Agenda packet, regular meeting — West Covina City Council, April 15, 2025 (part 2 of 4)

ORDINANCE NO. 2530

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
WEST COVINA, CALIFORNIA, AMENDING SECTION 22-
141 OF DIVISION 5 OF ARTICLE IV OF CHAPTER 22 OF

THE WEST COVINA MUNICIPAL CODE TO MAKE

CHANGES TO THE EXISTING TRUCK ROUTES
The City Council of the City of West Covina hereby finds and declares as follows:

WHEREAS, on December 10, 2024, the Traffic Committee reviewed and subsequently voted on a request to recommend that the City Council review the City’s current truck routes and consider removing certain streets that can potentially lead large trucks through residential neighborhoods; and
WHEREAS, on February 18, 2025, the City Council approved the list of recommendations made by the Traffic Committee from its November 2024 to January 2025 meetings, which included the recommendation to consider revisions to the City’s truck routes; and
WHEREAS, the City Council desires to amend Section 22-141 of Division 5 of Article IV of Chapter 22 of the West Covina Municipal Code to make changes to the existing truck routes; and
WHEREAS, all legal requirements prior to the adoption of this Ordinance have occurred.

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, DOES ORDAIN AS FOLLOWS:

SECTION 1. Recitals. The above recitals are true and correct and are incorporated herein.

SECTION 2. Amendment to Section 22-141. Section 22-141 of Division 5 of Article IV of Chapter 22 of the West Covina Municipal Code shall be amended to read as follows:

Sec. 22-141. Established.

The following streets and portions of streets are hereby designated and established as truck routes, to wit:

Amar Road, from Azusa Avenue to the westerly city limits.

Azusa Avenue, from the northerly city limits to the southerly city limits.

Ordinance No. 2530

Page 2 of 4 ends

Azusa Canyon Road, from San Bernardino Road to the northerly city limits.

Barranca Avenue, from Garvey Avenue South to the northerly city limits.

Citrus Street, from Garvey Avenue South to Workman Avenue.

Francisquito Avenue, from Glendora Avenue to the westerly city limits.

Garvey Avenue: (1) North portions between Barranca Street and the Barranca Street westbound freeway off-ramp. (2) South portions between West Covina Parkway and Sunset Avenue, between Citrus Street and the Citrus Street eastbound freeway on-ramp, and between Barranca Street and the Barranca Street eastbound freeway on-ramp.

Glendora Avenue, from Vincent Avenue to the southerly city limits.

Grand Avenue, from the San Bernardino Freeway to the northerly city limits.

Holt Avenue, from the Holt Avenue eastbound freeway off-ramp to the easterly city limits.

San Bernardino Road.

Sunset Avenue, from Francisquito Avenue to the southerly city limits.

Valley Boulevard.

Vincent Avenue, from Glendora Avenue to the San Bernardino Freeway on- and off-ramps.

West Covina Parkway, from Glendora Avenue to Garvey Avenue North.

SECTION 3. Environmental Compliance. The City Council hereby finds that it can be seen with certainty that there is no possibility the adoption and implementation of this Ordinance will have a significant effect on the environment. The Ordinance is therefore exempt from the environmental review requirements of the California Environmental Quality Act pursuant to Section 15061(b)(3) (General Rule) of Title 14 of the California Code of Regulations.

SECTION 4. Inconsistencies. Any provision of the West Covina Municipal Code or appendices thereto inconsistent with the provisions of this Ordinance, to the extent of such inconsistencies and no further, is hereby repealed or modified to that extent necessary to affect the provisions of this Ordinance.

SECTION 5. Severability. If any section, subsection, sentence, clause, phrase, or portion of this Ordinance is for any reason held to be invalid or unconstitutional by the Ordinance No. 2530

Page 3 of 4 ends

decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council of the City of West Covina hereby declares that it would have adopted this Ordinance and each section, subsection, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses, phrases, or portions be declared invalid or unconstitutional.

SECTION 6. Certification. The City Clerk shall certify to the passage and adoption of this Ordinance and shall cause the same to be published or posted as required by law.

SECTION 7. Effective Date. This Ordinance shall take effect thirty (30) days after its final passage.

PASSED, APPROVED AND ADOPTED this _____ day of ______, 2025.

Tony Wu
Mayor

APPROVED AS TO FORM ATTEST
Thomas P. Duarte Lisa Sherrick
City Attorney Assistant City Clerk
Ordinance No. 2530

Page 4 of 4 ends

I, LISA SHERRICK, Assistant City Clerk of the City of West Covina, California, do hereby certify that the foregoing Ordinance No. 2530 was introduced at a regular meeting of the City Council held on the 15th day of April, 2025, and adopted at a regular meeting of the City Council held on the ____ day of _____, 2025, by the following vote of the City Council:

AYES:

NOES:

ABSENT:

ABSTAIN:

Lisa Sherrick
Assistant City Clerk
ATTACHMENT NO. 3
REDLINE OF REVISIONS TO SECTION 22-141
(Changes Denoted in Underline and Strikethrough)
Sec. 22-141. Established.

The following streets and portions of streets are hereby designated and established as truck routes, to wit:

Amar Road, from Azusa Avenue to the westerly city limits.

Azusa Avenue, from the northerly city limits to the southerly city limits.

Azusa Canyon Road, from San Bernardino Road to the northerly city limits.

Barranca Avenue, from the South Garvey Avenue South to the northerly city limits.

California Avenue, northerly of Plaza Drive.

Citrus Street, from the South Garvey Avenue South to Workman Avenue.

Francisquito Avenue, from Glendora Avenue to the westerly city limits.

Garvey Avenue: (1) North portions between Pacific Avenue and Sunset Avenue and between Barranca Street and the Barranca Street westbound freeway offramp. (2) South portions between West Covina Parkway and Sunset Avenue, Glendora Avenue, between Citrus Street and the Citrus Street eastbound freeway on-ramp, and between Barranca Street and the Barranca Street eastbound freeway on-ramp.

Glendora Avenue, from Lakes Drive Vincent Avenue to the southerly city limits.

Grand Avenue, from the San Bernardino Freeway to the northerly city limits.

Holt Avenue, from the Holt Avenue eastbound freeway off-ramp to the easterly city limits.

Lakes Drive.

Plaza Drive.

San Bernardino Freeway.

San Bernardino Freeway interchanges.

San Bernardino Road.

State Street.

Sunset Avenue, from Francisquito Avenue to the southerly city limits.

Sunset Avenue, from North Garvey Avenue to West Covina Parkway.

Valley Boulevard.

Vincent Avenue, from Glendora Avenue to North Garvey Avenue. the San Bernardino Freeway on- and off-ramps.

Walnut Creek Parkway, from Vincent Avenue to Glendora Avenue.

West Covina Parkway, from Glendora Avenue to South Garvey Avenue North.

AGENDA ITEM NO. 4

AGENDA STAFF REPORT
City of West Covina | Office of the City Manager
DATE: April 15, 2025
TO: Mayor and City Council
FROM: Paulina Morales, City Manager
SUBJECT: Consideration of City Hall CCTV
RECOMMENDATION:

It is recommended that the City Council take the following actions:

1. Find that the City's bidding requirements and procedures are inefficient and impractical for the procurement of the installation of CCTV cameras at City Hall and in Council Chambers in accordance with Section 2-335(10) of the West Covina Municipal Code.

2. Authorize the City Manager to negotiate and execute an agreement with AM-TEC Total Security, Inc. (AM-TEC Security) in an amount not to exceed $129,221.59.

3. Adopt the following resolution:

RESOLUTION NO. 2025-29 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST

COVINA, CALIFORNIA, ADOPTING A BUDGET AMENDMENT FOR THE FISCAL YEAR COMMENCING JULY 1, 2024 AND ENDING JUNE 30, 2025 (CITY HALL CCTV IMPLEMENTATION).

BACKGROUND:

At the December 17, 2024 City Council meeting, Councilmember Gutierrez requested that the City Manager work with the West Covina Police Department (WCPD) to look into options for the installation of CCTV cameras throughout City Hall and Council Chambers to protect the public, City staff, and City Council Members from any potential threats. The City Council confirmed Councilmember Gutierrez's request.

DISCUSSION:

The WCPD, aiming for practical, cost-effective, and efficient solutions, focused on utilizing AM-TEC Security, a company that has provided security integration services to the WCPD, City Hall, and Public Works since 2018. AM-TEC Security is responsible for designing, installing, and maintaining access control systems and surveillance cameras across these locations without any issues, making them a trusted partner in this security effort. AM-TEC is a leader in the security industry with over 40 years of experience and possesses in-depth knowledge of the City of West Covina's infrastructure, building construction, and network systems, making the expansion of current security measures seamless and efficient. Further, given the proprietary nature of the existing systems and the active warranties on the installed equipment, selecting an alternate provider would compromise the integrity, compatibility, warranties, and security of the existing infrastructure. warranties, and security of the existing infrastructure.

Section 2-335(10) of Division 2 of Article VII of Chapter 2 of the West Covina Municipal Code provides the following exemption from the City's competitive bidding requirements: "When the City Council determines, by minute action or resolution, that the compliance with the bidding requirements and procedures is inefficient, impractical, or not in the best interest of the city, based on specifically identified conditions set forth on the record."
For the reasons outlined above, staff is requesting that the City Council find that compliance with the City's bidding requirements and procedures is inefficient and impractical in connection with the procurement for the installation of CCTV cameras at City Hall and authorize the City Manager to negotiate and enter into an agreement with AM-TEC Security in an amount not to exceed $129,221.59.

Staff is also requesting that the City Council approve the proposed resolution, approving the necessary budget amendment for this procurement.

LEGAL REVIEW:

The City Attorney's Office has reviewed the resolution and approved it as to form and will review and approve the agreement as to form prior to execution.

OPTIONS:

The City Council has the following options:

1. Adopt staff’s recommendation; or

2. Provide alternative direction.

Prepared by: Maria- Luisa Olea, Acting Finance Director & Human Resources/Risk Management
Additional Approval: Roxanne E. Lerma, Assistant City Manager Fiscal Impact
FISCAL IMPACT:

The total cost for the installation of the City Hall CCTV project is $129,222. Funds available for this project are in Fund 160.

Project
No.

Project
Name
Fund Account No. FY
2024-25
Budget
Request
Project
Cost
C250XX City
Hall
CCTV
160 160.503.80.81.00.00.75.75000. 129,222 $129,221.59
Attachments
Attachment No. 1 - CCTV & Metal Detector Presentation
Attachment No. 2 - CCTV Quote
Attachment No. 3 - AmTec Letter
Attachment No. 4 - Resolution No. 2025-29
CITY COUNCIL GOALS & OBJECTIVES: Protect Public Safety
Enhance City Image and Effectiveness

CITY HALL CCTV &
Metal Detector Implementation
Presented by WCPD Chief Cortina
Tuesday, February 18, 2025
ATTACHMENT NO. 1
Ø CCTV coverage of City Hall Exterior
Ø City Hall Parking Lot
Ø Interior of Council Chambers
Ø Council Chambers Access Control
Ø Replacing 2 outdated PD cameras
Ø Maintenance to PD exterior cameras
Labor: $65,000
Materials: $65,000
Total: $130,000
Estimate for Project Cost
Camera Types
PNM-C34404RQPZ
Ø 4K 4Ch PTRZ + 2MP 40x PTZ AI Camera
Ø Multi-sensor with 4 separate camera views, 1 controllable PTZ for a total of 5 cameras in one unit
PNM-C32083RVQ
Ø 4K x 4ch AI Camera
Ø Multi-sensor with 4 separate camera views
Camera Types
PNM-C12083RVD
Ø 6MP x 2CH AI Multi-directional Camera
Ø Multi-sensor camera with 2 views
Camera Types
QNV-C9083R
Ø 8MP IR Vandal Dome Camera
Ø 9 of these cameras will be installed
Camera Types
XNF-9010RV
Ø 12MP IR Fisheye Camera
Ø Camera that looks in a 360-degree pattern
Camera Features
Ø Required Equipment:

Walk-thru Detector (approximately $6,000)
Hand-Held Detector (approximately $300)
Metal Detector Considerations
Ø Required Staffing:
• 2 security personnel for entire meeting
(estimated hourly rate: $80 dollars per hour per
person)
• 2 Council Meetings a month plus Planning Commission
Meetings averaging at 4 hours per meeting = $31,000/year minimum
Metal Detector Considerations
CUSTOMER ESTIMATE NO. 5820
West Covina Police
1444 W Garvey Ave S
West Covina CA 91790
Created Date: 2/4/2025
Date: 2/4/2025
Valid For: 30 Day(s)
Site: West Covina Police *
Salesperson: Jeffrey Torok
Avigilon Access Control for Council Chambers:

Access Control Equipment:

Avigilon access control can, power supply, door controllers for 2 doors, and battery backup.

Part # Item Quantity Unit Price Total
AC-LSP-2DRMER-LCK
Two Door Mercury Dual Voltage Integrated Power
System supporting two AC-MER-CONT-1DR or one
AC-MER-CONT-2DR (Mercury hardware sold
separately). The advantage of a dual voltage power
supply is the ability to power both Mercury boards
and door locks from the same supply. Includes a
painted steel enclosure; removable pre drilled back
plate; controller standoffs and mounting screws
and a 75 watt 12V/2A and 24V/2A power supplybattery charger. The power supply is pre-wired to four Class 2; Power Limited (CL2PL) outputs (C4P
Board) delivering a regulated independent power
connection to each Mercury board and lock power
and control. The power supply features dual
outputs (12 & 24volts DC); form ‘C’ fault relay
contacts; a fire alarm input and network interface
(interface module sold separately) to enable
monitoring; reporting and control of the power
system from Access Control Manager (ACM) link.

Battery space for two 12V; 8Ah batteries is available
in cabinet (unless using two AC-MER-CONT-1DR).

Cabinet size: 12” x 14" x 4.5" with door lock and two
(2) keys. Weight 14 lb.(LifeSafety Power Part
Number: FPO75-B100C4PE1M)

1.00 $539.33 $539.33
AC-MER-CONTLP1501
Intelligent Controller; Linux Based with 1 door; 2
inputs and 2 outputs; PoE+ Support; expandable up
to 17 doors. (Mercury Part #: LP1501)

1.00 $761.66 $761.66
AC-MER-CONMR50
Series 3 Single Reader Interface Module: mag or
wiegand; 2 inputs; 2 relays (Mercury Part Number:

MR50-S3)

1.00 $405.47 $405.47
NP7-12 YUASA NP 7-12 12 VOLT 7AH BATTERY 2.00 $33.00 $66.00 Total $1,772.46
Incl. Tax of $0.00

Page 1 ends

ATTACHMENT NO. 2
CUSTOMER ESTIMATE NO. 5820
Door Hardware:

Door hardware has 2-readers, 2-electrified panic hardware kits with REX, 2-door loops, and door contacts.

Part # Item Quantity Unit Price Total
20NKS-00-0000
00 Signo20, Mullion, 13.56mHz &125kHz,
OSDP/Wiegand, Pigtail, Mobile Ready 2.00 $285.59 $571.18

COMMAND AC
MLRK1-VD
MLRK1-VD EL LATCH-PULLBACK KIT
L/BASEPLMOTOR DRIVEN 2.00 $395.63 $791.26

COMMAND AC

VDREXKIT-ED
VDREXKIT-ED REQ2EXIT,VON DUPRIN EXIT
DEVIC33/35 AND 98/99 SERI 2.00 $58.05 $116.10
KEEDEX INC KDLB K-DLB ARMOR DOOR LOOP 1/4"ID,FLEX,18 2.00 $41.18 $82.36 180RS-12-B GRI 180RS-12-B RECESSED STUBBY DOOR SWITCH
3/4" DIAMETER, BROWN 2.00 $10.50 $21.00
Total $1,581.90
Incl. Tax of $0.00
Access Control Cable & Wire Molding:

Cable, and wire molding, for two door controllers, power supply, electrified panic hardware, and readers, in council chambers.

Part # Item Quantity Unit Price Total
21965002 Genesis Access Control Riser Rl Yellow Bundle Cable 1.00 $866.52 $866.52 Wavenet
09W-350EA4-4
Wavenet 09W-350EA4-4 Cat5E Yellow Riser Cable
350MHz 1000' Box 0.50 $144.38 $72.19
MC Electrical
14/2 MC Electrical 14/2 x 50 ft. Solid MC Lite Cable 1.00 $85.33 $85.33 C210 Wiremold Cordmate II Cord Cover 12 ft. Kit, Cord
Hider for Home or Office, Holds 3 Cables, White 2.00 $47.33 $94.66 Total $1,118.70
Incl. Tax of $0.00
Labor:

Labor needed to install access control can, power supply, door controllers, run cable, electrical, wire molding for 2 doors, program, and provide training.

Part # Item Quantity Unit Price Total
PW LA Labor $8,250.00
Total $8,250.00
Incl. Tax of $0.00
Additional Hanwha Cameras for City Hall:

Camera Equipment:

This section is for the list of equipment below:
3-multi sensor cameras with PTZ mounted underneath the 3rd floor deck on the S/W, S/E, & N/E Corner. 1-multi sensor camera on the first floor by the elevators. 2-multi sensor cameras on 3rd floor on S/E & N/W corner. 1-multi sensor on east side of council chambers.
1-dome camera on 2nd floor looking at bridge to top parking level.

Page 2 ends

CUSTOMER ESTIMATE NO. 5820
4-dome cameras on inside hallways on 2nd and 3rd floor. 2-dome cameras in council chambers.
2-dome cameras to replace 2 cameras on 1st floor on south side. 1-360 fish eye camera in training room on 1st floor adjacent council chambers.

Part # Item Quantity Unit Price Total
PNMC34404RQPZ
Wisenet P series network vandal outdoor MultiDirectional camera with PTZ, [AI ON] 4CH x 8MP @ 15FPS / [AI OFF] 4CH x 8MP @ 20FPS + PTZ 40x 2MP
@ 60FPS, 4CH Remote PTRZ Lens 3.3~5.7mm (FoV
H: 109?~56?, V: 55?~31?), triple codec
H.265/H.264/MJPEG, 120dB WDR; IR viewable [4CH]
length 20m (65ft) / [PTZ] WiseIR 200m (656ft),
Analytics events based on AI engine: Object
detection [Person/Vehicle
(Car/Bus/Truck/Motorcycle/Bicycle)], IVA (Virtual
line/Area, Enter/Exit, Loitering, direction, intrusion), Appear/Disappear, WiseNR ?(using AI engine),
WiseStream?(Based on AI engine), I/O Box
compatibility; TPM with FIPS 140-2 level2, micro SD
card 512GB x2, IP66, IK10, NEMA4X, Operating
Temperature: -40?C~+50?C(-40?F~+122?F), HPoE
(injector included), Hard-coated dome bubble

3.00 $4,661.46 $13,984.38
PNMC32083RVQ
Wisenet P series network vandal outdoor MultiDirectional camera [AI ON] 4CH x 8MP @ 15FPS / [AI OFF] 4CH x 8MP @ 20FPS, Motorized Varifocal Lens

3.3~5.7mm (FoV H: 109?~56?, V: 55?~31?), triple
codec H.265/H.264/MJPEG, 120dB WDR; IR viewable
length [PoE+] 15m (49ft) / [HPoE] 20m (65ft), USB
port for easy installation, Analytics events based on
AI engine: Object detection [Person/Vehicle
(Car/Bus/Truck/Motorcycle/Bicycle)], IVA (Virtual
line/Area, Enter/Exit, Loitering, direction, intrusion), Appear/Disappear, WiseNR ?(using AI engine),
WiseStream?(Based on AI engine), I/O Box
compatibility; TPM with FIPS 140-2 level2, micro SD
card 512GB x2, IP66, IK10, NEMA4X, Operating
Temperature: -40?C~+55?C(-40?F~+131?F), PoE+
/HPoE, Hard-coated dome bubble

1.00 $1,962.72 $1,962.72
PNMC12083RVD
Network vandal outdoor 2CH AI IR dome camera,
(6MP X 2 sensors) 12MP @ 15fps, 3.4~6.8mm(2x)
(95.08?~47.64?) motorized varifocal lens, Triple
codec (H.265/H.264/MJPEG), IR viewable length 25m
(82ft), USB port for easy installation, Day & Night
(ICR), extremeWDR (120dB), DIS, Handover,
Analytics events based on AI engine: Object
detection(Person/Face/Vehicle/License plate), IVA
(Virtual line/Area, Enter/Exit, Loitering, direction,
intrusion), Analytics events : Defocus detection,

3.00 $1,257.37 $3,772.11

Page 3 ends

CUSTOMER ESTIMATE NO. 5820
Camera Equipment:

Part # Item Quantity Unit Price Total
Motion detection, Tampering, Audio detection,
Sound classification, Appear/Disappear, FIPS 140-2,
micro SD card 512GB, IP66, NEMA4X, IK10,
Operating temperature: -40?C~+55?C(-40?F ~
+131?F), Power: PoE+, Metal shielded RJ-45, Hardcoated dome bubble QNV-C9083R
Wisenet Q network outdoor vandal dome camera,
4K @ 30fps, motorized vari-focal lens 3.2~10.2mm
(H: 104?~31? / V: 55?~17?), triple codec
H.265/H.264/MJPEG with Wisestream III (Based on
AI engine), WiseNR?(Based on AI engine), WDR
120dB, IR viewable length 30m (98ft), WiseMD
based on AI engine, Classified object type:

Person/Vehicle (vehicle type:
car/bus/truck/motorcycle/bicycle); IVA events based
on AI engine: Virtual line (Crossing/Direction),
Virtual area
(Loitering/Intrusion/Enter/Exit/(Dis)Appear), *Audio:

Selectable(mic in/line in), defocus detection, hallway
View, SD card, video analytics, USB for easy
installation, open platform, IP66, IK10, PoE,
Operating temperature -30?C~+55?C(-22?F ~
+131?F) white color. * Alarm I/O and audio is
supported through an optional cable (SPP-C7400)

9.00 $570.42 $5,133.78
XNF-9010RV
Powered by WN7, 1/2.3" 12MP CMOS, Max
resolution 3008x3008 @ 30FPS, 1.08mm fixed focal
lends, Stereo graphic type lens, enhanced
resolution for the peripheral regions, H.265, H.264,
MJPEG codec supported, Fisheye, Single panorama,
Double panorama, Quad view, On board
dewarping, Digital PTZ, extreme WDR (120dB),
WiseStream? support, Wise IR, IR viewable length

32.8' (10m),? Virtual channel support, Plugin
support, selectable I/O port, Video Analytics,
Heatmap, People counting, Queue management,
Hard coated dome cover, Handover,
IP66/IK10/NEMA4X, PoE, 12VDC

1.00 $736.02 $736.02
SBP-156HMW
Hanging mount, Material : Aluminum, Color : White,
Dimensions : ?95.5x77.0 mm( ?3.76x3.03"),
Compatible with: XNP-9300RW/8300RW/6400RW,
QNP-6320R/6250R/6320H/6250H

3.00 $45.37 $136.11
SBP-300CMW Pendant Mount Accessory, white 3.00 $55.14 $165.42 SBP-300KMW1 Corner Mount Adapter Accessory, use with
SBP-300WMW1, White color, made of aluminum 2.00 $55.14 $110.28 SBP-300WMW1 Wall Mount Accessory (white), Compatible with white hanging caps 2.00 $55.14 $110.28
SBP-215HMW Hanging mount for PNM-C7083RVD/7082RVD and 2.00 $27.92 $55.84

Page 4 ends

CUSTOMER ESTIMATE NO. 5820
Camera Equipment:

Part # Item Quantity Unit Price Total
PNM-C12083RVD/12082RVD
SBV-215WCW Weather cap for PNM-C7083RVD/7082RVD and
PNM-C12083RVD/12082RVD 1.00 $27.92 $27.92
SBV-140BW
Back box for dome cameras. Compatible with: QNVC8083R/C9083R, QNV-C8011R/C8012/C9011R, QND-6011/6021,
QND-8011/8021, QND-6012R/6022R/6082R,
QND-7012R/7022R/7082R, QNE-8011R/8021R

1.00 $34.20 $34.20
Total $26,229.06
Incl. Tax of $0.00
Camera License:
17-WAVE camera licenses.

Part # Item Quantity Unit Price Total
WAVE-PRO-01
WAVE Professional License. Enables one (1) IP
stream recording, includes life-time SW upgrade.

No annual & maintenance cost required.

1.00 $115.16 $115.16
WAVE-PRO-16
WAVE Professional License. Enables sixteen (16) IP
stream recording, includes life-time SW upgrade.

No annual & maintenance cost required.

1.00 $1,619.24 $1,619.24
Total $1,734.40
Incl. Tax of $0.00
Camera Network:

POE injector for multi sensor and termination connectors for cameras and switch.

City to provide POE switch and connection to server at police department.

Part # Item Quantity Unit Price Total
TPE-215GI Trendnet 2.5g Poe+ Injector 1.00 $65.79 $65.79

PLATINUM
202010J
PLATINUM 202010J CAT6+ CONN 100/JAR
*PM=MOD PLUG RJ45 8C C6 40.00 $1.70 $68.00
Total $133.79
Incl. Tax of $0.00
Cable and Conduit:

Necessary cable and conduit for the 17 cameras installed at City Hall.

Part # Item Quantity Unit Price Total
Wavenet
09W-6EA4-9 Wavenet 09W-6EA4-6 Cat6 cable white 1000' box 5.00 $195.25 $976.25 4105012025K
1/2 in. Dia x 25 ft. Non Metallic UL Liquid Tight
Electrical Conduit Kit with 2 Straight and 2 Angle
Fittings Included

5.00 $36.75 $183.75
WSB350G COMMERCIAL ELECTRIC 1/2 in. 1-Gang 3-Holes
Weatherproof Box, Gray 8.00 $8.15 $65.20
5173-0 BELL 1-Gang Weatherproof Cover,
Vertical/Horizontal, Blank, Gray 8.00 $2.53 $20.24

Page 5 ends

CUSTOMER ESTIMATE NO. 5820
Cable and Conduit:

Part # Item Quantity Unit Price Total
26152 3/4 in. Electrical Metallic Tube (EMT) 1-Hole Straps 20 pack 2.00 $9.04 $18.08
853428 EMT 1/2 in. x 10 ft. Electric Metallic Tube (EMT) Conduit 10.00 $10.23 $102.30
26230 1/2 in. Electrical Metallic Tube (EMT) Compression Connectors (5-Pack) 2.00 $6.87 $13.74
051411262419 1/2 in. Electrical Metallic Tube (EMT) Compression Coupling (5-Pack) 2.00 $4.19 $8.38
Halex 58305 1/2 in. Type LL Threaded Conduit Body 4.00 $8.68 $34.72 58905 1/2 in. Rigid Type LR Threaded Conduit Body with
Cover and Gasket 2.00 $9.37 $18.74
26151 1/2 in. Standard Fitting Electrical Metallic Tube (EMT) 1-Hole Straps (25-Pack) 2.00 $9.40 $18.80
C210 Wiremold Cordmate II Cord Cover 12 ft. Kit, Cord
Hider for Home or Office, Holds 3 Cables, White 2.00 $47.33 $94.66 Total $1,554.86
Incl. Tax of $0.00
Installation:

AM-TEC will install 17-cameras according to provided map, install all cable, conduit, configure system, program, and provide training.

Part # Item Quantity Unit Price Total
Scissor Lift (1 Day Use) 3.00 $150.00 $450.00
Bucket Lift (1-Day Use) 1.00 $150.00 $150.00
PW LA Labor $33,660.00
Total $34,260.00
Incl. Tax of $0.00
Additional Hanwha Cameras for Police Department:

Camera Equipment:

This section is for 3 multi sensor PTZ cameras.
1-multi sensor PTZ on N/E corner.
1-multi sensor PTZ on S/E corner.
1-multi sensor PTZ on S/W corner.

3.00 $4,661.46 $13,984.38

Page 6 ends

CUSTOMER ESTIMATE NO. 5820
Additional Hanwha Cameras for Police Department:
line/Area, Enter/Exit, Loitering, direction, intrusion), Appear/Disappear, WiseNR ?(using AI engine),
WiseStream?(Based on AI engine), I/O Box
compatibility; TPM with FIPS 140-2 level2, micro SD
card 512GB x2, IP66, IK10, NEMA4X, Operating
Temperature: -40?C~+50?C(-40?F~+122?F), HPoE
(injector included), Hard-coated dome bubble
SBP-300KMW1 Corner Mount Adapter Accessory, use with
SBP-300WMW1, White color, made of aluminum 3.00 $55.14 $165.42 SBP-156WMW
Wall/Pole mount, Material : Aluminum, Color :

White, Dimensions :135(W)x183(H)x302(D)mm
(5.31x7.20x11.89"), Compatible with:

XNP-9300RW/8300RW/6400RW,
QNP-6320R/6250R/6320H/6250H. Stainless Steel
Pole straps are not included.

3.00 $103.99 $311.97
Total $14,461.77
Incl. Tax of $0.00
Camera Licenses:

AM-TEC will reuse existing camera licenses.

Part # Item Quantity Unit Price Total
Total $0.00
Incl. Tax of $0.00
Camera Network:
8-network connections for cameras and switch.

City to provide POE switches.

Part # Item Quantity Unit Price Total

PLATINUM
202010J
PLATINUM 202010J CAT6+ CONN 100/JAR
*PM=MOD PLUG RJ45 8C C6 8.00 $1.70 $13.60
Total $13.60
Incl. Tax of $0.00
Cable and Conduit:

AM-TEC will reuse existing cable and add additional conduit.

Part # Item Quantity Unit Price Total
4105012025K
1/2 in. Dia x 25 ft. Non Metallic UL Liquid Tight
Electrical Conduit Kit with 2 Straight and 2 Angle
Fittings Included

3.00 $36.75 $110.25
Total $110.25
Incl. Tax of $0.00

Page 7 ends

CUSTOMER ESTIMATE NO. 5820
Installation:

AM-TEC will install 3-multi sensor PTZ cameras, configure cameras, program, and provide training.

Part # Item Quantity Unit Price Total
PW LA Labor $5,610.00
Total $5,610.00
Incl. Tax of $0.00
Hanwha Cameras for Parking Structure and Parking Lot:

Camera Equipment:

This section is for 2 multi sensor PTZ cameras.
1-multi sensor PTZ on west side of parking lot.
1-multi sensor PTZ on west side of top level parking structure.

2.00 $4,661.46 $9,322.92
SBP-156WMW
Wall/Pole mount, Material : Aluminum, Color :

White, Dimensions :135(W)x183(H)x302(D)mm
(5.31x7.20x11.89"), Compatible with:

XNP-9300RW/8300RW/6400RW,
QNP-6320R/6250R/6320H/6250H. Stainless Steel
Pole straps are not included.

3.00 $103.99 $311.97
Total $9,634.89
Incl. Tax of $0.00
Camera Licenses:
2-Additional WAVE camera licenses for the 2 multi sensor cameras with PTZs.

Part # Item Quantity Unit Price Total
WAVE-PRO-01
WAVE Professional License. Enables one (1) IP
stream recording, includes life-time SW upgrade.

No annual & maintenance cost required.

2.00 $115.16 $230.32
Total $230.32

Page 8 ends

CUSTOMER ESTIMATE NO. 5820
Camera Licenses:

Part # Item Quantity Unit Price Total
Incl. Tax of $0.00
Camera Network, Radios, and UPS Power:
2-point-to-point radios, 1-UPS power, 1-48volt to POE++ high power switch, POE injectors, and data ends.

City to provide POE switches.

Part # Item Quantity Unit Price Total

PLATINUM
202010J
PLATINUM 202010J CAT6+ CONN 100/JAR
*PM=MOD PLUG RJ45 8C C6 14.00 $1.70 $23.80
202051J PLATINUM TOOLS ezEX44 RJ45 Shielded External
Ground Connector 6.00 $6.97 $41.82
MPL-260-CNN
MultiHaul™ TG point-to-point bundle, 1000Mbps,
plug & play setup, includes 2 x radios, PoE injectors,
MK

1.00 $1,314.47 $1,314.47
UPL12/24-200-
600
UPSPro 12/24V 200Ah 2400Wh Outdoor Backup
Power System, 12/24V Out, 60A MPPT TempComp
Chrg Ctrl w/Status Disp/30A Ld Ctrl, 120/240VAC In
48V 600W Batt Chrg, 2-4"Pole/Wall Mt AL Lock Encl

1.00 $2,544.68 $2,544.68
TP-SW5GVERSABT
5Prt Unmng GigE Versa PoE L2 Net Switch, 44-58V
WireTerm In, 1x 90W 802.3bt PoE + 3x 802.3at 30W
PoE + 1x 24V 12W Pasv PoE Port, Pinout
4pr:1,2,4,5V+;3,6,7,8V-, 2pr:4,5V+;7,8V-,
Shield/Surge, DIN Mt

1.00 $430.58 $430.58
Shipping: 1 Box 20 x 17 x 24 38 lbs 4 Boxes 14 x 10 x
13 42 lbs each 1 Box 12 x 9 x 4 2 lbs 1.00 $189.31 $189.31 Total $4,544.66
Incl. Tax of $0.00
Cable, Conduit, and Camera Pole:

Camera pole, electrical cable, shielded Ct6E cable, Cat6, conduit, boxes, and fittings.

Part # Item Quantity Unit Price Total
4105012025K
1/2 in. Dia x 25 ft. Non Metallic UL Liquid Tight
Electrical Conduit Kit with 2 Straight and 2 Angle
Fittings Included

2.00 $36.75 $73.50
6ESOSPBK2 WAVENET CAT6E OUTDOOR SHIELDED CABLE 1.00 $330.00 $330.00 Wavenet
09W-6EA4-9 Wavenet 09W-6EA4-6 Cat6 cable white 1000' box 0.50 $195.25 $97.63 112-1472CR 100 ft. 14 Gauge White Solid Copper THHN Wire 1.00 $56.13 $56.13 112-1471CR 100 ft. 14 Gauge Black Solid Copper THHN Wire 1.00 $56.13 $56.13 112-1475CR 100 ft. 14 Gauge Green Solid Copper THHN Wire 1.00 $56.13 $56.13 853428 EMT 1/2 in. x 10 ft. Electric Metallic Tube (EMT) Conduit 28.00 $9.23 $258.44
26230 1/2 in. Electrical Metallic Tube (EMT) Compression Connectors (5-Pack) 4.00 $8.87 $35.48
051411262419 1/2 in. Electrical Metallic Tube (EMT) Compression Coupling (5-Pack) 5.00 $6.19 $30.95

Page 9 ends

CUSTOMER ESTIMATE NO. 5820
Cable, Conduit, and Camera Pole:

Part # Item Quantity Unit Price Total
26151 1/2 in. Standard Fitting Electrical Metallic Tube (EMT) 1-Hole Straps (25-Pack) 4.00 $9.40 $37.60
58605 1/2 in. Rigid Standard Fitting Type-LB Threaded
Aluminum Conduit Body 6.00 $9.37 $56.22
Halex 58305 1/2 in. Type LL Threaded Conduit Body 3.00 $9.37 $28.11 58905 1/2 in. Rigid Type LR Threaded Conduit Body with
Cover and Gasket 3.00 $9.37 $28.11
WB2550 1/2 in. Weatherproof 5-Hole Double Gang Box 1.00 $14.62 $14.62 2-Gange Cover
Plate Gray 2-Gang Weatherproof Blank Cover 1.00 $5.80 $5.80 10A4SS188S 10 Foot Square Straight Aluminum Security Camera Pole, 4 Inch Wide, 0.188 Inch Wall Thickness 1.00 $1,233.23 $1,233.23 White Powder
Coat White Powder Coat 1.00 $89.10 $89.10
Shipping 1 Light Pole 1.00 $343.75 $343.75
Total $2,830.93
Incl. Tax of $0.00
Installation:

AM-TEC will install 2-multi sensor PTZ cameras, 2-point-to-point radios, install UPS power system with electrical, install conduit on parking structure to police department, configure cameras, program, and provide training.

Part # Item Quantity Unit Price Total
Bucket Lift (1-Day Use) 2.00 $150.00 $300.00
PW LA Labor $11,880.00
Total $12,180.00
Incl. Tax of $0.00
Camera Cleaning for City Hall & Police Department:

One Time Cleaning:

AM-TEC will clean all inside, outside, and parking structure cameras at City Hall and Police Department. AMTEC will clean cameras according to manufactures recommendation.

Cameras with calcium build up or camera dome fading will be polished with a compound and sealed with ceramic coating.

Cleaning supplies, polishing material, and ceramic coating are included in this quote.

Part # Item Quantity Unit Price Total
PW LA Labor $2,970.00
Total $2,970.00
Incl. Tax of $0.00

Page 10 ends

CUSTOMER ESTIMATE NO. 5820
Please respond to [email protected] with a
confirmation of acceptance if you would like to proceed.

Please verify with your local authority if you will require a permit.

Note that any unexpected condition or exception beyond the standard scope of installation will/may require a change order.

Labor $63,270.00
Materials $65,951.59
Total $129,221.59
Incl. Tax of $0.00
Powered by TCPDF (www.tcpdf.org) Page 11/11
ATTACHMENT NO. 3
ATTACHMENT NO. 4
RESOLUTION NO. 2025-29
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF WEST COVINA, CALIFORNIA, ADOPTING A
BUDGET AMENDMENT FOR THE FISCAL YEAR
COMMENCING JULY 1, 2024 AND ENDING JUNE 30,
2025 (CITY HALL CCTV IMPLEMENTATION)
The City Council of the City of West Covina hereby finds and declares as follows:

WHEREAS, on May 7, 2024, the City Manager presented to the City Council a proposed budget for Fiscal Year 2024-25 in compliance with Section 2-151(m) of the West Covina Municipal Code; and
WHEREAS, the City held meetings and community workshops and conducted an online budget survey in order to solicit input from the public regarding the proposed budget; and
WHEREAS, on June 4, 2024, the City Council adopted a budget for the 2024-2025 Fiscal Year; and
WHEREAS, amendments must periodically be made to the budget to conform to changed circumstances following adoption of the budget.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. The City Council hereby approves Budget Amendment No. 2025-14, attached hereto as Exhibit A, for Fiscal Year 2024-25.

SECTION 2. The City Clerk shall certify to the adoption of this resolution and shall enter the same in the book of original resolutions and it shall become effective immediately.

APPROVED AND ADOPTED this 15th day of April, 2025.

Tony Wu
Mayor
APPROVED AS TO FORM ATTEST
Thomas P. Duarte Lisa Sherrick
City Attorney Assistant City Clerk
I, LISA SHERRICK, Assistant City Clerk of the City of West Covina, California, do hereby certify that the foregoing Resolution No. 2025-29 was duly adopted by the City Council of the City of West Covina, California, at a regular meeting thereof held on the 15th day of April, 2025, by the following vote of the City Council:

AYES:

NOES:

ABSENT:

ABSTAIN:

Lisa Sherrick
Assistant City Clerk
Exhibit A
City of West Covina
Fiscal Year 2024-25
Budget Amendment No. 2025-14
City Hall CCTV Implementation
Fund Name (Fund No.) Current
Budget
Proposed
Amendment
Amended
Budget
Capital Projects (160)
Revenue 468,192 468,192
Expenditures 7,079,877 129,222 7,209,099
Fund (160) Total -6,611,685 -129,222 -6,740,907
AGENDA ITEM NO. 5

AGENDA STAFF REPORT
City of West Covina | Office of the City Manager
DATE: April 15, 2025
TO: Mayor and City Council
FROM: Paulina Morales, City Manager
SUBJECT: CONSIDERATION OF PROFESSIONAL SERVICE AGREEMENTS FOR FIRE

PREVENTION PLAN CHECK SERVICES
RECOMMENDATION:

It is recommended that the City Council take the following actions:

1. Authorize the City Manager to execute a Professional Services Agreement with KJ Consultants Inc. for Fire Prevention plan check and inspection services, for a term of five (5) years, in an annual amount not to exceed $40,000, in such final form as approved by the City Attorney.

