be facilitated by the 2021-2029 Housing Element are within the growth envisioned and assessed in the 2030 General Plan EIR. Section 4.13, Population and Housing, of the 2030 General Plan EIR evaluated the impacts of approximately 134,613 individuals by 2030, and 135,389 individuals by 2035; the 2021- 2029 Housing Element Update would accommodate up to approximately 131,501 persons.
Future development will require project-specific evaluation to determine compliance with City regulations and determine if any potential public services and facilities impacts are less than significant. These potential impacts cannot be assessed in a meaningful way until a project site and development components are known. Any impacts identified for an individual project would be addressed through the project approval process, including design review and (when applicable) environmental review and mitigation measures specific to any potential impacts of that project.
Furthermore, all projects proposed under the 2021-2029 Housing Element would be required to conform with the 2030 General Plan and updated General Plan goals and policies related to public services and facilities listed below:
Goal CS-3 Community Education. High-quality and equitably distributed educational facilities are available that provide an education for the children and youth of Simi Valley as well as life-long learning opportunities for all residents.
Policy CS-3.1 Provision of Schools. Work with the SVUSD to provide school sites and upgrade existing facilities that serve the needs of the community.
Policy CS-3.2 New School Sites. Assist SVUSD to find appropriate sites for new or expanded school facilities within infill development opportunities in the community.
Goal CS-4 Library Services and Facilities. Library facilities are provided that enhance Simi Valley’s quality of life and create opportunities for self-learning and cultural and academic enrichment.
Policy CS-4.1 Library Services. Continue to support Ventura County in the provision of library services and programs to meet the needs of residents.
Policy CS-4.3 Satellite Libraries. Develop new freestanding “satellite libraries” or shared library facilities with area schools, at new community centers, or within private development in order to supplement services offered at the Simi Valley Library.
Policy CS-4.7 Alternative Service Delivery. Work with Ventura County and other agencies, as necessary, to explore alternative models to deliver library services to Simi Valley residents, in situations when Ventura County cannot provide the level and/or type of services desired by the City, and the means to fund payment of these services.
Goal S-4 Police Services, Crime Prevention, and Protection. Quality police services are provided that protect the long-term safety and well-being of Simi Valley residents, businesses, and visitors from criminal activities.
Policy S-4.1 Response Time Standards. Achieve and maintain appropriate response times for all call priority levels to provide responsive police services for the safety of residents and visitors.
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Policy S-4.2 Staffing Standards. Maintain optimum staffing levels for both sworn police officers and civilian support staff to provide quality police services to the community.
Policy S-4.7 Crime Prevention through Design. Support and encourage the use defensible space concepts (site and building lighting, visual observation of open spaces, secured areas, etc.) in the design of new development and rehabilitation projects
Policy S-4.8 Development Review. Review new development and rehabilitation projects for security measures as part of the development review process.
Goal S-6: Fire and Emergency Services. Coordinated fire protection and emergency medical services are provided to ensure residents and businesses are prepared for health, natural, and human-caused hazards and can respond quickly and effectively to maintain a safe and healthy community.
Policy S-6.1 Ventura County Fire Protection District, Emergency Medical Services Agency, and Simi Valley Hospital Coordination. Continue to work with and support the Ventura County Fire Protection District, Emergency Medical Services (EMS) Agency, and Simi Valley Hospital with regard to planning, communicating, and providing adequate personnel, equipment, facility, and infrastructure to maintain a high level of fire and emergency response services in Simi Valley.
Goal S-7 Fire Protection. People and property in Simi Valley are protected from urban and wildfires.
Policy S-7.2 New Development in Fire Hazard Areas. Require new development, including additions to existing structures, in or adjacent to fire hazard areas to minimize hazards to life and property by using fire preventive site design and building materials, offering adequate access, using fire-safe landscaping materials, and incorporating defensible space and other fire suppression techniques.
Policy S-7.4 Emergency Facilities. Require new development and subdivisions to include appropriate emergency facilities and infrastructure to assist and support wildfire suppression.
Policy S-7.6 Fire Hazard Preparedness. Minimize exposure to fire hazards through proactive code enforcement, public education programs, use of modern fire prevention measures, quick and safe access for emergency equipment and evacuation, and emergency management preparation.
Policy S-7.8 Fire Protection Systems. Encourage existing commercial and multiple-unit residential uses to install fire protection systems, as required by the State building and fire codes for new development, and encourage the installation and use of automatic sprinkler systems in existing structures.
Policy S-7.13 Funding. Ensure that new developments pay a pro-rata share for increased fire protection as necessitated by their construction.
While the 2021-2029 Housing Element would facilitate development of up to 2,392 housing units, the City has no information on the specifics of any future projects at this time. The potential public services impact of future projects would therefore be assessed at the time of permit application for each project. Projects facilitated by the 2021-2029 Housing Element would adhere to Ventura 778
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Final Initial Study – Mitigated Negative Declaration 127 County Ordinance 4386, which requires development projects to pay Fire Protection Fees in conjunction with the issuance of building permits. In accordance with the School Facilities Act of 1986 and the Leroy Green School Facilities Program, Simi Valley Unified School District collects developer fees from commercial, industrial, and residential development in order to fund school facilities, services, and improvements.
With implementation of the 2030 General Plan and General Plan Update’s goals and policies, and the required fees discussed above, the potential impact of the 2021-2029 Housing Element on or from public services and facilities would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.4. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered parks, or the need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects that would regulate new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts related to parks. Furthermore, the additional housing unit totals proposed under the 2021-2029 Housing Element are within the growth envisioned and assessed in the 2030 General Plan EIR. Section 4.13, Population and Housing, of the 2030 General Plan EIR evaluated the impacts of approximately 134,613 individuals by 2030, and 135,389 individuals by 2035; the 2021- 2029 Housing Element Update would accommodate up to approximately 131,501 persons.
While potential impacts of the 2021-2029 Housing Element related to parks cannot be assessed in a meaningful way until specific project sites and development components are known, any impacts identified for individual projects would be addressed through the project approval process, including design review and (when applicable) environmental review and mitigation measures specific to any impacts determined to be potential for that project. As discussed in Section 16, Recreation, of this IS-MND, the 2021-2029 Housing Element would be subject to goals, policies, and regulations designed to ensure continued provision of adequate parks to the community while avoiding significant environmental effects to or from parks. This impact would therefore be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 129 16 Recreation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
a. Would the project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated? □ □ ■ □
b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment? □ □ ■ □
Environmental Setting
As discussed in the City’s 2030 General Plan EIR, the Rancho Simi Recreation and Park District (Park District) owns, operates, and maintains regional and local parks and open spaces areas in Simi Valley. Including over 50 parks and trails, with Simi Valley alone houses 39 parks (RSRPD 2021).
