CITY OF VERNON
Prepared for:
City of Vernon
4305 S. Santa Fe Avenue
Vernon, CA 90058
Prepared by:
811 W. 7th Street, Suite 200
Los Angeles, CA 90017
June 2023
Vernon Westside Zone Change and
General Plan Amendment
Final Program Environmental Impact Report
CITY OF VERNON
Vernon Westside Zone Change and
General Plan Amendment
Final Program Environmental Impact Report
Prepared for:
City of Vernon
4305 S. Santa Fe Avenue
Vernon, California 90058
Prepared by:
Impact Sciences, Inc.
811 W. 7th Street, Suite 200
Los Angeles, California 90017
June 2023
Impact Sciences, Inc. i Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
TABLE OF CONTENTS
Section Page
1.0 Introduction ............................................................................................................................................1.0-1
1.1 Process .......................................................................................................................................1.0-1
1.2 Content of the Final PEIR........................................................................................................1.0-2
1.3 Review and Certification of the Final PEIR..........................................................................1.0-2
2.0 Comment Letters and Responses .........................................................................................................2.0-1
2.1 Responses to Comments Received on the Draft PEIR ........................................................2.0-1
2.2 Corrections and Additions....................................................................................................2.0-11
3.0 Mitigation Monitoring and Reporting Program ................................................................................3.0-1
3.1 Introduction ..............................................................................................................................3.0-1
4.0 List of EIR Preparers ..............................................................................................................................4.0-1 List of Tables
Table Page
2.0-1 List of Commenters on the Draft PEIR................................................................................................2.0-1
3.0-1 Mitigation Monitoring and Reporting Program Matrix....................................................................3.0-2 Impact Sciences, Inc. 1.0-1 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
1.0 INTRODUCTION
This document is the Final Program Environmental Impact Report (PEIR) for the Vernon Westside Zone Change and General Plan Amendment. This document together with the Draft PEIR and its technical appendices comprise the Final PEIR. The document has been prepared by the City of Vernon (City) in accordance with the California Environmental Quality Act (CEQA).
The Final PEIR is required under Section 15132 of the State CEQA Guidelines to include the Draft PEIR, comments and recommendations received on the Draft PEIR, the responses of the lead agency to significant environmental issues raised by those comments in the review and consultation process, and any other relevant information added by the lead agency (including minor changes to the PEIR). A Mitigation Monitoring and Reporting Program (MMRP) is also required; it can be a separate document, or, as in this case, included in the Final PEIR.
The evaluation and response to comments is an important part of the CEQA process as it allows the following: (1) the opportunity to review and comment on the methods of analysis contained within the Draft PEIR; (2) the ability to detect any omissions which may have occurred during preparation of the Draft PEIR; (3) the ability to check for accuracy of the analysis contained within the Draft PEIR; (4) the ability to share expertise; and (5) the ability to discover public concerns.
This document provides revisions to the Draft PEIR made in response to comments, staff review, and/or changes to the proposed project. These revisions also correct, clarify, and amplify the text of the Draft EIR, as appropriate, and do not alter the conclusions of the Draft PEIR.
1.1 PROCESS
In accordance with Section 15050 of the State CEQA Guidelines, the City is the lead agency that prepared both the Draft and Final PEIR for the Project.
The City prepared and circulated the Draft PEIR for a period of 45 days, extending from March 30, 2023, and ending on May 14, 2023. The Draft PEIR was available for review at Vernon City Hall; an electronic copy of the Draft PEIR was posted on the City’s website. A community meeting was held on Thursday, April 27, 2023, via Zoom. A Notice of Availability of the Draft PEIR was transmitted to responsible and trustee agencies, regulatory agencies and others to request comments on the Draft PEIR, pursuant to State CEQA Guidelines Section 15086. One comment letter was received during the comment period and one comment was received after the end of the comment period both comment letters are responded to in this
1.0 Introduction
Impact Sciences, Inc. 1.0-2 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
Final PEIR. The Final PEIR, together with the Zone Change and General Plan Amendment, will be submitted to Vernon City Council for review, and the Council will consider certification of the Final PEIR and approval of the Zone Change and General Plan Amendment.
1.2 CONTENT OF THE FINAL PEIR
As discussed above, the primary intent of the Final PEIR is to provide a forum to air and address comments pertaining to the analysis contained within the Draft PEIR. Pursuant to Section 15088 of the State CEQA Guidelines, the City has reviewed and addressed all comments received on the Draft PEIR by the comment period deadline. Included within the Final PEIR are the written comments that were submitted during the public comment period.
In order to adequately address the comments provided by interested agencies and the public in an organized manner, this Final PEIR includes the following chapters and appendices:
Section 1.0, Introduction. This chapter provides a brief introduction to the Final PEIR and its contents.
Section 2.0, Responses to Comments. This chapter provides a list of commenting agencies, organizations, and individuals. Responses to all comments on the Draft PEIR are also included in this chapter. Some of the comment letters received provided comments on the Zone Change and General Plan Amendment (not the anticipated environmental impacts). These project-related comments are addressed separately as part of the planning process. This chapter also provides a list of corrections and additions to the Draft PEIR.
None of the changes significantly impact the conclusions presented in the Draft PEIR.
Section 3.0, Mitigation Monitoring and Reporting Program. This chapter includes the MMRP prepared in compliance with the requirements of Section 21081.6 of the California Public Resources Code and Section 15091(d) and 15097 of the State CEQA Guidelines.
The Final PEIR also includes the previously circulated Draft PEIR.