2. Authorize the City Manager to execute a Professional Services Agreement with MAK Fire Protection Engineering & Consulting, Inc. for Fire Prevention plan check and inspection services, for a term of five (5) years, in an annual amount not to exceed $20,000, in such final form as approved by the City Attorney.

BACKGROUND:

The Fire Prevention Bureau of the Fire Department is responsible for conducting plan check services for all construction projects within the City. These reviews ensure compliance with the California Fire Code, California Building Code, and California Health & Safety Code, and are critical to maintaining life safety standards in new and renovated developments.

Currently, the Bureau is staffed by one full-time Fire Prevention Specialist and several part-time Fire Prevention Specialists, whose primary responsibilities are focused on conducting field inspections. While these team members play a critical role in maintaining on-site compliance and safety, the Bureau does not have dedicated staff assigned to conduct plan reviews in-house.

To meet the demands of ongoing development activity and ensure timely plan review services, the City engages plan check consultants to supplement internal resources. This approach provides several key benefits:

Operational Continuity: Ensures timely review of construction plans without causing delays to the development process.

Cost Efficiency: Consultant services are funded through permit fees, minimizing the financial burden on the General Fund and avoiding the need for full-time plan check personnel.

Scalable Support: Allows the City to respond flexibly to fluctuations in project volume without permanently expanding staff.

Specialized Expertise: Consultants bring up-to-date knowledge of fire codes and regulations, ensuring thorough and compliant reviews.
ensuring thorough and compliant reviews.

Consultant Agreements
On October 20, 2020, the City Council authorized Professional Services Agreements with three consulting firms:

KJ Consultants (Susan Privitera-Johnson) – Not to exceed $30,000 MAK Fire Protection Engineering & Consulting, Inc. – Not to exceed $15,000 PE Consulting Group – Not to exceed $15,000
The City has successfully utilized the services of KJ Consultants and MAK Fire Protection, both of which have consistently delivered high-quality and dependable plan check services. PE Consulting Group was unable to meet the City’s insurance requirements and did not provide services.

On July 19, 2022, the City Council approved the ratification of expenditures for KJ Consultants and MAK Fire Protection and authorized:

A Second Amendment to the agreement with KJ Consultants A Third Amendment to the agreement with MAK Fire Protection Subsequent amendments were executed to extend the terms of both contracts:

MAK Fire Protection agreement currently expires on June 30, 2025 KJ Consultants agreement currently expires on September 30, 2025 DISCUSSION:

The use of plan check consultants continues to be an effective and financially responsible strategy to support the Fire Prevention Bureau’s operations. As noted, current staffing is focused primarily on inspections, and the City lacks dedicated in-house personnel to consistently manage fire plan review services. The demand for plan checks fluctuates with the pace of development activity, and utilizing consultants allows the City to scale services up or down as needed without committing to permanent staffing increases.

The annual cost for plan check services provided by KJ Consultants and MAK Fire Protection varies based on the volume of construction activity submitted each fiscal year. Both consultants are compensated in accordance with the fee schedules outlined in their respective professional services agreements. Importantly, these costs are fully recovered through permit and plan check fees paid by applicants, making them pass-through expenses.

The table below summarizes the total consultant expenditures over the past five fiscal years:

Vendor FY19-20 FY20-21 FY21-22 FY22-23 FY23-24
KJ Consultants $0.00 $23,790 $38,215 $59,779 $8,260
MAK Fire Protection $23,360 $7,161 $26,606 $50,797 $8,110 As illustrated above, annual expenditures fluctuate depending on demand. The temporary reduction in consultant costs during FY 2023–24 reflects a part-time staff member assuming some plan check responsibilities on an interim basis. However, with development activity expected to remain steady, and internal staffing remaining limited, maintaining consultant support is necessary to ensure continuity and responsiveness in plan review services.

Procurement and Contract Authority
Section 2-327 of the West Covina Municipal Code defines "professional services" as "services that involve the exercise of professional discretion and independent judgment based on an advanced or specialized knowledge, expertise or training gained by formal studies or experience. Such services include, but are not limited to, those provided by accountants, appraisers, architects, attorneys, auditors, economic and financial advisors, election consultants, engineers, environmental consultants, information services consultants, instructors, insurance advisors, land use consultants, plan checkers, physicians, public relations consultants, surveyors, and other specialized consultants."
In order to ensure continued access to qualified and responsive plan check support for fire-related construction review, staff recommends the City Council authorize the City Manager to execute new Professional Services Agreements with the following terms:

KJ Consultants, Inc. – Term of five (5) years, with an annual not-to-exceed amount of $40,000 MAK Fire Protection Engineering & Consulting, Inc. – Term of five (5) years, with an annual not-to-exceed amount of $20,000
Both agreements would be effective July 1, 2025.

LEGAL REVIEW:

The City Attorney's Office has reviewed the agreements and approved them as to form and will review them as to final form prior to execution.

OPTIONS:

The City Council has the following options:

1. Approve staff's recommendations; or

2. Provide alternative direction.

Prepared by: Mike Browne, Acting Fire Chief
Additional Approval: Roxanne E. Lerma, Assistant City Manager Fiscal Impact
FISCAL IMPACT:

Expenditures for Fire Prevention plan check services are passed through to the applicant through plan check fees. There is no fiscal impact on the general fund. Cost for services are allocated out of the Fire Department Fire Prevention Bureau, Professional Services Account No. 110.502.32.41.00.00.61.61100. Expenditures are directly offset by revenues obtained. Revenues are reflected in the Fire Department Fire Prevention Revenue Account No. 110.408.32.00.00.00.46.46300.

Attachments
Attachment No. 1 - Professional Services Agreement with KJ Consultants Inc.

Attachment No. 2 - Professional Services Agreement with MAK Fire Protection Engineering & Consulting, Inc.

CITY COUNCIL GOALS & OBJECTIVES: Protect Public Safety
A Well-Planned Community
Expand Economic Development Opportunities
ATTACHMENT NO. 1

CITY OF WEST COVINA

PROFESSIONAL SERVICES AGREEMENT
WITH
KJ CONSULTANTS INC.

FOR

PLAN CHECK AND INSPECTION SERVICES FOR THE FIRE DEPARTMENT THIS PROFESSIONAL SERVICES AGREEMENT is made and entered into as of July 1, 2025 (“Effective Date”), by and between the CITY OF WEST COVINA, a municipal corporation (“City”), and KJ CONSULTANTS INC., a California corporation (“Consultant”).

RECITALS
A. City proposes to utilize the services of Consultant as an independent contractor to City to provide plan check and inspection services as requested by the Fire Department, as more fully described herein; and
B. Consultant represents that it has that degree of specialized expertise necessary and holds all necessary licenses to practice and perform the services herein contemplated; and C. City and Consultant desire to contract for the specific services described herein and desire to set forth their rights, duties and liabilities in connection with the services to be performed; and
D. No official or employee of City has a financial interest, within the provisions of Sections 1090-1092 of the California Government Code, in the subject matter of this Agreement.

NOW, THEREFORE, for and in consideration of the mutual covenants and conditions contained herein, the parties hereby agree as follows:

1.0. SERVICES PROVIDED BY CONSULTANT

1.1. Scope of Services. Consultant shall provide the following professional services:
(a) Plan check review for new construction and remodeled plans, as requested by the City. Consultant shall ensure that all plans submitted to the City’s Fire Prevention Bureau meet all applicable fire and life safety requirements as outlined in Federal, State, and local laws, codes, and regulations. (b) Ensure that all plan reviews are completed and returned to the Fire Prevention Bureau within seven (7) days of Consultant’s receipt or fortyeight (48) hours of receipt for expedited services. (c) In a professional manner, furnish all labor, technical, administrative, professional and other personnel, supplies and materials, equipment, printing, vehicles, transportation, office space and facilities, tests, testing and analysis, and calculations necessary or proper to perform and complete the services required by this Agreement, except as herein expressly specified to be furnished by the City.

1.2. Professional Practices. All professional services to be provided by Consultant pursuant to this Agreement shall be provided by personnel experienced in their respective fields and in a manner consistent with the standards of care, diligence and skill ordinarily exercised by KJ Consultants Inc.

Form Revised October 2024
2 professional consultants in similar fields and circumstances in accordance with sound professional practices. Consultant also warrants that it is familiar with all laws that may affect its performance of this Agreement and shall advise City of any changes in any laws that may affect Consultant’s performance of this Agreement. Consultant shall keep itself informed of State and Federal laws and regulations which in any manner affect those employed by it or in any way affect the performance of its service pursuant to this Agreement. The Consultant shall at all times observe and comply with all such laws and regulations. City officers and employees shall not be liable at law or in equity for any claims or damages occurring as a result of failure of the Consultant to comply with this section.

1.3. Performance to Satisfaction of City. Consultant agrees to perform all the work to the reasonable satisfaction of the City. Evaluations of the work will be conducted by the City Manager or his or her designee. If the quality of work is not satisfactory, City in its discretion has the right to:
(a) Meet with Consultant to review the quality of the work and resolve the matters of concern;
(b) Require Consultant to repeat the work at no additional fee until it is satisfactory; and/or
(c) Terminate the Agreement as hereinafter set forth.

1.4. Warranty. Consultant warrants that it shall perform the services required by this Agreement in compliance with all applicable Federal and California employment laws, including, but not limited to, those laws related to minimum hours and wages; occupational health and safety; fair employment and employment practices; workers’ compensation; and all other Federal, State and local laws and ordinances applicable to the services required under this Agreement.

1.5. Non-Discrimination. In performing this Agreement, Consultant shall not engage in, nor permit its agents to engage in, discrimination in employment of persons because of their race, religious creed, color, national origin, ancestry, physical disability, mental disability, reproductive health decisionmaking, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or veteran or military status, except as permitted pursuant to Section 12940 of the California Government Code.

1.6. Non-Exclusive Agreement. Consultant acknowledges that City may enter into agreements with other consultants for services similar to the services that are subject to this Agreement or may have its own employees perform services similar to those services contemplated by this Agreement.

1.7. Confidentiality. Employees of Consultant in the course of their duties may have access to financial, accounting, statistical, and personnel data of private individuals and employees of City. Consultant covenants that all data, documents, discussion, or other information developed or received by Consultant or provided for performance of this Agreement are deemed confidential and shall not be disclosed by Consultant without written authorization by City. City shall grant such authorization if disclosure is required by law. All City data shall be returned to City upon the termination of this Agreement. Consultant’s covenant under this Section shall survive the termination of this Agreement.

1.8. Public Records Act Disclosure. Consultant has been advised and is aware that KJ Consultants Inc.

Form Revised October 2024
3 this Agreement and all reports, documents, information and data, including, but not limited to, computer tapes, discs or files furnished or prepared by Consultant, or any of its subcontractors, pursuant to this Agreement and provided to City may be subject to public disclosure as required by the California Public Records Act (California Government Code Section 7920.000 et seq.).

Exceptions to public disclosure may be those documents or information that qualify as trade secrets, as that term is defined in California Government Code Section 7924.510, and of which Consultant informs City of such trade secret. The City will endeavor to maintain as confidential all information obtained by it that is designated as a trade secret. The City shall not, in any way, be liable or responsible for the disclosure of any trade secret including, without limitation, those records so marked if disclosure is deemed to be required by law or by order of the court.

2.0. COMPENSATION AND BILLING

2.1. Compensation. City agrees to pay Consultant in accordance with the fee schedule set forth in Exhibit “A,” attached hereto and incorporated herein (the “Fee Schedule”). Consultant’s annual compensation shall not exceed Forty Thousand Dollars ($40,000.00).

2.2. Additional Services. Consultant shall not receive compensation for any services provided outside the Scope of Services specified herein unless the City, prior to Consultant performing the additional services, approves such additional services in writing. It is specifically understood that oral requests and/or approvals of such additional services or additional compensation shall be barred and are unenforceable. Should the City request in writing additional services that increase the Scope of Services, an additional fee based upon the Consultant’s standard hourly rates shall be paid to the Consultant for such additional services.

2.3. Method of Billing. Consultant may submit invoices to the City for approval on a progress basis, but no more often than once a month. Said invoice shall be based on the total of all Consultant’s services which have been completed to City’s sole satisfaction. City shall pay Consultant’s invoice within forty-five (45) days from the date City receives said invoice. Each invoice shall describe in detail the services performed, the date of performance, and the associated time for completion. Any additional services approved and performed pursuant to this Agreement shall be designated as “Additional Services” and shall identify the number of the authorized change order, where applicable, on all invoices.

2.4. Records and Audits. Records of Consultant’s services relating to this Agreement shall be maintained in accordance with generally recognized accounting principles and shall be made available to City for inspection and/or audit at mutually convenient times from the Effective Date until three (3) years after the termination or expiration of this Agreement.

3.0. TIME OF PERFORMANCE

3.1. Commencement and Completion of Work. Unless otherwise agreed to by the parties, the professional services to be performed pursuant to this Agreement shall commence within five (5) days from the Effective Date of this Agreement. Failure to commence work in a timely manner and/or diligently pursue work to completion may be grounds for termination of this Agreement.

3.2. Excusable Delays. Neither party shall be responsible for delays or lack of performance resulting from acts beyond the reasonable control of the party or parties. Such acts shall include, but not be limited to, acts of God, fire, strikes, material shortages, compliance with laws or regulations, riots, acts of war, or any other conditions beyond the reasonable control of a KJ Consultants Inc.

Form Revised October 2024
4 party. If a delay beyond the control of the Consultant is encountered, a time extension may be mutually agreed upon in writing by the City and the Consultant. The Consultant shall present documentation satisfactory to the City to substantiate any request for a time extension.

4.0. TERM AND TERMINATION

4.1. Term. This Agreement shall commence on the Effective Date and continue for a period of five (5) years, ending on June 30, 2030, unless previously terminated as provided herein or as otherwise agreed to in writing by the parties.

4.2. Notice of Termination. The City reserves and has the right and privilege of canceling, suspending or abandoning the execution of all or any part of the work contemplated by this Agreement, with or without cause, at any time, by providing at least fifteen (15) days prior written notice to Consultant. In the event of such termination, Consultant shall immediately stop rendering services under this Agreement unless directed otherwise by the City. If the City suspends, terminates or abandons a portion of this Agreement such suspension, termination or abandonment shall not make void or invalidate the remainder of this Agreement.

If the Consultant defaults in the performance of any of the terms or conditions of this Agreement, it shall have ten (10) days after service upon it of written notice of such default in which to cure the default by rendering a satisfactory performance. In the event that the Consultant fails to cure its default within such period of time, the City shall have the right, notwithstanding any other provision of this Agreement, to terminate this Agreement without further notice and without prejudice to any other remedy to which it may be entitled to at law, in equity, or under this Agreement.

The City also shall have the right, notwithstanding any other provisions of this Agreement, to terminate this Agreement, at its option and without prejudice to any other remedy to which it may be entitled to at law, in equity, or under this Agreement, immediately upon service of written notice of termination on the Consultant, if the latter should:
(a) Be adjudged bankrupt;
(b) Become insolvent or have a receiver of its assets or property appointed because of insolvency;
(c) Make a general assignment for the benefit of creditors; (d) Default in the performance of any obligation or payment of any indebtedness under this Agreement;
(e) Suffer any judgment against it to remain unsatisfied or unbonded of record for thirty (30) days or longer; or
(f) Institute or suffer to be instituted any procedures for reorganization or rearrangement of its affairs.

4.3. Compensation. In the event of termination, City shall pay Consultant for reasonable costs incurred and professional services satisfactorily performed up to and including the effective date of the City’s written notice of termination, within forty-five (45) days after the effective date of the notice of termination or the final invoice of the Consultant, whichever occurs KJ Consultants Inc.

Form Revised October 2024
5 last. Compensation for work in progress shall be prorated based on the percentage of work completed as of the effective date of termination in accordance with the fees set forth herein.

4.4. Documents. In the event of termination of this Agreement, all documents prepared by Consultant in its performance of this Agreement including, but not limited to, finished or unfinished design, development and construction documents, data studies, drawings, maps and reports, shall be delivered to the City within ten (10) days of the effective date of the notice of termination, at no cost to City.

5.0. INSURANCE

5.1. Minimum Scope and Limits of Insurance. Consultant shall obtain, maintain, and keep in full force and effect during the life of this Agreement all of the following minimum scope of insurance coverages with an insurance company authorized to do business in California, with a current A.M. Best’s rating of no less than A:VII, and approved by City:
(a) Commercial general liability insurance with coverage at least as broad as Insurance Services Office form CG 00 01, in an amount not less than Two Million Dollars ($2,000,000.00) per occurrence, Four Million Dollars ($4,000,000.00) general aggregate, for bodily injury, personal injury, and property damage. The policy must include contractual liability that has not been amended. Any endorsement restricting standard ISO “insured contract” language will not be accepted.
(b) Automobile insurance at least as broad as Insurance Services Office form CA 00 01 covering bodily injury and property damage for all activities of the Consultant arising out of or in connection with work to be performed under this Agreement, including coverage for any owned, hired, non-owned, or rented vehicles, in an amount not less than One Million Dollars ($1,000,000.00) combined single limit for each accident. (c) Workers’ compensation insurance as required by the State of California, with Statutory Limits, and Employer’s Liability Insurance with a limit of no less than One Million Dollars ($1,000,000.00) per accident for bodily injury or disease. Consultant agrees to waive, and to obtain endorsements from its workers’ compensation insurer waiving subrogation rights under its workers’ compensation insurance policy against the City, its officers, agents, employees, and volunteers for losses arising from work performed by Consultant for the City and to require each of its subcontractors, if any, to do likewise under their workers’ compensation insurance policies.

By execution of this Agreement, the Consultant certifies as follows:

I am aware of, and will comply with, Section 3700 of the California Labor Code, requiring every employer to be insured against liability of Workers’ Compensation or to undertake self-insurance before commencing any of the work.

The Consultant shall also comply with Section 3800 of the California Labor Code by securing, paying for and maintaining in full force and effect for the duration of this Agreement, complete Workers’ Compensation Insurance, KJ Consultants Inc.

Form Revised October 2024
6 and shall furnish a Certificate of Insurance to the City before execution of this Agreement by the City. The City, its officers and employees shall not be responsible for any claims in law or equity occasioned by failure of the consultant to comply with this section.
(d) Professional liability (errors & omissions) insurance that covers the services to be performed in connection with this Agreement, in the minimum amount of One Million Dollars ($1,000,000.00) per claim and in the aggregate. Any policy inception date, continuity date, or retroactive date must be before the Effective Date of this Agreement and Consultant agrees to maintain continuous coverage through a period no less than three (3) years after completion of the services required by this Agreement.

If the Consultant maintains higher limits or has broader coverage than the minimums shown above, the City requires and shall be entitled to all coverage, and to the higher limits maintained by the Consultant. Any available insurance proceeds in excess of the specified minimum limits of insurance and coverage shall be available to the City.

5.2. Endorsements. The insurance policies are to contain, or be endorsed to contain, the following provisions:
(a) Additional Insureds: The City of West Covina and its elected and appointed boards, officers, officials, agents, employees, and volunteers are additional insureds with respect to: liability arising out of activities performed by or on behalf of the Consultant pursuant to its contract with the City; products and completed operations of the Consultant; premises owned, occupied or used by the Consultant; automobiles owned, leased, hired, or borrowed by the Consultant.
(b) Notice of Cancelation: Each insurance policy required above shall provide that coverage shall not be canceled, except with notice to the City. (c) Primary Coverage: The Consultant’s insurance coverage shall be primary insurance as respects the City of West Covina, its officers, officials, agents, employees, and volunteers. Any other insurance maintained by the City of West Covina shall be excess and not contributing with the insurance provided by this policy.
(d) Waiver of Subrogation: Consultant hereby grants to City a waiver of any right to subrogation which any insurer of said Consultant may acquire against the City by virtue of the payment of any loss under such insurance.

Consultant agrees to obtain any endorsement that may be necessary to affect this waiver of subrogation, but this provision applies regardless of whether or not the City has received a waiver of subrogation endorsement from the insurer.
(e) Coverage Not Affected: Any failure to comply with the reporting provisions of the policies shall not affect coverage provided to the City of West Covina, its officers, officials, agents, employees, and volunteers. (f) Coverage Applies Separately: The Consultant’s insurance shall apply KJ Consultants Inc.

Form Revised October 2024
7 separately to each insured against whom claim is made or suit is brought, except with respect to the limits of the insurer’s liability.

5.3. Deductible or Self Insured Retention. If any of such policies provide for a deductible or self-insured retention to provide such coverage, the amount of such deductible or self-insured retention shall be approved in advance by City. The City may require the Consultant to purchase coverage with a lower retention or provide proof of ability to pay losses and related investigations, claim administration, and defense expenses within the retention. The policy language shall provide, or be endorsed to provide, that the self-insured retention may be satisfied by either the named insured or City.

5.4. Certificates of Insurance. Consultant shall provide to City certificates of insurance showing the insurance coverages and required endorsements described above, in a form and content approved by City, prior to performing any services under this Agreement. The City reserves the right to require complete, certified copies of all required insurance policies, including endorsements required by these specifications, at any time.

5.5. Non-limiting. Nothing in this Section shall be construed as limiting in any way the indemnification provision contained in this Agreement.

6.0. GENERAL PROVISIONS

6.1. Entire Agreement. This Agreement constitutes the entire agreement between the parties with respect to any matter referenced herein and supersedes any and all other prior writings and oral negotiations. This Agreement may be modified only in writing, and signed by the parties in interest at the time of such modification.

6.2. Representatives. The City Manager or his or her designee shall be the representative of City for purposes of this Agreement and may issue all consents, approvals, directives and agreements on behalf of the City, called for by this Agreement, except as otherwise expressly provided in this Agreement.

Consultant shall designate a representative for purposes of this Agreement who shall be authorized to issue all consents, approvals, directives and agreements on behalf of Consultant called for by this Agreement, except as otherwise expressly provided in this Agreement.

6.3. Key Personnel. It is the intent of both parties to this Agreement that Consultant shall make available the professional services of Kurt Johnson, who shall coordinate directly with City. Any substitution of key personnel must be approved in advance in writing by City’s Representative.

6.4. Notices. Any notices, documents, correspondence or other communications concerning this Agreement or the work hereunder may be provided by personal delivery, Email or by U.S. mail. If by U.S. mail, it shall be addressed as set forth below and placed in a sealed envelope, postage prepaid, and deposited in the United States Postal Service. Such communication shall be deemed served or delivered: (a) at the time of delivery if such communication is sent by personal delivery; (b) one (1) business day after the Email is sent if such communication is sent by Email, provided that no delivery failure notification has been received; and (c) 72 hours after deposit in the U.S. Mail as reflected by the official U.S. postmark if such communication is sent through regular United States mail.

KJ Consultants Inc.

Form Revised October 2024
8 IF TO CONSULTANT: IF TO CITY:

KJ Consultants Inc.
12340 Seal Beach Blvd. Ste. B131
Seal Beach, CA 90740
City of West Covina
1444 West Garvey Ave. South
West Covina, CA 91790
Email: [email protected]
Attn: Kurt Johnson
Email: [email protected]
Attn: Mike Browne
With a copy to:

City of West Covina
1444 West Garvey Ave. South
West Covina, CA 91790
Email: [email protected]
Attn: Sherri Yuasa

6.5. Attorneys’ Fees. If litigation is brought by any party in connection with this Agreement against another party, the prevailing party shall be entitled to recover from the opposing party all costs and expenses, including reasonable attorneys’ fees, incurred by the prevailing party in the exercise of any of its rights or remedies hereunder or the enforcement of any of the terms, conditions, or provisions hereof.

6.6. Governing Law. This Agreement shall be governed by and construed under the laws of the State of California without giving effect to that body of laws pertaining to conflict of laws. In the event of any legal action to enforce or interpret this Agreement, the parties hereto agree that the sole and exclusive venue shall be a court of competent jurisdiction located in Los Angeles County, California.

6.7. Assignment. Consultant shall not voluntarily or by operation of law assign, transfer, sublet or encumber all or any part of Consultant’s interest in this Agreement without City’s prior written consent. Any attempted assignment, transfer, subletting or encumbrance shall be void and shall constitute a breach of this Agreement and cause for termination of this Agreement.

Regardless of City’s consent, no subletting or assignment shall release Consultant of Consultant’s obligation to perform all other obligations to be performed by Consultant hereunder for the term of this Agreement.

6.8. Indemnification and Hold Harmless. Consultant agrees to defend, with counsel of City’s choosing, indemnify, hold free and harmless the City, its elected and appointed officials, officers, agents and employees, at Consultant’s sole expense, from and against any and all claims, demands, actions, suits or other legal proceedings brought against the City, its elected and appointed officials, officers, agents and employees arising out of the performance of the Consultant, its employees, and/or authorized subcontractors, of the work undertaken pursuant to this Agreement. The defense obligation provided for hereunder shall apply without any advance showing of negligence or wrongdoing by the Consultant, its employees, and/or authorized subcontractors, but shall be required whenever any claim, action, complaint, or suit asserts as its basis the negligence, errors, omissions or misconduct of the Consultant, its employees, and/or authorized subcontractors, and/or whenever any claim, action, complaint or suit asserts liability against the City, its elected and appointed officials, officers, agents and employees based upon the work performed by the Consultant, its employees, and/or authorized subcontractors under this Agreement, whether or not the Consultant, its employees, and/or authorized subcontractors are KJ Consultants Inc.

Form Revised October 2024
9 specifically named or otherwise asserted to be liable. Notwithstanding the foregoing, the Consultant shall not be liable for the defense or indemnification of the City for claims, actions, complaints or suits arising out of the sole active negligence or willful misconduct of the City. This provision shall supersede and replace all other indemnity provisions contained in the City’s specifications, which shall be of no force and effect.

6.9. Independent Contractor. Consultant is and shall be acting at all times as an independent contractor and not as an employee of City. Consultant shall have no power to incur any debt, obligation, or liability on behalf of City or otherwise act on behalf of City as an agent.

Neither City nor any of its agents shall have control over the conduct of Consultant or any of Consultant’s employees, except as set forth in this Agreement. Consultant shall not, at any time, or in any manner, represent that it or any of its agents or employees are in any manner agents or employees of City. Consultant shall secure, at its sole expense, and be responsible for any and all payment of Income Tax, Social Security, State Disability Insurance Compensation, Unemployment Compensation, and other payroll deductions for Consultant and its officers, agents, and employees, and all business licenses, if any are required, in connection with the services to be performed hereunder. Consultant shall indemnify and hold City harmless from any and all taxes, assessments, penalties, and interest asserted against City by reason of the independent contractor relationship created by this Agreement. Consultant further agrees to indemnify and hold City harmless from any failure of Consultant to comply with the applicable worker’s compensation laws. City shall have the right to offset against the amount of any fees due to Consultant under this Agreement any amount due to City from Consultant as a result of Consultant’s failure to promptly pay to City any reimbursement or indemnification arising under this paragraph.

6.10. PERS Eligibility Indemnification. In the event that Consultant or any employee, agent, or subcontractor of Consultant providing services under this Agreement claims or is determined by a court of competent jurisdiction or the California Public Employees Retirement System (PERS) to be eligible for enrollment in PERS as an employee of the City, Consultant shall indemnify, defend, and hold harmless City for the payment of any employee and/or employer contributions for PERS benefits on behalf of Consultant or its employees, agents, or subcontractors, as well as for the payment of any penalties and interest on such contributions, which would otherwise be the responsibility of City.

Notwithstanding any other agency, state or federal policy, rule, regulation, law or ordinance to the contrary, Consultant and any of its employees, agents, and subcontractors providing service under this Agreement shall not qualify for or become entitled to, and hereby agree to waive any claims to, any compensation, benefit, or any incident of employment by City, including but not limited to eligibility to enroll in PERS as an employee of City and entitlement to any contribution to be paid by City for employer contribution and/or employee contributions for PERS benefits.

6.11. Cooperation. In the event any claim or action is brought against City relating to Consultant’s performance or services rendered under this Agreement, Consultant shall render any reasonable assistance and cooperation which City might require.

6.12. Ownership of Documents. All findings, reports, documents, information and data including, but not limited to, computer tapes or discs, files and tapes furnished or prepared by Consultant or any of its subcontractors in the course of performance of this Agreement, shall be and remain the sole property of City. Consultant agrees that any such documents or information shall not be made available to any individual or organization without the prior consent of City. Any KJ Consultants Inc.

Form Revised October 2024
10 use of such documents for other projects not contemplated by this Agreement, and any use of incomplete documents, shall be at the sole risk of City and without liability or legal exposure to Consultant. City shall indemnify and hold harmless Consultant from all claims, damages, losses, and expenses, including attorneys’ fees, arising out of or resulting from City’s use of such documents for other projects not contemplated by this Agreement or use of incomplete documents furnished by Consultant. Consultant shall deliver to City any findings, reports, documents, information, data, in any form, including but not limited to, computer tapes, discs, files audio tapes or any other related items as requested by City or its authorized representative, at no additional cost to the City. Consultant or Consultant’s agents shall execute such documents as may be necessary from time to time to confirm City’s ownership of the copyright in such documents.

6.13. Electronic Safeguards. Consultant shall identify reasonably foreseeable internal and external risks to the privacy and security of personal information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of the information.

Consultant shall regularly assess the sufficiency of any safeguards and information security awareness training in place to control reasonably foreseeable internal and external risks, and evaluate and adjust those safeguards in light of the assessment.

6.14. Economic Interest Statement. Consultant hereby acknowledges that pursuant to California Government Code Section 87300 and the Conflict of Interest Code adopted by City, Consultant is designated in said Conflict of Interest Code and is therefore required to file an Economic Interest Statement (Form 700) with the City Clerk, for each employee providing advice under this Agreement, prior to the commencement of work, unless waived by the City Manager.

6.15. Conflict of Interest. Consultant and its officers, employees, associates and subconsultants, if any, will comply with all conflict of interest statutes of the State of California applicable to Consultant’s services under this agreement, including, but not limited to, the Political Reform Act of 1974 (California Government Code Section 81000, et seq.) and California Government Code Sections 1090-1092. Consultant covenants that none of Consultant’s officers or principals have any interest in, or shall acquire any interest, directly or indirectly, which will conflict in any manner or degree with the performance of the services hereunder, including in any manner in violation of the Political Reform Act. Consultant further covenants that in the performance of this Agreement, no person having such interest shall be used by Consultant as an officer, employee, agent, or subconsultant. Consultant further covenants that Consultant has not contracted with nor is performing any services, directly or indirectly, with any developer(s) and/or property owner(s) and/or firm(s) and/or partnership(s) owning property in the City and further covenants and agrees that Consultant and/or its subconsultants shall provide no service or enter into any agreement or agreements with a/any developer(s) and/or property owner(s) and/or firm(s) and/or partnership(s) owning property in the City prior to the completion of the work under this Agreement.

6.16. Prohibited Employment. Consultant will not employ any regular employee of City while this Agreement is in effect.

6.17. Order of Precedence. In the event of an inconsistency in this Agreement and any of the attached Exhibits, the terms set forth in this Agreement shall prevail. If, and to the extent this Agreement incorporates by reference any provision of any document, such provision shall be deemed a part of this Agreement. Nevertheless, if there is any conflict among the terms and conditions of this Agreement and those of any such provision or provisions so incorporated by reference, this Agreement shall govern over the document referenced.

KJ Consultants Inc.

Form Revised October 2024
11 6.18. Costs. Each party shall bear its own costs and fees incurred in the preparation and negotiation of this Agreement and in the performance of its obligations hereunder except as expressly provided herein.

6.19. No Third Party Beneficiary Rights. This Agreement is entered into for the sole benefit of City and Consultant and no other parties are intended to be direct or incidental beneficiaries of this Agreement and no third party shall have any right in, under or to this Agreement.

6.20. Headings. Paragraphs and subparagraph headings contained in this Agreement are included solely for convenience and are not intended to modify, explain or to be a full or accurate description of the content thereof and shall not in any way affect the meaning or interpretation of this Agreement.

6.21. Construction. The parties have participated jointly in the negotiation and drafting of this Agreement and have had an adequate opportunity to review each and every provision of the Agreement and submit the same to counsel or other consultants for review and comment. In the event an ambiguity or question of intent or interpretation arises with respect to this Agreement, this Agreement shall be construed as if drafted jointly by the parties and in accordance with its fair meaning. There shall be no presumption or burden of proof favoring or disfavoring any party by virtue of the authorship of any of the provisions of this Agreement.

6.22. Amendments. Only a writing executed by the parties hereto or their respective successors and assigns may amend this Agreement.

6.23. Waiver. The delay or failure of either party at any time to require performance or compliance by the other of any of its obligations or agreements shall in no way be deemed a waiver of those rights to require such performance or compliance. No waiver of any provision of this Agreement shall be effective unless in writing and signed by a duly authorized representative of the party against whom enforcement of a waiver is sought. The waiver of any right or remedy in respect to any occurrence or event shall not be deemed a waiver of any right or remedy in respect to any other occurrence or event, nor shall any waiver constitute a continuing waiver.

6.24. Severability. If any provision of this Agreement is determined by a court of competent jurisdiction to be unenforceable in any circumstance, such determination shall not affect the validity or enforceability of the remaining terms and provisions hereof or of the offending provision in any other circumstance. Notwithstanding the foregoing, if the value of this Agreement, based upon the substantial benefit of the bargain for any party, is materially impaired, which determination made by the presiding court or arbitrator of competent jurisdiction shall be binding, then both parties agree to substitute such provision(s) through good faith negotiations.

6.25. Counterparts and Electronic Signatures. This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, and may be executed by electronic signatures. All counterparts shall be construed together and shall constitute one agreement. Delivery of an executed counterpart of this Agreement by a .pdf data file or other scanned executed counterpart by email shall be equally as effective as delivery of a manually executed counterpart of this Agreement. Each duplicate and counterpart shall be equally admissible in evidence, and each shall fully bind each party who has executed it. The parties waive all right to challenge the admissibility or authenticity of this Agreement in a court of law based solely on the absence of an original signature.

KJ Consultants Inc.

Form Revised October 2024
12 6.26. Corporate Authority. The persons executing this Agreement on behalf of the parties hereto warrant that they are duly authorized to execute this Agreement on behalf of said parties and that by doing so the parties hereto are formally bound to the provisions of this Agreement.

6.27. Taxpayer Identification Number. Consultant shall provide City with a complete Request for Taxpayer Identification Number and Certification, Form W9, as issued by the Internal Revenue Service.
[SIGNATURE PAGE FOLLOWS.]
KJ Consultants Inc.

Form Revised October 2024
13 IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed by and through their respective authorized officers, as of the date first above written.

CITY OF WEST COVINA,
A municipal corporation
__________________________________ Date: __________________________ Paulina Morales
City Manager

CONSULTANT
__________________________________ Date: __________________________ Susan Privitera-Johnson
President
ATTEST:
__________________________________
Lisa Sherrick, CMC
Assistant City Clerk
APPROVED AS TO FORM:
__________________________________
Thomas P. Duarte
City Attorney
APPROVED AS TO INSURANCE:
__________________________________
Maria-Luisa Olea
Risk Management

EXHIBIT A

FEE SCHEDULE
A. PLAN CHECK FEES

1. Standard review: $70.00 per hour (or portion thereof)

2. Expedited review: $70.00 per hour +$150.00 fee for expediting

3. Travel time: $35.00 per hour (minimum 1 hour billed per trip)

4. Shipping rate: Actual cost

5. Notes:
a. Consultant will bill in 1-hour increments
b. Consultant will bill a minimum of 2 hours per review c. Rates set forth above include inspections for architectural/tenant improvements, fire sprinklers, fire alarms, fire extinguishing systems, and underground sprinklers
d. Initial submittal includes one free re-check
i. Excludes travel time
ii. Excludes expedited fee
iii. Excludes shipping rate
e. Additional rechecks/resubmittals billed at rates set forth above B. FIELD INSPECTION FEES

1. $100.00 per hour (or portion thereof)

2. Travel time: $35.00 per hour (minimum 1 hour billed per trip)

3. Notes:
a. Consultant will bill in 1-hour increments
b. Consultant will bill a minimum of 2 hours per inspection ATTACHMENT NO. 2

CITY OF WEST COVINA

PROFESSIONAL SERVICES AGREEMENT
WITH
MAK FIRE PROTECTION ENGINEERING & CONSULTING, INC.

FOR

PLAN CHECK AND INSPECTION SERVICES FOR THE FIRE DEPARTMENT THIS PROFESSIONAL SERVICES AGREEMENT is made and entered into as of July 1, 2025 (“Effective Date”), by and between the CITY OF WEST COVINA, a municipal corporation (“City”), and MAK FIRE PROTECTION ENGINEERING & CONSULTING, INC., a California corporation (“Consultant”).

NOW, THEREFORE, for and in consideration of the mutual covenants and conditions contained herein, the parties hereby agree as follows:

1.0. SERVICES PROVIDED BY CONSULTANT

Form Revised October 2024
2 and in a manner consistent with the standards of care, diligence and skill ordinarily exercised by professional consultants in similar fields and circumstances in accordance with sound professional practices. Consultant also warrants that it is familiar with all laws that may affect its performance of this Agreement and shall advise City of any changes in any laws that may affect Consultant’s performance of this Agreement. Consultant shall keep itself informed of State and Federal laws and regulations which in any manner affect those employed by it or in any way affect the performance of its service pursuant to this Agreement. The Consultant shall at all times observe and comply with all such laws and regulations. City officers and employees shall not be liable at law or in equity for any claims or damages occurring as a result of failure of the Consultant to comply with this section.

MAK Fire Protection Engineering & Consulting, Inc.

Form Revised October 2024
3 1.8. Public Records Act Disclosure. Consultant has been advised and is aware that this Agreement and all reports, documents, information and data, including, but not limited to, computer tapes, discs or files furnished or prepared by Consultant, or any of its subcontractors, pursuant to this Agreement and provided to City may be subject to public disclosure as required by the California Public Records Act (California Government Code Section 7920.000 et seq.).

2.0. COMPENSATION AND BILLING

3.0. TIME OF PERFORMANCE

Form Revised October 2024
4 laws or regulations, riots, acts of war, or any other conditions beyond the reasonable control of a party. If a delay beyond the control of the Consultant is encountered, a time extension may be mutually agreed upon in writing by the City and the Consultant. The Consultant shall present documentation satisfactory to the City to substantiate any request for a time extension.

4.0. TERM AND TERMINATION

Form Revised October 2024
5 effective date of the notice of termination or the final invoice of the Consultant, whichever occurs last. Compensation for work in progress shall be prorated based on the percentage of work completed as of the effective date of termination in accordance with the fees set forth herein.

5.0. INSURANCE

By execution of this Agreement, the Consultant certifies as follows:

The Consultant shall also comply with Section 3800 of the California Labor Code by securing, paying for and maintaining in full force and effect for the MAK Fire Protection Engineering & Consulting, Inc.