Within Simi Valley, the Park District operates 39 parks, which cover approximately 1,212.3 acres. Of the 39 parks found in Simi Valley, each is designated as either a Community Park (four), Special Use Park (eight), Neighborhood Park (24), Natural Park (four), or Mini Park (two) depending on the size and recreational facilities offered. The Park District uses the standard of five acres of parkland per 1,000 residents of local open space set by the National Recreation and Park Association and aims to have two acres of neighborhood parks and 3 acres of community parks for every 1,000 residents. As of 2009, within the City of Simi Valley there are approximately 9.6 acres of parkland per 1,000 residents, 1.64 acres of neighborhood parks, and 2.18 acres pf community parks per 1,000 residents.
Impact Analysis
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts related to recreational facilities. Furthermore, population growth from the additional housing units that could be facilitated in the Opportunity Areas under the 2021-2029 Housing Element is within the growth envisioned and assessed in the 2030 General Plan EIR. Section 4.13, Population and Housing, of the 2030 General Plan EIR evaluated the impacts of approximately 134,613 individuals 781
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by 2030, and 135,389 individuals by 2035; the 2021-2029 Housing Element Update would accommodate up to approximately 131,501 persons.
Future development will require project-specific review to determine compliance with City regulations and the level of significance of any potential impacts of the 2021-2029 Housing Element.
Potential impacts related to recreational facilities cannot be assessed in a meaningful way until a project site and development components are known. Any impacts identified for individual projects would be addressed through the project approval process, including design review and (when applicable) environmental review and mitigation measures specific to any potential impacts of that project. Furthermore, all projects proposed under the 2021-2029 Housing Element would be required to conform with the 2030 General Plan goals and policies listed below:
Goal PR-1 Parks and Recreation Facilities. Parks, recreation, and community facilities that enhance community livability and contribute to public health are available to serve the diverse recreational needs of residents and visitors.
Policy PR-1.2 Location of Facilities. Work with RSRPD to ensure that parks and recreational facilities are well dispersed throughout the community and include opportunities for all residents regardless of income.
Policy PR-1.3 Service Levels. Encourage RSRPD to provide two acres of neighborhood parks and three acres of community parks per 1,000 residents. Strive to provide park facilities so that all residents live within 2 miles of a community park and ½ mile of a neighborhood park.
Policy PR-1.16 Small Public Places for Infill Areas. Require new development to provide small plazas, pocket parks, civic spaces, and other gathering places that are available to the public, particularly in infill areas, in addition to Quimby Act requirements.
Policy PR-1.19 Funding. Work with RSRPD to fund the costs of acquisition and development of parks and recreation facilities through land dedication, Quimby Act funds, federal and state grants, in lieu fees, development impact fees, and other funding sources, as appropriate.
Policy PR-1.20 Development Agreements. Provide incentives and enter into development agreements with developers to contribute financing for parks and other amenities for infill and mixed-use areas.
Chapter 9-68, Dedication of Land for Park and Recreation Purposes, of the SVMC states that subdivisions requiring a Tentative Map must seek approval to dedicate land and/or payment of fees to the Rancho Simi Park and Recreation District for recreational purposes (City of Simi Valley 2012).
Projects facilitated by the 2021-2029 Housing Element Update that meet the criteria of requiring a Tentative Map would have the quantity of land dedicated or fee in lieu of dedication determined based on the estimated population generated and how that would affect the NRPA standard of five acres per 1,000 residents (City of Simi Valley 2012). While the 2021-2029 Housing Element would facilitate development of up to 2,392 housing units, the City has no information on the specifics of any future projects at this time. The potential impacts of future projects would be assessed at the time of permit application. The 2021-2029 Housing Element would be subject to the goals, policies, and regulations discussed above, which are designed to ensure continued provision of adequate recreational facilities to the community while avoiding significant environmental effects to or from these facilities. Impacts to or from recreational facilities would therefore be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 131 17 Transportation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Conflict with a program, plan, ordinance
or policy addressing the circulation
system, including transit, roadway,
bicycle and pedestrian facilities? □ □ ■ □
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ ■ □
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ ■ □
d. Result in inadequate emergency access? □ □ ■ □
Environmental Setting
Simi Valley is a suburban city in southern Ventura County served by east/west highways such as SR 118 and U.S. 101, north/south highways such as SR 23 and SR 27, and major arterial roadways in and adjacent to the city. SR 118 (which is a freeway in Simi Valley) provides regional access to the city, and the 2030 General Plan EIR states that this freeway carries between 80,000 and 135,000 daily trips into and out of Simi Valley, generally increasing from west to east. The network of major roadways in Simi Valley is primarily designed in a north/south and east/west grid pattern with primary and secondary arterials spaced between one mile and one-half mile intervals. Many of the primary and secondary arterials in Simi Valley are built out to the full paved cross section along the entire length (refer to Figure 4.16-1 of the 2030 General Plan EIR).
Simi Valley Transit serves the city with fixed-route bus service that connects to the Los Angeles Metro in the San Fernando Valley and with Ventura County Transit Center in the Simi Valley Mall (City of Simi Valley 2021). Bicycle routes within the city consist of a network of facilities that connect trails and transit stations with roadways through various bicycle facilities (Class I through III), that vary in their degree of separation from the vehicular lanes (City of Simi Valley 2008).
The 2021-2029 Housing Element proposes rezoning sites throughout the city in Opportunity Areas where largely infill development would occur, particularly along transit corridors and near existing commercial development. Infill development typically decreases vehicle miles travelled (VMT) because it places residential uses closer to services that support residents (e.g., grocery stores, restaurants, and other services) and encourages alternative modes of travel, such as walking and 783
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cycling. Furthermore, the rezone sites are, in many cases, situated near or adjacent to transportation corridors and transit areas, facilitating fewer and shorter trip lengths.
Impact Analysis
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? The 2021-2029 Housing Element proposes rezoning sites throughout the city to facilitate infill development during its eight-year planning horizon. Rather than conflicting with transportation policies and plans, like the Simi Valley Bicycle Master Plan (City of Simi Valley 2019), it would support implementation of those plans because development facilitated by the 2021-2029 Housing Element would support fulfillment of goals and policies that make Simi Valley more accommodating to non-vehicular travel, thereby reducing VMT. SCAG’s Regional Transportation Improvement Program also has programs to increase alternative transportation that would likewise be supported by infill development on the rezone sites throughout the city, as described in the 2021-2029 Housing Element (City of Simi Valley 2021).
The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts to transportation or affect existing plans that address transportation and mobility. Future development accommodated under the 2021-2029 Housing Element would be subject to development plan review to determine potential concerns related to transportation and VMT based on site-specific locations and development design. Development proposals for individual projects would be subject to adopted development guidelines, including standards that govern VMT, transportation, GHG, and associated issues. Any impacts identified for an individual project would be addressed through the project approval process, including design review specific to any potential impacts of that project.
Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
CEQA Guidelines Section 15064.3(b) require specific considerations of a project’s transportation impacts based on the vehicle miles traveled (VMT). This implements SB 743, which eliminates level of service as a basis for determining significant transportation impacts under CEQA and requires a different performance metric - VMT. With this change, the State shifted the focus from measuring a project’s impact upon operations (LOS) to measuring the impact of driving (VMT) on achieving its goals of reducing GHG emissions, encouraging infill development, and improving public health through active transportation.