1.3 REVIEW AND CERTIFICATION OF THE FINAL PEIR
Consistent with CEQA (Public Resource Code Section 21092.5), responses to agency comments are being forwarded to each commenting agency 10 days prior to certification of the Final PEIR. In addition, responses are also being distributed to all commenters via email. The Final PEIR can be downloaded at https://www.reimaginevernon.com/.
Impact Sciences, Inc. 2.0-1 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
2.0 COMMENT LETTERS AND RESPONSES
The Draft PEIR was submitted to the State Clearinghouse Office of Planning and Research and circulated for a 45-day public review on May 30, 2023. A community meeting was held on Thursday, April 27, 2023, via Zoom. A list of commenters on the Draft PEIR is shown in Table 2.0-1, List of Commenters on the Draft PEIR.
The original bracketed comment letters are provided followed by a numbered response to each bracketed comment. Individual comments within each letter are numbered and the response is given a matching number. The responses to comments did not require any changes to the Draft PEIR. Staff-initiated text changes are provided in Section 2.2, Corrections and Additions. Added text is shown in underline while deleted text is shown in strikethrough. The changes to the PEIR do not provide any new significant information and serve to clarify and amplify the information provided in the Draft PEIR.
Table 2.0-1
List of Commenters on the Draft PEIR
Letter
Number Organization Commenter Name Comment Date Response Page Number Letter 1 Los Angeles County Sanitation
Districts
Mandy Huffman April 27, 2023 2.0-5
Letter 2 County of Los Angeles,
Department of Public Works
Mark Pestrella May 23, 2023 2.0-11
2.1 RESPONSES TO COMMENTS RECEIVED ON THE DRAFT PEIR
The original bracketed comment letters are provided on the following pages, followed by the numbered responses. Individual comments within each letter are numbered and the response is given a matching number.
DOC 6908526.D23 A Century of Service
April 27, 2023
Ref. DOC 6880548
Mr. Daniel Wall, Public Works Director
City of Vernon, Public Works Department
4305 South Santa Fe Avenue
Vernon, CA 90058
Dear Mr. Wall:
DPEIR Response to Vernon Westside Zone Change and General Plan Amendment The Los Angeles County Sanitation Districts (Districts) received a Draft Program Environmental Impact Report (DPEIR) for the subject project on April 3, 2023. The proposed project is located within the jurisdictional boundaries of District No. 23. Previous comments submitted by the Districts to your agency in correspondence dated May 18, 2022 (copy enclosed) still apply to the subject project with the following comments:
1. Section 3.12 Utilities and Service Systems and Energy, Table 3.12-3 Project Area Existing Wastewater Generation (page 3.12-5) and Table 3.12-7 Project Wastewater Generation (page 3.12-22): to estimate the volume of wastewater the project will generate, go to www.lacsd.org, under Services, then Wastewater Program and Permits and select Will Serve Program, and then click on the Table 1, Loadings for Each Class of Land Use link for a copy of the Districts’ average wastewater generation factors.
2. The Districts should review future individual developments within the project area to determine whether or not sufficient trunk sewer capacity exists to serve each development and if Districts’ facilities will be affected by the development.
If you have any questions, please contact the undersigned at (562) 908-4288, extension 2743, or [email protected].
Very truly yours,
Mandy Huffman
Environmental Planner
Facilities Planning Department
MNH:mnh
Enclosure
1 2
3 Letter 1
DOC 6574241.D23
May 18, 2022
Ref. DOC 6532045
Mr. Daniel Wall
City of Vernon
4305 S. Santa Fe Avenue
Vernon, CA 90058
Dear Mr. Wall:
NOP Response to Vernon Westside Specific Plan
The Los Angeles County Sanitation Districts (Districts) received a Notice of Preparation (NOP) of a Draft Environmental Impact Report for the subject project on April 25, 2022. The proposed project is located within the jurisdictional boundaries of District No. 23. We offer the following comments regarding sewerage service:
1. The wastewater flow originating from the proposed project will discharge to local sewer lines, which are not maintained by the Districts, for conveyance to either or both the Districts’ Joint Outfall “H” Unit 1G Trunk Sewer, located in Alameda Street, south of Vernon Avenue, or Huntington Park Trunk Sewer, located in the public right-of-way north of Slauson Avenue, east of Malabar Street. The Districts’ 30-inch diameter Joint Outfall “H” Unit 1G Trunk Sewer has a capacity of 17.2 million gallons per day (mgd) and conveyed a peak flow of 7.7 mgd when last measured in 2014. The Districts’ 11.38-inch diameter Huntington Park Trunk Sewer has a capacity of 1.0 mgd and conveyed a peak flow of 0.3 mgd when last measured in 2019.
2. The wastewater generated by the proposed project will be treated at the Joint Water Pollution Control Plant located in the City of Carson, which has a capacity of 400 mgd and currently processes an average flow of 249.8 mgd.
3. In order to estimate the volume of wastewater the project will generate, go to www.lacsd.org, under Services, then Wastewater Program and Permits, select Will Serve Program, and scroll down to click on the Table 1, Loadings for Each Class of Land Use link for a copy of the Districts’ average wastewater generation factors.
4. The Districts are empowered by the California Health and Safety Code to charge a fee to connect facilities (directly or indirectly) to the Districts’ Sewerage System or to increase the strength or quantity of wastewater discharged from connected facilities. This connection fee is used by the Districts for its capital facilities. Payment of a connection fee may be required before this project is permitted to discharge to the Districts’ Sewerage System. For more information and a copy of the Connection Fee Information Sheet, go to www.lacsd.org, under Services, then Wastewater (Sewage) and select Rates & Fees. In determining the impact to the Sewerage System and applicable connection fees, the Districts will determine the user category (e.g. Condominium, Single Family Home, etc.) that best represents the actual or anticipated use of the parcel(s) or facilities on the parcel(s) in the development. For more specific information regarding the connection fee application procedure and fees, the developer should contact the Districts’ Wastewater Fee Public Counter at (562) 908-4288, extension 2727.