Form Revised October 2024
6 duration of this Agreement, complete Workers’ Compensation Insurance, and shall furnish a Certificate of Insurance to the City before execution of this Agreement by the City. The City, its officers and employees shall not be responsible for any claims in law or equity occasioned by failure of the consultant to comply with this section.
(d) Professional liability (errors & omissions) insurance that covers the services to be performed in connection with this Agreement, in the minimum amount of One Million Dollars ($1,000,000.00) per claim and in the aggregate. Any policy inception date, continuity date, or retroactive date must be before the Effective Date of this Agreement and Consultant agrees to maintain continuous coverage through a period no less than three (3) years after completion of the services required by this Agreement.

MAK Fire Protection Engineering & Consulting, Inc.

Form Revised October 2024
7 (f) Coverage Applies Separately: The Consultant’s insurance shall apply separately to each insured against whom claim is made or suit is brought, except with respect to the limits of the insurer’s liability.

5.5. Non-limiting. Nothing in this Section shall be construed as limiting in any way the indemnification provision contained in this Agreement.

6.0. GENERAL PROVISIONS

6.3. Key Personnel. It is the intent of both parties to this Agreement that Consultant shall make available the professional services of Mark Krikorian, who shall coordinate directly with City. Any substitution of key personnel must be approved in advance in writing by City’s Representative.

Form Revised October 2024
8 communication is sent through regular United States mail.

IF TO CONSULTANT: IF TO CITY:

MAK Fire Protection Engineering &
Consulting, Inc.
12130 Rahn Ave.

Granada Hills, CA 91344
Email: [email protected]
Attn: Mark Krikorian
City of West Covina
1444 West Garvey Ave. South
West Covina, CA 91790
Email: [email protected]
Attn: Mike Browne
With a copy to:

City of West Covina
1444 West Garvey Ave. South
West Covina, CA 91790
Email: [email protected]
Attn: Sherri Yuasa

Form Revised October 2024
9 Agreement, whether or not the Consultant, its employees, and/or authorized subcontractors are specifically named or otherwise asserted to be liable. Notwithstanding the foregoing, the Consultant shall not be liable for the defense or indemnification of the City for claims, actions, complaints or suits arising out of the sole active negligence or willful misconduct of the City. This provision shall supersede and replace all other indemnity provisions contained in the City’s specifications, which shall be of no force and effect.

Form Revised October 2024
10 shall not be made available to any individual or organization without the prior consent of City. Any use of such documents for other projects not contemplated by this Agreement, and any use of incomplete documents, shall be at the sole risk of City and without liability or legal exposure to Consultant. City shall indemnify and hold harmless Consultant from all claims, damages, losses, and expenses, including attorneys’ fees, arising out of or resulting from City’s use of such documents for other projects not contemplated by this Agreement or use of incomplete documents furnished by Consultant. Consultant shall deliver to City any findings, reports, documents, information, data, in any form, including but not limited to, computer tapes, discs, files audio tapes or any other related items as requested by City or its authorized representative, at no additional cost to the City. Consultant or Consultant’s agents shall execute such documents as may be necessary from time to time to confirm City’s ownership of the copyright in such documents.

6.16. Prohibited Employment. Consultant will not employ any regular employee of City while this Agreement is in effect.

MAK Fire Protection Engineering & Consulting, Inc.

6.22. Amendments. Only a writing executed by the parties hereto or their respective successors and assigns may amend this Agreement.

MAK Fire Protection Engineering & Consulting, Inc.

Form Revised October 2024
13 IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed by and through their respective authorized officers, as of the date first above written.

CITY OF WEST COVINA,
A municipal corporation
__________________________________ Date: __________________________ Paulina Morales
City Manager

CONSULTANT
__________________________________ Date: __________________________ Mark Krikorian
Principal
ATTEST:
__________________________________
Lisa Sherrick
Assistant City Clerk
APPROVED AS TO FORM:
__________________________________
Thomas P. Duarte
City Attorney
APPROVED AS TO INSURANCE:
__________________________________
Maria-Luisa Olea
Risk Management

EXHIBIT A

FEE SCHEDULE
A. PLAN CHECK FEES

1. Standard review: $70.00 per hour (or portion thereof)

2. Expedited review: $70.00 per hour +$150.00 fee for expediting

3. Travel time: $35.00 per hour (minimum 1 hour billed per trip)

4. Shipping rate: Actual cost

1. $100.00 per hour (or portion thereof)

2. Travel time: $35.00 per hour (minimum 1 hour billed per trip)

3. Notes:
a. Consultant will bill in 1-hour increments
b. Consultant will bill a minimum of 2 hours per inspection AGENDA ITEM NO. 6

AGENDA STAFF REPORT
City of West Covina | Office of the City Manager
DATE: April 15, 2025
TO: Mayor and City Council
FROM: Paulina Morales, City Manager
SUBJECT: CONSIDERATION OF INCREASING ANNUAL COMPENSATION FOR AGREEMENT WITH WEST COAST ARBORISTS, INC. FOR CITYWIDE TREE MAINTENANCE SERVICES FOR FISCAL YEAR 2024-2025
RECOMMENDATION:

It is recommended that the City Council take the following actions:

Authorize increasing the annual compensation to $869,819 for the Maintenance Services Agreement with West Coast Arborists, Inc. for Fiscal Year 2024-2025.

1. 2. Adopt the following resolution:

RESOLUTION NO. 2025-30 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST

COVINA, CALIFORNIA, ADOPTING A BUDGET AMENDMENT FOR THE FISCAL YEAR COMMENCING JULY 1, 2024 AND ENDING JUNE 30, 2025 (TREE MAINTENANCE SERVICES) BACKGROUND:

The Public Works Department is responsible for the maintenance of City-owned facilities and public infrastructure. One component of these maintenance responsibilities is establishing and managing an efficient and cost-effective tree maintenance program. Implementing an annual tree maintenance program is critical to ensuring the proper upkeep and maintenance of the City’s urban forest. These regular maintenance services vary in scope and frequency depending on the size, species and condition of trees.

The City is currently on a five-year tree trim cycle within the Citywide Maintenance District (Fund 188).

Prior to July 2024, the Landscape & Maintenance Districts (LMDs) 1, 2, 4,6 and 7 tree maintenance was done on an emergency or as-needed basis. As of July 2, 2024, the City Council approved placing the LMDs (Funds 181-187) on a five-year tree trimming cycle.

West Coast Arborists, Inc. (WCA) has been providing tree maintenance services to the City of West Covina since 1997. In 2020, the City issued a Request for Proposals for tree trimming services. On July 7, 2020, the City Council approved the agreement with WCA for a three (3) year term with two (2) one (1) year extension options, in an amount not exceeding $485,000 annually. In January 2021, the City and WCA amended the agreement to revise the scope of services and increase WCA's compensation for the 2020-2021 Fiscal Year. In August 2022, the City and WCA amended Section 2.1 of the agreement to remove the maximum compensation amount and provide that WCA would be paid in accordance with the approved fee schedule. On December 20, 2022, City Council approved the Third Amendment to the Maintenance Services Agreement, allowing a four percent (4%) cost adjustment. The City Council also Maintenance Services Agreement, allowing a four percent (4%) cost adjustment. The City Council also approved increasing the annual maximum compensation from $485,000 to $985,000 for Fiscal Year 2022-2023 only.

For fiscal year 2024-2025, the annual compensation for tree maintenance services under the agreement with WCA is $504,400. Since the beginning of the fiscal year, change orders totaling $81,200 have been processed, bringing the revised maximum compensation amount to $585,600. These changes were approved by the City Manager pursuant to the City Manager’s authority pursuant to Section 2.2 of the agreement to approve changes of up to 25% of the contract amount.

DISCUSSION:

Staff is currently requesting an increase of $284,219 in addition to WCA's current maximum compensation of $585,600. This will increase WCA's total compensation amount to $869,818 for Fiscal Year 2024–2025. This additional funding is necessary to cover expenditures already spent in addressing the following:

Eucalptus Trees -
The City is actively removing declining eucalyptus trees that have been severely impacted by bark beetle infestations—a statewide issue in California. Immediate removal is necessary to prevent the spread of the infestation to healthy trees. To date, 110 of the 1,666 identified eucalyptus trees have been removed as part of this ongoing mitigation effort.

High-Risk Trees -
A significant increase in the removal of high-risk trees, branches and debris was required this fiscal year due to widespread tree decline and aging throughout the City. These high-risk trees were identified through emergency after-hours reports by residents, grid inspections conducted by WCA, observations by City staff, and service requests submitted by residents that were confirmed to need removal. A total of 229 of the 1,556 high-risk trees identified have been removed this year.

Windstorm Emergency (January 2025) -
Severe weather conditions in January 2025 required an immediate response to tree-related hazards, including fallen trees/branches and compromised branches. Emergency response to fallen trees, tree branches and tree debris removal were handled by WCA.

It is important to note that the City is currently working with FEMA to submit reimbursements related to the Windstorm Emergency. The process takes approximately 18 months with reimbursements to follow. Staff is meeting with FEMA on a weekly basis to process the reimbursements, including In order to prevent further risks and hazards posed by high-risk trees, wind emergencies, and bark beetle infestation of eucalyptus trees, the issues were addressed immediately. The total amount for this is $206,685.80. The annual tree trimming cycle has been completed for this fiscal year. At this time, staff is asking for an additional $77,533.20 in the event of unforeseen emergency responses between now and the end of the fiscal year on June 30, 2025. The table below illustrates the expenditures related to this request:

Eucalyptus Trees $98,727.20
Citywide $49,429.02
Parks $39,873.25
LMD 2 $11,028.48
LMD 4 $7,627.85
Total Due to WCA $206,685.80
* Unforeseen Emergency Responses $77,533.20
Grand Total $284.219.00
Available funding for unforeseen emergency responses will be distributed throughout each of the line items based on past trends. The table below illustrates the allocations:
110.503.61.52.63.00.61.61300 $14, 271.75
188.503.61.52.62.00.61.61300 $11,974.98
182.503.61.52.64.00.61.61300 $5,000.52
184.503.61.52.64.00.61.61300 $46,285.95
* Unforeseen Emergency Responses $77,533.20
This information is included in the totals that are outlined in the Fiscal Impact section of this report.

Further, if no unforeseen emergencies occur between now and the end of the fiscal year on June 30, 2025, those funds will remain in fund balance.

WCA charges vary and are based on location, type of response (grid or emergency), size of the tree, type of tree, equipment used, and additional work that may coincide with the specific species of tree.

Provided in Attachment No. 2 is the WCA Compensation Schedule that is currency in place. While the attachment references 2022-2023, there have been no increases to the schedule of compensation.

In order to provide transparency and track expenditures, WCA charges are invoiced and recorded under the following categories: Parks, Medians, Sewer Related tree removals, and the six (6) Landscape Maintenance Districts: Citywide, LMD 1, LMD 2, LMD 4, LMD 6 and LMD 7. Landscape Maintenance Districts 2 and 4 have a slight overlap. Expenditures in the overlap are charged as appropriate.

Approving the requested funding increase will provide the City with the ability to:

Enhance the overall appearance of neighborhoods and public spaces.

Reduce liability exposure related to tree damage and falling limbs.

Mitigate fire and property risks by removing hazardous trees.

Allow for response to unforeseen emergency situations that may arise through the end of the fiscal year.

LEGAL REVIEW:

The City Attorney's Office has reviewed the resolution and approved it as to form.

OPTIONS:

The City Council has the following options:

1. Adopt staff’s recommendation; or

2. Provide alternative direction.

Additional Approval: Roxanne E. Lerma, Assistant City Manager Fiscal Impact
FISCAL IMPACT:

The annual compensation for the agreement was initially $504,400 for FY 2024-25. There were change orders processed in the amount of $81,200 that were under the 25% additional work provision for the agreement, increasing the total to $585,600. Pursuant to staff's recommendation, WCA's compensation is requested to be increased to a total of $869,819 for FY 2024-25 only. The requested increased amount will pay for the expenditures associated with the high-risk tree removals, windstorm emergency and the bark beetle infestation addressed this year.

A budget amendment is needed. The fiscal impact of this budget amendment request is $284,219.

There is sufficient funding available in the General Fund for Park Maintenance and in the Maintenance District Funds. The amounts are allocated as appropriate.

Account Number Account Description Current
Budget
Proposed
Amendment
Amended
Budget
110.503.61.52.63.00.61.61300. General Fund - (for Park
Maintenance)
759,074 54,145 813,219
188.503.61.52.62.00.61.61300. Citywide Maintenance
District
499,100 61,404 560,504
182.503.61.52.64.00.61.61300. Landscape Maintenance
District 2
274,420 16,029 290,449
184.503.61.52.64.00.61.61300. Landscape Maintenance
District 4
638,400 152,641 791,041
TOTAL $2,170,994 $284,219 $2,455,213
Attachments
Attachment No. 1 - Resolution No. 2025-30
Attachment No. 2 - Schedule of Compensation
CITY COUNCIL GOALS & OBJECTIVES: Protect Public Safety
CITY COUNCIL GOALS & OBJECTIVES: Protect Public Safety
Enhance City Image and Effectiveness
ATTACHMENT NO. 1
RESOLUTION NO. 2025-30
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF WEST COVINA, CALIFORNIA, ADOPTING A
BUDGET AMENDMENT FOR THE FISCAL YEAR
COMMENCING JULY 1, 2024 AND ENDING JUNE 30,
2025 (TREE MAINTENANCE SERVICES)
The City Council of the City of West Covina hereby finds and declares as follows:

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. The City Council hereby approves Budget Amendment No. 2025-13, attached hereto as Exhibit A, for Fiscal Year 2024-25.

SECTION 2. The City Clerk shall certify to the adoption of this resolution and shall enter the same in the book of original resolutions and it shall become effective immediately.

APPROVED AND ADOPTED this 15th day of April, 2025.

Tony Wu
Mayor
APPROVED AS TO FORM ATTEST
Thomas P. Duarte Lisa Sherrick, CMC
City Attorney Assistant City Clerk
I, LISA SHERRICK, ASSISTANT CITY CLERK of the City of West Covina, California, do hereby certify that the foregoing Resolution No. 2025-30 was duly adopted by the City Council of the City of West Covina, California, at a regular meeting thereof held on the 15th day of April, 2025, by the following vote of the City Council:

AYES:

NOES:

ABSENT:

ABSTAIN:

Lisa Sherrick, CMC
Assistant City Clerk
Exhibit A
City of West Covina
Fiscal Year 2024-25
Budget Amendment No. 2025-13
West Coast Arborist Budget Increase
Fund Name (Fund No.) Current
Budget
Proposed
Amendment
Amended
Budget
General Fund (110)
Revenue 94,459,637 94,459,637
Expenditures 95,142,883 54,145 95,197,028
General Fund (110) Total -683,246 -54,145 -737,391
Maintenance District #2 (182)
Revenue 276,700 276,700
Expenditures 514,678 16,029 530,707
Maintenance District #2 (182) Total -237,978 -16,029 -254,007 Maintenance District #4 (184)
Revenue 1,064,720 1,064,720
Expenditures 1,479,669 152,641 1,632,310
Maintenance District #4 (184) Total -414,949 -152,641 -567,590 Citywide Maintenance District (188)
Revenue 1,918,310 1,918,310
Expenditures 2,306,293 61,404 2,367,697
Citywide Maintenance District (188) Total -387,983 -61,404 -449,387 EXPENDITURE TOTAL INCREASE 284,219

CITY OF WEST COVINA
Schedule of Compensation for Year 2022 - 2023
Tree Maintenance Services performed by WCA, Inc.

Item Description
Grid Prune
2 LMD Grid Prune
3 Full Prune 0-18 DSH
4 Full Prune 19-30 DSH
5 Full Prune 31 + DSH
6 Crown Raise
7 Crown Clean 0-18 DSH
8 Crown Clean 19-30 DSH
9 Crown Clean 31 + DSH
10 Crown Reduction 0-18 DSH
11 Crown Reduction 19-30 DSH
12 Crown Reduction 31-36 DSH
13 Crown Reduction 36+ DSH
14 Date Palm Prune
15 Date Palm Trunk Clean
16 Fan Palm Prune
17 Fan Palm Trunk Clean
18 Palm Prune
19 Tree & Stump Removal 0-12 DSH
20 Tree & Stump Removal 13-18 DSH
21 Tree & Stump Removal 19-24 DSH
22 Tree & Stump Removal 25-30 DSH
23 Tree & Stump Removal 31-36 DSH
24 Tree & Stump Removal 36+ DSH
25 Tree Only Removal 0-12 DSH
26 Tree Only Removal 13-18 DSH
27 Tree Only Removal 19-24 DSH
28 Tree Only Removal 25-30 DSH
29 Tree Only Removal 31-36 DSH
30 Tree Only Removal 36+ DSH
31 Stump Removal
32 Plant 15 Gallon Tree
33 Plant 24" Box Tree
34 Plant 36" Box Tree
Printed on: 5/11/2022 1:46:55 PM
Unit Proposed Prices
Each $68.65
Each $149.75
Each $83.20
Each $124.80
Each $149.75
Each $61.35
Each $83.20
Each $124.80
Each $149.75
Each $93.60
Each $149.75
Each $191.35
Each $295.35
Each $208.00
Each $208.00
Each $87.35
Each $108.15
Each $68.65
Each $291.20
Each $707.20
Each $977.60
Each $1,268.80
Each $1,508.00
Each $1,965.60
Each $249.60
Each $644.80
Each $904.80
Each $1,144.00
Each $1,424.80
Each $1,788.80
Inch $20.80
Each $187.20
Each $374.40
Each $1,040.00

Page 1 of 2 ends

ATTACHMENT NO. 2

AGENDA ITEM NO. 7

AGENDA STAFF REPORT
City of West Covina | Office of the City Manager
DATE: April 15, 2025
TO: Mayor and City Council
FROM: Paulina Morales, City Manager
SUBJECT: CONSIDERATION OF A MITIGATED NEGATIVE DECLARATION, PRECISE PLAN NO. 23-05, CONDITIONAL USE PERMIT NO. 23-04, AND VARIANCE NO. 24-02 AT 725/741 S. ORANGE AVENUE FOR A 42,000 SQUARE-FOOT

PSYCHIATRIC/BEHAVIORAL HEALTH FACILITY ADDITION, INCLUDING REMOVAL OF 25 SIGNIFICANT TREES AND A 79 PARKING SPACE DEFICIENCY RECOMMENDATION:

It is recommended that the City Council:

1. Open the public hearing; and either
a. Uphold the Planning Commission's approval without changes and:
i. Adopt the following resolution to adopt the Mitigated Negative Declaration:

RESOLUTION NO. 2025-25 - A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF WEST COVINA, CALIFORNIA, ADOPTING A MITIGATED NEGATIVE

DECLARATION AND APPROVING AND ADOPTING A MITIGATION
MONITORING AND REPORTING PROGRAM FOR PRECISE PLAN NO. 23-05, CONDITIONAL USE PERMIT NO. 23-04, AND VARIANCE NO. 24-02 AT 725/741 S. ORANGE AVENUE PURSUANT TO THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT
ii. Adopt the following resolutions to approve the Precise Plan, Conditional Use Permit, and Variance:

RESOLUTION NO. 2025-26 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, APPROVING PRECISE PLAN NO. 23-05 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE AVENUE ALLOWING THE CONSTRUCTION OF A FOUR-STORY 42,000

SQUARE-FOOT PSYCHIATRIC/BEHAVIORAL HEALTH FACILITY ADDITION

AND ASSOCIATED TREE REMOVAL
RESOLUTION NO. 2025-27 - A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF WEST COVINA, CALIFORNIA, APPROVING CONDITIONAL USE PERMIT NO. 23-04 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE

AVENUE TO ALLOW A PSYCHIATRIC/BEHAVIORAL HEALTH FACILITY USE RESOLUTION NO. 2025-28 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, APPROVING VARIANCE NO. 24-02 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE AVENUE TO ALLOW A 79-SPACE PARKING DEFICIENCY
or
b. Uphold the Planning Commission's approval with revisions to the conditions of approval; or
c. Overturn the Planning Commission's approval and deny the project by adopting the following resolutions:

RESOLUTION NO. 2025-31 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, DENYING PRECISE PLAN NO. 23-05 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE AVENUE FOR THE
CONSTRUCTION OF A FOUR-STORY 42,000 SQUARE-FOOT

PSYCHIATRIC/BEHAVIORAL HEALTH FACILITY ADDITION AND ASSOCIATED

TREE REMOVAL
RESOLUTION NO. 2025-32 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, DENYING CONDITIONAL USE PERMIT NO. 23-04 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE AVENUE FOR

A PSYCHIATRIC/BEHAVIORAL HEALTH FACILITY USE
RESOLUTION NO. 2025-33 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, DENYING VARIANCE NO. 24-02 FOR THE PROPERTY LOCATED AT 725/741 S. ORANGE AVENUE FOR A 79-SPACE

PARKING DEFICIENCY
BACKGROUND:

Request/Project Details
The proposed construction consists of a four-story, 42,000-square-foot, 71-bed psychiatric/behavioral health facility in addition to the existing West Covina Medical Center building. The existing 38 trees to the east side of the property (25 of which are significant trees) will be removed as a part of the project. A variance is required because the site, with the proposed construction, does not comply with the required number of off-street parking spaces with a 79-parking space deficiency (229 spaces are required, 150 parking spaces are provided).

The project site is located northeast of the South Orange Avenue and the West Cameron Avenue intersection, south of the Interstate 10 Freeway. The overall project site is composed of three (3) separate parcels totaling 154,286 square feet in area. The site is currently occupied by the West Covina Medical Center hospital and medical office building. The site is designated for commercial land use by the General Plan and is in the Urban Center Zone of the Downtown Plan and Code area.

ITEM DESCRIPTION

ZONING AND GENERAL

PLAN LAND USE

DESIGNATION
Urban Center Zone of the Downtown Plan and Code; Commercial

SURROUNDING ZONING

AND LAND USES
North: Interstate 10 Freeway
East: Interstate 10 Freeway on/off-ramp
South: Urban Center Zone of the Downtown Plan and Code; Commercial (Floor and Decor)
West: General Urban Zone of the Downtown Plan and Code; Commercial (Parking Lot and Office Building)
CURRENT DEVELOPMENT Hospital and Medical Office Building LEGAL NOTICE Notice of the Public Hearing was mailed to all owners of properties within one thousand (1,000) feet of the subject site, as well as published in the San Gabriel Valley Tribune. Additionally, a notice of the Public Hearing was posted on the site.

Planning Commission Review
On February 11, 2025, the Planning Commission approved the construction of a 42,000-square-foot, four-story hospital addition for the psychiatric/behavioral health facility use and a parking variance for a 79-space parking deficit (with added/modified conditions of approval requiring additional parking lot landscaping and for the Variance/CUP to be brought back to the Planning Commission in two years for compliance review) at 725/741 S. Orange Avenue.

City Council Call Up
During the February 18, 2025 City Council meeting, the City Council called up the Planning Commission’s approval of the West Covina Medical Center project at 725/741 S. Orange Avenue (Mitigated Negative Declaration, Precise Plan No. 23-05, Conditional Use Permit No. 23-04 And Variance No. 24-02) for review with direction to increase the notification radius to 1,000 feet from the parking lot across Cameron on Orange Avenue (APN/AIN 8468-007-040) since this is the primary parking lot for the site/project. The City Council expressed concerns about parking, traffic/pedestrian safety, and the need for more public notification/participation. In addition, the City Council also desires to obtain further information on the operations plan.

DISCUSSION:

Precise Plan
Approval of a Precise Plan is required for the site plan and architectural review of the project. The project would add a psychiatric/behavioral health facility to the eastern portion of the existing West Covina Medical Center building. The proposed addition would be approximately 42,000 square feet in size and four stories high. It would adjoin and connect to an existing one-story medical hospital building on the project site.

The proposed building addition would have a total of 71 licensed beds and would be up to 70 feet in height. The patient drop-off area would be located to the southeast of the proposed building. The first floor of the proposed facility would consist of an ambulance drop-off area, a loading and receiving area, a kitchen services area, a lobby/reception area, staff areas, and utility rooms (e.g., electrical and information technology rooms). The kitchen services area would be developed to serve the 46 patient beds in the existing medical facility and the 71 patient beds in the proposed building. The second (2nd) through fourth (4th) floors would each have 12 patient rooms, exam/consultation rooms, a nursing station and offices, a dining area, and utility rooms. Indoor activity space is proposed on the western end of the second and third floors, and outdoor activity space is proposed at the eastern end of the second floor and at the western end of the fourth floor.

Mechanical service units would be provided on the rooftop of the proposed building and would be screened by a parapet wall.

Vehicular and pedestrian access to the project site would be located on Orange Avenue, with an existing driveway on the east side of the existing three-story medical office building. Sidewalks are located adjacent to the project site along Orange Avenue and Cameron Avenue.

Architectural Design
The proposed addition is designed to complement and be compatible with the existing medical office and hospital buildings. The exterior finish is proposed to be a smooth white/cream-colored stucco with gray and light yellow stucco/plaster finishes, and metal trim details.

Landscaping and Tree Removal
Existing vegetation on the eastern portion of the project site, including 38 existing trees, would be removed to accommodate the proposed project. Of the 38 existing trees that would be removed, 25 trees are classified as significant trees per Section 26-258 of the WCMC. Landscaping is proposed along the southeastern perimeter of the project site; on the southeast side of the patient drop-off area; and to the north, east, and south sides of the proposed building. The new landscaping would be drought-tolerant shrubs and cobblestones. A condition of approval has been added to the draft precise plan resolution requiring at least one 24-inch box sized (minimum) tree to be installed on the planter island in front of the proposed hospital addition and pay an in lieu amount equivalent to five (5) 24-inch box sized trees and five (5) 36-inch box size trees to the City's tree fund to be used to plant replacement trees on the City public right-of-way or publicly owned properties (i.e., Civic Center, parks), if additional replacement trees cannot be accommodated on the site.

The table below summarizes how the project compares with the WCMC standards:

PROPOSED STANDARDS
LOT AREA Existing 2.83 acres (123,823 square
feet) --------------------

BUILDING AREA
1st Floor
2nd-4th Floors
Total: 103,000 square feet
Existing - 61,000 square feet
New - 42,000 square feet
1st - 8,600 square feet
2nd - 11,300 square feet
3rd - 11,050 square feet
4th - 11,050 square feet
--------------------
HEIGHT 70 feet / 4 stories 70 feet / 5 stories
BUILDING COVERAGE 0.55 (68,350 Square Feet) --------------------

SETBACKS
Front (East)
Side (South)
Side (North)
Rear (West)
Front (South) - N/A (Existing)
Side (West) - N/A (Existing)
Side (East) - 32'-10"
Rear (North) - 32-8"
Front (South) - N/A (building is
existing)
Side (West) - 0
Side (East) - 0
Rear (North) - 5 Feet (Minimum)
Conditional Use Permit
The Downtown Plan and Code requires a Conditional Use Permit for mental institutions and hospitals. The proposed use is for a 71-bed psychiatric/behavioral health facility. According to the business operation plan (Attachment No. 2), the facility provides patients with behavior health assessment/evaluations and intensive psychiatric treatment and rehabilitation (i.e., medication changes and attending group therapies). All patients are expected to be transported to the proposed psychiatric/behavioral health facility via ambulance or non-medical emergency transport van from another facility (such as a skilled nursing or residential care facility). A comprehensive and safe discharge plan is developed, so the patient can return to the originating facility or be referred to a lower level of care or a continuum of care facility, as needed. To ensure that patients are not discharged onto the street or without proper housing as expressed in the submitted operations plan, a condition of approval was included in the Planning Commission-approved resolution requiring a discharge plan to have all patients transferred to another facility or to a family member's care.
care.

Community Benefit
The applicant offered to allow the City to drop-off unhoused individuals in need of mental health care to either receive care onsite or at another nearby facility operated by the West Covina Medical Center ownership group at a rate not to exceed 10 patients per day. This community benefit was included as a condition of approval to the Planning Commission-approved resolution.

Summary of Departmental Reviews
The proposed expansion of psychiatric care services at the West Covina Medical Center has undergone review by the City’s public safety departments and health officials. West Covina Police Department (WCPD) met with West Covina Medical Center staff to discuss the project. In addition, a follow-up meeting was conducted with West Covina Medical Center staff, Emanate Health-Queen of the Valley Hospital staff, the Acting Fire Chief, and a Department of Mental Health Director, discussing the impact the project will have on community services and resources. Based on the meetings, the following information was obtained by WCPD:The following provides a factual summary of the assessments conducted by the West Covina Police Department (WCPD), West Covina Fire Department (WCFD), and the West Covina Health Department:

Police Department Review (Attachment No. 3)
Intake and Patient Admission:

No walk-in or direct drop-off admissions will be allowed.

Patients must be medically cleared by a physician and referred from another medical facility.
80–90% of patients are anticipated to come from skilled nursing or residential care facilities.

Average patient stay is expected to be 8–10 days.

Transportation will occur via medical ambulance, not public emergency services.

The facility may receive up to 10 West Covina patients per day, with flexibility to accept more if needed.

Patient Discharge:

Most patients will be transitioned to other care or housing facilities through County programs.

An estimated 10–20% may be discharged voluntarily if deemed mentally stable, potentially remaining within the City and utilizing housing or transportation vouchers.

Fire Department Review (Attachment No. 4)
EMS Impact:

If the facility follows the Rosemead campus model of only admitting medically cleared patients, 911 call volume could remain low.

However, unforeseen medical complications could still occur and require emergency response.

Unlike the Rosemead model (which uses external ambulance services), the City operates its own EMS system, meaning increased calls would directly impact City resources.

Staffing levels, availability of on-site doctors, and internal medical protocols will be critical in determining reliance on 911.

Potential Strain on Resources:

Even modest increases in calls could affect response times and availability of EMS units for the broader community.

Behavioral health emergencies (e.g., patient outbursts or unauthorized departures) may require both EMS and law enforcement intervention.

Training and Coordination:

Psychiatric-related calls often involve longer scene times and specialized de-escalation.

Collaborative training between facility staff and public safety personnel is recommended to improve outcomes and reduce unnecessary emergency responses.

Establishing clear emergency protocols with the facility will be essential to minimize disruptions to City services.

Health Department Review (Attachment No. 5)
Dr. P. Basil Vassantachart, who oversees West Covina Health, reviewed the information provided by the application and the Police Department and Fire Department reports, and concluded that further review of the discharge protocol is needed. Although, the West Covina Medical Center’s psychiatric unit addition will help meet regional mental health care needs, the project may increase the number of unhoused individuals with mental illness in the City.

Mental Health Services Gap:

The facility addresses a significant need for regional mental health treatment services.

Discharge Protocol Concerns:

Further review of discharge procedures is warranted, particularly regarding patients released without structured follow-up.

Impact on Homelessness:

There is a potential increase in unhoused individuals with mental illness in West Covina, especially among patients voluntarily discharged with limited support.

Other Public Safety Impacts to Consider
The following are other potential public safety impacts that the project may have that should be addressed during the public hearing:

Behavioral Health Emergencies & Non-Medical 911 Calls
Psychiatric facilities may generate calls not just for medical emergencies but also for behavioral incidents such as violent outbursts, suicide attempts, or patients leaving the facility without authorization.

Calls from the facility often require both EMS and law enforcement response, potentially drawing significant City resources depending on the situation.

Call Duration and Unit Commit Time
Calls to psychiatric facilities may involve longer on-scene times, especially in situations requiring patient de-escalation, coordination with on-site staff, or use of restraints.

Training Needs for Fire/EMS Personnel
Increased interactions with psychiatric patients may require specialized training for first-responders in mental health crisis intervention and de-escalation techniques.

Proactively coordinating with the facility to provide joint training opportunities could improve outcomes and reduce unnecessary escalations.

Parking Variance
A variance is required because the site, with the proposed construction, does not comply with the required number of off-street parking spaces.

The West Covina Medical Center owns and utilizes the existing parking lot located on the west side of Orange Avenue, across the street from the project site. This parking lot has 132 off-street parking spaces, and would remain unchanged. The parking lot in the eastern portion of the project site currently has 55 parking spaces. With implementation of the proposed project, this parking lot would have six (6) parking spaces remaining. The existing ten (10) parking spaces located on the north side of the existing building will be retained, while the carport and the majority of parking spaces located on the west of the building will be retained, while the carport and the majority of parking spaces located on the west of the existing building will be removed/demolished with only two (2) parking spaces remaining. A total of 150 off-site surface parking spaces will be provided. Based on a parking ratio of one parking space per 250 square feet for the existing medical office building, and 1.5 parking spaces per 0.75 beds for the hospital (existing and proposed addition - 117 total beds), the site requires 351 off-street parking spaces based on the West Covina Development Code alone. Since the site is located in the Urban Center Zone of the Downtown Plan and Code area, the required parking ratio is 0.65 of the Development Code requirement.

The site with the proposed use and construction would require a total of 229 parking spaces, which results in a 79 parking space deficit.

REQUIRED PROVIDED
Medical Office
Building 116.8 x 0.65 = 76 --
Hospital 234 x 0.65 = 153 --
TOTAL 229 Parking Spaces 150 Parking
Spaces
A parking analysis was prepared for the project. According to the parking analysis, the project would require 31 parking spaces based on a peak demand of 25 employees per shift, 5 ambulances, and 1 visitor. The parking analysis also calculated the existing demand for the medical office building and existing hospital. The parking accumulation counts were conducted in 60 minute increments from 9 AM to 7 PM during two consecutive weekdays and one Saturday. The highest peak demand occurred at 10 AM on a Wednesday with 123 parking spaces being occupied. All other timeframes ranged from 13 to 119 parking spaces being occupied, with the weekend having the lowest demand.

Based on the parking analysis, the total peak parking demand would be 154 parking spaces, 4 parking spaces more than the number of off-street parking spaces provided by the project. However, based on the unique characteristics of the proposed use, in combination with the vacation of the existing medical office tenants and anticipated expansion of an adult day care program, the parking demand for the site is expected to be lower than the current parking demand. The expansion of the adult day care program would require a separate conditional use permit application and review by the Planning Commission at a future meeting. To address parking concerns, a condition of approval was included in the Planning Commission approved CUP and Variance resolutions, requiring the Planning Commission review and potential modification of the CUP and Variance if parking becomes an issue. In addition, to ensure that the parking lot on Orange Avenue, across from the project site, continues to provide parking for the West Covina Medical Center, a condition of approval was also added requiring this parking lot to remain a parking lot serving the West Covina Medical Center.

Collision Data
Collision data was obtained from the computerized collision records system maintained by the State of California called the Statewide Integrated Traffic Records Systems (SWITRS). A review of available collisions that were reported to SWITRS within 250-ft of the intersection of Orange Avenue and Cameron Avenue was conducted for a period of approximately 5 years, between January 2020 through December 2024 (most recent available data at the time of traffic review). According to the data obtained, there were 11 collisions reported within the 5-year review period. The Collision Investigation report is included as Attachment No. 7.

Since the majority of the proposed off-street parking would be provided in the existing parking lot on Orange Avenue, west of the site and across Cameron Avenue, there are concerns that the unsafe conditions would be exacerbated due to the expansion of the hospital and increase in pedestrian activities.

Development Impact Fees
The City adopted Development Impact Fees in December 2015. For this project, the applicant will be required to pay Development Impact Fees of $1.73 per square foot (or current fee). Based on the proposed square footage, the estimated cost of the development impact fee is $72,660.

Art in Public Places
The proposed project is subject to the provisions of the Art in Public Places ordinance (WCMC Section 17-41). The applicant may elect to pay an in-lieu fee, or provide public art onsite at a rate of 1% of the total project costs, excluding land.

GENERAL PLAN CONSISTENCY:

The City's General Plan Land Use Element designates the subject property for Commercial Uses. The project is consistent with the following General Plan policies:

FINDINGS:

Precise Plan
Findings necessary for the approval of a Precise Plan are as follows:
a. The proposed development plans and the uses proposed are consistent with the General Plan and any applicable specific plan.

The project site is designated as "Commercial" in the City's General Plan and the development of a behavioral health facility hospital addition is consistent with the General Plan's goals. The subject property is located south of the Interstate 10 Freeway. The project site is adjacent to commercial properties to the South, East, and West. The proposed project is consistent with the following General Plan policies:

Our Prosperous Community P2.4 Build on and grow West Covina's regional appeal Our Prosperous Community P2.7a Explore health/medical campus opportunities Our Prosperous Community P2.9 Support local businesses. b. The proposed development is consistent with adopted development standards for the zone and complies with all other applicable provisions of the Municipal Code.

The project includes the construction of a 42,000-square-foot hospital addition to the West Covina Medical Center. The proposed hospital addition complies with the Urban Center Zone of the Downtown Plan and Code standards. The project includes a variance application for a 79 off-street parking deficit that is justified based on the analysis of the future parking demands for the site.

The impact statements and collision history raise serious concerns for the safety, health, and welfare of residents. The off-site location of the parking lot across the street in combination with the increase in pedestrian traffic and vehicular activity due to the hospital expansion, may exacerbate unsafe street conditions and may increase the incidents of traffic collisions to residents or owners of property nearby. It is unclear if this finding can be made at this time. c. Granting the permit would not be detrimental to the public interest, health, safety, and welfare and would not unreasonably interfere with the use or enjoyment of property in the vicinity of the subject property.

The proposed project is surrounded by commercial uses, including an office building and a retail center. There is no evidence that granting the permit would not be detrimental to the public interest, health, safety, and welfare or would not unreasonably interfere with the use or enjoyment of property in the vicinity of the subject property based on the information provided in the application.

However, t here are discrepancies between the information provided to the Police Department and However, t here are discrepancies between the information provided to the Police Department and the operations plan regarding the manner of discharge of patients into the community. Based on this, it appears that there is no clear plan to ensure that all patients will have housing arrangements upon discharge. Allowing a patient to be discharged to an existing or newly created unhoused situation or status would be detrimental to the health, safety, and welfare and to the public interest.

It is unclear if this finding can be made.
d. The site is physically suitable for the type, density and intensity of the development being proposed, including vehicle access and circulation.

The site will be physically suitable for the type, density and intensity of the development being proposed. The project site will be visible from the surrounding areas, which include the Interstate 10 Freeway and commercial buildings. Vehicles would be able to access the project site via Orange Avenue. The application includes a parking variance to allow the construction of the project and its use with a 79-parking space deficiency. The impact statements and collision history raise serious concerns for the safety, health, and welfare of residents. The off-site location of the parking lot across the street in combination with the increase in pedestrian traffic and vehicular activity due to the hospital expansion, may exacerbate unsafe street conditions and may increase the incidents of traffic collisions to residents or owners of property nearby. It is unclear if this finding can be made at this time.
e. The architecture, site layout, location, shape, bulk, and physical characteristics of the proposed development are compatible with the existing and future land uses, and do not interfere with orderly development in the vicinity.

Conditional Use Permit
Findings necessary for the approval of a Conditional Use Permit are as follows:
a. That the proposed use at the particular location is necessary or desirable to provide a service or facility which will contribute to the general well-being of the neighborhood.

The proposed use is consistent with the Urban Center Zone. The Urban Center Zone is composed primarily of retail and service commercial, recreational, and business office land uses which, by their nature, are of a relatively high intensity. The proposed use is a 42,000-square-foot psychiatric/behavioral health facility. As conditioned, the facility will offer a unique service and community benefit by allowing the City to drop-off unhoused individuals in need of mental health care. However, there are discrepancies between the information provided to the Police Department and the operations plan regarding the manner of discharge of patients into the community. Based on this, it appears that there is no clear plan to ensure that all patients will have housing arrangements upon discharge. Allowing a patient to be discharged to an existing or newly created unhoused situation or status would be detrimental to the health, safety, and welfare and to the public interest. It is unclear if this finding can be made. b. That such use will not, under the circumstances of the particular case, be detrimental to the health, safety, peace or general welfare of persons residing or working in the vicinity or injurious to property or improvement in the vicinity.