Implementation of the 2021-2029 Housing Element would increase density on some sites throughout the city to meet the RHNA allocation. The Opportunity Areas identified in the 2021-2029 Housing Element would largely accommodate infill development that tends to reduce VMT because it places residential development close to commercial and office uses and produces opportunities to travel by foot or bicycle instead of automobile. As described under Environmental Setting, Simi Valley is served by public transit options and bicycle routes on city roadways. Future projects implemented under the 2021-2029 Housing Element are therefore likely to reduce VMT compared 784
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Final Initial Study – Mitigated Negative Declaration 133 to regional averages, due to residential uses being developed close to commercial, office, and other uses. Development that occurs under the 2021-2029 Housing Element would not substantially increase VMT in the city because the total increase in housing units associated with implementation of the 2021-2029 Housing Element was anticipated for development under the 2030 General Plan (see Section 14, Population and Housing of this IS-MND).
The City’s 2030 General Plan has the following policies that encourage reduced VMT Policy M-8.4 Accommodate Alternative Modes. Condition discretionary development to minimize traffic impacts by incorporating sidewalks and bicycle pathways, bicycle racks and lockers, ridesharing programs, transit improvements (bus turnouts, shelters, benches), transportation demand measures, and/or transit subsidies for employees or residents of the proposed development.
Policy M-11.1 Transportation Demand Management (TDM). Utilize and promote TDM measures to encourage and create incentives for the use of alternative travel modes, reduce vehicle miles traveled, disperse peak traffic, and better utilize the existing transportation infrastructure.
Policy M-11.2 Alternative Transportation Modes. Promote and encourage the use of alternative transportation modes, such as ridesharing, carpools, van pools, public transit, bicycles, and walking; and provide facilities that support such alternative modes.
Policy M-11.4 Demand Reduction Programs. Work with area businesses to develop programs that promote the use of multiple-occupancy vehicle programs for shopping, business, and other uses to reduce vehicle miles traveled.
Policy M-11.5 Transportation Demand Management (TDM) Programs. Encourage existing major employers to develop and implement TDM programs to reduce peak period trip generation such as the use of flex time, staggered working hours, high occupancy company-sponsored vehicles, ride-sharing programs, and any other means to lessen peak-hour commuter traffic.
Policy M-12.1 Bicycle Master Plan. Maintain and update the City’s Bicycle Master Plan to determine desired improvements to the City’s bicycle network and plan, including the Arroyo Simi Greenway, and prioritize improvements for orderly implementation coordinated with the capital improvement program.
Policy M-12.2 Bicycle Usage. Promote bicycling as an option for short trips and allow bicycles to connect to mass transit. (Imp A-1, A-2, LU-18, M-9)
Policy M-12.3 Bicycle Facilities. Incorporate bicycle and pedestrian facilities in the design plans for new streets and highways and, where feasible, in plans for improving existing roads.
The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts to transportation or affect existing plans that address transportation and mobility. Furthermore, future development accommodated under the 2021-2029 Housing Element would be subject to development plan review to determine potential concerns related to transportation and VMT based on site-specific locations and development design. Development proposals for individual projects would be subject to adopted development guidelines, including standards that govern VMT, 785
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transportation, GHG, and associated issues. Any impacts identified for an individual project would be addressed through the project approval process, including design review specific to any potential impacts of that project. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? Implementation of the 2021-2029 Housing Element could involve projects that will introduce new driveways or access roads to sites that are currently developed or those that are currently undeveloped (such as the Walnut Hills Opportunity Area or the Heyneman Lane Opportunity Area).
The SVMC Section 9-34.090 has specific design requirements for new access driveways. These include minimum standards for width, grade, angle, surface, and clearance. The City of Simi Valley Department of Public Works, Department of Environmental Services, and the Ventura County Fire Protection District would review individual project designs to determine if those standards would be satisfied. As most projects that would be developed under the 2021-2029 Housing Element would be infill projects, they would not involve creating new roadways or intersections or incompatible uses within the city. The Opportunity Area sites that are currently undeveloped have direct access to existing local streets. While new intersections of existing local streets with proposed new streets internal to these sites may be created if these sites are developed, they would be subject to the project-level review processes described above to ensure hazards from design features or incompatible uses are not created.
The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts to transportation or affect existing plans that address transportation and mobility. Furthermore, future development accommodated under the 2021-2029 Housing Element would be subject to development plan review to determine potential concerns related to transportation design and any impacts identified for an individual project would be addressed through the project approval process, including design review specific to any potential impacts for that project. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project result in inadequate emergency access? The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts to transportation or affect existing plans that address emergency access, including for fire and other emergency services (For further discussion of the project’s potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, see Section 9.c of this IS-MND). Furthermore, future development accommodated under the 2021-2029 Housing Element would be subject to development plan review to determine potential concerns related to emergency access, and any impacts identified for an individual project would be addressed through the project approval process, including design review specific to any potential impacts for that project. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Final Initial Study – Mitigated Negative Declaration 135 18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in a Public Resources Code
Section 21074 as either a site, feature, place,
or cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native American
tribe, and that is:
a. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in Public
Resources Code Section 5020.1(k)? □ ■ □ □
b. A resource determined by the lead
agency, in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1? In applying the criteria
set forth in subdivision (c) of Public
Resources Code Section 5024.1, the lead
agency shall consider the significance of
the resource to a California Native
American tribe. □ ■ □ □
Existing Conditions
For a discussion of Environmental Setting regarding Tribal Cultural Resources, please refer to the discussion in Section 5, Cultural Resources.
The City initiated the tribal consultation process, as required under Public Resources Code (PRC) Section 21080.3.1 and consistent with Assembly Bill (AB) 52 and Senate Bill (SB) 18 by mailing consultation letters on April 27, 2021 according to the requirements of SB 18, and on June 29, 2021 according to the requirements of AB 52, to contacts identified by the Native American Heritage Commission that have requested the City of Simi Valley notify them of projects subject to AB 52 or SB 18. As of the drafting of this report, the City has not received any responses requesting consultation. Under AB 52, Native American tribes have 30 days to respond to consultation notification and request further project information and formal consultation; under SB 18 Native American tribes have 90 days to respond requesting consultation. 787
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Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code Section 21074 that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code 21074 that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? As of July 1, 2015, California Assembly Bill 52 of 2014 (AB 52) was enacted and expanded CEQA by defining a new resource category, “tribal cultural resources [TCR].” AB 52 establishes that “A project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment” (Public Resources Code Section 21084.2). It further states that the lead agency shall establish measures to avoid impacts that would alter the significant characteristics of a tribal cultural resource, when feasible (Public Resources Code Section 21084.3).