1 2
3 Letter 1
Mr. Daniel Wall 2 May 18, 2022
DOC 6574241.D23
5. In order for the Districts to conform to the requirements of the Federal Clean Air Act (CAA), the capacities of the Districts’ wastewater treatment facilities are based on the regional growth forecast adopted by the Southern California Association of Governments (SCAG). Specific policies included in the development of the SCAG regional growth forecast are incorporated into clean air plans, which are prepared by the South Coast and Antelope Valley Air Quality Management Districts in order to improve air quality in the South Coast and Mojave Desert Air Basins as mandated by the CAA. All expansions of Districts’ facilities must be sized and service phased in a manner that will be consistent with the SCAG regional growth forecast for the counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial. The available capacity of the Districts’ treatment facilities will, therefore, be limited to levels associated with the approved growth identified by SCAG. As such, this letter does not constitute a guarantee of wastewater service, but is to advise the developer that the Districts intend to provide this service up to the levels that are legally permitted and to inform the developer of the currently existing capacity and any proposed expansion of the Districts’ facilities.
If you have any questions, please contact the undersigned at (562) 908-4288, extension 2743, or [email protected].
Very truly yours,
Mandy Huffman
Environmental Planner
Facilities Planning Department
MNH:mnh 1
2 3
Letter 1
Impact Sciences, Inc. 2.0-5 Vernon Westside Zone Change and General Plan Amendment PEIR 1335.003 June 2023
Letter 1 Los Angeles County Sanitation Districts
Mandy Huffman, Environmental Planner
1955 Workman Mill Road
Whittier, CA 90601-1400
April 27, 2023
Response 1-1
The commenter provides a set of introductory comments. The commenter references the previous comments (dated May 18, 2022) submitted during the Notice of Preparation comment period. No further response is required.
Response 1-2
The commenter provides a link to estimate the volume of wastewater for future projects. Table 3.12-3, Project Area Existing Wastewater Generation, and Table 3.12-7, Project Wastewater Generation provides calculations of the estimated net change in wastewater generation over the lifetime of the Project. These are programmatic estimates. The role of the Program EIR is to provide the public and decision makers with reasonably foreseeable impacts using the available methodologies and tools. The PEIR provided adequate analysis of the anticipated future wastewater generation using commonly available methods. Further, the comment does not identify the potential for new physical environmental impacts not addressed in the EIR, and no specific response is required. The comment will be included as part of the record and forwarded to the decision-makers for their review and consideration prior to any action being taken on the Project.
Response 1-3
The commenter states the Districts should review individual projects to determine whether there is sufficient trunk sewer capacity. As stated in the EIR on page 3.12-33, the future projects within the Joint Water Pollution Control Plant service area would be required to follow the guidance of the County of Los Angeles Sanitation Districts’ Sewer System Management Plan. The precise location and connection would need to be determined at the time development is proposed. Should any new connections or upgrades be required, such upgrades would be subject to subsequent environmental review.
COUNTY OF LOS ANGELES
DEPARTMENT OF PUBLIC WORKS
“To Enrich Lives Through Effective and Caring Service”
900 SOUTH FREMONT AVENUE
ALHAMBRA, CALIFORNIA 91803-1331
Telephone: (626) 458-5100
http://dpw.lacounty.gov
May 23, 2023
MARK PESTRELLA, Director
ADDRESS ALL CORRESPONDENCE TO:
P.O. BOX 1460
ALHAMBRA, CALIFORNIA 91802-1460
IN REPLY PLEASE
REFER TO FILE: LD-4
Mr. Daniel Wall
Public Works Director
City of Vernon Public Works Department
4305 South Santa Fe Avenue
Vernon, CA 90058
Dear Mr. Wall:
ENVIRONMENTAL PLAN (RPPL2023002244)
VERNON WESTSIDE ZONE CHANGE AND GENERAL PLAN AMENDMENT
As requested, Public Works reviewed the proposed project. The proposed project is the Vernon Westside Zone Change and General Plan's Program Environmental Impact Report (PEIR), which has been prepared to evaluate the potential environmental impacts associated with this project.
For specific revisions, additions, or deletions of wording directly from the project document the specific section, subsection, and/or item along with the page number is first referenced then the excerpt from the document is copied within quotations using the following nomenclature:
Deletions are represented by a strikethrough.
Additions are represented by italics along with an underline.
Revisions are represented by a combination of the above.
We offer the following comment for your consideration:
1. General Comments:
1.1. Coordinate any potential overlapping scope with the following Public Works projects:
*. RDC0016551 – Slauson Station project (C1210) is in the concept stage. *. RDC0016279 - Metro ATC Rail to River, Segment A, project is in the design stage.
1 2
Letter 2
Mr. Daniel Wall
May 23, 2023
*. RDC0016317 - Slauson Blue Line Station Intersection Improvements is in the construction stage.
*. RDC0016496 - Randolph Corridor Improvement is in the budgeted stage.
For questions regarding comment 1.1, please contact Andrew Choie of Public Works, Transportation Planning and Programs Division, at (626) 458-4975 or [email protected].
2. Section 3.6.1.2, Floodplain Mapping and Hydraulic Modeling, pg. 3.6-4-3.6-5:
2.1. Flood Hazards, Line 7: "FEMA maps do not identify any 100-year flood hazard areas within the city":
The City of Vernon does not participate in the National Flood Insurance Program (NFIP), and this may be the reason why there are no flood hazards mapped in the City. Contact the Mitigation Division of Federal Emergency Management Agency (FEMA), Region 9, to confirm the status of FEMA-mapped flood hazards in the City.