The proposed use is a behavioral health/psychiatric hospital facility. According to the operations plan, patients arrive at the facility via non-emergency medical vans or ambulances coming from other care facilities, and are never discharged to the street with nowhere to go. However, there are discrepancies between the information provided to the Police Department and the operations plan regarding the manner of discharge of patients into the community. Based on this, it appears that there is no clear plan to ensure that all patients will have housing arrangements upon discharge.

Allowing a patient to be discharged to an existing or newly created unhoused situation or status would be detrimental to the health, safety, and welfare and to the public interest. It is unclear if this finding can be made.
c. That the site for proposed use is adequate in size and is so shaped as to accommodate said use, as well as all yards, spaces, walls, fences, parking, loading, landscaping, and any other features necessary to adjust said use to the land and uses in the neighborhood and make it compatible therewith.

The existing building and site are adequate and are properly designed to accommodate all existing and proposed uses. The medical offices and existing hospital are long-standing facilities and uses that have provided adequate off-street parking for a number of years. Based on anticipated parking demands, adequate off-street parking will be available most times. It is unclear if the proposed use would negatively impact the adjacent commercial retail center and medical office building. The application includes a parking variance to allow the construction of the project and its use with a 79 parking space deficiency. The impact statements and collision history raise serious concerns for the safety, health, and welfare of residents. The off-site location of the parking lot across the street in combination with the increase in pedestrian traffic and vehicular activity due to the hospital expansion, may exacerbate unsafe street conditions and may increase the incidents of traffic collisions to residents or owners of property nearby. It is unclear if this finding can be made at this time.
d. That the site abuts streets and highways adequate in width and improvement to carry traffic generations typical of the proposed use and that street patterns of such a nature exist as to guarantee that such generation will not be channeled through residential areas on local residential streets.

The subject property abuts Orange and Cameron Avenues and is accessible via driveway on Orange Avenue. The site is accessible through streets located along commercial areas. Since patients are typically dropped off and picked up by a van or ambulance service, these vehicles come directly from the 10 Freeway off-ramp to the site, or from Cameron Avenue to Orange Avenue, and will not be channeled through residential areas. The parking lot across Orange Avenue is a longstanding use and will not be modified as part of this project. This finding can be made.
e. That the granting of such Conditional Use Permit will not adversely affect the general plan of the city, or any other adopted plan of the City.

Granting the CUP for the proposed use will not compromise the character of the surrounding neighborhood or be detrimental to the surrounding land uses. Allowing the proposed use is consistent with the policies and actions of the General Plan. The project is consistent with the following General Plan policies:

Variance
Findings necessary for the approval of a variance are as follows:
a. There are special circumstances (which may include, but are not limited to, size, shape, topography, location, or surroundings) applicable to the property which are not applicable to other property in the property’s vicinity under identical zoning classification.

The project site's location is unlike other properties in the vicinity in that it exhibits "island-like" characteristics in that it is directly adjacent to the I-10 Freeway to the north, I-10 Freeway off-ramp to the east, Orange Avenue to the south, and Cameron Avenue to the west; the site is not directly adjacent to any privately owned properties which eliminates the possibility of expanding the size of the lot to accommodate more parking onsite. This finding can be made. b. As a result of the special circumstances, the strict application of the Development Code deprives the property of meaningful privileges enjoyed by other property in the vicinity and under identical zoning classification.

Due to its "island-like" features, the site is not directly adjacent to any privately owned properties, which eliminates the possibility of expanding the size of the lot to accommodate more parking onsite. Furthermore, the lot's size and the current development constrain the location of the hospital expansion, necessitating the removal of existing onsite parking spaces. Other properties in the area are either underutilized, with abundant parking and large lots, or have the potential for expansion due to their proximity to other privately-owned properties. Thus, the strict application of the code deprives the property of meaningful privileges enjoyed by other properties in the vicinity and under identical zoning classifications. This finding can be made. c. Such variance is necessary to allow the property in question to have the same substantial property right possessed by other property in the same vicinity and zone.

The parking variance is necessary to allow the subject property to have the same substantial property right possessed by other properties in the same vicinity. Due to its "island-like" features, the site is not directly adjacent to any privately-owned properties, which eliminates the possibility of expanding the size of the lot to accommodate more parking onsite. Furthermore, the lot's size and the current development constrain the location of the hospital expansion, necessitating the removal of existing onsite parking spaces. Other properties in the area are either underutilized, with abundant parking and large lots, or have the potential for expansion due to their proximity to other privately-owned properties. This finding can be made.
d. The granting of such variance will not be materially detrimental to the public welfare or materially injurious to residents or owners of nearby properties.

Based on the parking analysis, the total peak parking demand would be 154 parking spaces, 4 parking spaces more than the number of off-street parking spaces provided by the project. Based on the unique characteristics of the proposed use, in combination with the vacation of the existing medical office tenants and anticipated expansion of an adult day care program, the parking demand for the site is expected to be lower than the current parking demand. However, t he off-site location of the parking lot across the street in combination with the increase in pedestrian traffic and vehicular activity due to the hospital expansion, may exacerbate unsafe street conditions and may increase the incidents of traffic collisions to residents or owners of property nearby. It is unclear if this finding can be made at this time.
e. That the granting of such variance shall be consistent with the adopted General Plan and any applicable specific plans.

The site has a "Commercial" General Plan land-use designation. Approval of the variance does not change the commercial use or land-use designation of the site. The project is consistent with the following General Plan policies:

This finding can be made.
f. The variance does not authorize a use or activity which is not otherwise expressly authorized by the zoning regulations governing the parcel of property.

The variance is to allow a 79 parking space deficit. The proposed behavioral health facility hospital use is allowed within the Downtown Plan and Code area with approval of a Conditional Use Permit.

This finding can be made.

LEGAL REVIEW:

The City Attorney's Office has reviewed the resolutions and approved them as to form.

OPTIONS:

The City Council has the following options:

1. Uphold the Planning Commission's approval of the project; or Uphold the Planning Commission's approval of the project with revisions to the conditions of approval; or

2. 3. Overturn the Planning Commission's decision and deny the project; or

4. Provide alternative direction.

ENVIRONMENTAL REVIEW:

Based on the findings of the Initial Study, this project would not result in significant environmental impacts. Mitigation measures for biological resources, geology and soils, cultural resources, geology and soils, hazards and hazardous materials, noise, transportation and tribal cultural resources will be required to reduce impacts to a less than significant level. Accordingly, a Mitigated Negative Declaration (MND) will be adopted, pursuant to Section 21080(c) of the Public Resources Code.

In compliance with CEQA, the State CEQA Guidelines, an MND was prepared and will be considered prior to approval of the project. The MND serves as a finding that the project would not have a significant effect on the environment, with the incorporation of mitigation measures, as appropriate.

Based on the environmental analyses, with compliance with applicable regulatory requirements and/or the implementation of mitigation measures, the Project would have less than significant impacts on humans, as it relates to the following environmental issue areas: aesthetics, hydrology and water quality, noise, recreation, utilities and service systems, agriculture and forestry resources, greenhouse gas emissions, land use and planning, population and housing, transportation, wildfire, air quality, energy, mineral resources and public services.

The proposed project’s impacts on the following issue areas would require the implementation of mitigation measures: biological resources, geology/soils, noise, transportation, cultural resources, and tribal cultural resources. All impacts would be avoided or reduced to less than significant levels after mitigation. Therefore, the proposed project would not result in environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly, with the implementation of mitigation measures. All impacts would be less than significant after mitigation.

A copy of the MND is attached to the proposed resolution to adopt the MND and can be found on the City’s Planning Division web page at the following link: Environmental Documents The MND includes a detailed discussion on all environmental issues related to the project including traffic and noise impacts and how any potential impacts were determined to be less than significant after mitigation.

The MND was circulated for public comment from January 15th through February 3rd. Comments were received from the Los Angeles County Sanitation Districts and the Department of Toxic Substance Control. The comments and responses to the comments are attached to the proposed resolution to adopt the MND.

Prepared by: Jo-Anne Burns, Deputy Community Development Director Additional Approval: Roxanne E. Lerma, Assistant City Manager Fiscal Impact
FISCAL IMPACT:

If approved, the project will require payment of approximately $72,660 in development impact fees paid to the City of West Covina. Development impact fees are one-time charges on new development to help offset the costs associated with providing infrastructure and public services. However, at this time, there is no evidence that the use/project, if approved, would or would not generate an immeasurable number of calls for service greater than other hospitals or medical uses that far exceeds the impact fees required.

Attachments
Attachment No. 1 - Planning Commission Approved Resolutions Attachment No. 2 - Business Operations Plan
Attachment No. 3 - Police Department Review
Attachment No. 4 - Fire Department Review
Attachment No. 5 - West Covina Health Review
Attachment No. 6 - Collision History
Attachment No. 7 - Resolution No. 2025-25 (Adopt MND)
Attachment No. 8 - Resolution No. 2025-26 (Precise Plan Approval) Attachment No. 9 - Resolution No. 2025-27 (CUP Approval) Attachment No. 10 - Resolution No. 2025-28 (Variance Approval) Attachment No. 11 - Resolution No. 2025-31 (Precise Plan Denial) Attachment No. 12 - Resolution No. 2025-32 (CUP Denial) Attachment No. 13 - Resolution No. 2025-33 (Variance Denial) Attachment No. 14 - Presentation
ATTACHMENT NO. 1

To: City of West Covina
Subject: Business Operations Plan
Date: July 11, 2024
The West Covina Medical Center (WCMC) is a one-story, for-profit licensed acute care hospital located at 725 South Orange Avenue in West Covina, California.

The project being submitted to planning is a four-story 42,000 square-foot psychiatric inpatient facility (WCMC Behavioral Health Addition) constructed on the east side of the WCMC site featuring three levels of nursing units over an at-grade arrival lobby. The total capacity for inpatient care will be 71 beds.

WCMC Behavioral Health Addition will have:
• 50 total number of staff
• 16 average number of staff during peak shift with staff shifts occurring from 7 am–7 pm and 7 pm–7 am • Less than five visitors per day and general hours for visitors will be 9 am-5 pm • Approximately 10 drop-offs per day number by emergency ambulance • Average Length of stay for one inpatient is 8-10 days General daily business operations:

All patients admitted to this proposed 71-bed psychiatric hospital will arrive via ambulance or non-medical emergency transport van, with very few exceptions. No sirens will be used. All patients admitted are called Direct Admit, meaning they don’t go through an emergency room. Their physician/psychiatrist issues the order for the Direct Admit. These patients almost entirely come from their institutional place of living, such as skilled nursing and residential care facilities. Patients are NEVER discharged from the hospital to the street.

Upon admission, the ambulances/vans will arrive to awaiting staff at the rear entrance on the north side of the property next to the freeway. The same holds true when discharged. Upon admission, the patient will undergo a behavior health assessment and evaluation as a routine part of their inpatient care. Then, they will undergo intensive psychiatric treatment and rehabilitation, i.e., medication change(s) and attending group therapies. A comprehensive and safe discharge plan is developed so the patient can return to the originating facility or be referred to a lower level of care or a continuum of care facility, as needed.

This psychiatric hospital will be a satellite hospital for our L.A. Downtown Medical Center main campus located at 1711 W Temple Street, Los Angeles, visible from the 101 freeway between Glendale Blvd. and Alvarado Blvd., about 30 minutes away. L.A. Downtown Medical Center is a General Acute Care Hospital (GACH) that provides traditional hospital services such as Radiology, Labs, Operating Rooms, and hospital beds. If a patient is admitted to the West Covina Psychiatric Hospital is in need medical care, they will be transferred to the main campus in Los Angeles. Patients are admitted to the psychiatric hospital for nonmedical reasons.

ATTACHMENT NO. 2
At West Covina Medical Center, we are no longer a General Acute Care Hospital, as we gave up the 13 medical surgical beds as unnecessary duplications with our Los Angeles Campus. The two Operating Rooms will instead become an Outpatient Surgery Center. The remaining 33-bed Sub Acute Hospital will continue, located next to the new psychiatric building. A Sub Acute is a level of care below a General Acute Care Hospital but above Skilled Nursing. They are all long-term patients likely to spend the remainder of their lives in this setting due to the severity of their illness/injury.

There is a Medical Office Building at the corner of Cameron Avenue and Orange Avenue, separate from the sub-acute and future psych hospital. On July 10, 2024, the tenants in the MOB (all on month-to-month leases) were issued a termination notice of their lease(s) and required to vacate the premises effective December 31, 2024. There is a Psychiatric Day Treatment Group Therapy Program with six (6) professional staff treating residents who come from residential care facilities to maintain their treatment. These individuals have a long history of psychiatric hospitalizations and need continued treatment. They are transported via three (3) minivans making multiple trips in the morning and returned by the same vehicles in the afternoon. The vehicles are required to use our main driveway and patient loading/unloading drop-off.

We have about 30-40 Adult Day Care patients that attend this day program Monday through Friday. Others are via Telehealth. This program is slated for expansion on January 1, 2025, and will require two (2) additional professional staff. We will spread patients out between the third floor and the second floor for a more comfortable therapeutic environment.

Lastly, West Covina campus was approved by the State and Federal governments to be merged into LA Downtown Medical Center license, last January 1, 2023, allowing administrative staff to be consolidated at the LA Downtown campus which reduced the number of employees at WCMC sub-acute hospital by six (6).

Existing Sub Acute Hospital
• 10 total number of staff during peak
• 8 drive and remaining use public transportation or are dropped off • 1-2 visitors per day, Patients are long-term
Medical Office Building
• Zero tenants and no more visitors
• Eight (8) total number of professional staff (considering future expansion 1/1/2025) • 30 – 40 patients per day dropped off by three minivans using main drop-off The main building entrance to the new psychiatric hospital visible to the front will go mostly unused, although some staff may use it or maintenance workers performing duties around the campus, plus government inspectors. The few family member visitors that arrive may use this entrance as well, but that’s pretty much it. The building will be discrete and will blend into the neighborhood, although we are largely hidden with the freeway to the north, Floor & Decor to the east, and our parking lot across the street to the south on Cameron Avenue. We anticipate the in and out traffic using the main driveway on Orange Avenue will be reduced. Our staff will no longer park on the main campus, utilizing our parking lot to the south on Cameron Avenue and Orange Avenue.

Submitted by
William A Nelson, MA
Chief Executive Officer

ANTONIO CORTINA
Chief of Police
1444 W. Garvey Avenue South • P.O. Box 2166 • West Covina, CA 91793 • Phone (626) 939-8500 • Fax (626) 939-8679 www.wcpd.org
WCPD Personnel were requested to meet with West Covina Medical Center Staff to discuss the proposed addition of a 42,000 square-foot, 71 bed psychiatric impatient facility (WCMC Behavioral health addition) at the West Covina Medical Center located at 725 S. Orange Ave in West Covina.

The main topics discussed in our initial meeting were primarily focused on the newly proposed psychiatric impatient facility and their proposed processes for receiving and discharging psychiatric patients in West Covina. A follow up meeting was also conducted discussing the impact of services and resources in the City and surrounding communities and included WCPD personnel, West Covina Medical Center Staff, Emanate Health-QVH Staff, the Acting WCFD Fire Chief, and the department’s DMH (Department of Mental Health) clinician.

Below is a synopsis of topics discussed.

Receiving/ Intake of Patients:

The West Covina Medical Center will not directly accept patients into their facility; meaning patients cannot be dropped off and/ or walk into the facility for treatment. The West Covina Medical Center also will not treat patients under the age of 18. All patients accepted into the facility must receive a medical clearance and be triaged from an accepted medical facility prior to being considered for admittance into a treatment program and/or, be referred to the facility by a physician/ psychiatrist who will issue a Direct Admit order.

A majority of the patients being housed and receiving treatment at the West Covina Medical Center will be received from an institutional place of living, such as skilled nursing and residential care facilities. The West Covina Medical Center staff indicated that these types of patients are never discharged from their facility to the street and are either returned via ambulance to the originating facility, or referred to a lower level of care facility. The West Covina Medical Center Staff believed this number accounts for approximately 80% of the patients they will be providing treatment to at their newly proposed facility, and that number could actually be higher at around 90%. The average length of stay for most of these patients is between 8-10 days.

The West Covina Medical Center will be part of a Los Angeles County wide network and based on availability, would except patients suffering from metal illness; who have been medically cleared, placed on a mental evaluation hold, and in need of a treatment facility for extended on-site psychiatric care, from any medical facility in the County. This includes patients triaged and cleared from the West Covina Medical Center’s main affiliate Downtown Campus (LADMC-located at 17711 W Temple St in Los Angeles). This could include patients county-wide, who have been taken to a medical facility on a 5150 hold by Law Enforcement, and received a medical clearance, and are in need of an on-site psychiatric facility for treatment beyond the emergency room. The West Covina Medical Staff explained their medical clearance policy could not allow them to accept patients suffering from certain medical conditions or patients who are under the influence of alcohol and/ or drugs, as those conditions would need to be properly treated at a medical facility before acceptance into their West Covina location could be permitted.

ATTACHMENT NO. 3

ANTONIO CORTINA
Chief of Police
1444 W. Garvey Avenue South • P.O. Box 2166 • West Covina, CA 91793 • Phone (626) 939-8500 • Fax (626) 939-8679 www.wcpd.org
Transportation to the West Covina Medical Center from a medical facility would be facilitated by medical ambulances, utilized by medical facilities throughout the County.

As part of the proposed project, the West Covina Medical Center offered the availability of 10 beds per day for patients requiring psychiatric treatment, stemming from West Covina specific cases.

Through conversation, it was learned that this means for example, that anyone who is in West Covina, has been placed on a 5150 hold, has received medical clearance, and requires continuing care in a psychiatric facility may be accepted and transported to the West Covina Medical Center for treatment, up to 10 patients a day, and possibly more if the need arises. This was explained to mean anyone, who meets the admission requirements, who was treated at a medical facility in West Covina, regardless of how they arrived there, would be considered a West Covina generated patient and would be eligible for acceptance into the West Covina Medical Center as part of the 10 patients a day offer. An example discussed was a patient arriving at Emanate Health –QVH in West Covina, regardless of where they may have been transported from (Private, medical ambulance, or Law Enforcement) who is triaged, medically cleared, and in need of on-site psychiatric treatment (placed on a 5150 hold), would qualify as a West Covina generated case. The benefit discussed was that the West Covina Medical center could be a location to offer on-site psychiatric treatment when Emanate Health- Parkside West or Aurora Charter Oak Hospital were at capacity and could not accept additional patients.

Discharge of Patients:

According to West Covina Medical Center Staff, most patients who would receive psychiatric treatment in their facility, as part of their safe discharge plan, would be required to be transported by the West Covina Medical Center to a follow up treatment or housing location upon their completion of treatment and discharge, through a County sponsored living/ treatment program; and would not be released into West Covina (if in fact, the County offered housing/ services are not in West Covina).

It was discussed, however, that if a patient who has been accepted and receives psychiatric treatment/ evaluation in the West Covina Medical Center facility, who is deemed to be a “self-direct” upon completion of treatment, would be permitted to discharge out of the building in West Covina from the facility, regardless of where they arrived from. It was explained that a “self-direct” patient would exhibit mental stability enough to be deemed able to care for themselves and eligible for voluntary release. Upon release, these patients would be offered services such as transportation/ housing vouchers offered through the County but would not be required to accept them. West Covina Medical Center Staff said they would also try and have a family member pick the patient up upon release from their facility. West Covina Medical Center Staff believed the number of patients that would be eligible for voluntary release from their West Covina facility would be somewhere in the range of 10-20% of those patients treated at their facility.

WEST COVINA FIRE DEPARTMENT
″Service with Integrity, Pride and Dedication″
Mike Browne
Acting Fire Chief
Impact Statement for West Covina Medical Center Expansion The expansion of West Covina Medical Center to include a mental health facility could have several impacts on emergency services, particularly 911 call volume. Here are some key considerations:

Potential Impacts on 911 Calls

1. Acute Medical Conditions
o If the facility follows the same model as the Rosemead campus, where patients are medically cleared before admission, the number of 911 calls for medical emergencies may be minimal.
o However, there is still potential for emergency calls due to unforeseen medical complications, such as cardiac events, seizures, or adverse reactions to medications.

2. Impact on Ambulance Availability
o Unlike Rosemead, where ambulances are handled by external agencies, the West Covina Fire Department operates its own ambulances. Any additional medical calls from this facility could strain EMS resources, reducing the availability of ambulances for the public.

3. Facility Staffing and Medical Capabilities
o If the facility has round-the-clock doctors, as cited by the West Covina Medical Center representatives, they may handle most medical issues in-house. o The level of on-site medical care, access to life-saving equipment, and protocols for handling deteriorating patients will play a role in determining how often 911 is needed.

4. Comparison to Similar Facilities
o While the Rosemead location reportedly rarely needs to call 911, differences in patient demographics, facility policies, and staff availability could result in different outcomes at the West Covina location.

5. Impact on Local EMS & Fire Department Resources
o If 911 call volume increases, the local fire department and EMS resources could experience additional strain, requiring delays in responding to additional calls in the city.
o Coordination with facility administrators to establish clear protocols for emergency response could mitigate unnecessary calls.

ATTACHMENT NO. 4
1444 W. Garvey Avenue S, West Covina, CA 91790
March 31st, 2025
Impact Statement for West Covina Medical Center
Psychiatric Unit Expansion
Material reviewed:

1. West Covina Medical Center Business Operation Plan.

2. West Covina Fire Department Impact Statement.

3. West Covina Police Department Meeting Report with Stakeholders Mental health and homelessness are among some of the issues of concern to the resident of West Covina. California does not have enough places were people can get mental health care and drug or alcohol treatment. In 2024, California passed proposition 1 approves a $6.4 billion bond to build (1) more places for mental health care and drug or alcohol treatment and (2) more housing for people with mental health drug, or alcohol challenges.

West Covina Medical Center psychiatric unit expansion will help fill the gap in mental health need in Los Angeles County. Incidence in mental health is generally lower in the City of West Covina comparing to Los Angeles county, but since the City has one of the only two hospitals in the region and one of the most busy emergency room in the region and often time have to handle patients in need of in-patient mental health and discharge planning.

PROS:

More available in-patient psychiatric beds available for local and regional needs.

Facilitate transfer and discharge of patients from the acute medical facility and easing the congestion in the emergency department of local hospital.

CONS:

May increase the number of homelessness with mental health illness in the City.

Will need to review their utilization review and discharge process protocol.

P. Basil Vassantachart, MD
Health Director and Health Officer
ATTACHMENT NO. 5

CITY OF WEST COVINA
Prepared By: Transtech Engineers, Inc. | Page 1 of 3

COLLISION INVESTIGATION
Collision data was obtained from the computerized collision records system maintained by the State of California called the Statewide Integrated Traffic Records Systems (SWITRS). A review of available collisions that were reported to SWITRS within 250-ft of the intersection of Orange Avenue and Cameron Avenue was conducted for a period of approximately 5 years, between January 2020 through December 2024 (most recent available data at the time of traffic review). Based on the information available, a summary breakdown of the number of collisions within the studied segment are listed below.
2024 – 0 collisions
2023 – 2 collisions
2022 – 4 collisions
2021 – 3 collisions
2020 – 2 collisions
Total Collisions: 11 collisions
ATTACHMENT NO. 6

CITY OF WEST COVINA
Prepared By: Transtech Engineers, Inc. | Page 2 of 3
PROJECT: Collision History at the Intersection of Orange Avenue and Cameron Avenue DATE: April 2, 2025
Table 1. Collision Table: Intersection of Orange Avenue and Cameron Avenue ID # Date Primary
Road
Secondary
Road Dist. Time
Day of
the
Week
Lighting
(Day,
Night,
Etc.)
Collision
Type
Severity
1 - Fatal
2 - Severe Injury
3 - Other Visible Injury
4 - Complaint of Pain
5 - Prop Dam Only (PDO)
Motor
Vehicle,
Pedestrian,
Bicycle
Involved
Collison
Factor and
Detail
Descriptions
1 9/6/23 Orange
Ave
Cameron
Ave
202'
S 7:55 WED Daylight Broadside 5 Other MV

SB DRVR

MAKING LFT

TRN HIT NB
DRVR

BROADSIDE
2 1/16/23 Orange
Ave
Cameron
Ave
219'
N 16:29 MON Daylight Broadside 4 Other MV

EB DRVR HIT

NB DRVR

BROADSIDE
DUE TO R-OW ISSUE
3 12/18/22 Cameron
Ave
Orange
Ave 0 12:52 SUN Daylight Broadside 5 Other MV

SB DRVR HIT

NB DRVR

MAKING LFT
TRN

BROADSIDE
4 11/30/22 Orange
Ave
Cameron
Ave 0 11:28 WED Dark-st Broadside 4 Other MV

EB DRVR RAN

STOP/SIG &

HIT NB DRVR

MAKING LFT
TRN
5 2/21/22 Orange
Ave
Cameron
Ave
120'
N 8:45 MON Daylight Rear End 5 PKD MV

SB DRVR AT
UNSAFE

SPEED REAR

ENDED TWO

SB PARKED
MV
6 2/16/22 Orange
Ave
Cameron
Ave
32'
N 15:50 WED Daylight Broadside 5 PKD MV
DRVR

BACKING HIT

EB PARKED
MV
7 7/27/21 Cameron
Ave
Orange
Ave 0 10:32 TUE Daylight Sideswipe 5 Other MV

PROC DRVR
MADE

IMPROP TRN
& SIDESWIPED

STOPPED EB
DRVR
8 5/2/21 Orange
Ave
Cameron
Ave
7'
N 1:03 SUN Dark-st Hit Object 5 Fixed Object

WB DRVR
UNDER

INFLUENCE

HIT FIXED
OBJECT
9 3/10/21 Orange
Ave
Cameron
Ave
20'
S 19:45 WED Dark-st Rear End 5 Other MV

NB DRVR AT
UNSAFE

SPEED REAR

ENDED TWO

NB DRVR
10 2/17/20 Orange
Ave
Cameron
Ave 0 10:11 MON Daylight Broadside 5 Other MV

NB DRVR

MAKING LFT

TRN HIT SB
DRVR

BROADSIDE
11 1/18/20 Orange
Ave
Cameron
Ave
170'
S 11:13 SAT Daylight Sideswipe 5 Other MV

NB DRVR

MAKING LFT
TRN

SIDESWIPED

NB DRVR

CITY OF WEST COVINA
Prepared By: Transtech Engineers, Inc. | Page 3 of 3
PROJECT: Collision History at the Intersection of Orange Avenue and Cameron Avenue DATE: April 2, 2025
Figure 1: Collision Diagram at Orange Avenue and Cameron Avenue PED & BIKE - Crash Type # of Crashes
Fatality (Death) 0
Severe Injury 0
Injury - Other Visible 0
Injury - Complaint of Pain 0
Property Damage Only 0
Total 0
LEGEND
ALL COLLISIONS - Crash Type
(Non-Ped & Bike
Collisions/Crashes)
# of Crashes
Fatality (Death) 0
Severe Injury 0
Injury - Other Visible 0
Injury - Complaint of Pain 2
Property Damage Only 9
Total 0
TOTAL CRASHES 11
1 2
3 4
5 6
7 8
9 11
10 RESOLUTION NO. 2025-25

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

WEST COVINA, CALIFORNIA, ADOPTING A MITIGATED

NEGATIVE DECLARATION AND APPROVING AND

ADOPTING A MITIGATION MONITORING AND
REPORTING PROGRAM FOR PRECISE PLAN NO. 23-05,
CONDITIONAL USE PERMIT NO. 23-04, AND VARIANCE
NO. 24-02 AT 725/741 S. ORANGE AVENUE PURSUANT

TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
The City Council of the City of West Covina hereby finds and declares as follows:

WHEREAS, the applicant, the West Covina Medical Center, filed with the City a verified application on the forms prescribed in Chapter 26 of the West Covina Municipal Code, requesting approval of a Precise Plan, Conditional Use Permit, and Variance (the “Project”) to:

Allow the construction of a four-story, 42,000 square feet psychiatric/behavioral health facility addition to the existing West Covina Medical Center building and associated tree removals and site improvements on a certain property described as:

Assessor’s Parcel No. 8474-001-022 in the records of the Los Angeles County Assessor; and
WHEREAS, the proposed Project is considered a “project” pursuant to the terms of the California Environmental Quality Act (CEQA); and WHEREAS, an Initial Study was prepared for said Project; and WHEREAS, the City, through its environmental consultant, prepared an Initial Study for the Project; and
WHEREAS, following completion of the Initial Study, the City determined that the proposed Project, with mitigation, would not have a significant impact on the environment and would not individually or cumulatively have an adverse effect on wildlife resources, as defined in Section 711.2 of the California Fish and Game Code; and WHEREAS, the City, through its environmental consultant, prepared an Initial Study and Mitigated Negative Declaration (IS/MND) which included revisions to and/or conditions placed on the Project, which were determined by the environmental coordinator to avoid or reduce the potentially significant effects to a level that is clearly less than significant and that there was, therefore, no substantial evidence that the Project, as revised and conditioned, would have a significant effect on the environment; and
ATTACHMENT NO. 7
WHEREAS, the applicant agreed to the revisions and conditions prior to the release of the IS/MND for public review; and
WHEREAS, the IS/MND was circulated for a 20-day public review period between January 15, 2025 and February 3, 2025; and
WHEREAS, comments were received during the public review period from the following entities: Los Angeles County Sanitation Districts and the Department of Toxic Substance Control. The letters and responses to comments are included in the final mitigation monitoring and reporting program; and
WHEREAS, on February 11, 2025, the Planning Commission conducted a duly noticed public hearing to consider the Project, including the IS/MND, at the conclusion of which the Planning Commission adopted resolutions adopting the IS/MND, the Precise Plan, the CUP, and the Variance; and
WHEREAS, on February 11, 2025, the City Council called up the Planning Commission’s approval of the Project for review; and
WHEREAS, on April 15, 2025, the City Council conducted a duly noticed public hearing to consider the Project; and
WHEREAS, in accordance with CEQA Guidelines Section 15074(b), the City has considered the proposed IS/MND together with the comments received during the public comment period and determined on the basis of the whole record before it that there is no substantial evidence that the Project will have a significant effect on the environment and that the MND reflects the City’s independent judgment and analysis; and WHEREAS, in making the various findings set forth herein, the City Council has considered all of the evidence presented by staff and the public, whether written or oral, and has considered the procedures and the standards required by the West Covina Municipal Code.

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. Recitals. The foregoing recitals are true and correct and are incorporated herein.

SECTION 2. Adoption of Mitigated Negative Declaration. The City Council of the City of West Covina hereby adopts the Initial Study/Mitigated Negative Declaration. In its entirety, the document consists of the Initial Study and Mitigated Negative Declaration dated January 2025, attached hereto as Exhibit A, and the Responses to Comments and Final Mitigation Monitoring and Reporting Program dated January 2025, attached hereto as Exhibit B. The City Council also approves and adopts the Mitigation Monitoring and Reporting Program set forth in Exhibit B.

SECTION 3. Record of Proceedings. The documents and other materials that constitute the record of proceedings upon which the City Council has based its decision are located in the office of the West Covina Deputy Community Development Director, 1444 West Garvey Avenue South, West Covina, CA 91790. The custodian of these documents and other materials is the West Covina Deputy Community Development Director.

SECTION 4. Compliance with Mitigation Measures. The applicant shall comply with the mitigation measures and monitoring or reporting requirements. Failure to comply with any mitigation measures and/or monitoring or reporting requirements will result in a written notice of violation from the City to the applicant at which time the City may order that all or a portion of pre-construction, construction, post-construction activity or project implementation must cease until compliance is reached.

SECTION 5. Notice of Determination. Upon approval of the Project by the City Council, the environmental coordinator shall file a Notice of Determination with the County Clerk of Los Angeles County.

SECTION 6. Effective Date. The City Clerk shall certify to the adoption of this Resolution and shall enter it into the book of original resolutions and it shall become effective immediately.

APPROVED AND ADOPTED on this 15th day of April, 2025.

Tony Wu
Mayor

APPROVED AS TO FORM ATTEST
Thomas P. Duarte Lisa Sherrick
City Attorney Assistant City Clerk
I, LISA SHERRICK, Assistant City Clerk of the City of West Covina, California, do hereby certify that the foregoing Resolution No. 2025-25 was duly adopted by the City Council of the City of West Covina, California, at a regular meeting thereof held on the 15th day of April 2025, by the following vote of the City Council:

AYES:

NOES:

ABSENT:

ABSTAIN:

Lisa Sherrick
Assistant City Clerk

EXHIBIT A

INITIAL STUDY AND MITIGATED NEGATIVE DECLARATION

WEST COVINA MEDICAL CENTER

BEHAVIORIAL HEALTH BUILDING ADDITION

INITIAL STUDY/

MITIGATED NEGATIVE DECLARATION
Prepared for

CITY OF WEST COVINA
Community Development Department
Planning Division
1444 West Garvey Avenue South
West Covina, CA 91790
Prepared by
TERRY A. HAYES ASSOCIATES INC.
3535 Hayden Avenue, Suite 350
Culver City, CA 90232
January 2025
West Covina Medical Center Behavioral Health Building Addition Table of Contents Initial Study/Mitigated Negative Declaration
taha 2022-079 i

TABLE OF CONTENTS
Page No.

1.0 INTRODUCTION ............................................................................................................... 1-1

1.1 Project Overview ....................................................................................................... 1-1

1.2 Environmental Compliance Requirements ................................................................ 1-1

1.3 Project Information .................................................................................................... 1-1

1.4 Discretionary Actions and Approvals ......................................................................... 1-2

1.5 Organization of this Initial Study/Mitigated Negative Declaration ............................... 1-2

2.0 PROJECT DESCRIPTION ................................................................................................ 2-1

2.1 Project Location and Existing Setting ........................................................................ 2-1

2.2 Project Description .................................................................................................... 2-3

2.3 Construction Activities and Schedule ........................................................................ 2-4

3.0 INITIAL STUDY CHECKLIST AND EVALUATION ........................................................... 3-1

3.1 Aesthetics ................................................................................................................. 3-2

3.2 Agriculture and Forestry Resources .......................................................................... 3-6

3.3 Air Quality ................................................................................................................. 3-7

3.4 Biological Resources ............................................................................................... 3-15

3.5 Cultural Resources.................................................................................................. 3-19

3.6 Energy .................................................................................................................... 3-24

3.7 Geology and Soils ................................................................................................... 3-26

3.8 Greenhouse Gas Emissions .................................................................................... 3-31

3.9 Hazards and Hazardous Materials .......................................................................... 3-36

3.10 Hydrology and Water Quality .................................................................................. 3-39

3.11 Land Use and Planning ........................................................................................... 3-44

3.12 Mineral Resources. ................................................................................................. 3-45

3.13 Noise....................................................................................................................... 3-46

3.14 Population and Housing .......................................................................................... 3-54

3.15 Public Services ....................................................................................................... 3-55

3.16 Recreation .............................................................................................................. 3-59

3.17 Transportation ......................................................................................................... 3-60

3.18 Tribal Cultural Resources ........................................................................................ 3-71

3.19 Utilities and Service Systems .................................................................................. 3-73

3.20 Wildfire: ................................................................................................................... 3-79

3.21 Mandatory Findings of Significance ......................................................................... 3-81

4.0 LIST OF PREPARERS AND SOURCES CONSULTED .................................................... 4-1

4.1 Lead Agency ............................................................................................................. 4-1

4.2 Initial Study Preparers ............................................................................................... 4-1

4.3 Sources Consulted .................................................................................................... 4-1

APPENDICES
Appendix A Air Quality and Greenhouse Gas Emissions Calculations Appendix B Noise Calculations
Appendix C Transportation Impact Study
West Covina Medical Center Behavioral Health Building Addition Table of Contents Initial Study/Mitigated Negative Declaration
taha 2022-079 ii
TABLE OF CONTENTS (cont.)
Page No.

LIST OF FIGURES
Figure 2-1 Project Location .................................................................................................. 2-2 Figure 2-2 Schematic Site Plan ............................................................................................ 2-5 Figure 2-3 Building Elevations – Southwest and Southeast .................................................. 2-6 Figure 2-4 Building Elevations – North and Northeast .......................................................... 2-7 Figure 2-5 Overall Site Elevations – North and South ........................................................... 2-8

LIST OF TABLES
Table 3-1 SCAQMD Air Quality Significance Thresholds – Mass Daily Emissions .............. 3-8 Table 3-2 Estimated Regional Construction Emissions ..................................................... 3-10 Table 3-3 Estimated Daily Operational Emissions ............................................................. 3-11 Table 3-4 Estimated Localized Construction Emissions .................................................... 3-13 Table 3-5 Global Warming Potential for Various Greenhouse Gases ................................ 3-32 Table 3-6 Estimated Annual Greenhouse Gas Emissions ................................................. 3-33 Table 3-7 Existing Ambient Noise Levels .......................................................................... 3-48 Table 3-8 Construction Equipment Noise Level Ranges .................................................... 3-48 Table 3-9 Construction Phase Noise Levels ...................................................................... 3-49 Table 3-10 Unmitigated Construction Noise Levels at Off-Site Sensitive Receptors ............ 3-49 Table 3-11 Mobile Source Noise Levels .............................................................................. 3-51 Table 3-12 Change in Mobile Source Noise Levels ............................................................. 3-51 Table 3-13 Vibration Velocities for Construction Equipment ................................................ 3-52 Table 3-14 Existing Without and With Proposed Project Peak Hour Traffic Conditions ....... 3-63 Table 3-15 Year 2026 Conditions Without and With Proposed Project Peak Hour Traffic Conditions ......................................................................................................... 3-63 Table 3-16 San Jose Hills Normal Year Supply and Demand Comparison .......................... 3-74 Table 3-17 San Jose Hills Single Dry Year Supply and Demand Comparison ..................... 3-74 Table 3-18 San Jose Hills Multiple Dry Year Supply and Demand Comparison .................. 3-74 Table 3-19 Cumulative Projects .......................................................................................... 3-82 West Covina Medical Center Behavioral Health Building Addition 1.0 Introduction Initial/Study Mitigated Negative Declaration
taha 2022-079 1-1

1.0 INTRODUCTION
This section provides an overview of the environmental review process for the proposed West Covina Medical Center Behavioral Health Building Addition Project (proposed project) and identifies environmental compliance requirements and the discretionary actions and approvals needed to implement the proposed project.

1.1 PROJECT OVERVIEW
The proposed project would add a behavioral health transition facility to the eastern portion of the existing West Covina Medical Center at 725 South Orange Avenue in the City of West Covina (project site). The proposed building would be approximately 42,000 square feet in size and four stories high.

It would adjoin and connect to an existing one-story medical hospital building on the project site.

1.2 ENVIRONMENTAL COMPLIANCE REQUIREMENTS
Section 15063(a) of the California Environmental Quality Act (CEQA) Guidelines requires the lead agency to prepare an Initial Study (IS) to determine if the proposed project may have a significant effect on the environment. The purpose of this document is to inform the City of West Covina, public agencies, and interested parties of the potential environmental effects resulting from the proposed project. For the proposed project to obtain an environmental clearance in the form of a Mitigated Negative Declaration (MND) in compliance with CEQA, any potential significant adverse effects must be mitigated to a less than significant level. This document alone does not determine whether the proposed project will be approved. Rather, it is a disclosure document aimed at equally informing all concerned parties and fostering informed discussion and decision-making regarding all aspects of the proposed project.