Project development would primarily occur on infill sites in areas with existing infrastructure and in areas that have been developed and disturbed previously. It is likely that previous grading, construction, and modern use of the sites would have either removed or destroyed tribal cultural resources within surficial soils. There are some Opportunity Areas that are currently undeveloped (such as the Walnut Hills Opportunity Area or the Heyneman Lane Opportunity Area), and in these areas the potential to encounter subsurface tribal cultural resources may be higher. There is some potential for subsurface tribal cultural resources throughout the city that could be disturbed by grading and excavation activities associated with new housing development. The 2030 General Plan goals and policies as discussed in Section 5, Cultural Resources, would apply to TCRs as well.
Effects on tribal cultural resources can only be determined once a specific project has been proposed because the effects depend highly on the individual project site conditions and the characteristics of the proposed activity. Although the current AB 52 consultation for this document did not result in contact with tribal representative concerned about TCR discovery, new TCRs may be identified over the course of the phased implementation of the 2021-2029 Housing Element.
Therefore, as specific projects are proposed, consultation with tribes under AB 52 (and SB 18, if applicable) shall occur per the requirements of these laws to determine if any TCRs may be impacted by project specific elements. If TCRs are identified during future tribal consultation efforts, impacts to any such TCRs would be potentially significant unless Mitigation Measures TCR-1 and TCR-2 are incorporated.
Mitigation Measures
TCR-1 Retain a Native American Monitor
If tribal cultural resources are identified during future tribal consultation efforts for future specific development projects or during construction of such projects, the project applicant for that project shall obtain the services of a qualified Native American Monitor(s) during construction-related ground disturbance activities. Ground disturbance is defined as activities that include, but are not limited to, pavement removal, potholing or auguring, grubbing, weed abatement, boring, grading, excavation, drilling, and trenching, within the project area. The monitor(s) shall be present on-site 788
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Final Initial Study – Mitigated Negative Declaration 137 during the construction phases that involve any ground disturbing activities. The Native American Monitor(s) shall complete monitoring logs daily to provide descriptions of the daily activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the construction-related ground disturbance activities are completed, or when the monitor has indicated that the site has a low potential for archeological resources.
TCR-2 Unanticipated Discovery of Tribal Cultural Resources If tribal cultural resources are identified during future tribal consultation efforts for future specific development projects or during construction of such projects, a qualified archaeologist and Native American Monitor shall be present during construction-related ground disturbance activities to identify any unanticipated discovery of tribal cultural resources. The qualified archaeologist and Native American monitor may be different individuals or the same individual if the City determines that individual qualifies as both a qualified archaeologist and Native American monitor. All archaeological resources unearthed by construction activities shall be evaluated by the qualified archaeologist and Native American Monitor. If the resources are determined to be human remains (see also Mitigation Measure CUL-3) the Coroner shall be notified, and if the human remains are Native American in origin, the Coroner shall notify the NAHC as mandated by state law, who will then appoint an MLD, who shall then coordinate with the landowner regarding treatment and curation of these resources. Typically, the MLD will request reburial or preservation for educational purposes. If a resource is determined by the qualified archaeologist to constitute a “historical resource” pursuant to CEQA Guidelines Section 15064.5(a) or a “unique archaeological resource” pursuant to PRC Section 21083.2(g), the qualified archaeologist shall coordinate with the applicant and the City to develop a formal treatment plan that would serve to reduce impacts to the resources. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and PRC Sections 21083.2(b) for unique archaeological resources. Preservation in place (i.e., avoidance) is the preferred manner of treatment. If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. Any historic archaeological material that is not Native American in origin shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be donated to a local school or historical society in the area for educational purposes.
Compliance with State and local laws, adherence to goals and policies within the 2030 General Plan, and implementation of Mitigation Measures TCR-1 and TCR-2 would reduce potential impacts to tribal cultural resources to a less than significant level.
LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
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Final Initial Study – Mitigated Negative Declaration 139 19 Utilities and Service Systems
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would implementation of the 2021-2029
Housing Element:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ ■ □
b. Have sufficient water supplies available
to serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years? □ □ ■ □
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
project’s projected demand in addition to
the provider’s existing commitments? □ □ ■ □
d. Generate solid waste in excess of State or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals? □ □ ■ □
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste? □ □ ■ □
Environmental Setting
As discussed in the City’s 2030 General Plan EIR, Ventura County Waterworks District No. 8 (District) and the Golden State Water Company (GSWC) are the two water purveyors that provide water service to the City of Simi Valley. Currently, Simi Valley receives its water through imported water, local groundwater, and local recycled water. Approximately 97 percent of the District and 90 percent of the GSWC’s water supply is imported water purchased from the Metropolitan Water District (MWD) via the Calleguas Municipal Water District. Collectively, it is anticipated that the City will be provided a water supply of 43,083 afy by 2030. This is 3 afy lower than the collective 2030 projected water demand of 43,086 afy (City of Simi Valley 2020). 791
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The Sanitation Services Division of the City’s Department of Public Works is responsible for the City’s sanitary sewer system and Water Quality Control Plan (WQCP). The collection system includes three lift station facilities and approximately 362 miles of gravity and pressure pipelines. Existing average daily flows during dry weather are approximately 7.7 mgd. During wet winter months when groundwater levels are high, the WWTP treats an average daily flow of up to 9.6 mgd.
The City’s solid waste is transferred to the Simi Valley Landfill and Recycling Center (SVLRC), located northwest of the City. The SVLRC currently provides all of Simi Valley’s daily refuse disposal needs.
The SVLRC is permitted to accept up to 3,000 tons per day (TPD) of refuse and can accept 6,250 tons of recyclable materials. The SVLRC recycles approximately 25 percent of all waste accepted. The average daily disposal for 2020 was 2,177 TPD, or approximately 73 of its permitted daily capacity.
The total permitted capacity of SVLRC is 119,600,000 cubic yards, and the estimated remaining permitted capacity is 82,954,873 cubic yards.
Impact Analysis
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Projects carried out under the 2021-2029 Housing Element would be concentrated in urban areas that are served by existing utilities infrastructure, including potable water, wastewater, stormwater drainage, electrical power, natural gas, and telecommunications facilities.
The City of Simi Valley Mobility and Infrastructure Element of the 2030 General Plan has established several regulatory requirements for the provision of domestic water, sewage treatment, and utility services to the entire community, many of which are described in Section 10, Hydrology and Water Quality. The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects that would regulate new housing development in Simi Valley. Because it is a policy document, the 2021-2029 Housing Element will not, in and of itself, result in impacts related to utilities and service systems. However, new development that is fostered by the adoption of the 2021-2029 Housing Element would be guided by specific policies in the City’s 2030 General Plan, such as:
Policy IU-1.2 Service for New Development. Require new development to provide adequate facilities or pay its fair share of the cost for facilities required to support growth.