FEMA's maps do not cover all possible flooding scenarios such as localized flooding issues. Many flood insurance claims are for flood damages that occur outside the FEMA 100-year flood zones. For this reason, FEMA and the County recommend residents consider purchasing flood insurance.
However, since the City does not participate in the NFIP, its residents are not eligible for flood insurance made available through the NFIP nor are they eligible for most forms of Federal flood disaster assistance. Residents instead would need to contact private carriers to ascertain the availability of flood insurance from them.
2.2. Flood Hazard Zones, Line 1: "The Los Angeles County Department of Public Works (Public Works) has incorporated data from the FEMA into an online map for El Niño Storm Hazard Areas":
The Public Works El Nino Storm Hazard Areas website, cited in the document, is no longer operable. However, it was based on Public Works' Flood Zone Determination website, which covers only FEMA flood zones in the coastal plains of Los Angeles County. Refer to the comment 2.1 regarding whether FEMA maps flood hazards in the City.
3 4
2 Letter 2
Mr. Daniel Wall
May 23, 2023
For questions regarding comment Nos. 2.1 and 2.2, please contact Diana Ibarra of Public Works, Stormwater Engineering Division, at (626) 458-6132 or [email protected].
3. Section 3.11.4, Environmental Impacts, pg. 3.11-14 – 3.11-15:
3.1. Page 3.11-14, Table 3.11-1, Total Home-based VMT per day:
The volumes for the project area and the City are both shown to be 2,611.
Justify this data since there are residents on the east side of Vernon, and it would make sense that the volume for the City should be higher than the project area.
3.2. Page 3.11-15, Table 3.11-2, Total Home-based VMT:
The volumes for the project area and the City are both shown to be 1,379.
Justify this data since there are residents on the east side of Vernon, and it would make sense that the volume for the City should be higher than the project area.
3.3. Page 3.11-15, Table 3.11-3, Total Home-based VMT:
The volumes for the project area and the City are both shown to be 19,315.
Justify this data since there are residents on the east side of Vernon, and it would make sense that the volume for the City should be higher than the project area.
3.4. Page 3.11-15, Paragraph 1, Line 4: "Under the Future Year 2040 No Project scenario, VMT per service population would be reduced by approximately 0.1 1 percent in the Project Area to 20.7, and 0.5 percent in the City of Vernon to 21.1 when compared to the existing conditions."
3.5. Page 3.11-15, Paragraph 2, Line 5: "Implementation of the Project is forecasted to reduce VMT per service population in the Project Area by approximately 0.7 3.4 percent and by 3.3 0.7 percent in the City, when compared to the Future No Project scenario."
For questions regarding comment Nos. 3.1 through 3.5, please contact Elizabeth Ibrahim of Public Works, Traffic Safety and Mobility Division, at (626) 300-4793 or [email protected].
6 9
4 5
7 8
Letter 2
Mr. Daniel Wall
May 23, 2023
4. Section 3.12, Utilities and Service Systems and Energy, Solid Waste, pg. 3.12-16:
We suggest the following edits:
4.1. Paragraph 1, title: "County of Los Angeles Integrated Waste Management Plan."
4.2. Paragraph 1, Line 6: "The IWMP calls for the establishment of 50 years of in-County permitted landfill capacity, as well as the County’s support for the development of disposal facilities out of the County establishes goals, policies, and strategies for the County to maintain adequate permitted disposal capacity, which includes the development of environmentally-safe and technically-feasible disposal facilities for solid waste that cannot be reduced, reused, recycled, or composted."
For questions regarding comment Nos. 4.1 and 4.2, please contact Trishena Robinson of Public Works, Environmental Programs Division, at (626) 238-5262 or [email protected].
If you have any questions or require additional information, please contact Toan Duong of Public Works, Land Development Division, at (626) 458-4921 or [email protected].
Very truly yours,
MARK PESTRELLA, PE
Director of Public Works
ARTHUR VANDER VIS, PE
Assistant Deputy Director
Land Development Division
DK:la
P:\ldpub\SUBPCHECK\Plan Checking Files\Projects submitted by Other Agencies\RPPL2023002244 - Vernon Westside Zone Change and General Plan Amendment\2023-05-10 Submittal\DPW_Not Cleared_2023-05-11_RPPL2023002244.docx 11 10
Letter 2
2.0 Comment Letters and Responses
Impact Sciences, Inc. 2.0-10 Vernon Westside Zone Change and General Plan Amendment PEIR 1335.003 June 2023
Letter 2 County of Los Angeles, Department of Public Works Mark Pestrella, P.E., Director of Public Works
900 South Fremont Avenue
Alhambra, CA 91803-1331
May 23, 2023
Response 2-1
The commenter provides a set of introductory comments. No further response is required.
Response 2-2
The comment provides a general request to coordinate with Public Works for any potential overlapping scope, including the following projects: Slauson Station, Metro ATC Rail to River, Slauson Blue Line Station Intersection Improvements, and Randolph Corridor Improvements. The comment will be included as part of the record and forwarded to the decision-makers for their review and consideration. The comment does not raise an issue within the meaning of CEQA and no response is required.
Response 2-3
The comment recommends contacting the Federal Emergency Management Agency (FEMA), Region 9, regarding the status of the FEMA-mapped flood hazards in the City. As discussed in Section 3.6.1.2, Floodplain Mapping and Hydraulic Modeling, of the DEIR, FEMA maps do not identify any 100-year flood hazard areas within the City. The FEMA Flood Map Service Center and the National Flood Hazard Layer (NFHL) Viewer indicates that the Project Area incorporates areas from two Flood Maps: 06037C1638G (revised December 21, 2018) and 06037C1805F (revised September 26, 2008). Both maps identify the Project Area as an area of minimal flood hazard (Zone X).