1.3 PROJECT INFORMATION
Project Title and Location: West Covina Medical Center Behavioral Health Building Addition
725 South Orange Avenue
West Covina, CA 91790
Lead Agency Name and Address: City of West Covina
Community Development Department
Planning Division
1444 West Garvey Avenue South
West Covina, CA 91790
Contact Person and Phone Number: Jo-Anne Burns, Deputy Community Development Director
(626) 939-8422
Project Sponsor’s Name and Address: Building Resources
2247 Lindsay Way
Glendora, CA 91740
West Covina Medical Center Behavioral Health Building Addition 1.0 Introduction Initial/Study Mitigated Negative Declaration
taha 2022-079 1-2

1.4 DISCRETIONARY ACTIONS AND APPROVALS
Discretionary actions include those local approvals or entitlements necessary to implement a project. The proposed project requires the following discretionary actions:
 Precise Plan – Approval of a Precise Plan is required for the architectural design and site layout of the proposed development.
 Conditional Use Permit – Approval of a Conditional Use Permit is required for hospitals in an Urban Center zoning district.
 Variance – Approval of a Variance is required because the site with the proposed construction does not comply with the required number of onsite parking spaces.  Tree Removal Permit – Approval of a Tree Removal Permit is required to remove significant trees on the project site, as defined in Section 26-258 of the West Covina Municipal Code (WCMC).

1.5 ORGANIZATION OF THIS INITIAL STUDY/MITIGATED NEGATIVE

DECLARATION
The content and format of this Initial Study/Mitigated Negative Declaration (IS/MND) is designed to meet the requirements of CEQA. This IS/MND is organized into the following four sections:

1.0 Introduction. This section provides an overview of the proposed project, describes the environmental compliance requirements, and identifies the discretionary actions and approvals needed for the proposed project.

2.0 Project Description. This section identifies the location of the project site; describes the project site, the surrounding area, and the proposed project; and provides an estimated timeline for the construction and implementation of the proposed project.

3.0 Initial Study Checklist and Evaluation. This section contains the CEQA Guidelines Appendix G: Initial Study Checklist and identifies the level of impact under each environmental impact category. This section also includes a discussion of the environmental impacts and any mitigation measures associated with each category.

4.0 List of Preparers and Sources Consulted. This section provides a list of the consultant team members who participated, and a list of sources and references used in the preparation of this IS/MND.

West Covina Medical Center Behavioral Health Building Addition 2.0 Project Description Initial Study/Mitigated Negative Declaration
taha 2022-079 2-1

2.0 PROJECT DESCRIPTION
This section identifies the location of the project site, describes the project site and the surrounding area, provides a detailed description of the proposed project, and provides an estimated timeline for the construction and implementation of the proposed project.

2.1 PROJECT LOCATION AND EXISTING SETTING

PROJECT LOCATION
The 2.83-acre project site (Assessor's Identification Number [AIN] 8474-001-022) is located at 725 South Orange Avenue in the City of West Covina. The project site is located towards the western end of the City’s Downtown district and is bounded by Interstate 10 (I-10) to the north with multifamily residential complexes north of the I-10 freeway; I-10 eastbound on- and off-ramps to the east; Orange Avenue to the southeast with an automotive service business, a specialty retail and its associated surface parking lot across the street; and Cameron Avenue to the west and southwest with offices (including medical offices) and the West Covina Medical Center surface parking lot across the street from the project site (northwest corner of the Orange Avenue/Cameron Avenue intersection). The West Covina Medical Center surface parking lot is currently used by patients, visitors, and staff of the medical center. The proposed project would be located at the eastern portion of the project site on approximately 36,400 square feet of the 2.83-acre project site. The project site and the surrounding uses are shown in Figure 2-1.

The project site is in the Urban Center (T-5) zoning district within the Downtown Plan Overlay Zone and has a General Plan land use designation of Commercial (C).

EXISTING SITE CONDITIONS
The project site is relatively flat and is currently occupied by the West Covina Medical Center, which consists of three adjoining low-rise structures and surface parking. The structure adjacent to Orange Avenue is a three-story 18,000-square-foot medical office building. The structure immediately northwest of this building is a 15,000-square-foot medical office building that is primarily one story. The northwestern corner of the 15,000-square-foot building is two stories.

Adjoining the northern portion of this 15,000-square foot medical office building is a 28,000-squarefoot medical hospital that is primarily one story. The southwestern corner of this 28,000-square-foot building is three stories.

Vegetation on the project site consists of grass, trees, and bushes. Landscaping is generally provided along the perimeter of the project site, along the sides of the existing buildings, in the courtyard between the medical hospital and the 15,000-square-foot medical office building, and in the surface parking lot at the eastern portion of the project site. The Arborist Report and Tree Protection Plan for the proposed project identified 87 trees on or adjacent to the project site, of which 57 trees are classified as significant per Section 26-258 of the WCMC.1 1Per WCMC Section 26-258, a significant tree is defined as a tree on private and/or public property that meets one or more of the following: a) located in the front yard of a lot or parcel and has a caliper of one foot or more; b) located in the street-side yard of a corner lot and has a caliper of one foot or more; and/or c) located anywhere on a lot, has a caliper of six inches or more, and is an oak tree native to California, California Sycamore, or American Sycamore. WCMC Section 26-258 defines caliper as the maximum diameter of the trunk of a tree measured at 4.5 feet above the natural grade. In the case of multi-trunked trees, caliper means the sum of the calipers of each individual trunk measured at 4.5 feet above grade.

TAHA 2022-079
West Covina Medical Center Behavioral Health Addition
Initial Study/Mitigated Negative Declaration

CITY OF WEST COVINA
FIGURE 2-1

PROJECT LOCATION AND SURROUNDING LAND USE
Source: TAHA, 2024.

West Covina Medical Center Behavioral Health Building Addition 2.0 Project Description Initial Study/Mitigated Negative Declaration
taha 2022-079 2-3
Trees on or adjacent to the project site include bird of paradise (Strelitzia nicolai), Brazilian pepper (Schinus terebinthifolia), brush cherry (Syzygium paniculatum), Buddhist pine (Podocarpus macrophyllus), Canary Island date palm (Phoenix canariensis), carrotwood (Cupaniopsis anacardioides), Chinese elm (Ulmus parvifolia), crepe myrtle (Lagerstroemia indica), Indian laurel (Ficus microcarpa), Mexican fan palm (Washingtonia robusta), pecan tree (Carya illinoinensis), Pygmy date palm (Phoenix roebelenii), Red frangipani (Plumeria rubra), and weeping fig (Ficus benjamina).

SURROUNDING AREA
The project site is generally surrounded by one- to three-story commercial buildings. Most of the commercial uses consist of offices, some of which are healthcare related. Specifically, a three-story office building and a surface parking lot that serves the West Covina Medical Center facility are located to the west across Cameron Avenue, with one- and two-story single-family residences, a twostory office building, and a one-story healthcare center located further west. The West Covina Medical Center surface parking lot on the west side of Cameron Avenue is currently used by patients, visitors, and staff of the medical center. An office park with one- and two-story buildings are located south of the Cameron Avenue/Orange Avenue intersection with single-family residences located further south and southwest. A one-story automobile service business, specialty retail business and its associated surface parking lot are located across Orange Avenue to the southeast with additional offices located further southeast. The I-10 eastbound on- and off-ramps are located to the east of the project site with a two-story healthcare-related office building and the City’s Civic Center located further east. The civic and public institutional buildings in the Civic Center range from one to three stories tall. A mix of one- to three-story multi-family residential and one- to two-story commercial uses are situated north of I-10 freeway.

The commercial uses and surface parking lot to the west, southwest, and south of the project site (across from Cameron Avenue) are in the General Urban (T-4) zoning district and have a General Plan land use designation of Neighborhood – Medium Density Residential (NM). The commercial uses and surface parking lot to the southeast (across from Orange Avenue) are in the Urban Center (T-5) zoning district and have a General Plan land use designation of Commercial (C). The multifamily residential uses north of I-10 are zoned as either Residential 15 dwelling units per acre (MF15), Residential 20 dwelling units per acre (MF-20), Residential 45 dwelling units per acre (MF-45), or Neighborhood Commercial (N-C). The R-A and MF-45 zoned residential uses have a General Plan land use designation of Neighborhood – High Density Residential (NH). The MF-20 and N-C zoned residential uses have a General Plan land use designation of NM. The commercial use to the north of I-10 is zoned N-C and has a General Plan land use designation of C.

Regional mass transit service is provided by Foothill Transit, with the closest bus stop located on Pacific Avenue, just north of Garvey Avenue North/I-10 on- and off-ramp, approximately 600 feet north of the project site across from the 1-10 freeway. Local transit service is provided by the City’s Go West Shuttle Blue Line. The closest shuttle stop is located on Orange Avenue, just southwest of Cameron Avenue, approximately 150 feet south of the project site.

An aerial photograph depicting the project site and the surrounding land uses is presented in Figure 2-1.

2.2 PROJECT DESCRIPTION
The proposed project would generally be located on approximately 36,400 square feet of the 2.83- acre project site. The existing 55-space surface parking lot at the eastern portion of the project site would be replaced with a four-story 42,000-square foot behavioral health facility with a patient dropoff area, ambulance drop-off area, six parking spaces, and new landscaping. The proposed building would adjoin and connect to the existing one-story medical hospital. The proposed building would West Covina Medical Center Behavioral Health Building Addition 2.0 Project Description Initial Study/Mitigated Negative Declaration
taha 2022-079 2-4
have a total of 71 licensed beds and would be up to 70 feet in height. The proposed patient dropoff area would be located to the southeast of the proposed building. All patients are expected to be transported to the proposed addition via ambulance or non-medical emergency transport van from another facility (such as a skilled nursing or residential care facilities) to the proposed facility for treatment. No sirens would be used.

The first floor of the proposed facility would consist of an ambulance drop-off area, a loading and receiving area, a kitchen services area, a lobby/reception area, staff areas, and utility rooms (e.g., electrical and information technology rooms). The kitchen services area would be developed to serve the existing 46 patient beds in the existing medical facility and the 71 patient beds for the proposed building. The patient drop-off area will be located to the southeast of the proposed building with the building entrance located at the southeastern end of the proposed addition. The ambulance drop-off area would be located on the north side of the proposed building, near the I-10 freeway.

The second through fourth floor would each have 12 patient rooms, exam/consultation rooms, nursing station and offices, a dining area, and utility rooms. Indoor activity space is proposed on the western end of the second and third floor, and outdoor activity space is proposed at the eastern end of the second floor and at the western end of the fourth floor. Mechanical services units for the proposed facility would be provided on the rooftop of the proposed building.

The parking lot at the eastern portion of the project site currently has 55 surface parking spaces.

With implementation of the proposed project, this surface parking lot would have four parking spaces. The existing ten parking spaces located on the north side of the existing building would remain, while the carport and parking spaces located on the west of the existing building would be removed/demolished with only two parking spaces remaining. The existing 132 off-site surface parking spaces on the west side of Orange Avenue (across the street from the project site) would remain unchanged.

Existing vegetation on the eastern portion of the project site, including 38 existing trees, would be removed to accommodate the proposed project. Of the 38 existing trees that would be removed, 25 trees are classified as significant trees per Section 26-258 of the WCMC. Landscaping is proposed along the southeastern perimeter of the project site; on the southeast side of the patient drop-off area; and to the north, east, and south sides of the proposed building. The new landscaping would be drought tolerant.

Figure 2-2 shows the proposed site plan, and Figures 2-3 through 2-5 illustrate the elevations for the proposed building.

2.3 CONSTRUCTION ACTIVITIES AND SCHEDULE
Construction of the proposed project is anticipated to begin in 2025 and would last for approximately 24 months. Approximately 36,400 square feet of the 2.83-acre project site would be disturbed.

Construction activities include site clearing, grading, building construction, and paving. Site clearing and grading is estimated to last for approximately two months, paving would last for approximately two months, and building construction would last for approximately 20 months. Although construction would primarily occur at the eastern portion of the project site, the existing parking area and drive aisles to the north and west of the existing medical hospital would be repaved with the proposed project. Construction activity would occur Mondays through Fridays for eight hours per day, in accordance with the City’s permitted hours of construction. Construction of the proposed project is expected to be completed in 2027.

TAHA 2022-079
West Covina Medical Center Behavioral Health Addition
Initial Study/Mitigated Negative Declaration

CITY OF WEST COVINA
FIGURE 2-2

SCHEMATIC SITE PLAN
Source: c|a ARCHITECTS, 2024.

TAHA 2022-079
West Covina Medical Center Behavioral Health Addition
Initial Study/Mitigated Negative Declaration

CITY OF WEST COVINA
FIGURE 2-3

SOUTHWEST AND SOUTHEAST ELEVATIONS
Source: c|a ARCHITECTS, 2022
2 Southeast Elevation Key Plan
1 Southwest Elevation Key Plan
TAHA 2022-079
West Covina Medical Center Behavioral Health Addition
Initial Study/Mitigated Negative Declaration

CITY OF WEST COVINA
FIGURE 2-4

NORTH AND NORTHEAST ELEVATIONS
Source: c|a ARCHITECTS, 2022
Northeast Elevation Key Plan
North Elevation
Roof
4th Floor
3rd Floor
2nd Floor
+18'
+32'
+46'
+60'
View from Interstate 10
Building Addition Ambulance drop-off
Vehicular drop off Skewed elevation
Metal fascia at 2nd floor line
Profiled metal fascia at roof
cornice.

Aluminum storefront window
system, paint finish
Smooth exterior plaster with clear
anodized 1" wide reveals
Smooth exterior plaster color
band at vehicular arrival level
Mechanical equipment screen at
roof level
Smooth exterior plaster, color 3
Smooth exterior plaster, color 2
Top of stair
tower
Roof
4th Floor
3rd Floor
2nd Floor
+18'
+32'
+46'
+60'
N
Key Plan
Smooth exterior plaster with clear
anodized 1" wide reveals
Smooth exterior plaster with clear
anodized 1" wide reveals, color 2
Smooth exterior plaster, color 3
Metal fascia at 2nd floor line
Smooth exterior plaster color
band at vehicular arrival level
Top of stair
tower
1 2
+70'
+70'
TAHA 2022-079
West Covina Medical Center Behavioral Health Addition
Initial Study/Mitigated Negative Declaration

CITY OF WEST COVINA
FIGURE 2-5

NORTH AND SOUTH ELEVATIONS
Source: c|a ARCHITECTS, 2022
Site Section, looking South
New 4 Level Building Existing 1 and 2 Story Building West Cameron Avenue Pacific Avenue/West
Covina Parkway
Exit
West Cameron Avenue Existing Building New Building
Site Section, looking North
Pacific
Avenue/West
Covina Parkway
Exit
N
Key Plan
Key Plan
As seen from Interstate 10
As seen from Orange Avenue
West Covina Medical Center Behavioral Health Building Addition Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-1

3.0 INITIAL STUDY CHECKLIST AND EVALUATION

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.

Aesthetics Agriculture/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: (To be completed by the Lead Agency):

On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a "potentially significant" or "potentially significant unless mitigated" 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.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Jo-Anne Burns, Deputy Community Development Director
Printed Name
City of West Covina
For
West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-2
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.1 AESTHETICS. Would the project:
a) Have a substantial adverse effect on a scenic
vista?    
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
   
c) Substantially degrade the existing visual
character or quality of public views of the site
and its surroundings? (Public views are those
that are experienced from publicly accessible
vantage point). If the project is in an urbanized
area, would the project conflict with applicable
zoning and other regulations governing scenic
quality?
   
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?
   
a) No Impact. A scenic vista is defined as a public viewpoint that provides expansive views of a highly valued landscape for the benefit of the general public. Public views are those that are experienced from a publicly accessible vantage point, such as a roadway or public park.

No scenic vistas are available on the project site or within the surrounding area. San Jose Hills is the nearest scenic vista to the project site. San Jose Hills is approximately 3.5 miles southeast of the project site and is not clearly visible from the project site and its surrounding area.2 Views of San Jose Hills are primarily blocked by intervening structures and trees.

Views of the San Gabriel Mountains to the north of the project site are blocked by the I-10 freeway. Clear unobstructed views of the San Gabriel Mountains and San Jose Hills are not available on the project site and its surrounding areas. Existing trees along the perimeter of the project site also block views of the San Gabriel Mountains and San Jose Hills from the project site. The proposed project would construct a four-story addition to the existing medical center on the project site with a height of up to 70 feet. Although the proposed building would be taller than the existing one- to three-story structures on the project site and in the surrounding area, the proposed project is not expected to obstruct any scenic vistas since none are available in the surrounding area. Intervening structures and trees would continue to block most views of the San Gabriel Mountains and San Jose Hills with implementation of the proposed project. Therefore, no impact would occur. b) No Impact. A significant impact would occur if the proposed project would substantially damage scenic resources within a state scenic highway. The project site is not located on or in the vicinity of a scenic highway. The nearest state-designated scenic highway is Angeles Crest Highway (State Route 2), approximately 15 miles northwest of the project site.3 The nearest state-eligible scenic highways are San Gabriel and Azusa Avenues north of Interstate 210, approximately four miles northeast of the project site. Due to intervening buildings, trees, and the I-10 freeway, the project site is not within the viewshed of these state-designated and state-eligible scenic highways. Therefore, no impact would occur. 2City of West Covina, West Covina General Plan, adopted December 2016. 3California Department of Transportation, California State Scenic Highway System Map, https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-3
c) Less-Than-Significant Impact with Mitigation Incorporated. The project site is in an urbanized area of the City and is in the Urban Center (T-5) zoning district within the Downtown Plan Overlay Zone. The project site has a General Plan land use designation of Commercial (C). The project site is developed with two buildings that are primarily one story in height, one three-story building, surface parking, and landscaping. Trees along the perimeter of the project site generally limit views of the western and eastern portions of the project site. The surrounding properties to the west, south, and east of the project site consists of primarily one- to three-story commercial uses. The proposed project would construct a four-story building that would be up to 70 feet high on the project site. The new building would adjoin the existing one-story medical hospital building on the project site. The proposed four-story building would have a modern architectural design with smooth white exterior walls and metal fascia between the first and second floor. The first floor of the southeast and southwest elevations would be painted yellow to identify the patient drop-off and the intake/lobby/waiting/reception areas. The design of the proposed building would be consistent with the visual character of the existing buildings on the project site and in the surrounding area. Additionally, the proposed structure would be set back approximately 130 feet from Orange Avenue and 210 feet from Cameron Avenue. The setback distances from the public rights-of-way would reduce the scale of the proposed building from the surrounding area. Along Orange Avenue, the trees along the perimeter of the project site would partially obstruct views of the proposed building, which would further reduce the scale of the proposed building. Along Cameron Avenue, the distance of the proposed building from the street, trees along the perimeter of the project site, and existing medical buildings on the project site would reduce the scale of the proposed building from the surrounding area.

The project site is in the Urban Center zoning district. Per the City’s Downtown Plan & Code, new buildings in this zoning district are to be up to five stories and a maximum of 70 feet in height.4 The proposed four-story, 70-foot-high building would comply with the building height requirement for the Urban Center Zone. The project site has 87 trees on or adjacent to the project site, of which 57 are classified as significant trees per Section 26-258 of the WCMC.

The proposed project would remove 38 trees, of which 25 trees are classified as significant trees. The proposed project would be required to comply with Chapter 26, Article VI, Division 9 (Preservation, Protection and Removal of Trees) of the WCMC. Per Section 26-259of the WCMC, a tree removal permit would be required and would need to be obtained by the applicant prior to the removal of any significant trees on or adjacent to the project site. Per Section 26-262 of the WCMC, any significant trees that would be removed are required to be replaced with trees of comparable species, size, and condition as the existing trees. If it is not possible to relocate the existing trees or provide replacement trees on or off the project site, the applicant would be required to provide payment of the proper restitution value of the trees or donate boxed trees to the City to be used elsewhere in the City. The design of the proposed project limits the number of trees that could be planted on the project site. As it is not possible for the applicant to relocate or replace the existing 25 significant trees that would be removed by the proposed project, the applicant would be required to plant replacement trees off site, provide payment for the restitution value of the trees, or donate box trees to the City.

Construction activities, such as grading and other ground disturbance activities, equipment access and staging, right-of-way clearance, and tree removal have the potential to adversely affect protected trees. These activities could potentially damage roots and/or require excessive canopy removal, which could affect tree health and mortality. Generally, encroachments within the dripline and optimal tree protection zone, such as root severance and soil compaction, increase the likelihood that the tree would experience temporary or permanent negative health impacts, such as dieback, decline, decay, and death. Encroachments within the structural 4City of West Covina, West Covina Downtown Plan & Code, adopted December 2016.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-4
rooting radius, particularly root severance of larger roots, increase the likelihood of tree destabilization. The Arborist Report and Tree Protection Plan for the proposed project determined that 15 trees, which would not be removed by the proposed project, would likely be affected by the proposed project. Of the 15 trees, construction of the proposed project would not compromise the health or structural integrity, would encroach approximately 30 percent or less of the dripline and/or the optimal tree protection zone, and/or would avoid the structural rooting radius of 11 trees. For the remaining four trees, the health or structural integrity may be compromised, construction activities would encroach greater than 30 percent or more of the dripline and/or optimal tree protection zone, and/or a portion of the structural rooting radius would be affected. After construction, these four trees may be at increased risk of failure during atypical weather events that produce high winds and oversaturated soil. The Arborist Report and Tree Protection Plan for the proposed project provide protective measures for the proposed project to implement. These measures include:
 Prohibiting grading, construction, or construction-related activities within the dripline of a significant tree or heritage tree;
 Providing construction barrier to shield significant trees and heritage trees from damage during construction;
 Requiring structures or impervious paving to be located outside of the dripline or a six-foot radius of the trunk perimeter, whichever is greater, of any significant tree or heritage tree;  Pruning branches that could be injured by vehicles or that could interfere with the development activity;
 Not allowing compaction of soil within the dripline of any tree;  Not permitting construction, including structures and walls, that disrupts the root system;  Requiring the landscaping and irrigation plan to be tailored per the needs of the retained trees;
 Allowing the Planning Director to impose additional measures determined necessary to preserve and protect the health of trees to remain, relocated trees, and new trees planted to replace those removed;
 Requiring a certified arborist to oversee activities that would affect tree roots or canopy;  Requiring temporary equipment staging and storage to be located in areas away from the canopies and dripline of trees;
 Requiring that any limbs and branches that are damaged be trimmed with clean and sharp pruners immediately in accordance with the American National Standards Institute standards, Section 8 Pruning Practices; and
 Limiting pruning and trimming of protected trees to only what is necessary for construction and to be conducted under the direct supervision of a certified arborist.5 The design of the proposed building would be consistent with the visual character of the existing buildings on the project site and the surrounding area and would comply with the City’s zoning and other regulations that govern scenic quality. New landscaping would be installed and would comply with the City’s landscape requirements. Additionally, the applicant would be required to comply with Chapter 26, Article VI, Division 10 (Preservation, Protection and Removal of Trees) of the WCMC with regards to the proposed tree removal. As development of the proposed project has the potential to affect 15 trees that would remain on the project site, implementation of Mitigation Measure A-1 would be required. Mitigation Measure A-1 would limit the effects that development of the proposed project would have on existing trees that would remain on the project site. Therefore, with implementation of Mitigation Measure A1, a less-than-significant impact on visual character and quality would occur. 5Rincon Consultants, Inc., West Covina Medical Center at 725 and 741 Orange Ave: Arborist Report and Tree Protection Plan, July 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-5
d) Less-Than-Significant Impact. A significant impact would occur if the proposed project would create a new source of substantial light or glare that adversely affects day or nighttime views in the surrounding area. The project site is located in an urbanized area with a moderate level of ambient lighting. Existing nighttime lighting sources on the project site and in the surrounding area include streetlights, vehicle headlights, lighting from surface parking lots, and interior and exterior building illumination from the project site and surrounding commercial uses. The proposed project would install exterior lighting at the proposed ambulance drop-off area, loading and receiving dock area, patient drop-off area, building entrance, and at the surface parking lot and driveway aisles. Exterior lighting levels associated with the proposed project would be consistent with the existing nighttime lighting levels of the project site and the surrounding area. No light sensitive land uses would be affected by the proposed project. Additionally, the proposed project would comply with the lighting standards in the WCMC, including Section 26-92 of the WCMC, which requires lights to be hooded and directed away from adjoining properties. Compliance with WCMC would prevent lighting on the project site from spilling over onto the surrounding area.

The proposed project does not include features that would introduce a major source of glare during the day and night. The proposed structures would be constructed with primarily nonreflective materials, such as stucco on the exterior facades. The use of metal would be limited to the fascia just above the first floor and at the roof cornice. The narrow strips of metal at the fascia above the first floor and at the roof cornice are not expected to generate a substantial amount of glare that would affect the surrounding area. Additionally, trees along the perimeter of the project site would further prevent glare from adversely affecting the surrounding area. Therefore, the proposed project would not create new sources of substantial light or glare, and a less-than-significant impact would occur.

MITGATION MEASURES
A-1 The applicant shall comply with all protective measures identified in the Arborist Report and Tree Protection Plan for the proposed project.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-6
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.2 AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment Project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural 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?
   
a-b) No Impact. Due to its urban setting, the project site and its surroundings are not included in the Farmland Mapping and Monitoring Program of the California Department of Conservation.6 In addition, the project site is not located within a zone designated for agricultural use or an area that is designated as Williamson Act contract lands. The project site is in the City’s Urban Center zoning district. No agricultural uses or related operations are present within the project site or in the surrounding area. Therefore, no impact on farmland would occur.
c-d) No Impact. The project site is located within an urban area that is not zoned as forest land. No forest land or forest resources are located on the project site or in the surrounding area.

Therefore, no impact would occur.
e) No Impact. As discussed in Responses to Checklist Questions 3.2(a) through (d), no agricultural or forestry operations occur on the project site or its vicinity. The proposed project would not introduce any changes that would result in the conversion of farmland or forest land to non-agricultural or forest use, respectively. Therefore, no impact would occur. 6California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/DLRP/CIFF/, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-7
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.3 AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?    
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is nonattainment under an
applicable federal or state ambient air quality
standard?
   
c) Expose sensitive receptors to substantial pollutant
concentrations?    
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial number
of people?
   
Air quality is typically characterized by ambient air concentrations of seven specific pollutants identified by the United States Environmental Protection Agency (USEPA) to be of concern with respect to health and welfare of the general public. Federal criteria air pollutants include groundlevel ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), respirable particulate matter ten microns or less in diameter (PM10), fine particulate matter 2.5 microns or less in diameter (PM2.5), and lead (Pb). These specific pollutants, known as criteria air pollutants, are pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. These pollutants are common byproducts of human activities and have been documented through scientific research to cause adverse health effects. The federal ambient concentration criteria are known as the National Ambient Air Quality Standards (NAAQS), and the California ambient concentration criteria are referred to as the California Ambient Air Quality Standards (CAAQS). In addition to the federal criteria pollutants, the state regulates visibility-reducing particles, sulfates, hydrogen sulfide, and vinyl chloride.

Air quality in California is governed by the California Clean Air Act (CCAA). The CCAA is administered by the California Air Resources Board (CARB) at the state level and by the air quality management districts at the regional and local levels. The CCAA requires all areas of the state to achieve and maintain the CAAQS by the earliest feasible date. The proposed project is located in the South Coast Air Basin (SCAB). The Los Angeles County portion of SCAB does not meet the CAAQS for O3, PM10, and PM2.5.

The air quality analysis for the proposed project is consistent with the methods described in the South Coast Air Quality Management District (SCAQMD) CEQA Air Quality Handbook (1993 edition), as well as the updates to the CEQA Air Quality Handbook.7 SCAQMD methodologies recommend that air pollutant emissions be analyzed in both regional and local contexts. Regional emissions refer to all emissions that would be associated with construction and operation of a project, while localized emissions refer to only those emissions that would be produced by sources located on the project site. To assist in the assessment of air pollutant emissions, the SCAQMD established maximum daily threshold values for air pollutant emissions from CEQA projects within the SCAB. The mass daily thresholds were derived using regional emissions modeling techniques to prevent the occurrence of air quality violations that would 7SCAQMD, Air Quality Analysis Guidance Handbook, http://www.aqmd.gov/home/regulations/ceqa/air-qualityanalysis-handbook, accessed January 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-8
obstruct implementation of the Air Quality Management Plan (AQMP) and hinder efforts to improve regional air quality.

Table 3-1 presents the SCAQMD mass daily air quality significance thresholds for regional and localized emissions of regulated pollutants resulting from construction activities, as well as regional mass daily thresholds for operational emissions.8 The localized construction thresholds are specific to SCAQMD Source Receptor Area (SRA) 11 for a one-acre construction site with sensitive receptors within 100 meters and were obtained from the SCAQMD localized significance threshold (LST) guidance document.9,10 The LST values were derived from regionally-specific modeling of pollutant emissions and designed to prevent localized pollutant concentrations from exceeding applicable ambient air quality standards near construction sites based on existing ambient air quality. The mass daily emissions thresholds were established as screening criteria for emissions from proposed CEQA projects. The SCAQMD generally advises that a project generating maximum daily emissions of the pollutants shown in Table 3-1 of lesser magnitude than the corresponding threshold values would not cause a significant air quality impact at the regional or local level.

TABLE 3-1: SCAQMD AIR QUALITY SIGNIFICANCE THRESHOLDS – MASS DAILY EMISSIONS Pollutant VOC NOX CO SOX PM10 PM2.5

CONSTRUCTION
Regional Threshold (lbs/day) 75 100 550 150 150 55
Localized Threshold (lbs/day) -- 96 1,113 -- 29 9

OPERATIONS
Regional Threshold (lbs/day) 55 55 550 150 150 55
Note: Construction LST values selected for a three-acre daily disturbance based on equipment inventory and 100-meter receptor distance in SRA 11.

SOURCE: SCAQMD, 2019; 2009.

The SCAQMD recognizes that air quality impacts for individual projects with emissions that remain below the thresholds shown in Table 3-1 would be considered less than significant at the project level and would not be cumulatively considerable. If maximum daily emissions would exceed applicable threshold values during construction or operations, opportunities to mitigate and reduce those emissions are required to be explored and implemented as feasible.

In addition to the mass daily thresholds for criteria pollutants and O3 precursors, SCAQMD has established CEQA significance thresholds related to toxic air contaminants (TACs) and odorous emissions. As a diverse class of pollutants, TACs include many different pollutants with varying degrees of toxicity and that affect human health in different ways. Within the field of health risk assessment, carcinogenic risk and non-carcinogenic hazards can be determined based on multipollutant exposures. According to SCAQMD methodology, health effects from carcinogenic air toxics are described in terms of excess incremental individual cancer risk. “Individual Cancer Risk” is the likelihood that a person continuously exposed to TAC concentrations over a 70-year lifetime will contract cancer based on the use of standard risk assessment methodology. SCAQMD established a project-specific TAC carcinogenic exposure threshold of an incremental excess cancer risk of 10 cases per million. For non-carcinogenic TACs, the acute and chronic exposures should not exceed a combined calculated Hazard Index value of 1.0, based on pollutant-specific reference-exposure levels.
8SCAQMD, SCAQMD Air Quality Significance Thresholds – Mass Daily Thresholds, April 2019. 9SCAQMD, Final Localized Significance Threshold Methodology Appendix C Mass Rate Lookup Tables, October 21, 2009.
10SCAQMD, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, 2008.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-9
Construction and operation of certain land use development projects may create public nuisances related to visible dust plumes and odors. The SCAQMD air quality significance thresholds address odorous emissions by invoking compliance with SCAQMD Rule 402. A project may have a significant air quality impact if construction or operation of that project creates a public nuisance condition in violation of SCAQMD Rule 402. Visible dust plumes are controlled through the enforcement of SCAQMD Rule 401 and SCAQMD Rule 403.
a) Less-Than-Significant Impact. The applicable air quality plan is the SCAQMD 2022 AQMP, which is based on regional growth projections assessed in the Southern California Association of Governments (SCAG) Connect SoCal 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) related to population and employment.

The 2022 AQMP provides policies and control measures that would reduce emissions to attain both state and federal ambient air quality standards by their applicable deadlines.

Environmental review of individual projects within the SCAB must demonstrate that daily construction and operational emissions thresholds, as established by SCAQMD, would not be exceeded. The environmental review must also demonstrate that individual projects would not increase the number or severity of existing air quality violations.

The SCAQMD CEQA Air Quality Handbook identifies two key indicators of consistency with the AQMP:
1) Whether the project would result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the air quality plan; and
2) Whether the project would exceed the forecasted growth incorporated into the AQMP via the RTP/SCS.

Consistency Criterion 1: Air Quality Violations
Construction Emissions. Air quality violations are determined by an SCAQMD Air Quality Inspector when a business is out of compliance with applicable SCAQMD rule requirements, permit conditions or legal requirements, or with applicable state or federal air pollution regulations. Air quality violations typically involve large industrial facilities that emit vast quantities of highly regulated pollutants and are not common among typical land use development projects. Construction of the proposed project would be conducted in accordance with the best management practices (BMPs) provided in SCAQMD Regulation IV, Rule 401 (Visible Emissions) and Rule 403 (Fugitive Dust). These BMPs include the application of water as a dust suppressant to material stockpiles and disturbed ground areas. The application of these BMPs would reduce fugitive dust emissions during construction activities by approximately 61 percent. All construction equipment and vehicles would be maintained and operated within manufacturer specifications to limit unnecessary emissions during use, and any vehicles traveling on unpaved surfaces would be required to limit their speed to 15 miles per hour or less. Construction of the proposed project would not have the potential to obstruct or conflict with implementation of the AQMP in the context of SCAQMD rule requirements.

Estimates of maximum daily air pollutant emissions that would be generated by construction activities can be used to demonstrate that the proposed project would not conflict with or obstruct implementation of the AQMP with regards to increasing the frequency or severity of existing air quality violations. SCAQMD devised its mass daily thresholds of significance as a screening tool for determining the potential significance of air pollutant emissions from CEQA projects. Emissions of air pollutants that would be generated by construction West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-10
activities were calculated using the California Emissions Estimator Model (CalEEMod, Version 2022.1.1.21). CalEEMod is the preferred regulatory tool for estimating air pollutant emissions associated with land use developments in California. Sources of air pollutant emissions associated with proposed project construction include heavy-duty diesel equipment exhaust, fugitive dust generation from material movement, off-gassing of volatile compounds from architectural finishing, haul truck trips, vendor material delivery trips, and construction worker trips.

Table 3-2 presents the maximum daily regional emissions that would be generated by each construction activity for the proposed project. Maximum daily emissions during construction are compared to the applicable SCAQMD mass daily thresholds of significance.

Construction of the proposed project would not generate daily emissions of criteria pollutants or O3 precursors in excess of any SCAQMD regional threshold. Thus, construction of the proposed project would not result in an increase in the frequency or severity of existing air quality violations, would not cause or contribute to new violations, and would not obstruct timely implementation of the AQMP.

TABLE 3-2: ESTIMATED REGIONAL CONSTRUCTION EMISSIONS
Construction Activity
Maximum Daily Emissions (Pounds Per Day)
VOC NOX CO SOX PM10 PM2.5
Site Preparation 0.2 2.7 3.5 <0.1 1.3 0.2
Grading 0.9 8.7 8.8 <0.1 2.9 1.4
Building Construction 1.5 6.1 23.3 <0.1 3.4 0.9
Paving + Architectural Coating 26.8 2.9 4.4 <0.1 0.8 0.2 Maximum Daily Emissions 26.8 8.7 23.3 <0.1 3.4 1.4
Regional Significance
Threshold 75 100 550 150 150 55
Exceed Threshold? No No No No No No
Note: Emissions modeling files can be found in Appendix A.

SOURCE: TAHA, 2024.

Operational Emissions. CalEEMod was also used to produce estimates of daily air pollutant emissions during future operation. CalEEMod generates default estimates of population growth and daily vehicle trips associated with land uses in lieu of project-specific information. Direct sources of operational emissions would include mobile source vehicle trips and area source emissions such as consumer product use (i.e., household cleaners) and landscaping activities. Indirect source emissions during operations would include energy consumption such as natural gas use associated with space heating, water heating, and stoves, as well as electricity for lighting and appliances. The primary source of operational emissions would be on-road vehicle travel. The Transportation Impact Study (TIS) for the proposed project, which is included in Appendix C, determined that operations would generate 452 daily vehicle trips.11 The CalEEMod program generates estimates of emissions from energy use (i.e., natural gas consumption) based on the land use type and size of the project and average building energy demand factors. Table 3-3 presents the estimated operation emissions of the proposed project. As shown, future operation of the 11Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-11
proposed project would not result in daily emissions that exceed any of the applicable SCAQMD regional thresholds.

TABLE 3-3: ESTIMATED DAILY OPERATIONAL EMISSIONS
Operational Activity
Maximum Daily Emissions (Pounds Per Day)
VOC NOX CO SOX PM10 PM2.5
Area Sources 1.5 <0.1 2.8 <0.1 <0.1 <0.1
Energy Sources <0.1 0.3 0.2 <0.1 <0.1 <0.1
Mobile Sources 1.5 1.3 13.9 <0.1 3.3 0.9
Daily Operational Emissions 3.0 1.6 16.9 <0.1 3.3 0.9
Regional Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
Note: Emissions modeling files can be found in Appendix A.

SOURCE: TAHA, 2024.

Consistency Criterion 2: AQMP Growth Forecast
The second AQMP consistency criterion requires that the proposed project does not exceed the growth assumptions in the AQMP. The population and employment assumptions used to estimate regional emissions in the AQMP are obtained from SCAG projections for cities and unincorporated areas within the SCAQMD jurisdiction. Projects that are consistent with regional growth projections are generally consistent with the AQMP. The proposed project is an addition to an existing medical center and would not construct any housing units. The proposed project is an addition to an existing medical center and would not construct any housing units. The proposed project would provide a net increase of approximately 50 jobs in the City that can be filled by the local labor force. There is no potential for this relatively small number of jobs to interfere with long-term growth forecasts. Thus, the proposed project would, therefore, have no potential to interfere with population, housing, or employment growth forecasts. Therefore, the proposed project would not result in growth that would exceed the projections incorporated into the AQMP.

Summary
The proposed project would not result in daily regional emissions that exceed the applicable SCAQMD thresholds, which were established to ensure that individual projects would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP (Consistency Criterion 1). Additionally, the proposed project would not have the potential to result in population and employment growth that would exceed the growth projections incorporated into the AQMP (Consistency Criterion 2). Therefore, the proposed project would be consistent with the AQMP, and a less-than-significant impact would occur.
b) Less-Than-Significant Impact. The Los Angeles County portion of SCAB has ongoing cumulative regional emissions for O3, PM10, and PM2.5 since the region is designated as non-attainment of the NAAQS and CAAQS for these air pollutants. Considering existing environmental conditions, SCAQMD propagated guidance that an individual project can emit allowable quantities of these pollutants on a regional scale without significantly contributing to cumulative emissions of criteria pollutants for which the region is nonattainment (Table 3-1). As such, individual projects that do not generate emissions greater than the SCAQMD regional significance thresholds are not expected to result in West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-12
cumulatively considerable net increase of any criteria pollutant for which SCAB is nonattainment. As discussed in Response to Checklist Question 3.3a, daily regional and localized emissions associated with construction and operation of the proposed project would be below all applicable regional SCAQMD thresholds. Therefore, the proposed project would not result in a cumulatively considerable net increase of non-attainment pollutants, and a less-than-significant impact would occur. c) Less-Than-Significant Impact. Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved.