The 2030 General Plan EIR noted that the future capacity of the Jensen Treatment Plant to accommodate growth in its service area was considered in the MWD’s 2010 RURMP and MWD determined demand for water through 2035 and plans infrastructure expansion to align with expected demand (City of Simi Valley 2012). Because projected growth under implementation of the 2021-2029 Housing Element is within SCAG projections for the 2040 growth horizon (see Section 14, Population and Housing of this IS-MND), this would continue to be the case for development related to 2021-2029 Housing Element implementation. New facilities would not be required. Nonetheless, based on the zoning changes that would be implemented as part of the 2021-2029 Housing Element, sewer capacity studies would be required as part of project approval, in some cases, to determine the adequacy of the sewer mains serving the area in which the proposed project would be located. Without specific project proposals, analysis of this topic would be speculative at this time. Implementation of City-determined degrees of adequacy for water and sewage capacity, 792
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Final Initial Study – Mitigated Negative Declaration 141 would however determine the requirements for new development in areas that may need increased capacity.
The Simi Valley Landfill and Recycling Center (SVLRC) would serve new development under the 2021-2029 Housing Element. The SVLRC has a capacity of 119.6 million cubic yards of waste. Based on the maximum permitted disposal rate of 6,000 tons per day (tpd), seven days per week, 358 days per year, the site could operate until 2051. Waste Management accepts waste from a variety of sources, but they are restricted to the approval rate of 6,000 tons per day. Therefore, the SVLRC, at a minimum, can accept waste until 2051. Therefore, the landfill will have sufficient capacity to accommodate the City’s increased solid waste disposal needs and because projected growth under implementation of the 2021-2029 Housing Element is within SCAG projections for the 2040 growth horizon (see Section 14, Population and Housing of this IS-MND), this would continue to be the case for development related to 2021-2029 Housing Element implementation. Furthermore, programs in SV-CAP address the reduction of solid waste through a variety of recycling and reuse requirements that are underway. The SVMC also contains regulations governing recycling facilities and requirements (Sections 6-3.060, 6-13.712, and 9-35.606).
Electricity is currently provided by Southern California Edison and natural gas service is provided by Southern California Gas. Telecommunications services would be provided by AT&T, SBC Telecom, or other providers, at the discretion of future tenants. Telecommunications are generally available throughout the city, and facility upgrades would not likely be necessary.
While new development could require increased levels of service from electric, gas, and telecommunications services, development under the 2021-2029 Housing Element would not require the relocation of facilities such that environmental impacts would occur. All new development facilitated by the 2021-2029 Housing Element requiring approval would undergo City review to ensure compliance with local and State laws and regional utilities capacities. With adherence to these requirements, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed in Section 10, Hydrology and Water Quality, the city is served by two water purveyors, Ventura County Waterworks District No. 8 (District) and the Golden State Water Company (GSWC).
The District currently serves about 68 percent of the developed portion of the City as well as some unincorporated areas of Ventura County adjacent to Simi Valley (City of Simi Valley 2012). The 2020 UWMP presents detailed projected water supply from both suppliers through 2035, which is summarized below.
The State Water Project is the ultimate source of imported water supply for the city, which is delivered by MWD and treated at the Joseph Jensen Water Filtration Plant before delivery to Calleguas and ultimately to the District and the GSWC. The current capacity of the Plant is 750 mgd and can be increased to 1,000 mgd in the future, if necessary. For reliability, MWD can deliver imported water supply from backup systems, such as the Colorado River Aqueduct system, should supply from the SWP be interrupted. MWD also has major water storage facilities including San Luis Rey Reservoir, Pyramid Lake, and Castaic Lake on the State Water Project and Diamond Valley Reservoir on the Colorado River Aqueduct system. Calleguas has Bard Reservoir and groundwater storage in the Las Posas Basin through its Aquifer Storage and Recovery Project to provide reliability for its supply. The District provides reliability of its supply through its 41 water storage tanks that 793
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have a combined storage of 56 million gallons or about 172 acre-feet. The District also supplements its local water supply with groundwater supply from its Gillibrand Basin wells and treatment plant and recycled water supply from the SVWQCP that can supplement imported water supplies purchased from Calleguas.
According to the 2020 UWMP, GSWC’s supply is expected to be 100 percent reliable through 2030.
This reliability is a result of 1) the projected reliability of Calleguas as a member of Metropolitan, which intends to provide 100 percent reliability and 2) a reliable groundwater supply. Supply reliability for the Simi Valley System depends upon the reliability of imported water from Calleguas and local groundwater supplies, as described above. Furthermore, the 2030 General Plan Natural Resources Element has goals and polices that address water conservation, as follows:
Goal NR-4 Water consumption is minimized through conservation methods and other techniques.
Policy NR-4.1 Water Conservation. Establish water conservation goals and benchmarks for the next 20-year period. Establish auditing methods to evaluate the extent of success in meeting goals as well as the effectiveness of conservation programs and technology.
Policy NR-4.2 Public Education. Establish a comprehensive water conservation program to educate the public, publicize regulations, and provide information regarding incentives. (Imp A-1, A-2, LU-18, IU-2, NR-9)
Policy NR-4.3 Water Conservation Measures. Require water conservation measures/devices that limit water usage for all new construction projects and major alterations to existing facilities, including public facilities. These measures should include the use of water-efficient landscaping and irrigation, stormwater capture, efficient appliances and fixtures, and use of “gray water” for irrigation.
Policy NR-4.4 Partnerships for Conservation. Explore partnerships with other public agencies (such as the Simi Valley Unified School District, Rancho Simi Recreation and Park District, and Ventura County Watershed Protection District) to reduce water consumption.
Policy NR-4.5 Water Efficient Landscaping. Require that drought-tolerant landscaping be installed for all private and City landscaping and parkways.
Policy NR-4.6 Irrigation Timing. Require that public and private irrigation be done at optimum times of the day, such as early mornings or late afternoon, and use weather sensors to facilitate optimum irrigation.
Policy NR-4.7 Monitoring System. Adopt state-of-the-art water monitoring systems to remotely monitor the City’s water usage, leaks, and ruptures. ( Policy NR-4.8 Infrastructure Upgrades. Continue to upgrade the City’s water infrastructure to minimize water leakage and ensure adequate supply for residents and businesses.
Finally, development projects implemented under the 2021-2029 Housing Element would be required to conform to the provisions of the California Green Building Code as adopted in SVMC Section 8.22-02 et seq. Individual projects would undergo design review to ensure this compliance at the time they are proposed and as part of the permitting process. Finally, SVMC adopted the Ventura County Waterworks Water Conservation Program with Chapter 11 of the code, which addresses water conservation measures to be implemented during supply shortage conditions, such 794
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Final Initial Study – Mitigated Negative Declaration 143 as drought. With adherence to local and State laws and implementation of the 2030 General Plan’s goals and policies, impacts associated with implementation of the 2021-2029 Housing Element to water supply in dry and multiple dry years would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
In specific areas, the implementation of the 2021-2029 Housing Element would allow for the rezoning of the sites identified in Table 3 to facilitate an increase in residential densities on rezone sites in the Opportunity Areas. Most of these sites are currently developed and connect to existing wastewater infrastructure. Infill projects proposed under the 2021-2029 Housing Element would also connect to that infrastructure. The 2030 General Plan EIR found that build-out of the 2030 General Plan would increase wastewater generation by 2.8 mgd of wastewater per day over then existing conditions and that, based on existing treatment levels at the WQCP and the design capacity, the WQCP had sufficient remaining capacity to treat the full increase in sewage attributable to growth anticipated under by 2035.