Response 2-4
The comment states that the Public Works El Nino Storm Hazard Areas website is no longer operable.
However, the website was based on the FEMA flood zones and refers to the previous comment regarding FEMA Flood Maps. Refer to Response 2-3.
Response 2-5
The comment states that the vehicle miles traveled (VMT) per day should be higher for the City than the Project Area. However, the 2,611 value is for the VMT, not the traffic volume. The VMT calculations were based on the Southern California Association of Governments model and the model’s Traffic Analysis Zone (TAZ) which offer a regional perspective. Therefore, the model often lacks the ability to capture small areas with a high level of accuracy. As a result, the Project Area effectively compassed all of the TAZs within the City where there are currently residential land uses (households and population). For this reason, the home-based VMT for the Project area is the same as that for the City.
2.0 Comment Letters and Responses
Impact Sciences, Inc. 2.0-11 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
Response 2-6
The comment states that the Future No Project VMT per day should be higher for the City than the Project Area. As provided in Response 2-5, the 1,379 value is for the VMT, not the traffic volume. Refer to Response 2-5.
Response 2-7
The comment states that the Future with Project VMT per day should be higher for the City than the Project Area. The 19,315 value is for the VMT, not the traffic volume. Refer to Response 2-5.
Response 2-8
The commenter notes that the Future Year 2040 No Project scenario would reduce VMT per service population by 1 percent. See Section 2.2, Corrections and Additions, for this revision made to Section 3.11, Transportation (page 3.11-15).
Response 2-9
The commenter notes that the Implementation of the Project would reduce VMT per service population in the Project Area by 3.4 percent and the City by 3.3 percent. See Section 2.2, Corrections and Additions, for this revision made to Section 3.11, Transportation (page 3.11-15).
Response 2-10
The commenter notes the word “of” is missing from the title. See Section 2.2, Corrections and Additions, for this revision made to Section 3.12, Utilities and Service Systems and Energy (page 3.12-16).
Response 2-11
The commenter provides clarifying language regarding the County’s Integrated Waste Management Plan.
See Section 2.2, Corrections and Additions, for this revision made to Section 3.12, Utilities and Service Systems and Energy (page 3.12-16).
2.2 CORRECTIONS AND ADDITIONS
As required by State CEQA Guidelines Section 15088, this section provides corrections or clarifications of certain statements in the DEIR. The correction(s) and/or addition(s) do not constitute significant new information, as defined by State CEQA Guidelines Section 15088.5, because none would result in new significant impacts or a substantial increase in the severity of any impact already identified in the DEIR.
New information is not significant unless the DEIR changes in a way that deprives the public of a
2.0 Comment Letters and Responses
Impact Sciences, Inc. 2.0-12 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
meaningful opportunity. Specifically, Section 15088.5(a) defines significant new information which requires recirculation to be any of the following:
1. A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.
4. The DEIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043).
Corrections or information has been added to the DEIR pursuant to State CEQA Guidelines Section 15132, as part of the preparation of the Final EIR (FEIR). Additions to the text of the DEIR are shown by underline and deletions from the text of the DEIR are shown by strikethrough unless otherwise described. Where mitigation measures are replaced or revised, the replacement or revised measures are listed under the relevant impact section; however, the revisions also apply to mitigation measures listed in the Executive Summary. As noted above, the following corrections and additions included herein involve minor modifications that clarify or amplify information contained in the DEIR and none would result in new significant impacts from those identified in the DEIR impact analysis or conclusions.
Transportation
“Under the Future Year 2040 No Project scenario, VMT per service population would be reduced by approximately 0.1 1 percent in the Project Area to 20.7, and 0.5 percent in the City of Vernon to
21.1 when compared to the existing conditions.”
“Implementation of the Project is forecasted to reduce VMT per service population in the Project Area by approximately 0.7 3.5 percent and by 0.7 3.2 percent in the City, when compared to the Future No Project scenario.”
2.0 Comment Letters and Responses
Impact Sciences, Inc. 2.0-13 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
Utilities and Service Systems and Energy
"County of Los Angeles Integrated Waste Management Plan."
"The IWMP calls for the establishment of 50 years of in-County permitted landfill capacity, as well as the County’s support for the development of disposal facilities out of the County establishes goals, policies, and strategies for the County to maintain adequate permitted disposal capacity, which includes the development of environmentally safe and technically feasible disposal facilities for solid waste that cannot be reduced, reused, recycled, or composted." Impact Sciences, Inc. 3.0-1 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
3.0 MITIGATION MONITORING AND
REPORTING PROGRAM
3.1 INTRODUCTION
The Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with Section 21081.6 of the California Environmental Quality Act (CEQA). It is the intent of this program to: (1) verify satisfaction of the required mitigation measures of the Program EIR (PEIR); (2) provide a methodology to document implementation of the required mitigation measures; (3) provide a record of the Monitoring Program; (4) identify monitoring responsibility; (5) establish administrative procedures for the clearance of mitigation measures; (6) establish the frequency and duration of monitoring; and (7) use existing review processes wherever feasible.
This MMRP describes the procedures that will be used to implement the mitigation measures adopted in connection with the approval of the project and the methods of monitoring such actions. It takes the form of a table identifying the responsible entity and timing for monitoring each mitigation measure.