CARB has identified the following groups who are most likely to be affected by air pollution:
children less than 14 years of age, the elderly over 65 years of age, athletes, and people with cardiovascular and chronic respiratory diseases. According to SCAQMD, air quality sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes.

SCAQMD has established 1,640 feet (500 meters) as the distance for assessing localized air quality impacts. Air quality sensitive land uses within 1,640 feet of the project site include:
 Mauna Loa Garden Apartments located approximately 365 feet (112 meters) to the north;
 Assisted Home Health and Hospice located approximately 415 (125 meters) feet to the west;
 Residences located approximately 570 feet (174 meters) to the southwest;  Four Palms Apartments located approximately 715 feet (218 meters) to northwest;  Residences located approximately 800 feet (230 meters) to the north;  Residences located approximately 915 feet (280 meters) to the northwest; and  Residences located approximately 1030 feet (315 meters) to the northeast.

Construction
Sensitive receptors near the project site may be exposed to pollutant concentrations emanating from emissions sources involved in construction activities. SCAQMD established an LST methodology to determine the likelihood of substantial criteria pollutant concentrations reaching sensitive receptor locations. The LST methodology involves screening values for daily NOX, CO, PM10, and PM2.5 emissions that are generated exclusively by sources located on the project site. Mobile source emissions on the roadway network are spread across long distances and do not directly affect sensitive receptors in close proximity to the project site. LST values were determined using emissions modeling based on ambient air quality measured throughout SCAB. If maximum daily emissions remain below the LST values during construction activities, it is highly unlikely that air pollutant concentrations in the ambient air would reach substantial levels sufficient to create public health concerns for sensitive receptors. As shown in Table 3-4 maximum daily emissions of criteria pollutants and ozone precursors would not exceed any applicable LST values. Therefore, construction of the proposed project would not result in exposure of sensitive receptors to substantial concentrations of criteria pollutants.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-13
TABLE 3-4: ESTIMATED LOCALIZED CONSTRUCTION EMISSIONS
Construction Activity
Maximum Daily On-Site Emissions (Pounds Per Day)
NOX CO PM10 PM2.5
Site Preparation 2.0 2.9 1.0 0.2
Grading 8.6 8.3 2.9 1.4
Building Construction 4.6 6.4 0.2 0.2
Paving + Architectural Coating 2.8 3.8 0.6 0.1
Maximum Daily Localized Emissions 8.6 8.3 2.9 1.4
Localized Significance Threshold /a/ 96 1,113 29 9
Exceed Threshold? No No No No
/a/ LST values correspond to a one-acre disturbance area in SRA 11 within 25 meters of the nearest sensitive receptor.

Note: Emissions modeling files can be found in Appendix A.

SOURCE: TAHA, 2024.

With regards to TAC emissions, carcinogenic risks, and non-carcinogenic hazards, the use of heavy-duty construction equipment and haul trucks during construction activities would release diesel PM to the atmosphere through exhaust emissions. Diesel PM is a known carcinogen, and extended exposure to elevated concentrations of diesel PM can increase excess cancer risks in individuals. However, carcinogenic risks are typically assessed over timescales of several years to decades, as the carcinogenic dose response is cumulative in nature. Short-term exposures to diesel PM would have to involve extremely high concentrations in order to exceed the SCAQMD air quality significance threshold of 10 excess cancers per million.

Construction of the proposed project is forecasted to last for approximately 24 months, and over the course of construction, average diesel PM emissions from on-site equipment would be approximately 0.13 pounds per day. This magnitude of diesel PM emissions is a conservative estimate based on the assumed near-continuous operation of equipment during the workday, when in reality there may be considerable downtime throughout days of active construction. Emissions would be distributed across the construction site where equipment is active and would be dispersed quickly due to the elevated atmospheric mixing height and higher wind speeds during the daytime. It is unlikely that diesel PM concentrations would reach levels of any public health concern at sensitive receptor locations in the project vicinity during the construction period, and diesel PM emissions would cease upon completion of construction activities. Therefore, the proposed project would result in a less-than-significant impact related to construction TAC emissions, concentrations, and exposures.

Operation
The proposed project does not include an industrial component that would constitute a new substantial stationary source of operational air pollutant emissions and does not include a land use that would generate a substantial number of heavy-duty truck trips within the region. The proposed project would not generate air toxic emissions that would expose sensitive receptors to substantial pollutant concentrations. Therefore, the proposed project would result in a less-than-significant impact related to substantial pollutant concentrations during operational activities.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-14
d) Less-Than-Significant Impact. Odors are the only potential construction and operational emissions that have the potential to adversely affect a substantial number of people other than the emissions addressed in Response to Checklist Questions 3.3a through 3.3c.

During construction, potential sources that may produce objectionable odors include equipment exhaust, application of asphalt and architectural coatings, and other interior and exterior finishes. Odors from these sources would be localized and generally confined to the immediate area surrounding the project site, would be temporary in nature, and would not persist beyond the termination of construction activities. The proposed project would utilize typical construction techniques, and odors would be typical of most construction sites. Odors from construction activities would decrease, dissipate away from the construction area, and quickly diluted. Therefore, the proposed project would result in a less-than-significant impact related to construction odors.

Land uses and industrial operations that are associated with odor complaints generally include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies and fiberglass molding.12 During operational activities, the proposed kitchen services within the medical facility addition would produce some odors and smells associated with the preparation of food in the kitchen service area, which would be typical of the types of odors that currently exist in the commercial area.

Operations of the kitchen facility would comply with SCAQMD Rule 402, which would prohibit any air quality discharge that would be a nuisance or pose any harm to individuals of the public. Therefore, the proposed project would result in a less-than-significant impact related to operational odors.
12SCAQMD, CEQA Air Quality Handbook, 1993.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-15
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.4 BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special
status species in local or regional plans, policies,
or regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
   
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of Fish
and Game or US Fish and Wildlife Service?
   
c) Have a substantial adverse effect on 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 tree
preservation policy or ordinance (e.g., oak trees
or California walnut woodlands)?
   
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?
   
a) No Impact. A significant biological impact would occur if the proposed project would cause the loss or destruction of individuals of a candidate, sensitive, or special status species or the degradation of sensitive habitat for these species. The project site is located in an urban area surrounded by commercial and residential uses. Plant life on the project site is limited to non-native and ornamental species used for landscaping. Animal life is comprised of common bird, insect, reptile, and small mammal species. The California Natural Diversity Database (CNDDB), a computerized database that identifies past occurrences of species of special concern (e.g., plants, animals, and communities that are rare, threatened, or endangered), does not identify any candidate, sensitive, or special status species on the project site or within 1.3 miles of the project site.13 The entire project site has been previously disturbed and developed with urban uses (i.e., structures, ornamental landscaping, and paved areas).

Suitable habitat for special-status wildlife species does not occur within the project site. Since no special-status species were identified or have high likelihood of occurring on the project site, it is unlikely that the proposed project would result in the loss or destruction of individual candidate, sensitive, or special status species or the degradation of sensitive habitat.

Therefore, the proposed project would not have an 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 13California Department of Fish and Wildlife, California Natural Diversity Database, https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data#43018408-cnddb-in-bios, accessed April 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-16
Wildlife (CDFW) or the United States Fish and Wildlife Service (USFWS), and no impact would occur.
b) No Impact. As discussed in Response to Checklist Question 3.4a, the project site is located within an urbanized area surrounded by commercial and residential uses. The project site is bordered by the I-10 freeway to the north, Cameron Avenue to the west and southwest, and Orange Avenue to the southeast. The project site and the adjacent surrounding areas do not contain any riparian habitat or features necessary to support riparian habitat. Additionally, CNDDB has not listed any riparian habitat or other sensitive natural communities on or in the vicinity of the project site.14 Therefore, the proposed project would not have any effect on riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS, and no impact would occur. c) No Impact. A significant impact would occur if federally protected wetlands were modified or removed as a result of the proposed project. The project site does not contain any state or federally protected wetlands. The project site is located in an urbanized area and is designated for commercial uses. There are no federally protected wetlands adjacent to or in proximity to the project site. The nearest water body is Walnut Creek Wash, a concretelined channel approximately 1,350 feet south of the project site. CNDDB has not listed any riparian habitat or other sensitive natural communities on or in the vicinity of the project site.15 The proposed project would not have any effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Therefore, no impact would occur.
d) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would interfere with, or remove access to, a migratory wildlife corridor or impede use of native wildlife nursery sites. The project site and the surrounding area are highly developed with urban uses, and no wildlife corridors are on or in proximity to the project site. The project site does not contain any state or federally protected wetlands that would contain migratory fish or other wildlife species. If migratory birds were to traverse the project site, the birds would likely utilize mature vegetation on the project site, some of which may potentially provide nesting sites for migratory birds. The Arborist Report and Tree Protection Plan for the proposed project identified 87 trees on or adjacent to the project site, of which 38 trees would be removed and 15 trees would likely be affected by construction of the proposed project. Construction activities would likely encroach into the dripline, optimal tree protection zone, and/or a portion of the structural rooting radius of the 15 trees.

The tree survey that was conducted as part of the Arborist Report and Tree Protection Plan identified a nesting pair of common ravens (Corvus corax) in a Mexican fan palm at the West Covina Medical Center parking lot at the west side of Cameron Avenue, across the street from the project site. Due to the proximity of nesting birds to the project site, the removal of trees on and adjacent to the project site, and that construction of the proposed project could potentially affect existing trees, it is possible that project-related construction activities could potentially affect migratory birds; however, the proposed project is required to comply with the Migratory Bird Treaty Act (MBTA)16 and the California Fish and Game Code (CFGC).17
14California Department of Fish and Wildlife, California Natural Diversity Database, https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data#43018408-cnddb-in-bios, accessed April 2023. 15Ibid.
16Migratory Bird Treaty Act, 16 United States Code Chapter 7, Subchapter II, Section 703. 17California Department of Fish and Game Code Section 3513.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-17
Under MBTA and CFGC, it is unlawful to take or possess any migratory nongame bird.18 To ensure that the proposed project complies with MBTA and CFGC, implementation of Mitigation Measure BR-1 would be required. Mitigation Measure BR-1 would require a nesting survey be conducted if tree removal or trimming activities occur during the nesting season (generally from February 1 to August 31). The nesting survey would be conducted prior to tree removal or trimming activities to ensure that no active nests are present. By avoiding clearing and tree trimming during the bird-breeding season or performing nest surveys to ensure no active nests are present prior to clearing and tree trimming activities, the proposed project would be in compliance with the MBTA and pertinent sections of the CFGC. With implementation of Mitigation Measure BR-1, the proposed project is not expected to interfere with wildlife movement or impede the use of native wildlife nursery sites. Therefore, a less-than-significant impact would occur with implementation of Mitigation Measure BR-1.
e) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project were inconsistent with local regulations pertaining to biological resources. As discussed in Response to Checklist Question 3.1c, the proposed project would remove 38 trees, of which 25 trees are classified as significant trees based on the definition of significant trees in Section 26-258 of the WCMC. The proposed project would be required to comply with Chapter 26, Article VI, Division 9 (Preservation, Protection and Removal of Trees) of the WCMC. Per Section 26-262 of the WCMC, a tree removal permit would be required and would need to be obtained by the applicant to remove any of the significant trees on or adjacent to the project site. Per Section 26-263 of the WCMC, any significant trees that would be removed are required to be replaced with trees of comparable species, size, and condition as the existing trees. If it is not possible to relocate the existing trees or provide replacement trees on or off the project site, the applicant would be required to provide payment of the proper restitution value of the trees or donate boxed trees to the City to be used elsewhere in the City. The replacement or relocation of all 25 significant trees on the project site may not be possible due to the size, design, and orientation of the proposed project. To comply with the City’s Preservation, Protection and Removal of Trees Ordinance, the applicant would be required to plant replacement trees off site or provide payment for the restitution value of the trees or donate box trees to the City.

The Arborist Report and Tree Protection Plan for the proposed project determined that 15 trees that would remain on the project site would likely be affected by the proposed project. Of the 15 trees, construction the proposed project would not compromise the health or structural integrity, would not encroach more than 30 percent of the dripline and/or the optimal tree protection zone, and/or would avoid the structural rooting radius of 11 trees. For the remaining four trees, the health or structural integrity may be compromised, construction activities would encroach more than 30 percent of the dripline and/or optimal tree protection zone, and/or a portion of the structural rooting radius would be affected. After construction, these four trees may be at increased risk of failure during atypical weather events that produce high winds and oversaturated soil. The Arborist Report and Tree Protection Plan provides protective measures to limit the potential adverse effects that the proposed project may have on existing trees that would remain on the project site.19
18“Take” is defined by the USFWS (Federal Endangered Species Act Section 3(19)) as to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” “Take” is defined by the California Fish and Game Code Section 86 as to “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.
19Rincon Consultants, Inc., West Covina Medical Center at 725 and 741 Orange Ave: Arborist Report and Tree Protection Plan, July 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-18
With regards to the trees that are proposed to be removed as part of the proposed project, the proposed project would comply with the City’s Preservation, Protection and Removal of Trees Ordinance since the applicant would be required to plant replacement trees off site or provide payment for the restitution value of the trees or donate box trees to the City. However, since the proposed project has the potential to affect the health and integrity, dripline, optimal tree protection zone, and/or structural rooting radius of trees during construction, Mitigation Measure A-1 would be required to reduce impacts on trees that would remain on the project site. Therefore, with implementation of Mitigation Measure A-1, a less-than-significant impact with regards to tree preservation would occur.
f) No Impact. The project site is located in an urbanized area and surrounded primarily by commercial and residential uses. The project site is not located within or adjacent to the boundaries of any adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. Therefore, no impact would occur.

MITGATION MEASURES
See Mitigation Measure A-1.

BR-1 All tree removal and tree trimming activities shall be performed prior to or after the birdbreeding season of February 1st through August 31st (i.e., only between September 1 and January 31). If clearing/vegetation removal or tree trimming is planned to occur during the breeding season, a nest survey shall be conducted by a qualified biologist no more than one week prior to any clearing or tree trimming activities. Work may proceed only if no active bird nests are detected. The biologist conducting the nest survey shall document a negative survey with a report indicating that no impacts to active avian nests shall occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-19
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.5 CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
Section 15064.5?
   
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to Section 15064.5?
   
c) Disturb any human remains, including those
interred outside of formal cemeteries?    
a) No Impact. CEQA Guidelines Section 15064.5 generally defines a historical resource as any object, building, structure, site, area, place, record, or manuscript determined to be historically significant or significant in the architectural or cultural annals of California.

Historical resources are further defined as being associated with significant events, important persons, or distinctive characteristics of a type, period or method of construction; representing the work of an important creative individual; or possessing high artistic values.

The project site is developed with a medical center and is not listed in the National Register of Historic Places (National Register) or the California Register of Historic Resources (California Register). The project site was evaluated as a potential historical resource in the City’s 2019 Historic Resource Inventory Update.20 The project site was evaluated according to the established designation criteria for listing in the National Register, California Register, and as a City of West Covina landmark or historic district.

A property is eligible for listing in the National Register if it is at least 50 years of age, possess significance in American history and culture, architecture, or archaeology, and meets one or more of the following four established criteria:

A. Associated with events that have made a significant contribution to the broad patterns of our history;
B. Associated with the lives of persons significant in our past; C. Embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
D. Yield, or may be likely to yield, information important in prehistory or history.

The criteria for eligibility of listing in the California Register are based upon National Register criteria but are identified as 1 through 4 instead of A through D. A property is eligible for listing in the California Register if it is at least 50 years of age and possess significance at the local, state, or national level, under one or more of the following four criteria:

1. It is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States;
20City of West Covina, Historic Context Statement, 1945-1978 & Historic Resource Inventory Update, December 2019, https://www.westcovina.org/departments/community-development/planning-division/historicpreservation, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-20

2. It is associated with the lives of persons important to local, California, or national history;

3. It embodies the distinctive characteristics of a type, period, or method of construction or represents the work of a master, or possesses high artistic values; or

4. It has yielded, or has the potential to yield, information important in the prehistory or history of the local area, California, or the nation.

The City’s Historic Resource Preservation Ordinance (WCMC Chapter 17, Article III) identifies the criteria under which a property may be designated in the City. A property may be designated a landmark if it is at least 50 years old and meets one or more of the following five criteria:

A. It exemplifies or reflects special elements of the City’s cultural, social, economic, political, aesthetic, engineering, or architectural history; B. It is identified with persons or events significant in local, regional, state or national history;
C. It embodies distinctive characteristics of a style, type, period, or method of construction, or is a valuable example of the use of indigenous materials or craftsmanship;
D. It is representative of the notable work of a builder, designer, or architect; or E. It has a unique location or physical characteristic(s) or represents an established and familiar visual feature or landmark of a neighborhood, community, or the City.

According to the City’s 2019 Historic Resource Inventory Update, the West Covina Medical Center was one of the first medical facilities in the City and was constructed to meet the needs of the rapidly growing community. The medical center was constructed in several phases. It was originally constructed in 1949 and was founded by doctors and brothers-inlaw Bernard Finch and Franklin Gordon. The medical center was constructed as a one-story masonry building with a flat, mansard metal roof; was planned to have between 40 and 50 rooms; and would provide complete medical services. The medical center was expanded in 1958 and became the West Covina Hospital. Additions were also added in 1971 and 1980.

The property is currently known by its original name, West Covina Medical Center.

The City’s 2019 Historic Resource Inventory Update identified the West Covina Medical Center property as one of the 90 properties that warranted further evaluation as a potential historical resource. A full evaluation of the project site was documented on the California Department of Parks and Recreation (DPR) 523 form and is summarized below.21 The DPR 523 form indicates that the West Covina Medical Center appears eligible for listing in the National Register and California Register as an individual property through survey evaluation and appears to be individually eligible for local listing or designation through survey evaluation. The project site appears to be significant under the National Register Criterion A, California Register Criterion 1, and West Covina Landmark Criterion A for its association with postwar institutional development. The project site is associated with private institutional development in the immediate postwar period and represents the beginning of this trend during the period. However, the project site does not retain sufficient 21City of West Covina, Historic Context Statement, 1945-1978 & Historic Resource Inventory Update, Attachment 4, December 2019, https://www.westcovina.org/departments/community-development/planningdivision/historic-preservation, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-21
physical integrity to convey that association and is, therefore, not eligible for listing under these criteria.

With regards to National Register Criterion B, California Register Criterion 2, and West Covina Landmark Criterion B, Finch lived in Covina, while Gordon lived in West Covina.

Both had medical practices in Covina before opening their West Covina medical office.

Though they appear to have been active in their communities, no evidence is available to suggest that they could be significant to the history of medicine or some other aspect of history in West Covina. Therefore, the project site does not appear to be eligible under National Register Criterion B, California Register Criterion 2, or West Covina Landmark Criterion B.

With regards to National Register Criterion C, California Register Criterion 3, and West Covina Landmark Criteria C and D, the buildings on the project site are not representative of a particular style of architecture. It does not appear to be an important example of construction practices from the period and does not possess high artistic value. Initially constructed as a one-story L-shaped building accessed from Garvey Avenue, the medical center was substantially altered in 1958 when the hospital was constructed. What was once the primary elevation of the medical center appears to be located within the courtyard between the hospital and medical center. Further additions were made between 1968 and 1976. These alterations occurred during the property’s period of significance. However, they create an appearance of a building from the 1960s and 1970s rather than from the 1940s.

The hospital portion of the building was designed by architect Mansell Lee Dexter. Dexter (1910-1992) received his education at San Jose State College; University of California, Los Angeles; and Art Center College of Design in Pasadena. After working as a draftsman for the firm of Maurice Fleishman from 1952 to 1955, Dexter formed his own practice. Other examples of his work include Auburn Faith Hospital (1966), Sonora Community Hospital Long Term Care Unit (1967), Los Banos Community Hospital (1967), Delta Memorial Hospital in Antioch (1967), and Feather River Hospital in Paradise (1968). There is no evidence that Dexter could be considered a master architect, and the building does not appear to be eligible under the National Register Criterion C, California Register Criterion 3, or West Covina Landmark Criterion D as representative of the notable work of a builder, designer or architect. The project site is not a component of a significant and distinguishable entity (a historic district) because it is not united historically or aesthetically with the surrounding properties by a plan or physical development. Thus, the project site does not appear to be eligible under National Register Criterion C, California Register Criterion 3, or West Covina Landmark Criterion C.

National Register Criterion D and California Register Criterion 4 generally apply to archaeological resources but may apply to a built resource in instances where a property may contain important information about such topics as construction techniques or human activity. In any case, the property must be the principal source of information. It is unlikely for the property of a private medical institution to contain important information about archaeological resources. Therefore, the project site does not appear to be eligible under National Register Criterion D or California Register Criterion 4.

The West Covina Medical Center does not appear to meet West Covina Landmark Criterion E. It does not appear to have a unique location or physical characteristic(s) or represent an established and familiar visual feature or landmark of a neighborhood, community, or the City. For properties to be considered under West Covina Landmark Criterion E, integrity of feeling and association are essential. This project site lacks integrity of feeling and association due to alterations that were made after the period of significance, and the project site no longer conveys its historic significance.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-22
As the project site does not appear to be eligible for listing under any of the National Register, California Register, or West Covina Landmark criteria, the proposed project is not expected to cause an adverse change in the significance of a historical resource, and no impact would occur.
b) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if a known or unknown archaeological resource were removed, altered, or destroyed as a result of the proposed project. CEQA Guidelines Section 15064.5 defines significant archaeological resources as resources which meet the criteria for historical resources, as discussed above in Response to Checklist Question 3.5a, or resources that constitute unique archaeological resources associated with a scientifically recognized important prehistoric or historic event or person.

The project site is located in an urbanized area that has been subject to previous grading and development. Any surficial archaeological resources that may have existed on the project site are likely to have been previously disturbed or removed. Although no archaeological resources are known to exist on the project site, encountering unanticipated archaeological resources during ground disturbance is a possibility, and implementation of Mitigation Measure CR-1 would be required to reduce the potential for the destruction of any significant archaeological resource. Mitigation Measure CR-1 consists of procedural steps to take in the event of an unanticipated discovery during construction. Therefore, with implementation of Mitigation Measure CR-1, impacts related to archaeological resources would be less than significant.
c) Less-Than-Significant Impact. The project site is not part of a formal cemetery and is not known to have been used for disposal of historic or prehistoric human remains. There are no known human remains on the project site, and human remains are not expected to be encountered during construction of the proposed project. While no formal cemeteries, other places of human interment, or burial grounds or sites are known to exist within the project site, there is always a possibility that human remains may be unexpectedly encountered during construction. In the unlikely event that human remains are encountered, the proposed project would be required to comply with Section 7050.5 of the California Health and Safety Code. If human remains of Native American origin are discovered during construction, the proposed project would also be required to comply with applicable regulations related to the handling of Native American human remains, including Public Resources Code (PRC) Section 5097. With compliance of the State Health and Safety Code Section 7050.5 and applicable regulations related to the handling of human remains of Native American origin, no impact would occur.

MITIGATION MEASURES
CR-1 If archaeological resources are encountered during ground-disturbing activities, the City of West Covina Community Development Department shall be immediately informed of the discovery. All work shall cease in the area of the find or diverted away from the discovery to a distance of 50 feet until a qualified archaeologist has evaluated the find in accordance with federal, state, and local guidelines, including those set forth in PRC Section 21083.2.

Personnel of the project shall not collect or move any archaeological materials or associated materials. Construction activity may continue unimpeded on other portions of the project site.

Construction shall not resume in the locality of the discovery until the identified resources are properly assessed and consultation between the qualified archaeologist, the City of West Covina Community Development Department, the applicant’s representative, and all other concerned parties takes place and reaches a conclusion approved by the City of West Covina Community Development Department.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-23
The qualified archaeologist shall be retained by the project applicant to determine if the find is classified as a significant cultural resource pursuant to the CEQA definition of historical resources (CEQA Guidelines Section 15064.5[a]) and/or unique archaeological resources (PRC Section 21083.2[g]). If the resource is determined by the qualified archaeologist to constitute a “historical resource” or “unique archaeological resource,” the qualified archaeologist shall make recommendations on the treatment and disposition of the find. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and PRC Section 21083.2(b) for unique archaeological resources. The treatment plan shall be reviewed by the City of West Covina Community Development Department prior to implementation. Upon approval by the City of West Covina Community Development Department, the treatment plan shall be implemented, and the City shall be provided with a final report on the treatment and disposition of the find prior to issuance of a Certificate of Occupancy.

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, it shall be offered to a local school or historical society in the area for educational purposes. See Mitigation Measure TR-2 for archaeological material that are Native American in origin.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-24
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.6 ENERGY. Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
   
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?    
a-b) Less-Than-Significant Impact. The main forms of available energy supply are electricity, natural gas, and oil. During construction of the proposed project, energy would be primarily consumed in the form of electricity associated with the conveyance of water used for dust control, powering lights, electronic equipment, or other construction activities that require electrical power. Construction activities typically do not involve the consumption of natural gas. Additional sources of construction-related energy consumption would be in the form of petroleum-based fuels associated with the use of off-road construction vehicles and equipment, round-trip construction worker travel to the project site, and delivery and haul truck trips. Construction activities would comply with CARB’s “In-Use Off-Road Diesel Fueled Fleets Regulation”, which limits engine idling times to reduce harmful emissions and reduce wasteful consumption of petroleum-based fuel. Additionally, the proposed project would comply with the California Renewable Portfolio Standard, the Clean Energy and Pollution Reduction Act of 2015 (Senate Bill [SB] 350). Compliance with local, state, and federal regulations would reduce short-term energy demand during proposed project construction to the extent feasible, and the proposed project construction would not result in a wasteful or inefficient use of energy.

During operations of the proposed project, Southern California Edison would provide electricity and Southern California Gas Company would provide natural gas to the project site. Energy use associated with operation of the proposed project would be typical of a medical facility, requiring electricity and natural gas for interior and exterior building lighting; heating, ventilation, and air conditioning systems (HVAC); electronic equipment; machinery; refrigeration; appliances; security systems; and more. Maintenance activities during operations, such as landscape maintenance, would involve the use of electric or gaspowered equipment. High efficiency lighting fixtures would be used. In addition to on-site energy use, the proposed project would result in transportation energy use associated with vehicle trips generated by staff and visitors. However, the proposed project would not involve any characteristics or processes that would require the use of equipment that would be more energy intensive than is used for comparable activities or involve the use of equipment that would not conform to current emissions standards and related fuel efficiencies.

In September 2011, the City adopted an Energy Action Plan to guide the City toward attainable conservation goals that may also significantly reduce the impact of greenhouse gas (GHG) emissions within the community. The Energy Action Plan proposes several policies related to energy-efficiency and conservation, including energy and water conservation design features in new development projects. The proposed project would be subject to the California Building Code (Title 24), including the California Green Building Standards Code, which requires new buildings to reduce water consumption, employ building commissioning to increase building system efficiencies for large buildings, divert construction waste from landfills, and install low pollutant-emitting finish materials. The proposed project would be consistent with the Energy Action Plan by complying with the West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-25
California Green Building Standards Code. The California Green Building Standard Code, referred to as CalGreen, is the first statewide Green Building Code. CalGreen lays out minimum requirements for newly constructed buildings in California, which reduces GHG emissions through improved efficiency and process improvements. It requires builders to install plumbing that cuts indoor water use by as much as 20 percent, to divert 50 percent of construction waste from landfills to recycling, and to use low-pollutant paints, carpets, and floors. The proposed project does not include any feature (i.e., substantially alter energy demands) that would interfere with the implementation of these state and City codes and plans. Therefore, a less-than-significant impact would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-26
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.7 GEOLOGY AND SOILS. Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on
other substantial evidence of a known fault?
Refer to division of Mines and Geology
Special Publication 42.
   
ii) Strong seismic ground shaking?    
iii) Seismic-related ground failure, including
liquefaction?    
iv) Landslides?    
b) Result in substantial soil erosion or the loss of
topsoil?    
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potential 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 waste water
disposal systems where sewers are not available
for the disposal of waste water?
   
f) Directly or indirectly destroy a unique
paleontological resource or unique geologic
feature?
   
a.i) No Impact. A significant impact would occur if the proposed project would exacerbate existing environmental conditions in a manner that would increase the potential to expose people or structures to substantial adverse effects associated with the rupture of a known earthquake fault. The Alquist-Priolo Earthquake Fault Zoning Act regulates development near active faults to mitigate the hazard of surface fault rupture. It prohibits the location of most structures for human occupancy across the trace of active faults. The Act also establishes Earthquake Fault Zones and requires geologic/seismic studies of all proposed developments within 1,000 feet of the zone. The Earthquake Fault Zones are delineated and defined by the State Geologist and identify areas where potential surface rupture along a fault could occur. According to the California Department of Conservation Earthquake Zones of Required Investigation, the project site is not located within the Alquist-Priolo Special Studies Zone, and no trace of any known active or potentially active fault passes through the project site.22 The proposed project is a behavioral health transition facility and does not involve any activities that would potentially exacerbate existing environmental conditions so as to increase the potential to expose people or structures to the rupture of a known earthquake fault. The type of development proposed 22California Department of Conservation, Earthquake Zone of Required Investigation, https://maps.conservation.ca.gov/cgs/EQZApp/app/, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-27
would not involve deep excavation into the Earth or boring of large areas creating unstable seismic conditions or stresses in the Earth’s crust that would result in the rupture of a fault.

Therefore, no impact would occur.
a.ii) Less-Than-Significant Impact. A significant impact would occur if the proposed project would exacerbate existing environmental conditions in a manner that would increase the potential to expose people or structures to substantial adverse effects related to strong ground shaking from severe earthquakes. As with all properties in the seismically active Southern California region, the project site is susceptible to moderate and occasionally high levels of ground motion during a seismic event. The ground motion characteristics of any future earthquakes in the region would depend on the characteristics of the generating fault, the distance to the epicenter, the magnitude of the earthquake, and the site-specific geologic conditions. The proposed project does not involve activities that would increase the potential to expose people or structures to the adverse effects associated with strong seismic ground shaking. Additionally, the design and construction of the proposed building addition is required to conform to the California Building Code seismic standards, California Department of Health Care Access and Information (HCAI) seismic safety requirements, as well as all other applicable codes and standards that address issues related to strong seismic ground shaking. Therefore, a less-than-significant impact would occur. a.iii) No Impact. A significant impact would occur if the proposed project would exacerbate existing environmental conditions in a manner that would increase the potential to expose people or structures to substantial adverse effects related to seismic-related ground failure, including liquefaction. Liquefaction typically occurs when a saturated or partially saturated soil becomes malleable and loses strength and stiffness in response to an applied stress caused by earthquake shaking or other sudden change in stress conditions. Soil liquefaction occurs when loose, saturated, granular soils lose their inherent shear strength due to excess water pressure that builds up during repeated movement from seismic activity. Liquefaction usually results in horizontal and vertical movements from the lateral spreading of liquefied materials and post-earthquake settlement of liquefied materials. According to the California Department of Conservation’s Earthquake Zones of Required Investigation, the project site is not located within a liquefaction hazard zone.23 Historical high groundwater on the project site is mapped deeper than 50 feet below the ground surface. The geotechnical investigation conducted for the project site concluded that the potential for liquefaction to occur beneath the project site is very low.24 The proposed project would be constructed in accordance with the California Building Code, which is designed to assure safe construction and includes building foundation requirements appropriate to site conditions. Therefore, no impact would occur.
a.iv) No Impact. A significant impact would occur if the proposed project would exacerbate existing environmental conditions in a manner that would increase the potential to expose people or structures to substantial adverse effects related to landslides. The project site and its surrounding area are relatively flat. According to the California Department of Conservation’s Earthquake Zones of Required Investigation, the project site is not located within an earthquake-induced landslide area.25 Therefore, no impact would occur. b) Less-Than-Significant Impact. A significant impact would occur if construction activities or future uses associated with the proposed project would result in substantial soil erosion or 23California Department of Conservation, Earthquake Zone of Required Investigation, https://maps.conservation.ca.gov/cgs/EQZApp/app/, accessed March 2023. 24Albus & Associates, Inc., Geotechnical Investigation, Proposed Behavioral health Building Addition, West Covina Medical Center, 725 South Orange Avenue, West Covina, Los Angeles County, California, April 6, 2023. 25California Department of Conservation, Earthquake Zone of Required Investigation, https://maps.conservation.ca.gov/cgs/EQZApp/app/, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-28
loss of topsoil. During ground disturbing activities, such as grading, the project site could potentially be subject to soil erosion or loss of topsoil. However, the proposed project would be required to comply with local, state, and federal regulations and standards related to minimizing potential erosion impacts, including the latest requirements of the City-enforced National Pollution Discharge Elimination System (NPDES) Construction General Permit, best management practices (BMPs), and applicable pollution control and erosion protection measures pursuant to the City’s Drainage and Grading Ordinance (WCMC Chapter 9, Article 1). The NPDES Construction General Permit regulates stormwater discharges from construction sites. As part of the NPDES permit and City’s standard urban stormwater mitigation plan (SUSMP), the City requires the project applicant and construction contractors to implement BMPs to control sediment and erosion. See Response to Checklist Question 3.10a for further information regarding NPDES, SUSMP, and BMPs. Chapter 9 of the WCMC requires that the project applicant prepare an erosion control plan and requires the construction contractor to implement erosion control measures during ground disturbing activities. With compliance with the NPDES Construction General Permit, BMPs, and applicable City’s regulations in WCMC Chapter 9, impacts related to soil erosion and loss of topsoil would be less than significant.
c) No Impact. A significant impact would occur if the proposed project would cause geologic unit or soil on the project site to become unstable or, if the project site is on unstable geologic unit or soil, the proposed project would exacerbate existing conditions so as to increase the potential for landslides, lateral spreading, subsidence, liquefaction, or collapse. As discussed under Response to Checklist Questions 3.7a.iii and 3.7a.iv, the project site is not located within a liquefaction hazard zone or an earthquake-induced landslide area, respectively.26 The proposed project would not create liquefaction or landslide hazards because the proposed project does not involve activities that would affect seismic conditions or alter underlying soil or groundwater characteristics that govern liquefaction potential.

Additionally, the project site and the surrounding area are relatively flat and, thus, are not susceptible to landslides and the likelihood of lateral spreading is low. According to the geotechnical investigation for the project site, the potential of lateral spreading is not likely to occur within the project site due to a lack of liquefiable soils in the upper 50 feet.27 Subsidence and ground collapse generally occur in areas with active groundwater withdrawal or petroleum production. The extraction of groundwater or petroleum from sedimentary source rocks can cause the permanent collapse of the pore space previously occupied by the removed fluid. The compaction of subsurface sediments by fluid withdrawal will cause subsidence or ground collapse overlying a pumped reservoir. The project site and its vicinity do not contain any subsurface oil extraction facilities or groundwater withdrawal activities.28 The project site is located in an area with commercial, residential, and health care-related uses. The proposed project would develop a four-story structure that would adjoin the existing medical hospital on the project site. Construction and operation of the proposed project would not involve activities known to cause or trigger subsidence and is not anticipated to adversely affect soil stability or increase the potential for local or regional landslides, lateral spreading, subsidence, liquefaction, or collapse. The proposed project would be constructed in accordance with the California Building Code, which is designed to assure safe construction and includes building foundation requirements appropriate to site conditions. Thus, the proposed project would not cause or exacerbate existing conditions 26California Department of Conservation, Earthquake Zone of Required Investigation, https://maps.conservation.ca.gov/cgs/EQZApp/app/, accessed March 2023. 27Albus & Associates, Inc., Geotechnical Investigation, Proposed Behavioral health Building Addition, West Covina Medical Center, 725 South Orange Avenue, West Covina, Los Angeles County, California, April 6, 2023. 28California Department of Conservation, Well Finder,
https://maps.conservation.ca.gov/doggr/wellfinder/#openModal/-117.93414/34.05815/13, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-29
associated with landslides, lateral spreading, subsidence, liquefaction, or collapse. No impact would occur.
d) Less-Than-Significant Impact. A significant impact would occur if the proposed project were built on expansive soils without proper site preparation or adequate foundations for proposed buildings, thus posing a hazard to life and property. Expansive soils have relatively high clay mineral content and are usually found in areas where underlying formations contain an abundance of clay minerals. Due to its high clay content, expansive soils expand with the addition of water and shrink when dried, which can cause damage to overlying structures. Changes in soil moisture content can result from rainfall, landscape irrigation, utility leakage, roof drainage, perched groundwater, drought, or other factors.

Soil materials encountered on the project site during the geotechnical investigation consist of primarily artificial fills and Quaternary alluvial fan deposits. Artificial fill materials were encountered in the upper two to four feet across the project site. Deeper localized fills may be encountered within the project site particularly due to underground utility improvements.

The fill materials consist of silty sands, which were brown and generally very loose to loose and damp to moist. The alluvial materials were typically comprised of sands and gravels, which tend to grade coarser materials with depth. The materials encountered consisted of silty sands, sands, sands with gravels, and gravelly sands. The materials are typically light brown, damp and medium dense to very dense. The geotechnical investigation concluded that the near-surface soils on the project site are generally anticipated to possess a very low expansion potential.29 Additionally, the proposed project would be required to comply with all applicable building codes and standards, including the California Building Code, which is designed to assure safe construction and includes building foundation requirements appropriate to site conditions. Therefore, a less-than-significant impact would occur. e) No Impact. A significant impact would occur if adequate wastewater disposal were not available to the project site. The project site is fully developed and located in an urbanized area of the City, where wastewater infrastructure is currently in place. The proposed project would connect to the existing sanitary sewer system and would not include septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur. f) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would directly or indirectly destroy a unique paleontological resource or unique geologic feature. Paleontological resources are fossils (e.g., preserved bones, shells, exoskeletons, and other remains) and other traces of former living things.

Paleontological resources may be present in fossil-bearing soils and rock formations below the ground surface. Ground-disturbing activities in fossil-bearing soils and rock formations have the potential to damage or destroy paleontological resources that may be present below the ground surface.

The project site is located in an urbanized area that has been subject to previous grading and development. No unique geologic features exist on or adjacent to the project site. The proposed project does not involve deep levels of excavation. Ground-disturbing activities would generally take place in previously disturbed soils and are not expected to disturb native soil. However, it is possible that unanticipated paleontological resources may be encountered during ground disturbance, and implementation of Mitigation Measure GS-1 would be required to reduce the potential for the destruction of a unique paleontological resource. Mitigation Measure GS-1 consists of procedural steps to take in the event of an 29Albus & Associates, Inc., Geotechnical Investigation, Proposed Behavioral health Building Addition, West Covina Medical Center, 725 South Orange Avenue, West Covina, Los Angeles County, California, April 6, 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-30
unanticipated paleontological resource discovery during construction. Therefore, less-thansignificant impacts would occur with implementation of Mitigation Measure GS-1.