The anticipated growth under the 2021-2029 Housing Element falls within the growth anticipated by SCAG through 2035, as discussed in Section 14, Population and Housing, and is therefore within the growth levels anticipated under the 2030 General Plan and 2030 General Plan EIR analysis.
Furthermore, the following 2030 General Plan policy requires sufficient sewer service be maintained:
Policy IU-3.1 Peak Flow Service. Provide sufficient wastewater conveyance, pumping, and treatment capacity for peak sewer flows and infiltration Based on the zoning changes that would be implemented as part of the 2021-2029 Housing Element, sewer capacity studies would be required as part of project approval, in some cases, to determine the adequacy of the sewer mains serving the area in which the proposed project would be located. Without specific project proposals, analysis of this topic would be speculative at this time. However, with adherence to the policy listed above and all City requirements to meet peak flow service for sewer and infiltration, implementation of development under the 2021-2029 Housing Element would not require an additional expansion of the wastewater treatment plant.
Future development under the 2021-2029 Housing Element would be required to comply with federal, State, regional, and local regulations, and the goals and policies identified above. Therefore, given existing and anticipated future capacity at the WQCP, wastewater generation expected from the 2021-2029 Housing Element build-out and updates to 2030 General Plan goals and policies, impacts to the wastewater treatment facilities associated with implementation of the General Plan Update would be less than significant
LESS THAN SIGNIFICANT IMPACT
d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e. Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
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A significant impact could occur if 2021-2029 Housing Element would conflict with any statutes and regulations governing solid waste. In compliance with State legislation, any project development would be required to implement a Solid Waste Diversion Program and divert at least 75 percent of the solid waste generated from the applicable landfill site. In addition, project development that occurs as part of 2021-2029 Housing Element implementation would comply with federal, State, and local statutes and regulations related to solid waste, such as the California Waste Integrated Waste Management Act (AB 939), MWD’s Stormwater Integrated Resources Plan (SWIRP), and the City’s recycling program, as discussed above.
The 2021-2029 Housing Element, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Simi Valley. Because it is a policy document, the Housing Element Update will not, in and of itself, result in impacts related to solid waste in the city. Any 2021-2029 Housing Element would be subject to policies and standards described in the City’s 2030 General Plan. Therefore, projects implemented under the 2021-2029 Housing Element would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Wildfire
Final Initial Study – Mitigated Negative Declaration 145 20 Wildfire
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
If located in or near state responsibility areas
or lands classified as very high fire hazard
severity zones, would implementation of the
2021-2029 Housing Element:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ ■ □
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire? □ □ ■ □
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment? □ □ ■ □
d. Expose people or structures to significant
risks, including downslopes or
downstream flooding or landslides, as a
result of runoff, post-fire slope instability,
or drainage changes? □ □ ■ □
Environmental Setting
A wildfire is an uncontrolled fire in an area of extensive combustible fuel, including vegetation and structures. Wildfires differ from other fires in that they take place outdoors in areas of grassland, woodlands, brushland, scrubland, peatland, and other wooded areas that act as a source of fuel, or combustible material. Buildings may become involved if a wildfire spreads to adjacent communities.
The primary factors that increase an area’s susceptibility to wildfire include slope and topography, vegetation type and condition, and weather and atmospheric conditions.
Simi Valley is located near the county line between Ventura and Los Angeles Counties, and is situated near rugged topography with highly flammable vegetation. As such, much of the surrounding area has been designated a Very High Fire Hazard Severity Zone by CALFIRE (City of Simi Valley 2021). Like much of Southern California, Simi Valley experiences wet winters and warm, dry summers that dry out vegetation. During the fall, Santa Ana winds, known for their dry air and high 797
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wind speeds originating in the deserts north and east of Los Angeles County, sweep west into the county and further desiccate vegetation.
As discussed in the Safety and Noise Element of the 2030 General Plan, fires that occur along the wildland-urban interface are more hazardous for people and property as they can spread into urbanized areas. The greatest potential for fire occurs at the urban fringe and in the hillside areas that surround the valley floor. Development in these areas includes commercial and light industrial uses along the SR 118 corridor, with residential development closer to the open space areas.
The study area for wildfire includes the areas in which the Opportunity Areas with rezone sites occur and not the entire city, although uncontrolled wildfire can impact larger areas. The 2021-2029 Housing Element is a policy document and as such does not propose specific development projects, but only facilitates density needed to accommodate the 6th cycle RHNA. The City cannot assess the specific impacts of specific projects as those have yet to be proposed on the Opportunity Areas, which are largely situated in areas currently zoned for commercial, light industrial, mixed use, and residential uses. Project-specific impacts will be ascertained during the permitting process for those projects. The impact analysis below therefore discusses potential impacts at a programmatic level and describes how they would be addressed at the time future developments are proposed.
Impact Analysis
a. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
The California Department of Forestry and Fire Protection (CALFIRE) maps fire hazards based on zones, referred to as Fire Hazard Severity Zones (FHSZ). Factors that affect the severity of a FHSZ include fuel, slope, and fire weather. There are three levels of severity: 1) Moderate FHSZs; 2) High FHSZs; and 3) Very High FHSZs (CALFIRE 2021). As discussed above, areas at risk for wildfire in Simi Valley are concentrated around the perimeter of the community within the undeveloped hillsides and mountainous areas, and along SR 118, basically framing the entire city. These areas have been designated as a Very High FHSZ by CAL FIRE (City of Simi Valley 2021). Several of the Opportunity Areas, such as Walnut Hills and Heyneman Lane, are either in or near this Very High FHSZ.
As discussed in Section 9, Hazards and Hazardous Materials, construction activities for future projects could interfere with adopted emergency response or evacuation plans because of temporary construction activities. However, temporary construction used for project development that could impede emergency access would be subject to the City’s permitting process. Additionally, increased housing development density in urban areas of the City under the 2021-2029 Housing Element could result in additional traffic on area roadways. However, in the event of a wildfire, implementation of the City’s Multi-Hazard Mitigation Plan and Emergency Response Program would provide guidance to City personnel in the event of an evacuation. City permitting requirements and implementation of applicable policies and regulations would ensure that future development under the 2021-2029 Housing Element would not impair or physically interfere with adopted emergency response or evacuation procedures. Therefore, impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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Environmental Checklist
Wildfire
Final Initial Study – Mitigated Negative Declaration 147 b. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
The Opportunity Areas described in the 2021-2029 Housing Element are primarily infill development, located on previously developed land. Although heavy duty equipment used during construction of individual projects facilitated by the Housing Element Update may produce sparks that could ignite local vegetation, projects would comply with requirements related to construction equipment and fire suppressant (such as California Public Resources Code Section 4442).