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-2 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
Table 3.0-1
Mitigation Monitoring and Reporting Program Matrix
Mitigation Measure
Mitigation
Monitoring
Timing
Responsible Monitoring Entity
Impact – Air Quality
AQ-1: Dust Control Compliance with SCAQMD Rule 403
Any project whose construction activities involve the use of construction equipment and require a permit from City of Vernon Department of Public Works, must be consistent with SCAQMD Rule 403, best available dust control measures shall be implemented during Ground Disturbance Activities and active construction operations capable of generating dust.
Ongoing as
projects are
proposed
City of Vernon, Department of Public
Works
AQ-2: Equipment Maintenance
Any project whose construction activities involve the use of construction equipment and require a permit from City of Vernon Department of Public Works, must maintain construction equipment in good, properly tuned operating condition, as specified by the manufacturer, to minimize exhaust emissions. Documentation demonstrating that the equipment has been maintained in accordance with the manufacturer’s specifications shall be maintained per the proof of compliance requirements for a minimum of five years after the Certificate of Occupancy is issued. All construction equipment shall achieve emissions reductions that are no less than what could be achieved by a Tier 3 diesel emission control strategy for a similarly sized engine as defined by CARB regulations.
Ongoing as
projects are
proposed
City of Vernon, Department of Public
Works
AQ-3: Vehicle Idling Limit and Notification Signs
Any project whose construction activities involve the use of construction equipment and require a permit from City of Vernon Department of Public Works, shall limit vehicle idling during construction activities to five minutes as set forth in the California Code of Regulations, Title 13, Section 2449. Signs shall be posted in areas where they will be seen by vehicle operators stating idling time limits.
Ongoing as
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City of Vernon, Department of Public
Works
AQ-4: Non-Diesel Fueled Electrical Power
Any project whose construction activities involve the use of construction equipment and require a permit from City of Vernon Department of Public Works must obtain electricity from power poles rather than temporary gasoline or diesel-powered generators shall be used To the Extent Available and Feasible.
Ongoing as
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City of Vernon, Department of Public
Works
AQ-5: Emissions Standards for Off-Road Construction Equipment Greater than 50 Horsepower Any project whose construction activities involve the use of construction equipment, require a permit from City of Vernon Department of Public Works, and involve at least 5,000 cubic yards of on-site cut/fill on any given day, shall meet the U.S. Environmental Protection Agency’s (U.S. EPA) Tier 4 emission standards for all off-road diesel-powered construction equipment equal to or greater than 50 horsepower during construction. Operators shall maintain records of all off-road equipment associated with Project construction to document that each piece of equipment used meets these emission standards per the proof of compliance requirement for a minimum of Ongoing as
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City of Vernon, Department of Public
Works
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-3 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
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five years after the Certificate of Occupancy is issued.
In lieu of compliance with the above requirement, an air quality study prepared in accordance with the SCAQMD’s Air Quality Handbook may be provided by the Applicant or Owner demonstrating that Project construction activities would not exceed the SCAQMD’s regional and localized construction thresholds.
AQ-6: Use of Low Polluting Fuels
Any project whose construction activities involve the use of construction equipment, require a permit from City of Vernon Department of Public Works, and involve at least 5,000 cubic yards of on-site cut/fill on any given day, shall use low polluting fuels (i.e., compressed natural gas, liquid petroleum gas, and unleaded gasoline) for construction equipment less than 50 horsepower. In lieu of compliance with the above requirement, an air quality study prepared in accordance with the SCAQMD’s Air Quality Handbook may be provided by the Applicant or Owner demonstrating that Project construction activities would not exceed the SCAQMD’s regional and localized construction thresholds.
Ongoing as
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City of Vernon, Department of Public
Works
AQ-7: Emission Standards for On-Road Haul Trucks
Any project whose construction activities involve the use of construction equipment, require a permit from City of Vernon Department of Public Works, and involve more than 90 round-trip haul truck trips on any given day for demolition debris and import/export of soil, shall require construction haul truck operators for demolition debris and import/export of soil to use trucks that meet the California Air Resources Board’s (CARB) 2010 engine emissions standards at 0.01 g/bhp-hr. of particulate matter (PM) and 0.20 g/bhp-hr. of nitrogen oxides (NOX) emissions. Operators shall maintain records of all trucks associated with Project construction to document that each truck used meets these emission standards per the proof of compliance requirements in Subsection I.D.6.
In lieu of compliance with the above requirement, an air quality study prepared in accordance with the SCAQMD’s Air Quality Handbook may be provided by the Applicant or Owner demonstrating that Project construction activities would not exceed the SCAQMD’s regional and localized construction thresholds.
Ongoing as
projects are
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City of Vernon, Department of Public
Works
AQ-8: Routes for On-Road Haul Trucks
Any project whose construction activities involve the use of construction equipment and require a permit from City of Vernon Department of Public Works, shall reroute construction trucks away from congested streets or Sensitive Uses for construction contractors, as feasible. The burden of proving that compliance is infeasible shall be upon the Applicant or Owner. Where avoiding Sensitive Uses and congested streets altogether is infeasible, routing away from Sensitive Uses shall be prioritized over routing away from congested streets.
Ongoing as
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City of Vernon, Department of Public
Works
Impact – Cultural Resources
CUL-1: Historical Built Environment Studies
For projects where demolition or alteration of buildings or structures greater than 45 years is proposed, prior to the issuance of any demolition permits, the applicant shall prepare an inventory of buildings proposed for demolition located on the project site. The project applicant shall retain a historian or architectural historian who meets or exceeds the Secretary of Interior’s Professional Qualifications Standards to document and evaluate the historical significance of the affected buildings or structures in accordance with CEQA. If such documentation Ongoing as
projects are
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City of Vernon, Department of Public
Works
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-4 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
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and evaluation indicate that the building or structure qualifies as a significant historical resource, the resource shall be avoided and preserved in place if feasible. If avoidance or preservation is not feasible, a Historical Resources Treatment Plan or similar proposed plan, shall be prepared and implemented. Further documentation may be required and may include but is not limited to archival quality photographs, measured drawings, oral histories, interpretive signage, and/or other measures including, potentially, alteration of the resource in accordance with Secretary of the Interior’s Standards or relocation of the resource.