MITIGATION MEASURES
GS-1 In the event paleontological resources are encountered during construction, the City of West Covina Community Development Department shall be immediately informed of the discovery. All work shall cease in the area of the find and a qualified paleontologist shall be contacted to evaluate the find before restarting work in the area. The City shall require that all paleontological resources identified on the project site be assessed and treated in a manner determined by the qualified paleontologist. Typically, fossils can be safely salvaged quickly by a single paleontologist and not disrupt construction activity. In some cases, larger fossils (such as complete skeletons or large mammal fossils) require more extensive excavation and longer salvage periods. In this case, the paleontologist shall have the authority to temporarily direct, divert or halt construction activity to ensure that the fossil(s) can be removed in a safe and timely manner. Any significant paleontological resources found during construction monitoring shall be prepared, identified, analyzed, and permanently curated in an approved regional museum repository under the oversight of the qualified paleontologist. Fossils of undetermined significance at the time of collection may also warrant curation at the discretion of the project paleontologist. Work in the area of the discovery shall resume once the find is properly documented and the qualified paleontologist authorizes resumption of construction work.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-31
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.8 GREENHOUSE GAS EMISSIONS. Would the project:
a) Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on
the environment?
   
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
   
a) Less-Than-Significant Impact. GHG emissions refer to a group of emissions that are generally understood to play a critical role in controlling atmospheric temperature near the Earth’s surface by allowing high frequency shortwave solar radiation to enter the planet’s atmosphere and then subsequently trapping low frequency infrared radiative energy that would otherwise emanate back out into space. The greenhouse effect compares the Earth and the atmosphere surrounding it to a greenhouse with glass panes; the glass panes in a greenhouse let heat from sunlight in and reduce the amount of heat that escapes. The levels of GHGs in the atmosphere affect how much heat energy can be absorbed.

Radiative forcing is an expression of the net difference in energy entering Earth’s atmosphere versus leaving it. Each GHG possesses its own degree of climate forcing ability to absorb low frequency infrared energy, meaning that some GHGs are more effective in trapping heat in the atmosphere than others. Water vapor is the most environmentally prevalent GHG, however, definitive methods are not established to regulate emissions and concentrations of water vapor in the atmosphere. After water vapor, carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) are the most ubiquitous GHGs, and CO2 is commonly used as the standard reference for characterizing the relative global warming potential (GWP) of other GHGs. The GWP value describes the relative magnitude of climate forcing effects of GHGs and is used to convert emissions into CO2-equivalents (CO2e).

Table 3-5 presents the GWP value and atmospheric lifetime of CO2, CH4, and N2O, as well as other regulated GHGs emitted by human activities. GHG emissions that would be generated by the proposed project are assessed in units of metric tons of CO2e (MTCO2e).

Section 15064.4 of the CEQA Guidelines states that a lead agency should make a goodfaith effort to describe, calculate, or estimate the amount of GHG emissions resulting from a project, and that the lead agency should consider the following factors when assessing the significance of impacts from GHG emissions on the environment:
 The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting;
 Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and
 The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-32
TABLE 3-5: GLOBAL WARMING POTENTIAL FOR VARIOUS GREENHOUSE GASES Pollutant Lifetime (Years) /a/
Global Warming
Potential (20-Year)
Global Warming
Potential (100-Year)
/b/
Carbon Dioxide (CO2) -- 1 1
Methane (CH4) 12 21 25
Nitrous Oxide (N2O) 114 310 298
Nitrogen Trifluoride 740 Unknown 17,200
Sulfur Hexafluoride (SF6) 3,200 23,900 22,800
Perfluorocarbons (PFCs) 2,600-50,000 6,500-9,200 7,390-12,200 Hydrofluorocarbons (HFCs) 1-270 140-11,700 124-14,800
/a/ Lifetime refers to the approximate amount of time it would take for the anthropogenic increment to an atmospheric pollutant concentration to return to its natural level as a result of either being converted to another chemical compound or being taken out of the atmosphere via a sink.
/b/ The United States primarily uses the 100-year GWP as a measure of the relative impact of different GHGs. However, the scientific community has developed a number of other metrics that could be used for comparing one GHG to another. These metrics may differ based on timeframe, the climate endpoint measured, or the method of calculation. For example, the 20-year GWP is sometimes used as an alternative to the 100-year GWP. Just like the 100-year GWP is based on the energy absorbed by a gas over 100 years, the 20-year GWP is based on the energy absorbed over 20 years. This 20-year GWP prioritizes gases with shorter lifetimes, because it does not consider impacts that happen more than 20 years after the emissions occur. Because all GWPs are calculated relative to CO2, GWPs based on a shorter timeframe will be larger for gases with lifetimes shorter than that of CO2, and smaller for gases with lifetimes longer than CO2.

SOURCE: CARB, Global Warming Potentials, https://www.arb.ca.gov/cc/inventory/background/gwp.htm, accessed October 16, 2023.

CEQA Guidelines direct lead agencies to adopt thresholds of significance for GHG emissions. However, the CEQA Guidelines allow some flexibility in selecting the most appropriate thresholds of significance. When adopting these thresholds, the CEQA Guidelines allow lead agencies to consider thresholds of significance adopted or recommended by other public agencies, or recommended by experts, provided that the thresholds are supported by substantial evidence, and/or to develop their own significance threshold.

Neither the City nor SCAQMD has officially adopted a quantitative threshold value for determining the significance of GHG emissions that would be generated by projects under CEQA. SCAQMD established a GHG Significance Threshold Stakeholder Working Group to establish an interim GHG significance threshold until the state establishes a GHG significance threshold or provides recommended guidance on establishing a GHG significance threshold. The Working Group proposed a tiered screening methodology for assessing the potential significance of GHG emissions generated by CEQA projects.30 The tiered screening methodology was outlined in the minutes of the final Working Group meeting on September 28, 2010.31 The Working Group proposed a 3,000 MTCO2e annual threshold for commercial projects, which was derived using a 90 percent capture rate for proposed CEQA projects within the SCAQMD jurisdiction. Projects with annual GHG emissions below 3,000 MTCO2e are assumed to result in less than significant impacts.

GHG emissions that would be generated by the proposed project were estimated using CalEEMod, as recommended by the SCAQMD. CalEEMod quantifies GHG emissions from construction and future operation of projects. Sources of GHG emissions during project construction would include heavy-duty off-road diesel equipment and vehicular travel to and 30SCAQMD, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October 2008.
31SCAQMD, Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15, September 28, 2010, www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significancethresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, accessed October 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-33
from the project site. In accordance with SCAQMD methodology, the total amount of GHG emissions that would be generated by construction of the proposed project was amortized over a 30-year operational period to represent long-term impacts. Sources of GHG emissions during future project operation would include employee and delivery vehicular travel, energy consumption, water use, and solid waste disposal at off-site facilities.

Additionally, the 38 trees that would be removed during construction would result in minor indirect increases in GHG emissions through reduction of carbon sequestration on the project site.

Table 3-6 presents estimated GHG emissions that would be released to the atmosphere on an annual basis by the proposed project. Construction of the proposed project would produce 966.3 MTCO2e emissions, or 32.2 MTCO2e annually over a 30-year amortization period. The total annual operating emissions would be approximately 946.7 MTCO2e per year after accounting for amortized construction emissions. This mass rate is substantially below the most applicable SCAQMD quantitative draft interim threshold of 3,000 MTCO2e per year. Therefore, impacts related to GHG would be less than significant.

TABLE 3-6: ESTIMATED ANNUAL GREENHOUSE GAS EMISSIONS
Scenario and Emission Source
Carbon Dioxide Equivalent
(Metric Tons per Year)
Construction Emissions Amortized (Direct) /a/ 32.2
Area Source Emissions (Direct) 1.3
Energy Source Emissions (Indirect) 174.9
Mobile Source Emissions (Direct) 580.8
Waste Disposal Emissions (Indirect) 141.6
Water Distribution Emissions (Indirect) 12.9
Vegetation Change (Indirect) 2.9
Refrigerants (Direct) 0.2
TOTAL 946.7
SCAQMD Draft Interim Significance Threshold 3,000
Threshold Exceeded? No
/a/ Based on SCAQMD guidance, the emissions summary also includes construction emissions amortized over a 30-year span.

SOURCE: TAHA, 2024
b) Less-Than-Significant Impact. Assembly Bill (AB) 32 requires CARB to develop and enforce regulations for the reporting and verification of statewide GHG emissions and directs CARB to set a GHG emission limit, based on 1990 levels, to be achieved by 2020.

The bill sets a timeline for adopting a scoping plan for achieving GHG reductions in a technologically and economically feasible manner. On December 11, 2008, CARB adopted the Scoping Plan, which sets forth the framework for facilitating the state’s goal of reducing GHG emissions to 1990 levels by 2020. The First Update of the Scoping Plan was adopted on May 22, 2014. CARB adopted the 2017 Scoping Plan in November 2017, which details strategies to cut back 40 percent of GHGs by 2030. AB 32, the updated first Scoping Plan, and the 2017 Scoping Plan do not have regulations implementing, for specific projects, the legislature’s statewide goals for reducing GHGs.32
The Scoping Plan outlines a series of technologically feasible and cost-effective measures to reduce statewide GHG emissions, including expanding energy efficiency programs, 32Center for Biological Diversity v. California Department of Fish and Wildlife, 62 Cal..4th 204, November 30, 2015.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-34
increasing electricity production from renewable resources (at least 33 percent of the statewide electricity mix), increasing automobile efficiency, implementing the Low-Carbon Fuel Standard, and developing a cap-and-trade program. These measures are designed to be implemented by state agencies. The proposed project would not interfere with implementation of AB 32 and measures contained within the Scoping Plan to reduce GHG emissions.

The California legislature enacted SB 375 in 2008 to set regional targets for the reduction of GHG emissions and to require the preparation of Sustainable Communities Strategies (SCS) by metropolitan planning organizations to achieve GHG reduction targets set by the CARB. The SCAG SCS presents strategies and tools that incorporate best practices for achieving the state-mandated reductions in GHG emissions at the regional level through reduced per-capita vehicle miles traveled (VMT). SB 743 was enacted in 2013 to evolve the assessment of transportation impacts under CEQA, and SB 743 was incorporated into the CEQA Guidelines in 2018 by promulgating the use of VMT and VMT reductions as a significance threshold metric because it meets the statutory criteria of promoting the reduction of GHG emissions. As discussed in Response to Checklist Question 3.17a, below, and in the Transportation Impact Study for the proposed project, which is included in Appendix C, the proposed project would be located in a low VMT area and would be screened out of a VMT analysis.33 Thus, the proposed project would not conflict with the SCAG SCS and would not have the potential to conflict with regional GHG emissions targets and VMT reduction efforts of SB 375 and SB 743, respectively.

The proposed project would not impede the attainment of the GHG reduction goals for 2030 or 2050 identified in Executive Order (E.O.) S-03-05 and SB 32, or the carbon neutrality goal for 2045 identified in E.O. B-55-18. E.O. S-03-05 establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80 percent below 1990 levels by 2050. SB 32 establishes for a statewide GHG emissions reduction target whereby CARB, in adopting rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40 percent below 1990 levels by December 31, 2030. E.O. B-55-18 establishes an additional statewide policy goal to achieve carbon neutrality as soon as possible and no later than 2045 and to achieve and maintain net negative emissions thereafter.

With regards to local climate planning initiatives, the City adopted an Energy Action Plan in 2011 to guide the City toward attainable conservation goals that may also significantly reduce the impact of GHG emissions within the community. The proposed project would be consistent with the Energy Action Plan by complying with the California Building Code (Title 24), including the California Green Building Standards Code. The California Green Building Standard Code, referred to as CalGreen, is the first statewide Green Building Code.

CalGreen lays out minimum requirements for newly constructed buildings in California, which reduces GHG emissions through improved efficiency and process improvements. It requires builders to install plumbing that cuts indoor water use by as much as 20 percent, to divert 50 percent of construction waste from landfills to recycling, and to use low-pollutant paints, carpets, and floors.

The City’s General Plan includes a series of policies for implementing a well-planned community. Applicable policies aimed at reducing GHG emissions include the following:
33Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-35
 Policy P1.3: Minimize the adverse impacts of growth and development on air quality and climate.
 Policy P3.6: Reduce West Covina’s production of greenhouse gas emissions and contribution to climate change and adapt to the effects of climate change.34 The proposed project would be consistent with Policies P1.3 and P3.6 of the City’s General Plan since the proposed project would comply with all applicable regulations associated with reducing GHG emissions, such as CalGreen.

Overall, the proposed project would not conflict with applicable plans, policies, and regulations associated with reducing GHG emissions. Therefore, less-than-significant impacts are expected.
34City of West Covina, West Covina General Plan, adopted December 2016.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-36
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.9 HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
   
b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
   
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
   
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
   
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety hazard
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?
   
g) Expose people or structures, either directly or
indirectly to a significant risk of loss, injury or
death involving wildland fires?
   
a-b) Less-Than-Significant Impact. A significant impact would occur if the proposed project would create a significant hazard to the public or the environment through the routine transport, use, and disposal of hazardous materials, or if it would create a significant hazard through the accidental release of hazardous materials into the environment. Construction of the proposed project would involve the temporary use of potentially hazardous materials, including vehicle fuels, oils, and transmission fluids. Operations of the proposed project would involve the use and storage of hazardous substances, such as chemicals used in patient treatment, infection prevention and infection control; pharmaceuticals; sterilants and disinfectants; custodial products (e.g., cleaning supplies, solvents, paints); and landscaping supplies (e.g., pesticides). The use would be similar to those that are currently used at the existing on-site medical facilities. The use, transport, and disposal of hazardous substances during construction and operations of the proposed project would comply with all applicable standards and regulations, including the Medical Waste Management Act (California Health and Safety Code Sections 117600-118360). The proposed project does not involve any uses or activities that would result in the use or discharge of unregulated hazardous materials and/or substances, or create a public hazard through the transport, use, or disposal of hazardous materials. All hazardous materials during construction and operational activities would be handled in compliance with applicable standards and regulations. As the proposed project would comply with all applicable standards and regulations related to hazardous materials during construction and operational activities, the proposed would not create a significant hazard to the public or the environment through the transport, use, disposal, and accidental release of hazardous materials. Therefore, impacts West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-37
related to the creation of hazards to the public or the environment would be less than significant.
c) Less-Than-Significant Impact. No schools are located within one-quarter mile of the project site. As discussed in Response to Checklist Questions 3.9a-b, construction of the proposed project would involve the temporary use of potentially hazardous materials (including vehicle fuels, oils, and transmission fluids), and operations of the proposed project would involve the use of hazardous materials (such as chemicals used in patient treatment, infection prevention and infection control; pharmaceuticals; sterilants and disinfectants; custodial products; and landscaping supplies). The proposed project would comply with all applicable standards and regulations related to the transport, use, and disposal of hazardous materials during construction and operational activities. Therefore, the proposed project would not emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of a school. A less-than-significant impact would occur. d) Less-Than-Significant Impact. The California Department of Toxic Substances Control (DTSC) and the State Water Resources Control Board (SWRCB) each maintain a database (EnviroStor and GeoTracker, respectively) that provides access to detailed information on hazardous waste sites and their cleanup statuses. EnviroStor focuses on hazardous waste facilities and sites with known contamination or sites with possible reasons for further investigation. GeoTracker focuses on sites that impact or have the potential to impact water quality in California, with an emphasis on groundwater. The project site is not on the EnviroStor database.35 The project site is listed on the Geotracker database as a leaking underground storage tank cleanup site. However, the cleanup status of the project site is listed as completed and closed as of December 13, 2007.36 Therefore, a less-thansignificant impact would occur. e) No Impact. The project site is not located in an airport land use plan area, or within two miles of any public or public use airports, or private air strips. The closest airport to the project site is San Gabriel Valley Airport, which is approximately 4.9 miles west of the project site. Therefore, the proposed project would not result in an airport- or airstrip-related safety hazard for people residing or working in the area, and no impact would occur. f) Less-Than-Significant Impact. The Natural Hazard Mitigation Plan (NHMP) is the City’s adopted emergency response plan. It addresses the City’s planned response to extraordinary emergency situations associated with man-made and natural disasters and provides a list of activities that may assist the City in reducing risk and preventing loss from natural hazard events. The NHMP addresses multi-hazard issues, as well as activities from earthquakes, earth movements, flooding, wildfires, and windstorms. The NHMP identifies the West Covina Medical Center as a critical facility.37 The proposed project would not involve any uses that would interfere with the NHMP.

The project site is located adjacent to I-10, which is identified as a freeway disaster route by the County of Los Angeles Department of Public Works.38 Although construction of the 35Department of Toxic Substances Control, EnviroStor, https://www.envirostor.dtsc.ca.gov/public/, accessed May 2023.
36Department of Toxic Substances Control, GeoTracker,
https://geotracker.waterboards.ca.gov/profile_report?global_id=T0603726822&mytab=esidata&subcmd=edfsummarytable# esidata, accessed May 2023.
37City of West Covina, Natural Hazard Mitigation Plan, Section 3: Risk Assessment, Map 2 Critical Facilities, https://www.westcovina.org/departments/fire-/disaster-preparedness/natural-hazaard-mitigation-plan/section-3-riskassessment/#Map%20#3, accessed May 2023. 38County of Los Angeles Department of Public Works, Disaster Routes, http://dpw.lacounty.gov/dsg/disasterroutes/map/West%20Covina.pdf, accessed May 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-38
proposed project may involve temporary lane closures on Orange Avenue, this roadway would remain accessible to vehicular traffic and emergency vehicles would still be able to travel along this roadway. Access to all surrounding properties would be maintained. Any construction activities occurring with the public right-of-way, such as construction of sidewalks and driveway approach, and construction activities that would obstruct portions of the streets are required to obtain an engineering permit from the City. As part of the engineering permit, the City requires the preparation and implementation of a construction staging and traffic management plan. The City also requires light barricades, delineators, and traffic control personnel be provided if construction activities occur within the public right-of-way.

Construction and operational activities would not require temporary or permanent closure of any streets, including designated disaster routes near the project site. Additionally, the proposed project would be reviewed by the City’s Fire Department to ensure that the proposed project would not interfere with the City’s NHMP or evacuation routes.

The proposed project would be designed to accommodate emergency vehicles to the project site. The proposed project would be designed to accommodate emergency vehicles and would allow adequate emergency access to the project site in accordance with the City’s driveway standards and the West Covina Fire Department (WCFD) requirements. The proposed driveway aisles would be designed to meet the minimum width and turning dimension requirements of WCFD. The turnaround area in front of the proposed building would be designed to accommodate fire trucks. Vehicles, including emergency response vehicles, would be able to access the project site via Orange Avenue. No roads would be closed by construction or operation of the proposed project. Emergency vehicles would be able to travel along roadways, and access to all surrounding properties would be maintained.

Therefore, the proposed project would not impair the implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, and a less-thansignificant impact would occur. g) No Impact. The project site is located in an urbanized area and is surrounded primarily by commercial and residential uses. The project site is not located within or adjacent to a wildland area. No large, undeveloped areas and/or steep slopes that may pose wildfire hazards are located on or near the project site. Additionally, the project site is not located in a fire hazard severity zone, as identified by the California Department of Forestry and Fire Protection (CalFire). The nearest fire hazard zone is located approximately 2.6 miles southeast of the project site.39 The proposed project would not involve activities that would expose people or structures to the risk of loss, injury, or death involving wildland fires.

Therefore, no impact would occur.
39California Department of Forestry and Fire Protection, California Fire Hazard Severity Zone Viewer, https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414, accessed May 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-39
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.10 HYDROLOGY AND WATER QUALITY. Would the project:
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 offsite;
   
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?     e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
   
a) Less-Than-Significant Impact. Construction of the proposed project would require site clearing, grading, and building construction activities. During construction, surface water quality could potentially be affected by loose soils, debris, construction wastes, and fuels that could be carried off-site by surface runoff in into local storm drains, which drain into water resources. However, the proposed project would be required to comply with all federal, state, and local regulations related to water quality standards and wastewater discharge.

The project applicant and construction contractors would be required to comply with the NPDES permit program, which was created by the Clean Water Act to address water pollution from point sources (e.g., pipes, channels, and tunnels) that discharge pollutants to the waters of the United States. The NPDES Construction General Permit is issued by the State Water Resource Control Board and enforced by the City. Construction activities subject to this permit include clearing, grading, excavation, stockpiling, and other ground disturbances. During the plan review process, the City’s Engineering Division would review the development plans for the proposed project to make sure that the proposed project complies with the City’s stormwater requirements. The project applicant and construction contractors would also be required to implement BMPs that are required by the City’s Engineering Division as part of the NPDES permit, including sediment and erosion control.

The project applicant and construction contractors would be required to comply with applicable regulations in Chapter 9 of the WCMC, including Article I (Drainage and Grading) West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-40
and Article II (Stormwater and Urban Run-Off Pollution Control). WCMC Chapter 9, Article I, Section 9-36 requires development projects to comply with the City’s SUSMP conditions, which includes low impact development structural and non-structural BMPs, source control BMPs, and structural and non-structural BMPs. LID is a stormwater management strategy that emphasizes conservation and the use of existing natural site features integrated with stormwater controls to most closely mimic natural hydrologic patterns in residential, commercial, and industrial settings. LID controls effectively reduce the amount of impervious area of a completed project site and promote the use of infiltration and other controls that reduce runoff. Source control BMPs would prevent runoff contact with pollutant materials that would otherwise be discharged into the municipal storm drains. Compliance with the NPDES Construction General Permit and applicable regulations in the WCMC would reduce the risk of water degradation from soil erosion and other pollutants related to construction activities. The proposed project would not violate any water quality standards or waste discharge requirements during construction.

As the project applicant would be required to comply with all applicable water quality standards and waste discharge requirements during construction and operations of the proposed project, impacts would be less than significant. b) Less-Than-Significant Impact. The project site is not currently used for groundwater recharge activities. Furthermore, the proposed project would not install any groundwater wells and would not otherwise directly or indirectly withdraw any groundwater during construction or operations of the proposed project. The proposed project would not deplete groundwater supplies or interfere substantially with groundwater recharge. As discussed in Response to Checklist Question 3.19a, domestic water service to the project site is provided by Suburban Water Systems, which would be able to provide reliable water supplies for an average year, single dry year, and multiple dry years for the project site through 2045. The proposed project would be served by available water supply and would not significantly deplete groundwater supplies or interfere with groundwater recharge. Therefore, a lessthan-significant impact would occur. c.i) Less-Than-Significant Impact. A significant impact would occur if the proposed project would substantially alter the existing drainage pattern of the project site, including through the alteration of the course of an existing stream or river or through the addition of impervious surfaces, in a manner that would result in a substantial erosion or siltation on or off-site. The project site is located in an urbanized area of the City. Existing surface water drainage from the project site generally flows south and southwest towards Orange Avenue.

Surface runoff from the project site is currently collected by an existing catch basin located in the driveway on the project site (near the driveway entrance) and off-site on Orange Avenue, west of Cameron Avenue. A catch basin is also located on Cameron Avenue adjacent to the project site. The proposed project would increase the amount of impervious surfaces on the project site compared to existing conditions. The existing catch basin on the project site would be replaced with a new catch basin at a similar location. Another catch basin would be installed at the northeastern portion of the project site. The proposed project would also install a new stormwater infiltration tank to capture stormwater on the project site. New storm drain lines would be installed to connect the new on-site catch basins to the stormwater infiltration tank. With the installation of the on-site stormwater infiltration tank, runoff leaving the project site would not substantially increase compared to existing conditions.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-41
During construction, on-site soils would be temporarily exposed to surface water runoff; however, the proposed project would be required to comply with local, state, and federal regulations and standards related to minimizing potential erosion, including WCMC Chapter 9 regarding drainage and grading. The City requires that the project applicant prepare an erosion control plan and that the construction contractor implement erosion control measures during ground disturbing activities. Therefore, the proposed project would not substantially alter the existing drainage pattern of the project site in a manner that would result in substantial erosion or siltation, and less-than-significant impact would occur. c.ii) Less-Than-Significant Impact. A significant impact would occur if the proposed project would substantially alter the existing drainage pattern of the project site, including through the alteration of the course of an existing stream or river or through the addition of impervious surfaces, in a manner that would substantially increase the rate or amount of surface runoff and would result in flooding on- or off-site. The project site is located within an urbanized area of the City with existing stormwater infrastructure in place. Runoff from the project site is currently collected by an existing catch basin located in the driveway of the project site and off-site on Orange Avenue, west of Cameron Avenue.

As discussed in Response to Checklist Question 3.10c.i, the proposed project would increase the amount of impervious surfaces on the project site compared to existing conditions. The existing catch basin on the project site would be replaced with a new catch basin at a similar location. Another catch basin would be installed at the northeastern portion of the project site. The proposed project would also install a stormwater infiltration tank on the project site. New storm drain lines would be installed to connect the new on-site catch basins to the stormwater infiltration tank to capture stormwater on-site. With the installation of the on-site catch basins and stormwater infiltration tank, runoff leaving the project site would not substantially increase compared to existing conditions and stormwater runoff would not increase in a manner that would result in flooding on- or off-site. Therefore, a lessthan-significant impact would occur. c.iii) Less-Than-Significant Impact. A significant impact would occur if the proposed project would increase the rate or amount of surface runoff in a manner which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. As discussed in Response to Checklist Question 3.10a, the proposed project would be required to comply with all federal, state, and local regulations related to water quality standards and wastewater discharge, including Chapter 9 of the WCMC regarding drainage and grading. Construction contractors are required to comply with NPDES requirements prior to the issuance of a demolition, grading, and building permit, which include sediment and erosion control. The proposed project would include BMPs to limit the amount of polluted runoff that enters the stormwater drainage system. BMPs are required under NPDES and by the City’s Engineering Division as part of the NPDES permit.

Compliance with applicable regulations and City requirements would ensure that during construction, impacts related to creating or contributing to runoff that would exceed the capacity of the City’s existing storm drain system or provide additional sources of polluted runoff would be less than significant.

Operation of the proposed project would not increase stormwater runoff in a manner that would exceed the capacity of the existing stormwater drainage system within the public rights-of-way or provide substantial additional sources of polluted runoff. As discussed in Response to Checklist Questions 3.10c.i and 3.10c.ii, the proposed project would replace the existing catch basin with a new catch basin at a similar location and another catch basin would be installed at the northeastern portion of the project site. The proposed project would also install a stormwater infiltration tank on the project site. New storm drain lines would be installed to connect the new on-site catch basins to the stormwater infiltration tank. On-site West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-42
stormwater runoff would be conveyed towards the infiltration tank and would allow stormwater to percolate into the subsurface soils. Any stormwater that is not captured by the stormwater infiltration tank would be conveyed to the existing catch basin on Orange Avenue.

The proposed stormwater infiltration tank would limit the amount of stormwater runoff that leaves the project site. Therefore, a less-than-significant impact would occur. c.iv) Less-Than-Significant Impact. A significant impact would occur if the proposed project would substantially alter the drainage pattern in a manner that would impede or redirect flood flows.

The project site is designated as Zone X (shaded) by the Federal Emergency Management Agency (FEMA), which is an area subject to flooding from the 500-year flood (0.2 percent annual chance of flooding).40 As discussed in Response to Checklist Questions 3.10c.i and

3.10c.ii, stormwater runoff on the project site would be conveyed towards an on-site stormwater infiltration tank that would allow stormwater to percolate into the subsurface soils.

Any stormwater that is not captured by the underground infiltration system would be conveyed to the existing catch basin on Orange Avenue. With installation and operation of the on-site stormwater infiltration tank, stormwater runoff would not increase in a manner that would exceed the capacity of the existing stormwater drainage system within the public rights-of-way. Therefore, the proposed project would not alter the project site’s drainage patterns in a manner that would impede or redirect flood flows, and a less-than-significant impact would occur.
d) Less-Than-Significant Impact. A significant impact would occur if the proposed project is in a flood hazard, tsunami, or seiche zone and would risk the release of pollutants due to project inundation. A seiche is an oscillation of a body of water in an enclosed or semienclosed basin, such as a reservoir, harbor, or lake. A tsunami is a sea wave produced by a significant undersea disturbance. Mudflows result from the down-slope movement of soil and/or rock under the influence of gravity. The project site is not located near a body of water that is large enough to create a seiche during a seismic event. The project site is located approximately 29 miles east of the Pacific Ocean and is not within a coastal zone or tsunami inundation area. As discussed in Response to Checklist Question 3.10c.iv, the project site is subject to flooding from the 500-year flood (0.2 percent annual chance of flooding). According to the City’s Natural Hazard Mitigation Plan and the California Department of Water Resources, Division of Safety of Dams, the project site is subject to potential inundation in the event of dam failure at the Puddingstone Dam.41,42 However, it is unlikely for inundation to occur due to dam failure and, in accordance with California Water Code Section 6160, each dam is required to have an Emergency Action Plan in place to guide emergency response in case of dam failure. While there is little that can be done if the project site is flooded, the risk of releasing pollutants during flooding would be consistent with the existing risks for the project site and its surrounding area. The proposed project does not involve uses or activities that would exacerbate this risk. Therefore, less-than-significant impact would occur.
40Federal Emergency Management Agency, FEMA Flood Map Service Center, https://msc.fema.gov/portal/search?AddressQuery=725%20s%20orange%20ave%2C%20west%20covina#searchresult sanchor, accessed May 2023.
41City of West Covina, Natural Hazard Mitigation Plan, Section 8: Flood, https://www.westcovina.org/departments/fire/disaster-preparedness/natural-hazard-mitigation-plan/section-8-flood, accessed May 2023.
42California Department of Water Resources, Division of Safety of Dams, California Dam Breach Inundation Maps, https://fmds.water.ca.gov/webgis/?appid=dam_prototype_v2, accessed May 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-43
e) No Impact. A significant impact would occur if the proposed project would conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. The project site is located in the San Gabriel River watershed, which is regulated by the Los Angeles Regional Water Quality Control Board (LARWQCB). Water quality standards for the Los Angeles region, including the San Gabriel River watershed, are set forth in the LARWQCB Water Quality Control Plan: Los Angeles Region Basin Plan (Basin Plan), which was last updated in 2014. The Basin Plan establishes water quality objectives to protect the valuable uses of surface waters and groundwater within the Los Angeles region. Under Section 303(d) of the Clean Water Act, the Basin Plan is intended to protect surface waters and groundwater from both point and nonpoint sources of pollution within the project area and identifies water quality standards and objectives that protect the beneficial uses of various waters. In order to meet the water quality objectives established in the Basin Plan, LARWQCB established total maximum daily loads, which are implemented through stormwater permits. As discussed in Response to Checklist Question

3.10a, the proposed project would be required to comply with applicable regulations associated with water quality. Compliance with these regulations would ensure that the proposed project would be consistent with the Basin Plan.

The City is underlain by the San Gabriel Valley Groundwater Basin and approximately 80 percent of the City’s potable water is from the local groundwater basin. The Sustainable Groundwater Management Act requires local public agencies and groundwater sustainability agencies in high- and medium-priority basins to develop and implement groundwater sustainability plans (GSPs) or alternatives to GSPs. GSPs are detailed road maps for how groundwater basins would reach long term sustainability. The project site is located in a very low-priority basin and, to date, no sustainable groundwater management plan has been developed for this groundwater basin.43
The proposed project would not conflict with or obstruct implementation of the Basin Plan.

Therefore, no impact would occur related to water quality control plans or sustainable groundwater management plans.
43California Department of Water Resources, SGMA Basin Prioritization Dashboard, https://gis.water.ca.gov/app/bp-dashboard/final/, accessed May 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-44
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.11 LAND USE AND PLANNING. Would the project:
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?
   
a) No Impact. The project site is located within an urbanized area surrounded by primarily health care-related and commercial uses. The project site and its surrounding uses are served by existing roadways. No street closures would result with implementation of the proposed project. Orange Avenue and Cameron Avenue would continue to provide vehicular access to the project site and the surrounding area. Pedestrian access would be maintained on the sidewalks along public roads surrounding the project site. Access to all uses would not be disrupted. The proposed project does not include any elements that would physically divide or block access to or through the community, and no separation of uses or disruption of access between land use types would occur as a result of the proposed project. Therefore, no impact would occur.
b) Less-Than-Significant Impact. A significant impact would occur if the proposed project conflicts with applicable land use plans, policies, or regulations in a manner that would result in a significant environmental impact. The project site is in the Urban Center Zone and has an existing General Plan land use designation of Commercial (C). The proposed project would construct a four-story behavioral health facility adjacent to the existing medical center buildings on the project site. The proposed building would be up to 70 feet high. Hospitalrelated uses are permitted on the project site with approval of a conditional use permit (CUP). Approval of a Precise Plan for the site plan and architecture of the proposed project is also required. The height of the proposed structure is permitted in the Urban Center Zone, which has a maximum height limit of five stories and 70 feet. The proposed project would comply with all applicable Zoning regulations associated with the Urban Center Zone. the requirements of the Urban Center Zone of the City’s Downtown Plan and Code, and other City zoning regulations. The proposed project does not involve any General Plan amendments or changes that would conflict with the City’s General Plan, Downtown Plan and Code, and applicable regulations in the WCMC. As the proposed project would require a CUP and a Precise Plan, the proposed project would be reviewed by the City’s Planning Commission as part of the discretionary review process for a CUP and Precise Plan. The regulatory procedures provide the City with further assurances for review and opportunities to incorporate additional conditions to ensure that the proposed project would improve the character and condition of the project site. Therefore, the proposed project would not conflict with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, and the proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation. Therefore, a less-than-significant impact would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-45
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.12 MINERAL RESOURCES. Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?
   
b) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific plan,
or other land use plan?
   
a-b) No Impact. The project site is developed with a surface parking lot and a medical facility.

The surrounding area consists of commercial and health care-related uses. The project site is not located within an area that contains known mineral resources appropriate for mineral extraction that would be of value to the region and the residents of the state. Furthermore, the project site is not located near any oil fields, and no oil extraction and/or quarry activities have historically occurred on or are presently conducted at the project site. Therefore, the proposed project would not result in the loss of availability of any known regionally valuable or locally important mineral resource, and no impact would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-46
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.13 NOISE. Would the project:
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 ground-borne vibration or
ground-borne 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, expose people
residing or working in the project area to
excessive noise levels?
   
a) Less-Than-Significant Impact with Mitigation Incorporated. Sound is technically described in terms of the loudness (amplitude) and frequency (pitch). The standard unit of measurement for sound is the decibel (dB). The human ear is not equally sensitive to sound at all frequencies.

The A-weighted scale, abbreviated dBA, reflects the normal hearing sensitivity range of the human ear.

Noise is generally defined as unwanted sound. The degree to which noise can impact the human environment ranges from levels that interfere with speech and sleep (annoyance and nuisance) to levels that cause adverse health effects (hearing loss and psychological effects). Human response to noise is subjective and can vary greatly from person to person.

Factors that influence individual response include the intensity, frequency, and pattern of noise, the amount of background noise present before the intruding noise, and the nature of work or human activity that is exposed to the noise source.

Studies have shown that the smallest perceptible change in sound level for a person with normal hearing sensitivity is approximately 3 dBA. A change of at least 5 dBA would be noticeable and may evoke a community reaction. A 10-dBA increase is subjectively heard as a doubling in loudness and would likely cause a negative community reaction. Noise levels decrease as the distance from the noise source to the receiver increases. Noise levels generated by a stationary noise source, or “point source,” will decrease by approximately 6 dBA over hard surfaces (e.g., pavement) for each doubling of the distance. For example, if a noise source produces a noise level of 89 dBA at a reference distance of 50 feet, then the noise level would be 83 dBA at a distance of 100 feet over hard surface from the noise source, 77 dBA at a distance of 200 feet, and so on. Noise levels generated by a mobile source will decrease by approximately 3 dBA over hard surfaces for each doubling of the distance.

This noise analysis discusses sound levels in terms of Community Noise Equivalent Level (CNEL) and Equivalent Noise Level (Leq). CNEL is an average sound level during a 24-hour period. CNEL is a noise measurement scale, which accounts for noise source, distance, single event duration, single event occurrence, frequency, and time of day. Human reaction to sound between 7:00 p.m. and 10:00 p.m. is as if the sound were actually 5 dBA higher than if it occurred from 7:00 a.m. to 7:00 p.m. From 10:00 p.m. to 7:00 a.m., humans perceive sound as if it were 10 dBA higher due to the lower background level. Hence, the CNEL is obtained by adding an additional 5 dBA to sound levels in the evening from 7:00 West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-47
p.m. to 10:00 p.m. and 10 dBA to sound levels in the night from 10:00 p.m. to 7:00 a.m.

Because CNEL accounts for human sensitivity to sound, the CNEL is always a higher number than the actual 24-hour average. Leq is the average noise level on an energy basis for any specific time period. The Leq for one hour is the average energy noise level during the hour. The average noise level is based on the energy content (acoustic energy) of the sound. Leq can be thought of as the level of a continuous noise which has the same energy content as the fluctuating noise level. The equivalent noise level is expressed in units of dBA.

Summary of Applicable Noise Regulations/Standards
The City has established noise standards to control unnecessary, excessive and annoying noise. The standards are codified in WCMC Article IV (Noise Regulations). Noise created by radios, television sets, and similar devices is regulated by WCMC Section 15-94 (Radios, television sets, and similar devices). The WCMC states that between the hours of 10:00 p.m. on one day and 7:00 a.m. of the following day, it is unlawful to use or operate any radio receiving set, musical instrument, phonograph, television set, or other machine or device for the producing or reproducing of sound or any device by which voice, music, or any other sound is amplified, in such a manner as to create any noise which causes the noise level at the property line of any property (or if a condominium or apartment house, within any adjoining unit or apartment), building, structure or vehicle to be plainly audible at a distance of 50 feet.

Construction noise is governed by WCMC Section 15-95 (Construction and Building Projects), which prohibits the use of construction tools, equipment, or the performance of any outside construction on buildings, structures, or projects within 500 feet of a residential zone which would cause the ambient noise level to be exceeded by 5 dB as measured at property lines, except for the hours of 7:00 a.m. to 8:00 p.m. Unloading and loading activity is prohibited within 500 feet of a residential zone, except for the hours of 6:00 a.m. to 8:00 p.m.

The City’s General Plan Noise Element provides guidance on improving the safety and health of the community and abatement of excessive noise. The General Plan outlines land use compatibility standards as a guideline for locating new land uses, which have been adopted from the California Office of Noise Control. Policy 6.24 of the General Plan requires potential noise impacts on nearby noise sensitive receptors be analyzed for new development and, as feasible, require noise mitigation to address any identified significant impacts.

Existing Noise Levels
Noise-sensitive land uses are locations where people reside or where the presence of unwanted sound could adversely affect the use of the land. Residences, schools, hospitals, guest lodging, libraries, and some passive recreation areas would each be considered noise-sensitive and may warrant unique measures for protection from intruding noise. A distance of 500 feet is generally used as the screening distance for noise in an existing urban environment. Noise sensitive receptors within 500 feet of the project site include the following:
 Existing West Covina Medical Center facilities on the project site;  Mauna Loa Garden Apartments, approximately 365 feet to the north; and  Assisted Home Health and Hospice, approximately 415 feet to the west.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-48
To characterize the existing noise environment around the project site, short-term noise measurements were taken using a SoundPro DL Sound Level Meter on Thursday, March 16, 2023 between 10:30 a.m. and 12:30 p.m. Hourly noise levels within the project area ranged from 55.2 to 70.2 dBA Leq. Roadway noise was the most significant source of noise in the area. Monitoring locations and existing noise levels are shown in Table 3-7.

TABLE 3-7: EXISTING AMBIENT NOISE LEVELS
Noise Monitoring Location Sound Level (dBA, Leq)
Cameron Ave. and Garvey Ave. 68.4
Pacific Ave. and Garvey Ave. 69.9
Orange Ave. and Cameron Ave. 70.2
Residence (830 Van Horn Ave.) 55.2
SOURCE: TAHA, 2024.