Development of new buildings and renovations would adhere also to the most recent fire code requirements. Additionally, the General Plan Update contains the following goals and policies to increase fire protection:
Goal S-7 Fire Protection. People and property in Simi Valley are protected from urban and wildfires.
Policy S-7.2 New Development in Fire Hazard Areas. Require new development, including additions to existing structures, in or adjacent to fire hazard areas to minimize hazards to life and property by using fire preventive site design and building materials, offering adequate access, using fire-safe landscaping materials, and incorporating defensible space and other fire suppression techniques.
Policy S-7.3 Fire Department Review. Continue review by the Ventura County Fire Protection District of all proposed structures and developments in the community to mitigate potential wildland fire loss and damage.
Policy S-7.4 Emergency Facilities. Require new development and subdivisions to include appropriate emergency facilities and infrastructure to assist and support wildfire suppression.
Policy S-7.5 Emergency Evacuation Routes. Require new development in wildland/urban interface areas to have adequate access to existing evacuation routes.
Policy S-7.6 Fire Hazard Preparedness. Minimize exposure to fire hazards through proactive code enforcement, public education programs, use of modern fire prevention measures, quick and safe access for emergency equipment and evacuation, and emergency management preparation.
Policy S-7.8 Fire Protection Systems. Encourage existing commercial and multiple-unit residential uses to install fire protection systems, as required by the State building and fire codes for new development, and encourage the installation and use of automatic sprinkler systems in existing structures.
Policy S-7.9 Fuel Modification. Ensure that new development complies with fuel modification requirements of the Ventura County Fire Protection District, as applicable, with fuel mitigation plans required for any development adjacent to open space or wildland areas.
Because development facilitated by the 2021-2029 Housing Element would primarily be infill development located in already built-out locations and would comply with local and State fire safety provisions, development on the rezone sites would not exacerbate wildfire risks. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
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c. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Implementation of the 2021-2029 Housing Element would prioritize the development of new housing in urban areas of the city near existing transit and as infill in areas already developed. The Walnut Hills Opportunity Area and the Heyneman Lane Opportunity Area would require new roads and other infrastructure near Very High FHSZs but, in keeping with State law (SB 1160), new utilities would be placed underground and would not exacerbate fire risk or result in other temporary or ongoing impacts to the environment. Impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
As shown in Figure 4.9-2 of the City’s 2030 General Plan EIR, there are six designated types of flood zones in the City. The Opportunity Areas described in the 2021-2029 Housing Element are primarily infill development, located on previously developed land, away from hillsides. As such, development facilitated by the 2021-2029 Housing Element would not expose people or structures to risk of post- fire landslide, slope instability or drainage changes. The Walnut Hills and Heyneman Lane Opportunity Areas are currently undeveloped and near hillside areas. Development on these sites would be governed by 2030 General Plan policies that guide hillside development. Development in landslide hazard areas would be required to adhere to Chapter 9.32, Hillside Performance Standards, of the SVMC, as well as regulations of the California Building Code in Chapter 8.11 of the SVMC. Furthermore, project-specific geotechnical studies would be required for all projects (SVMC Section 9-64.100) to identify areas at risk for landslide if a wildfire were to occur and projects would be required to mitigate for that risk.
LESS THAN SIGNIFICANT IMPACT
800
1039
Environmental Checklist
Mandatory Findings of Significance
Final Initial Study – Mitigated Negative Declaration 149 21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Does the project:
a. Have the potential to substantially
degrade the quality of the environment,
substantially reduce the habitat of a fish
or wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, substantially reduce
the number or restrict the range of a rare
or endangered plant or animal or
eliminate important examples of the
major periods of California history or
prehistory? □ ■ □ □
b. Have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the
effects of other current projects, and the
effects of probable future projects)? □ □ ■ □
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or
indirectly? □ □ ■ □
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? As described in Section 4, Biological Resources, the Opportunity Areas proposed in the 2021-2029 Housing Element consist mostly of infill development in areas already developed with urban uses.
They are generally located away from riparian and other sensitive habitats. Adherence with 2030 General Plan goals and policies would minimize impacts from potential direct effects to special- status species and project implementation, but mitigation measures would be necessary in some areas, specifically mitigation measures BIO-1 through BIO-9 would be necessary in some cases to reduce these potential impacts to a less than significant level. 801
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Section 5, Cultural Resources, and Section 7, Geology and Soils, explain that, while no historical, archeological, or paleontological resources, have been identified in the Opportunity Areas, mitigation measures have been identified in this IS-MND in case of unanticipated discovery of archaeological and paleontological resources, and these measures would ensure adequate procedures are followed in case of unanticipated discovery, such as a Worker Environmental Awareness Program prior to construction; and halting work and retaining a qualified archaeologist or paleontologist if finds are made. The proposed project would therefore, with incorporated mitigation, not eliminate important examples of the major periods of California history or prehistory.
LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) As described in the discussion of environmental checklist Sections 1 through 21, the proposed project would have no impact, a less than significant impact, or a less than significant impact with mitigation incorporated for all environmental issues. These include short-term, long-term, and where appropriate, cumulative impacts. The analysis of the proposed project is inherently cumulative in nature because the project is a plan/program identifying potential future development sites to accommodate the City’s RHNA allocation over the 2021-2029 planning period.
Certain resource areas (e.g., agricultural and mineral) were determined to have no impact in comparison to existing conditions. Therefore, the project would not contribute to cumulative impacts related to these issues. Other issues (e.g., archaeological and paleontological resources, geology and soils, and hazards and hazardous materials) are by their nature project-specific and impacts at one location do not add to impacts at other locations or create additive impacts. In addition, the proposed project would not generate population growth in exceedance of regional and City forecasts; therefore, it would not contribute substantially to any cumulative increases in demand for public services, or utilities such as water, wastewater, and solid waste service. The project’s contribution to cumulative impacts would not be cumulatively considerable and cumulative impacts of the proposed project would therefore be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
In general, and as analyzed in this Initial Study, impacts to human beings are associated with air quality contaminants, hazards related to adverse geologic conditions, exposure to hazards and hazardous materials, and excessive noise. As detailed in analyses in Section 3, Air Quality, Section 7, Geology and Soils, Section 9, Hazards and Hazardous Materials , Section 10, Hydrology and Water Quality , and Section 13, Noise, the proposed project would not result, either directly or indirectly, in substantial adverse effects related to these hazards. Compliance with applicable rules and regulations described throughout this Initia l Study would reduce potential impacts on human beings to a less than significant level.
LESS THAN SIGNIFICANT IMPACT
802
1041
References
Final Initial Study – Mitigated Negative Declaration 151 References
Bibliography
California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan.
December 14, 2017. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf (accessed August 2021).
______. 2021. Ventura County. Ambient Air Quality Standard Designation Tool [GIS data set].
Ww2.arb.ca.gov/aaqs/aaqs-designation-tool (accessed July 2021).
California Department of Conservation (CDOC). 2021. Well Finder CalGEM GIS. https://maps.conservation.ca.gov/doggr/wellfinder/#openModal/-118.71399/34.29839/16 (accessed July 2021).