As defined in the California Code of Regulations (CCR) Title 4(3) Section 15126.4 (b)(2), in some circumstances, documentation of a historical resource, by way of historic narrative, photographs or architectural drawings, as mitigation for the effects of demolition of the resource will not mitigate the effects to point where clearly no significant effect on the environment would occur. In these cases, the Historical Resources Treatment Plan, or comparable plan, shall also evaluate the feasibility of retaining significant buildings or structures in their original locations and rehabilitating them according to the Secretary of the Interior’s Standards and Guidelines for Rehabilitating Historic Buildings.
CUL-2: Archaeological Resource Studies
Prior to any approval by the City for projects that involve any demolition, grading, trenching, or other ground disturbance, a Phase 1 Cultural Resources Study conducted by a qualified archaeologist meeting the Secretary of the Interior standards in archaeology shall be required. A Phase 1 study shall include a pedestrian survey of the project site to identify potential surficial archaeological resources and sufficient background archival research and field sampling to determine whether subsurface prehistoric or historic remains may be present. If the project site is completely paved and/or developed, a pedestrian survey may not be required. Archival research should include, at minimum, a records search conducted at the South Central Coast Information Center (SCCIC) and a Sacred Lands File (SLF) search conducted with the NAHC.
Any cultural resources identified shall be avoided and preserved in place if feasible. Where preservation is not feasible, each resource shall be subject to a Phase 2 evaluation for significance and eligibility for listing in the CRHR. Phase 2 evaluation shall include any necessary archival research to identify significant historical associations as well as mapping of surface artifacts, collection of functionally or temporally diagnostic tools and debris, and excavation of a sample of the cultural deposit to characterize the nature of the sites, define the artifact and feature contents, determine horizontal boundaries and depth below surface, and retrieve representative samples of artifacts and other remains.
Cultural materials collected from the sites shall be processed and analyzed in the laboratory according to standard archaeological procedures. The age of archaeological resources shall be determined using radiocarbon dating or other appropriate procedures; lithic artifacts, faunal remains, and other cultural materials shall be identified and analyzed according to current professional standards. The significance of the sites shall be evaluated according to the criteria of the CRHR. The results of the investigations shall be presented in a technical report following the standards of the California Office of Historic Preservation publication “Archaeological Resource Management Reports: Recommended Content and Format (1990 or latest edition)”. Upon completion of the work, all artifacts, other cultural remains, records, photographs, and other documentation shall be curated at an appropriate curation facility. All fieldwork, analysis, report production, and curation shall be fully funded by Ongoing as
projects are
proposed
City of Vernon, Department of Public
Works
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-5 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
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the applicant.
If any of the resources meet CRHR significance standards, the City shall ensure that all feasible recommendations for mitigation of impacts are incorporated into the final design and any permits issued for development. Any necessary archaeological data recovery excavation shall be carried out by a Registered Professional Archaeologist according to a research design reviewed and approved by the City prepared in advance of fieldwork and using appropriate archaeological field and laboratory methods consistent with the California Office of Historic Preservation Planning Bulletin 5 (1991), Guidelines for Archaeological Research Design, or the latest edition thereof.
As applicable, the final Phase 1 Inventory, Phase 2 Testing and Evaluation, Phase 3 Data Recovery reports shall be submitted to the City prior to final inspection of a construction permit.
Recommendations contained therein shall be implemented throughout all ground disturbance activities including, at minimum, requirements to follow for unanticipated archaeological discoveries during construction.
CUL-3: Unanticipated Discovery of Tribal Cultural Resources In the event that a cultural resource of Native American origin is identified in the Project Area during the implementation of MM CUL-2 or during any project-related ground disturbance, the City of Vernon, as Lead Agency, shall consult with local Native American tribes who have requested notification of projects under AB 52.
If the City, in consultation with the local Native American tribe(s), determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and implemented in accordance with state guidelines and in consultation with representatives of the Native American tribe(s). The mitigation plan may include but would not be limited to avoidance, capping in place, excavation and removal of the resource, interpretive displays, sensitive area signage, or other mutually agreed upon measures.
Ongoing as
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City of Vernon, Department of Public
Works
CUL-4: Unanticipated Discovery of Paleontological Resources In the event that paleontological resources are unearthed during ground-disturbing activities, the City of Vernon Public Works Division will be notified immediately, and all work will cease in the area of the find until a qualified paleontologist evaluates the find. Construction activity may continue unimpeded on other portions of the Project Site. The paleontologist shall determine the location, the time frame, and the extent to which any monitoring of earthmoving activities shall be required. The found deposits would be treated in accordance with federal, State, and local guidelines, including those set forth in California PRC § 21083.2.
Ongoing as
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City of Vernon, Department of Public
Works
Impact – Hazards and Hazardous Materials
HAZ-1: Phase I Investigation
Prior to construction activities onsite, a Phase I investigation shall be conducted to assess if there are any reasons to suspect that hazardous materials could be present. If current or past use of contaminants of potential concern are discovered through the Phase I investigation, or if the property has ever contained a gas station, dry cleaners or hazardous chemical storage tanks, a Phase II would be required. The Phase II investigation shall be conducted in accordance with guidelines developed by the Department of Toxic Substances Control (DTSC) and Environmental Protection Agency (EPA) for site assessments. The Phase II investigation shall estimate the potential threat to public health and the environment if concentrations of pesticides are encountered using Ongoing as
projects are
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City of Vernon, Department of Public Works
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-6 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
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methods outlined in DTSC’s Preliminary Endangerment Assessment Guidance Manual and DTSC’s Screening Level Human Health Risk Assessment guidance for implementing screening level risk analysis. The Phase II investigation shall be submitted to the City of Vernon for review and approval by an independent third-party reviewer. If the Phase II testing reveals concentrations of contaminants above health-based screening levels for residential exposure, remediation of the site shall be required to address residual contamination above healthbased level of concern. Remediation may include excavation and disposal of impacted soil or capping elevated areas beneath paved areas. The Construction Contractor shall implement the recommendations outlined in the Phase II.
Impact – Noise
NOI-1: During case-by-case review of individual projects, the City shall consider the application of the following strategies to reduce construction noise levels to the maximum extent feasible:
● Mufflers. Construction equipment shall be properly maintained and all internal combustion engine driven machinery with intake and exhaust mufflers and engine shrouds, as applicable, shall be in good condition and appropriate for the equipment. During construction, all equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers, consistent with manufacturers’ standards.
● Electrical Power. Electrical power, rather than diesel equipment, shall be used to run compressors and similar power tools and to power any temporary structures, such as construction trailers or caretaker facilities. ● Equipment Staging. All stationary equipment shall be staged as far away from the adjacent sensitive receptors as feasible.
● Equipment Idling. Construction vehicles and equipment shall not be left idling for longer than five minutes when not in use.
● Workers’ Radios. All noise from workers’ radios shall be controlled to a point that they are not audible at sensitive receptors near construction activity.
● Smart Back-up Alarms. Mobile construction equipment shall have smart back-up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels. Alternatively, back-up alarms shall be disabled and replaced with human spotters to ensure safety when mobile construction equipment is moving in the reverse direction.
● Disturbance Coordinator. Project applicants shall designate a disturbance coordinator who shall be responsible for responding to any local complaints about construction noise. The noise disturbance coordinator shall determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and identify remedies to correct the problem. A telephone number for the disturbance coordinator shall be conspicuously posted at the construction site.
Ongoing as
projects are
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City of Vernon, Department of Public
Works
3.0 Mitigation Monitoring and Reporting Program
Impact Sciences, Inc. 3.0-7 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
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NOI-2: During case-by-case review of individual projects, the City shall consider the application of the following strategy to reduce construction noise levels to the maximum extent feasible:
Temporary Sound Barriers. For construction activities located directly adjacent to sensitive receivers (e.g., residences, schools), temporary sound barriers shall be installed and maintained by the construction contractor between the construction site and adjacent receivers during the demolition, site preparation, grading phases, and building phases of construction. Temporary sound barriers shall consist of either sound blankets or other sound barriers/techniques such as acoustic padding or acoustic walls placed near adjacent residential buildings that have been field-tested to reduce noise. Barriers shall be placed such that the line-of-sight between noisegenerating construction equipment and adjacent sensitive land uses is blocked and shall be placed as close to the source equipment as feasible. As an alternative, applicants may prepare a Noise Study that demonstrates construction noise would not exceed ambient noise levels at nearby sensitive resources. The Noise Study shall incorporate best management practices and other noise reduction measures to reduce noise levels.
Ongoing as
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City of Vernon, Department of Public
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NOI-3: Prior to any grading or construction activity within 25 feet of an extremely fragile building (nonengineered timber and masonry) or potentially historical resource, applicants shall prepare a Vibration Control Plan. The Vibration Control Plan shall be prepared by a qualified structural engineer and shall include methods to minimize vibration, including but not limited to:
● Use of drilled piles or the use of a sonic vibratory pile driver rather than impact pile driving. ● Use of rubber-tired equipment rather than metal-tracked equipment. ● Avoiding the use of vibrating equipment when allowed by best engineering practices.
The Vibration Control Plan shall include a pre-construction survey letter establishing baseline conditions at potentially affected adjacent buildings. The survey letter shall provide a shoring design to protect the adjacent buildings from potential damage. The structural engineer may recommend alternative procedures that produce lower vibration levels, such as sonic pile driving or caisson drilling instead of impact pile driving. Development projects shall implement the structural engineer’s recommendations.
A Statement of Compliance signed by the Applicant and Owner is required to be submitted to Building and Safety at plan check and prior to the issuance of any permit. The Vibration Control Plan, prepared as outlined above, shall be documented by a qualified structural engineer, and shall be provided to the City upon request.
Ongoing as
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City of Vernon, Department of Public
Works
Impact Sciences, Inc. 4.0-1 Vernon Westside Zone Change & General Plan Amendment Final PEIR 1335.003 June 2023
4.0 LIST OF EIR PREPARERS
Impact Sciences, Inc., has prepared this environmental document for the City of Vernon. Persons directly involved in the review and preparation of this report include:
CITY OF VERNON
Daniel S. Wall, P.E., Director of Public Works
Manuel Garcia, Deputy Director of Public Works
THE ARROYO GROUP – SPECIFIC PLAN
Phil Burns, AICP, Principal
Lance Lowrey, ASLA, Senior Associate
Margaret Muñoz, Associate Planner
ITERIS, INC. – TRAFFIC ANALYSIS
Deepak Kaushik, Associate Vice President
Sean Daly, Senior Planner
IMPACT SCIENCES, INC. – EIR PREPARATION
Jessica Kirchner, AICP, CEO & Managing Principal
Brett Pomeroy, Associate Principal
Kara Yates Hines, Director of Operations & Publications Manager Margaret Lin, Senior Project Manager
Eleni Getachew, ENV SP, Planner
Annalie Sarrieddine, Associate Planner