California Department of Finance (DOF). 2021. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark. May 2021. https://www.dof.ca.gov/Forecasting/Demographics/Estimates/E-5/ (accessed June 2021).
California Department of Transportation (Caltrans). 2019. California State Scenic Highways [tabular dataset]. August 2019. https://dot.ca.gov/programs/design/lap-landscape-architecture-and- community-livability/lap-liv-i-scenic-highways (accessed July 2021). _____. 2020. Transportation and Construction Vibration Guidance Manual (CT-HWANP-RT-20- 365.01.01). April. https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf (accessed August 2021).
California Department of Toxic Substances Control. 2021. EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/ (accessed August 2021).
California Energy Commission (CEC). 2021a. Total System Electric Generation. https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2019- total-system-electric-generation (accessed August 2021). ____. 2021b. “Supply and Demand of Natural Gas in California.” https://www.energy.ca.gov/data- reports/energy-almanac/californias-natural-gas-market/supply-and-demand-natural-gas- california (accessed August 2021).
Intergovernmental Panel on Climate Change (IPCC). 2014. Climate Change 2014 Synthesis Report.
Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and L.A.
Meyer (eds.)]. IPCC, Geneva, Switzerland.
National Park Service. 2015. Santa Monica Mountains – Riparian Woodland. https://www.nps.gov/samo/learn/nature/riparian-woodland.htm (accessed July 2021).
Southern California Association of Governments (SCAG). 2016. 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy. April 7, 2016. https://scag.ca.gov/resources-prior- plans (accessed August 2021).
______. 2020. 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy.
September 3, 2020. https://scag.ca.gov/read-plan-adopted-final-plan (accessed August 2021).
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Simi Valley, City of. 2001. Residential Design Guidelines. https://www.simivalley.org/home/showpublisheddocument/197/636898214285930000 (accessed August 2021).
______. 2012. Simi Valley General Plan Environmental Impact Report – SCH No. 2009121004 – Volume I: Final EIR. https://www.simivalley.org/departments/environmental- services/planning-division/documents-applications-and-development-activity/general-plan (accessed July 2021).
______. 2015. City of Simi Valley Landscape Design Guidelines. https://www.simivalley.org/home/showpublisheddocument/196/636306346286630000 (accessed August 2021).
______. 2021a. Housing Element Update.
______. 2021b. Safety and Noise Element Update.
State Water Resources Control Board. 2021. GeoTracker . https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Simi+Valley (accessed August 2021).
United States (U.S.) Census, 2011-2012. Census Viewer, Simi Valley, California Population. http://censusviewer.com/city/CA/Simi%20Valley (accessed August 2021).
United States Energy Information Administration (EIA). 2021a. Profile Data. July 15, 2021. https://www.eia.gov/state/data.php?sid=CA#ConsumptionExpenditures (accessed August 2021).
______. 2021b. California State Profile and Energy Estimates. February 18, 2021. https://www.eia.gov/state/?sid=CA (accessed August 2021).
Ventura County Air Pollution Control District. 2003. Ventura County Air Quality Assessment Guidelines. http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf (accessed August 2021).
List of Preparers
Rincon Consultants, Inc. prepared this IS-MND under contract to the City of Simi Valley. Persons involved in data gathering analysis, project management, and quality control are listed below.
RINCON CONSULTANTS, INC.
Matt Maddox, Principal
Greg Martin, AICP, Senior Planner/Project Manager
April Durham, Lead Analyst
Daphne Virlar-Knight, Analyst
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Appendix A
Responses to Comments on the Draft IS-MND
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GPA-2021-0001: Draft Housing Element Update
for the 2021-2029 Planning Period Responses to Comments on the Draft IS-MND
Responses to Comments on the Draft IS-MND
This section includes comments received during the circulation of the Draft Initial Study-Mitigated Negative Declaration (IS-MND) prepared for the City of Simi Valley GPA-2021-0001: Draft Housing Element Update for the 2021-2029 Planning Period (Project).
The Draft IS-MND was circulated for a 20-day public review period that began on August 26, 2021 and ended on September 24, 2021. The City of Simi Valley received four comment letters on the Draft IS-MND. The commenters and the page number on which each commenter’s letter appear are listed below.
Letter No. and Commenter Page No.
1 Sergio Vargas, Deputy Director, Watershed Planning and Permits Division, Watershed Protection District, Ventura County Public Works Department 2 2 Miya Edmonson, IGR/CEQA Branch Chief, California Department of Transportation, District 7 6 3 Nicole Collazo, Air Quality Specialist, Planning Division, Ventura County Air Pollution Control District (VCAPCD) 13
4 Erinn Wilson-Olgin, Environmental Program Manager I, South Coast Region, Department of Fish and Wildlife, State of California Natural Resources Agency 19 The comment letters and responses follow. The comment letters have been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number.
The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in comment Letter 1). If any revisions have been made to the IS-MND in response to these comments, they are shown with deleted text in strikethrough (strikethrough) format and added text in underline (underline) format in both this Responses to Comments section and in the body of the Initial Study in the Final IS-MND.
1 807
1046
WATERSHED
PROTECTION
WATERSHED PLAN
NING AND PERMITS DIVISION
800 South Victoria Avenue, Ventura, California 93009
Sergio Vargas, Deputy Director – (805) 650-4077
M E M O R A N D U M
DATE: September 1, 2021
TO: Monica Dionne
City of Simi Valley
FROM: Sergio Vargas, Deputy Director, Watershed Planning and Permits S.V.
SUBJECT: GPA-2021-001 Housing Element 2021-2029
Watershed Protection (WP) District Project Number: WC2021-0062
Pursuant to your request dated August 26, 2021 this office has reviewed the submitted materials and provides the following comments.
PROJECT LOC
ATION:
Simi Valley,
CA
PROJECT DE
SCRIPTION:
The project co
nsists of a comprehensive update to the 2013-2021 Housing Element, which comprises Chapter 4 of the Simi Valley 2030 General Plan (adopted in 2012). The 2013-2021 Housing Element was adopted in February 2014 and was designed to bring the Housing Element into compliance with State law in place at that time as part of the fifth cycle of Regional Housing Needs Assessment (RHNA) allocations. The General Plan Program Environmental Impact Report (2012 EIR) was completed in June 2012.
State law requires that housing elements shall be updated every eight years (California Government Code sections 65580 to 65589.8). The proposed update, the 2021- 2029 Housing Element, identifies sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups defined under state law (California Government Code Section 65583), analyzes governmental constraints to housing maintenance, improvement, and development, addresses conservation and improvement of the condition of existing affordable housing stock, and out lines policies that promote housing opportunities for all persons. The current project updates the City of Simi Valley Housing Element as part of the sixth cycle planning period, which spans October 2021 through October 2029.
WATERSHED PROT
ECTION COMMENTS:
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GPA-2021-001 Hous
ing Element 2021-2029
September 1, 2021