Construction Noise
Construction activity would result in temporary increases in ambient noise levels in the area surrounding the project site on an intermittent basis. Noise levels would fluctuate depending on the construction phase, equipment type and duration of use, distance between the noise source and receptor, and presence or absence of noise attenuation barriers. Typical noise levels from various types of equipment that may be used during each construction phase are listed in Table 3-8.

TABLE 3-8: CONSTRUCTION EQUIPMENT NOISE LEVEL RANGES
Construction Equipment Noise Level at 50 feet (dBA, Leq)

SITE PREPARATION
Backhoe 73.6
Excavator 76.7

GRADING PHASE
Backhoe 73.6
Dozer 77.7
Excavator 76.7

BUILDING CONSTRUCTION PHASE
Backhoe 73.6
Crane 72.6
Forklift 79.4
Gradall 79.4

PAVING PHASE
Concrete Mixer Truck 74.8
Backhoe 73.6

ARCHITECTURAL COATING PHASE
Air Compressor 73.7
Aerial Lift 67.7
SOURCE: FHWA, Roadway Construction Noise Model, Version 1.1, 2008.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-49
Construction activities typically require the use of numerous pieces of noise-generating equipment. In addition, truck trips would be required to remove excavated materials and import fill material. The noise levels shown in Table 3-9 take into account the likelihood that multiple pieces of construction equipment would be operating simultaneously and the typical overall noise levels that would be expected for each phase of construction. When considered as an entire process with multiple pieces of equipment, building construction would generate the loudest noise level of approximately 82.4 dBA Leq at 50 feet.

TABLE 3-9: CONSTRUCTION PHASE NOISE LEVELS
Construction Phase Noise Level at 50 Feet (dBA)
Site Preparation 78.4
Grading 80.2
Building Construction 82.4
Paving 77.3
Architectural Coating 74.7
SOURCE: FHWA, Roadway Construction Noise Model, Version 1.1, 2008.

Table 3-10 presents the estimated noise levels at off-site sensitive receptors nearest to the project site for informational purposes. The most noise-intensive construction activities would occur during the early phases of construction (e.g., site preparation, grading and structural framing). The majority of the latter phases of construction would occur within the newly constructed building and would result in lower noise levels than exterior construction.

The analysis demonstrates that construction noise is expected to be less than existing noise levels at off-site sensitive receptors. The proposed project would be constructed in a manner typical of urban infill projects and would not require unusually noisy activities such as pile driving. In addition, the proposed project would not require nighttime construction activities.

Construction would comply with the allowable construction hours of 7:00 a.m. to 8:00 p.m. as defined in the WCMC, which is designed to control noise exposure. Therefore, construction noise would result in a less-than-significant impact to off-site sensitive land uses.

TABLE 3-10: UNMITIGATED CONSTRUCTION NOISE LEVELS AT OFF-SITE SENSITIVE

RECEPTORS
Sensitive Receptors
Distance to
Construction
(Feet)
Existing Ambient
Noise Level
(dBA, Leq)
Typical Construction
Noise Level at Sensitive
Receptor (dBA, Leq)
Mauna Loa Garden Apartments 365 69.2 65.1
Assisted Home Health &
Hospice 415 68.4 64.0
SOURCE: TAHA, 2024.

The proposed project would be located on the same property as the existing West Covina Medical Center, which includes medical facilities that are sensitive to increased noise levels.

These facilities, which are owned and operated by the applicant, may experience short-term disruptive noise events during construction. To reduce construction noise levels at noise sensitive uses, the proposed project would be required to implement Mitigation Measure N1. This mitigation measure requires the preparation of a Noise Control Plan to minimize exposure to these existing medical facilities. With implementation of Mitigation Measure N1, on-site construction noise impacts would be reduced to less than significant levels.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-50
Operational Noise
Stationary Noise Sources. The proposed project would include several stationary sources of noise, including heating, ventilation, and air conditioning (HVAC) systems; parking lot activities; activities at the patient drop-off area; and activities at the ambulance drop-off area.

HVAC equipment typically generates noise levels of approximately 60 dBA at 50 feet.44 Neither the WCMC nor the City’s General Plan Noise Element have established quantitative noise thresholds regarding HVAC equipment. Per WCMC Section 26-53, mechanical equipment, including HVAC systems, are required to be placed behind a parapet wall when located on a rooftop and fully enclosed when located at ground level. The parapet wall and enclosures would further reduce HVAC noise levels by 10 dBA or more, resulting in a noise level of approximately 50 dBA at 50 feet. HVAC equipment would be fully screened and would be approximately 500 feet away from the Assisted Home Health and Hospice and residences along Van Horn Avenue. The existing noise level along Cameron Avenue is approximately 68.4 dBA Leq. HVAC noise levels would not be 5 dBA above the existing noise level and, thus, operations of HVAC equipment would not result in a noticeable change in noise levels that may evoke a community reaction. Therefore, the proposed project would result in a less-than-significant impact related to HVAC equipment.

The proposed project would reduce on-site parking on the east side of the project site from 55 to 4 parking spaces. A patient drop-off from passenger vehicles would be located at the eastern portion of the project site. Sources of noise would include engines accelerating, doors slamming, car alarms, and people talking. Passenger vehicles traveling at 10 miles per hour would generate a noise level of approximately 50 dBA at 50 feet.45 Activities occurring from the six parking spaces and patient drop-off area are not expected to incrementally increase existing noise level since fewer parking spaces would be provided compared to existing conditions. Therefore, the proposed project would result in a less-than-significant impact related to parking and patient drop-off from passenger vehicles.

The proposed ambulance drop-off area would be located at the rear of the proposed building at the northern portion of the project site. All patients admitted to the proposed facility would arrive via ambulance or non-medical emergency transport van. No sirens would be used.

The surrounding land uses, including sensitive receptors, would not have direct line-of-sight to the proposed ambulance drop-off area. Noise from the ambulance drop-off area to land uses to the north would be shielded by freeway infrastructure, including a soundwall on the north side of the I-10 freeway. The existing landscaping and transportation infrastructure would obstruct views of the ambulance drop-off area to the east of the project site. Given the location of the proposed ambulance drop-off area at the rear of the proposed building and that no sirens would be used for ambulances or non-medical emergency transport vans transporting patients to the proposed facility, the proposed project would result in a lessthan-significant impact related to the ambulance drop-off. 44Cowan, James P., Handbook of Environmental Acoustics, 1994. 45California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Figure 4-1 A-Weighted Baseline FHWA (Federal Highway Administration) TNM (Traffic Noise Model) REMEL (Reference Energy Mean Emission Level) Curves, September 2013.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-51
Mobile Sources. The proposed project would generate approximately 452 daily trips, 34 AM peak hour trips, and 36 PM peak hour trips. Table 3-11 shows roadway noise levels for Existing and Year 2026 conditions. As shown in Table 3-12, the roadway noise increase attributed to the proposed project would be less than 1 dBA on the local roadway network and is not anticipated to result in a perceptible change in sound level for a person with normal hearing sensitivity or result in a 5 dBA CNEL or more increase. Therefore, the proposed project would result in a less-than-significant impact related to mobile noise levels.

TABLE 3-11: MOBILE SOURCE NOISE LEVELS
Roadway Segment
Estimated dBA, Leq at 50 Feet
Existing
(2023)
Year 2026
No Project
Year 2026
with Project
Cameron Ave. between Pacific Ave. and Orange
Ave. 66.9 67.2 67.3
Cameron Ave. between Orange Ave. and Toluca
Ave. 61.6 61.7 61.9
Orange Ave. between Garvey Ave. and Cameron
Ave. 67.0 67.4 67.5
Toluca Ave. between Pacific Ave. and Cameron Ave. 59.2 59.5 59.5 SOURCE: TAHA, 2024.

TABLE 3-12: CHANGE IN MOBILE SOURCE NOISE LEVELS
Roadway Segment
Estimated dBA, Leq at 50 Feet
Year 2026 with Project
vs. Year 2026 without
Project (2023)
Existing (2023) vs.

Year 2026 with Project
Cameron Ave. between Pacific Ave. and Orange
Ave. 0.3 0.4
Cameron Ave. between Orange Ave. and Toluca
Ave. 0.1 0.3
Orange Ave. between Garvey Ave. and Cameron
Ave. 0.4 0.5
Toluca Ave. between Pacific Ave. and Cameron Ave. 0.3 0.3 SOURCE: TAHA, 2024.

Summary
Overall, construction noise is expected to be less than existing noise levels at off-site sensitive receptors. The existing West Covina Medical Center facilities may experience short-term disruptive noise events during proposed project construction. Mitigation Measure N-1 would be required to reduce on-site construction noise impacts to less than significant levels. Therefore, construction noise would result in a less-than-significant impact with mitigation incorporated.

Operational noise, such as noise from HVAC equipment, parking lot, patient drop-off area, and activities and ambulance drop-off area, are not expected to cause ambient noise levels at noise sensitive receptor to noticeably increase. A less-than-significant impact would occur during operations of the proposed project.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-52
b) Less-Than-Significant Impact. A significant impact would occur if the proposed project would generate excessive groundborne vibration or groundborne noise levels. Operations of the proposed project would not include significant sources of vibration. Vehicle trips associated with the proposed project would not generate perceptible levels of groundborne vibration or groundborne noise as rubber-tired vehicles rarely create ground-borne vibration problems unless there is a discontinuity or bump in the road that causes the vibration.46 Construction activity can generate varying degrees of vibration, depending on the construction procedure and the construction equipment used. Operation of construction equipment generates vibrations that spread through the ground and diminish in amplitude with distance from the source. The effect on buildings located in the vicinity of a construction site often varies depending on soil type, ground strata, and construction characteristics of the receiver building(s). The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, and to damage at the highest levels.

Because construction activity is short-term and equipment moves around a project site, the primary concern regarding construction vibration relates to building damage. Activities that can result in damage include demolition and site preparation in close proximity to sensitive structures. Typical vibration levels associated with relevant construction equipment are provided in Table 3-13. Importantly, construction would not require pile driving, which generates elevated vibration levels above what typical construction equipment does.

TABLE 3-13: VIBRATION VELOCITIES FOR CONSTRUCTION EQUIPMENT Equipment Peak Particle Velocity at 25 feet (Inches/Second) Large Bulldozer 0.089
Loaded Trucks 0.076
Small Bulldozer 0.003
SOURCE: Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.

The City has not established vibration standards for construction activities. The Federal Transit Administration has published guidance stating that non-engineered timber and masonry buildings (e.g., typical single-family residential buildings) can withstand peak particle velocity (PPV) vibration of levels of at least 0.2 inches per second without experiencing damage. Reinforced concrete and masonry buildings (e.g. medical centers, commercial buildings) can withstand vibration levels of 0.5 inches per second.

The nearest off-site structure is a commercial building located approximately 300 feet to the southwest of the project site. Vibration levels at this distance would be less than 0.002 inches per second and would not exceed the 0.5 inches per second vibration damage threshold. Similarly, other structures located further away would not experience vibration levels that would exceed the vibration damage threshold. The existing West Covina Medical Center facilities would be located approximately 10 feet from where heavy equipment may be operating. Vibration levels generated by a large bulldozer at 10 feet would be approximately 0.352 inches per second and would be less than the 0.5 inches per second vibration damage threshold.

The City regulates construction disturbances through limiting the allowable hours of activities to between 7:00 a.m. to 8:00 p.m. Commercial construction is typically over by 46Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-53
4:00 p.m. even though later construction is allowed. Complying with the City standards is considered sufficient for limiting exposure to vibration levels.

As the proposed project would not generate perceptible vibration levels during operations and construction activities would not result in vibration levels that would generate elevated vibration levels that would damage existing buildings. Therefore, the proposed project would result in a less-than-significant impact related to vibration. c) No Impact. The proposed project is not located within an airport land use plan and is not within two miles of a private airstrip or public airport. The nearest airport is San Gabriel Valley Airport, approximately 4.9 miles to the west. There is no potential to expose people working or residing in the area to excessive aircraft noise. Therefore, no impact related to excessive airport noise would occur.

MITGATION MEASURES
N-1 The construction contractor shall develop and implement a Noise Control Plan to minimize excessive noise levels at the existing West Covina Medical Center during construction. At a minimum, the Noise Control Plan shall require the following:
 Prior to initiating construction activity, the construction contractor shall coordinate with the West Covina Medical Center administration to discuss construction activities that would generate high noise levels. Coordination between the administration and the construction contractor shall continue on an as-needed basis throughout the construction phase of the proposed project to minimize potential disruption to medical facilities.
 Power construction equipment (including combustion engines), fixed or mobile, shall be equipped with muffling devices consistent with manufacturers’ standards. All equipment shall be properly maintained to assure that no additional noise would be generated due to worn or improperly maintained parts.
 The construction contractor shall use “quiet” gasoline‑powered compressors or electrically powered compressors as well as electric rather than gasoline‑ or diesel‑powered forklifts for small lifting, where feasible.  The construction contractor shall locate construction equipment as far as feasible from adjacent or nearby noise-sensitive receptors.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-54
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.14 POPULATION AND HOUSING. Would the project:
a) Induce substantial unplanned population growth
in an area either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of roads
or other infrastructure)?
   
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
   
a) Less-Than-Significant Impact. A significant impact would occur if the proposed project would induce substantial population growth that would not have otherwise occurred as rapidly or in as great a magnitude. The proposed project would add a behavioral health building to the eastern portion of the project site. The new building would adjoin and connect to the existing medical hospital building on the project site. Medical offices are also located on the project site. No residential uses are currently located on the project site and no residential uses are being proposed. The proposed building addition would serve to meet the behavioral health needs of the existing population in the surrounding communities. No additional homes would be built as a result of the proposed project. The proposed project would provide a net increase of approximately 50 jobs in the City that can be filled by the local labor force. While the proposed project would increase the number of employees on the project site, it is expected that workers from nearby communities would be available to serve the needs of the proposed project. Employees are not expected to relocate to the surrounding area and, thus, would not result in a substantial permanent increase in population. Additionally, the proposed project is located in a developed portion of the City and is served by existing roads and utility infrastructure. The proposed project does not propose extension of roads or other infrastructure that would encourage development beyond what is already planned in the City and the surrounding communities. Therefore, the proposed project would not directly or indirectly induce substantial unplanned population growth, and impacts would be less-than-significant.
b) No Impact. A significant impact would occur if the proposed project would displace substantial numbers of existing people or housing. Medical offices and a medical hospital are currently located on the project site, and the proposed project would add a behavioral health facility to the project site. No residential uses are located on the project site, and no housing would be displaced as a result of the proposed project. The proposed project would not require the construction of replacement housing elsewhere. Therefore, no impact would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-55
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
LessThanSignificant
Impact
No
Impact

3.15 PUBLIC SERVICES. Would the project:
a) Result in substantial adverse physical impacts
associated with the provision of new or physically
altered governmental facilities, need for new or
physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public
services:

i) Fire protection?    
ii) Police protection?    
iii) Schools?    
iv) Parks?    
v) Other public facilities?    
a.i) Less-Than-Significant Impact. A significant impact would occur if the proposed project would result in the provision of or need for new or physically altered fire protection services, the construction and/or operation of which would cause significant environmental impacts in order to maintain service ratios, response times, or other performance objectives. The WCFD provides fire protection and paramedic services to residents and businesses within the City. The City is divided into five fire districts, and each fire district is served by a fire station.

The project site is within the fire district of Fire Station No. 1, located at 819 South Sunset Avenue.47 The project site is approximately 0.3 “road mile” south of this fire station, which would ensure a maximum response time of five minutes or less.

Construction of the proposed project may generate traffic associated with the movement of construction equipment, removal of materials from site clearing, and construction worker trips. Construction activities associated with the proposed project are not expected to directly block emergency routes since construction would not involve any street closures.

Although slow-moving construction-related vehicles may be present along streets, emergency access would remain available along all surrounding streets. Emergency vehicles would be able to circumvent slow-moving construction-related vehicles using sirens during emergencies.

The proposed building addition would incrementally increase demand for fire protection services. However, the proposed project would be constructed to comply with the requirements of the City’s Fire Code (Article II of the WCMC), which requires adequate fire flow for the project site, fire prevention and suppression measures, fire access, and a sufficient number of hydrants. The proposed project would be designed to accommodate emergency access to and within the project site. The proposed drive aisles would be designed to meet the minimum width and turning dimensions as required by WCFD. Additionally, the proposed building addition would be constructed to meet the current building code requirements for fire safety. The applicant would be required to submit project plans to WCFD and incorporate WCFD fire protection and suppression features that are appropriate for the proposed project. Compliance with the City’s Fire Code and the inclusion of the WCFD fire suppression and suppression 47City of West Covina, Fire Department, https://www.westcovina.org/departments/fire, accessed August 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-56
measures would ensure that operation of the proposed project would not cause WCFD to expand the existing Fire Station 1, or any other fire stations within the City.

Per Chapter 17, Article IV of the WCMC, new structures constructed as a result of the proposed project would be subject to the payment of development impact fees, which would be used to pay for the construction of any additional fire facilities, fire facility improvements, equipment, and vehicles required as a result of the proposed project.

As the proposed project would be required to comply with the City’s Fire Code, WCFD requirements, and pay development impact fees, the proposed project would not increase demand on fire protection services in a manner that would adversely affect WCFD service ratios, response times, or other performance objectives. Therefore, impacts related to fire protection services would be less than significant.
a.ii) Less-Than-Significant Impact. A significant impact would occur if the proposed project would result in the provision of or need for new or physically altered police protection services, the construction and/or operation of which would cause significant environmental impacts in order to maintain service ratios, response times, or other performance objectives.

The West Covina Police Department (WCPD) provides police protection services to residents and businesses within the City of West Covina. WCPD headquarters is located at 1444 West Garvey Avenue approximately 0.6 “road mile” southeast from the project site.

Project construction may generate traffic associated with the movement of construction equipment, removal of materials from site clearing, and construction worker trips. However, construction activities are temporary and would not involve the closure of an entire street.

Emergency access would remain available along all surrounding streets and would not directly block emergency routes. Although slow-moving construction-related vehicles may be present along streets, emergency access would remain available along all surrounding streets. Emergency vehicles would be able to circumvent slow-moving construction-related vehicles using sirens during emergencies.

Project plans would be submitted to the WCPD Crime Prevention unit for review and appropriate on-site security features would be required by WCPD. Furthermore, as discussed in Response to Checklist Question 3.15a.i, the proposed project would be required to pay development impact fees, which would be used to pay for any additional law enforcement facilities, police facility improvements, vehicles, equipment, and services required as a result of the proposed project. Therefore, a less-than-significant impact related to police protection services would occur.
a.iii) Less-Than-Significant Impact. A significant impact would occur if the proposed project would induce substantial employment or population growth, which could increase demand for school facilities that would exceed the capacity of the schools, necessitating a new school or physical alteration of an existing school, the construction of which would cause a significant environmental impact. The project site is located within the West Covina Unified School District (WCUSD). Monte Vista Elementary School, Walnut Grove Intermediate School, and Edgewood High School are the closest schools that serve the project site. In the 2021-2022 school year, Monte Vista Elementary School, which serves grades TK through 6, had a total enrollment of 454 students.48 Walnut Grove Intermediate School, which serves grades 7 and 48Monte Vista Elementary School, Monte Vista Elementary School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year), https://drive.google.com/file/d/1OzIpS_shfj3hmvWHTudF2kZNJYXTj-m/view, accessed August 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-57
8, had a total enrollment of 319 students during the 2021-2022 school year.49 Edgewood High School, which serves grades 9 through 12, had a total enrollment of 855 students during the same school year.50
The need for new school facilities is typically associated with a population increase that generates an increase in enrollment large enough to cause new schools to be constructed.

No residential units would be constructed as part of the proposed project. Although the proposed project would increase the number of employees on the project site, the proposed project is not expected to result in a permanent increase in population since workers from nearby communities are expected to serve the needs of the proposed project. Nevertheless, it is possible that employees from the project site may decide to have their children attend schools that serves the project site (rather than from the employees’ school of residence), which could potentially increase student population of the schools that serve the project site.

In accordance with California Education Code Section 17620, the applicant of the proposed project would be required to pay school district fees to the West Covina Unified School District to fund the construction or reconstruction of school facilities. Pursuant to California Government Code Section 65995(3)(h), the payment of statutory fees “...is deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization…on the provision of adequate school facilities.” Therefore, impacts related to school facilities would be less than significant. a.iv) Less-Than-Significant Impact. A significant impact would occur if the proposed project would induce substantial population growth resulting in the need for and/or the provision of new or physically altered parks, the construction of which would cause significant environmental impacts. The City’s Public Services Department is responsible for the provision, maintenance, and operation of public recreational and park facilities and services within the City. As discussed in Response to Checklist Question 3.14a, the proposed project is not expected to result in a permanent increase in population since no residential uses are proposed and employees from the project site would come from nearby communities.

Although it is possible that employees from the project site may use nearby parks and recreational facilities, the additional demand on nearby parks and recreational facilities are not expected to increase in a manner that would require the need for or the provision of new or physically altered parks and recreational facilities. Additionally, the proposed project would be required to pay development impact fees, which would contribute funding for parks and recreational facilities. Any additional park services required as a result of the proposed project would be mitigated by the applicant paying the development impact fee. Therefore, impacts would be less than significant.
a.v) Less-Than-Significant Impact. A significant impact would occur if the proposed project would result in substantial employment or population growth that could generate a demand for other public facilities, including roads, transit, utilities, and libraries, that would exceed the capacity available to serve the project site, necessitating new or physically altered public facilities, the construction of which would cause significant environmental impacts. Potential impacts to roads and transit are discussed in Section 3.17, Transportation, and potential impacts to utilities are discussed in Section 3.19, Utilities and Service Systems. With regards 49Walnut Grove Intermediate School, Walnut Grove Intermediate School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year), https://drive.google.com/file/d/1BKS0LVdz4yivta56JITKJ0zkHsBTPLLg/view, accessed August 2023. 50Edgewood High School, Edgewood High School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year), https://drive.google.com/file/d/1Eh6FyjFcBsbAWih4ohZ6_2SGKaGMfQzZ/view, accessed August 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-58
to libraries, the City is served by the West Covina Library located at 1601 West Covina Parkway approximately 0.2 miles east of the project site.

The proposed project would increase employment on the project site, which could potentially incrementally increase the demand on library facilities. The West Covina Library is part of the County of Los Angeles Public Library system, which is financed by property taxes from the service area, general county funds, parcel tax, grants, feeds, and funds raised by the Library Foundation. As a result, the proposed project would contribute to the financing of library services through property taxes, which would mitigate the need for new or physically altered government facilities that support library use. Therefore, less-than-significant impacts related to library facilities would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-59
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.16 RECREATION. Would the project:
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?
   
a) Less-Than-Significant Impact. A significant impact would occur if the proposed project would result in an increased use of existing parkland and recreational facilities in a manner that would accelerate or induce their physical deterioration. As discussed in Response to Checklist Question 3.15a.iv, although the proposed project would not result in a permanent increase in population, employees from the project site may use nearby parks and recreational facilities, which would create additional demand on these parks and recreational facilities. However, the potential increase in the use of existing public park and recreational facilities by the proposed project would not be at a level that would result in physical deterioration of existing parks and other recreational facilities and would not require or need new or physically altered facilities. The proposed project would be required to pay development impact fees, which would contribute funding for parks and recreational facilities. Any additional park services required as a result of the proposed project would be mitigated by the applicant paying the development impact fee. Thus, the proposed project would not substantially increase the use of existing neighborhood and regional parks or other recreational facilities that would cause or accelerate adverse deterioration of existing parks and recreational facilities. Therefore, a less-than-significant impact is anticipated. b) Less-Than-Significant Impact. A significant impact would occur if the proposed project would include or require the construction or expansion of recreational facilities, the construction and operation of which would have an adverse physical effect on the environment. The proposed project does not include any parks and recreational facilities.

As discussed in Response to Checklist Question 3.15a.iv, the proposed project would be required to pay development impact fees, which would contribute funding for public parks and recreational facilities. Any additional park services required as a result of the proposed project would be mitigated by the applicant paying the development impact fees. Therefore, a less-than-significant impact would occur.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-60
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
LessThanSignificant
Impact No Impact

3.17 TRANSPORTATION. Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
   
b) Would the project 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 uses (e.g., farm
equipment)?
   
d) Result in inadequate emergency access?    
a) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Alternative Transportation Modes
The proposed project would not conflict with alternative transportation modes that serve the area surrounding the project site. The project site and its surrounding area is served by Foothill Transit Line 178 and the City’s Go West Shuttle Blue Line. The nearest bus stop for the City’s Go West Shuttle Blue Line is on Orange Avenue, approximately 150 feet south of the project site. The nearest bus stop for Foothill Transit Line 178 is on Pacific Ave, north of the I-10 freeway, approximately 600 feet north of the project site. The bus stop for these two transit lines is also located at the West Covina Parkway/Toluca Avenue intersection, south of the I-10 freeway, approximately 950 feet from the project site. Foothill Transit Lines 178, 185, 272, and 281 have a bus stop at the Sunset Avenue/West Covina Parkway intersection, approximately 0.4 mile southeast of the project site. The proposed project does not include components that would disrupt services to Foothill Transit and the City’s Go West Shuttle.

The bus and shuttle lines would continue to serve the project site and the surrounding area.

According to the City’s General Plan, Cameron Avenue (adjacent to the project site) and Orange Avenue (southwest of Cameron Avenue) are designated as Class III bike routes.

The proposed project does not involve any components that would affect these or other bikeways in the surrounding area. Additionally, the existing sidewalks along Cameron Avenue and Orange Avenue would remain with implementation of the proposed project and would continue to be used by pedestrians to access the project site and the surrounding uses.

Circulation-related Plans and Policies
The City’s General Plan Circulation Element (Our Accessible Community Chapter of the General Plan) sets forth actions and policies pertaining to accident and traffic safety, transit and public transportation, and bicycle routes and pedestrian facilities, among other things.

Relevant adopted policies include the following:
 Policy 4.2: Accommodate multimodal mobility, accessibility and safety needs when planning, designing, and implementing transportation improvements, improving access and circulation for all users of City streets.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-61
 Policy 4.3: Establish protection of human life and health as the highest transportation system priorities and seek to improve safety through the design and maintenance of streets, sidewalks, intersections and crosswalks.
 Policy 4.4: Allocate street space equitably among all modes.  Policy 4.5: Work to eliminate barriers to pedestrian and bicycle travel.  Policy 4.6: Work with transit providers to develop high-quality facilities for transit users, including access facilities.
 Policy 4.13: Synchronize traffic signals and develop operational enhancements at the I10 freeway interchanges to reduce traffic congestion.

The City’s Active Transportation Plan also sets forth a number of objectives and goals to promote a balanced multi-modal transportation network that serves pedestrians, bicyclists, transit riders and motorists of all ages and abilities. The Active Transportation Plan includes objectives pertaining to programs that support bicycling, including programs that introduce and promote education, encouragement, and outreach, facilitate non-motorized travel to transit stations and stops, and encourage non-motorized travel to shops and restaurants.

The Plan also provides specific recommendations for promoting walking and bicycling activities within the City, such as improving street crossings and lightings for pedestrians, implementing pedestrian safety measures in neighborhood streets, closing gaps to enhance crosstown connections for the bicycle network, enhancing bicycle facilities, and linking to other regional routes in adjacent cities.

The proposed project would not conflict with the applicable goals, objectives, and policies of the City’s General Plan and the City’s Active Transportation Plan. As discussed in Response to Checklist Question 3.17c, Mitigation Measure T-1 would be implemented to provide greater visibility and safety to pedestrians and motorists at the existing crosswalk at the Orange Avenue/Cameron Avenue intersection. Mitigation Measure T-2 would be implemented to improve the line of sight at the on-site and off-site parking lots.

Implementation of these mitigation measures would improve safety along Orange Avenue and at the Orange Avenue/Cameron Avenue intersection and would support Policies 4.2,

4.3, 4.5 of the City’s General Plan Circulation Element.

The proposed project would be accessible by vehicles, pedestrians, bicyclists, and transit users. Sidewalks are located adjacent to the project site along Orange Avenue and Cameron Avenue, and a designated Class III bike route is located on Cameron Avenue adjacent to the project site. The bike routes would not be altered by the proposed project.

Walkways would be provided on the project site to connect the proposed project to the public sidewalks and bike routes. The walkways would minimize the extent of pedestrian and bicycle interaction with vehicles at the project site and would provide a comfortable, convenient, and safe environment, which in turn can encourage use of active transportation modes.

The project site is within walking distance (i.e., less than 0.5 mile) of Foothill Transit Line 178 and the City’s Go West Shuttle Blue Line. The proposed project is not expected to affect access or safety at the existing bus stops and is not expected to hinder public transit service in the surrounding area. The proposed project is not expected to preclude the City from constructing bicycle facilities or pursuing bicycle network improvements along local roadways within the surrounding area. Development of the proposed project would not prevent the City from completing any proposed transit, bicycle, or pedestrian facilities.

Vehicular circulation on the project site would be designed to comply with the City’s Municipal Code and the requirements of the City’s Fire Department. As detailed below under “I-10 Off-Ramp Vehicle Queuing,” the proposed project would not cause or contribute towards vehicle queuing that would extend back into the I-10 freeway mainline travel lanes.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-62
Level of Service
While delay-based metric (including level of service [LOS]) is no longer used in the determination of significance of transportation impacts, it is used in project planning. The City of West Covina’s Transportation Study Guidelines note that the City has established vehicle LOS standards which local infrastructure will strive to maintain. The LOS standards apply to discretionary approvals of new land use projects.51 Volume-to-capacity (v/c) ratio is a ratio that compares the number of vehicles using an intersection during peak hour to the capacity of the intersection. The v/c ratio measures whether an intersection has sufficient capacity for the movement of vehicles. A small v/c value indicates excess capacity, while a large v/c value indicates severe congestion. The overall intersection v/c ratio is subsequently assigned an LOS value to describe intersection operations. LOS is typically used to describe the operating conditions of a roadway based on factors such as speed, travel time, and delay.52
For signalized intersections, the City may require improvements or other strategies to reduce the v/c ratio to acceptable levels if the proposed project meet the following condition:
 The addition of project traffic results in the increase in v/c ratio equal to or greater than

0.020 at an intersection that degrades from acceptable operations (LOS E or better) to unacceptable operations (LOS F).

For unsignalized intersections, the City may require improvements or other strategies to reduce the LOS to acceptable levels if both of the following conditions are met:
 The addition of project traffic to an intersection results in the degradation of overall intersection operations from acceptable operations (LOS E or better) to unacceptable operations (LOS F), and
 Project-related increase in traffic contributes 10 percent or more to the total peak hour volume at an intersection that is already operating at LOS F.

Operations. According to the Transportation Impact Study for the proposed project, which is included in Appendix C, the proposed project would generate an additional 452 daily vehicle trips, of which 34 trips would be during the AM peak hour and 36 trips would be during the PM peak hour.53 The Transportation Impact Study evaluated LOS at two study intersections (Orange Avenue/Cameron Avenue and Toluca Avenue/Cameron Avenue) under Existing and Year 2026 conditions. Orange Avenue/Cameron Avenue is a signalized intersection, and Toluca Avenue/Cameron Avenue is an unsignalized intersection.

Year 2026 conditions account for the development of related projects within one mile of the project site and background (or ambient) traffic growth between existing and future year 2026 conditions. Related projects within one mile of the project site were obtained from information on file with the City of West Covina and City of Baldwin Park Community Development Departments. Additionally, the ambient traffic growth rate of one percent per 51City of West Covina, City of West Covina Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment, September 2020.
52LOS varies from LOS A (free flow conditions) to LOS F (jammed conditions). The acceptable operating condition for intersections in the City of West Covina is LOS E or better. Any intersection that operates at LOS F is considered deficient.
53Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-63
year was used to account for typical growth in traffic volumes due to the development that would occur further than one mile of the project site.

Tables 3-14 and 3-15 present traffic conditions at the two study intersections under Existing (2023) and Year 2026 scenarios, respectively. Orange Avenue/Cameron Avenue intersection would operate at LOS B and C during the AM and PM peak hour, respectively, under Existing without and with the proposed project conditions. This intersection would operate at LOS A and B during the AM and PM peak hour, respectively, under Year 2026 conditions without and with proposed project conditions. The Toluca Avenue/Cameron Avenue intersection would operate at LOS B under Existing and Year 2026 without and with proposed project conditions during the weekday AM and PM peak hour conditions. The proposed project is not expected to cause any of the study intersections to operate at a deficient LOS (i.e., LOS F). The incremental increase in vehicle delay, or v/c ratio, would be

0.1 or less during the AM and PM peak hour conditions at the two intersections under Existing and Year 2026 scenarios. The proposed project would maintain acceptable operations (i.e., LOS E or better) at the two study intersections. Thus, intersection operations would not be degraded, and no intersection improvements or transportation demand management measures are proposed or required for the proposed project.54 TABLE 3-14: EXISTING WITHOUT AND WITH PROPOSED PROJECT PEAK HOUR TRAFFIC

CONDITIONS
Intersection
Peak
Hour
Existing without Project Existing with Project Change
V/C or Delay LOS V/C or Delay LOS in Delay
Orange Ave./Cameron
Ave.

AM
PM

0.644

0.727
B
C

0.655

0.740
B
C

0.011

0.013
Toluca Ave./Cameron Ave. AM
PM

13.4 13.8
B
B

13.5 13.9
B
B

0.1 0.1
SOURCE: Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Heath Addition Project, September 17, 2024.

TABLE 3-15: YEAR 2026 CONDITIONS WITHOUT AND WITH PROPOSED PROJECT PEAK

HOUR TRAFFIC CONDITIONS
Intersection
Peak
Hour
Year 2026 without Project Year 2026 with Project Change V/C or Delay LOS V/C or Delay LOS in Delay
Orange Ave./Cameron
Ave.

AM
PM

0.574

0.633
A
B

0.588

0.640
A
B

0.014

0.007
Toluca Ave./Cameron Ave. AM
PM

13.9 14.7
B
B

14.0 14.7
B
B

0.1 0.0
SOURCE: Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Heath Addition Project, September 17, 2024.

Construction. Construction-related vehicle trips would be generated by construction worker vehicles, construction trucks, and miscellaneous/delivery trucks traveling to and from the project site. During peak construction activities, construction of the proposed project is estimated to generate approximately 212 vehicle trips on a daily basis to and from the site by construction workers. This estimated vehicle trips assumes overlapping construction phases. Construction-related activities would typically occur between 7:00 a.m. and 3:00 54Ibid.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-64
p.m. Mondays through Fridays. Late departures would occur only when overtime is necessary to maintain the construction schedule but would occur no later than 5:00 p.m. A majority of construction worker trips would generally occur outside of peak commute hours of adjacent street traffic. Assuming that 50 percent of the construction worker trips would overlap with the weekday PM peak hour, a maximum of 53 outbound construction worker vehicle trips would occur during the weekday PM peak hour.

The construction workforce would likely be generated from all parts of the Los Angeles region, and construction worker-related traffic is anticipated to be largely freeway-oriented.

Construction workers would likely arrive and depart via the on- and off-ramps serving the I10 freeway. The most commonly used freeway ramps would be on Pacific Avenue and West Covina Parkway as these ramps are closest to the project site.

Construction truck trips may consist of trucks exporting and delivering materials and equipment to and from the project site site. CalEEMod generates default estimates of daily vehicle trips associated with land use development projects when project-specific information is not available. Since the number of construction trucks trips that would be required for the proposed project is currently unknown, CalEEMod was used to obtain the estimated number of truck trips that would occur during construction of the proposed project.

CalEEMod estimates a maximum of 10 haul truck trips per day, or approximately 30 passenger car equivalent (PCE) vehicle trips per day, during peak construction activities. It is estimated that no more than 12 PCE vehicle trips would occur during both the weekday AM and PM peak hours.

Additional trips may be generated by miscellaneous/delivery trucks traveling to and from the project site. These trucks may consist of smaller pick-up trucks or four-wheel drive vehicles used by construction supervisors and/or City inspectors who are expected to travel to and from the project site. During peak construction activities, five miscellaneous trucks are anticipated. If these miscellaneous truck trips all occur during a single day, up to 10 truck trips per day, or approximately 20 daily PCE vehicle trips per day, would be generated to and from the project site by miscellaneous/delivery trucks. Of these trips, no more than 4 PCE vehicle trips would occur during both the weekday AM and PM peak hours.

When combined, construction worker vehicles, construction trucks, and miscellaneous trucks are forecasted to generate up to 262 daily PCE trips, 16 AM peak hour PCE vehicle trips, and 69 PM peak hour PCE vehicle trips during a typical weekday. While four related projects are within a one-mile radius of the project site, two of these related projects are located within two blocks of the project site, which is the distance that would typically be expected to result in potential concurrent construction traffic effects. It is possible that construction of some of these related projects could overlap with construction of the proposed project.

Although the proposed construction would generate more peak hour vehicle trips than proposed project operations, daily vehicle trips during the construction period would be less than the proposed project’s overall daily operational trips. Construction vehicle trips are not expected to result in any deficiencies in the intersection LOS.

Construction of the proposed project is not expected to result in any street closures.

However, portions of the sidewalks or lanes adjacent to the project site may need to be temporarily closed. If temporary sidewalk or lane closures are necessary, a construction staging and traffic management plan would be prepared, as required per City policy. This plan would require review and approval by the City’s Department of Public Works. Related projects in the City would also be required to prepare and implement construction staging and traffic management plans to address any anticipated temporary lane closures or re- West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-65
routing of vehicle and bicycle traffic, sidewalk closures or pedestrian re-routing. Thus, construction vehicle trips are not expected to result in any deficiencies in the intersection LOS.55
I-10 Off-Ramp Vehicle Queuing
The California Department of Transportation (Caltrans) Interim Local Development Intergovernmental Review Safety Review Practitioners provides guidance to Caltrans, lead agencies, developers, and consultants conducting safety reviews for land use projects and plans affecting the state highway system. The proposed project is expected to generate new project trips at the following intersections that are closest to the I-10 freeway off- ramps and project site:
 I-10 Freeway Eastbound Off-Ramp-Orange Avenue/Cameron Avenue, and  I-10 Freeway Westbound Off-Ramp-Garvey Avenue North/West Covina Parkway.

The off-ramp vehicle queuing analysis is presented in the Transportation Impact Study for the proposed project (Appendix C). As discussed in the Transportation Impact Study, total vehicle queuing for the off-ramp lanes at the two I-10 off-ramp intersections closest to the project site would be able to accommodate vehicle queues exiting the I-10 freeway under Existing and Year 2926 without and with project scenarios during the weekday AM and PM peak hours. The proposed project is not expected to cause or contribute towards vehicle queuing which extends back into the I-10 freeway mainline travel lanes resulting in unsafe speed differentials between adjacent lanes.56
Vehicle Miles Traveled
VMT measures the amount and distance of vehicle travel attributed to a project or use. The following VMT analysis is based on the Transportation Impact Study for the proposed project, which is included in Appendix C.

The City of West Covina has adopted three screening criteria that may be applied to screen development projects out of detailed VMT analysis:
1) Transit Priority Area (TPA) screening
2) Low VMT area screening
3) Project type screening
Development projects are not required to satisfy all of the screening criteria in order to screen out of further VMT analysis; satisfaction of one criterion is sufficient for screening purposes.

Caltrans Transportation Impact Study Guide (TISG) provides guidance on Caltrans’ review of land use projects. The TISG references the December 2018 Technical Advisory prepared by the state’s Office of Planning and Research as the basis for guidance on VMT assessment. The City’s adopted VMT methodology and screening criteria are substantially consistent with the recommendations provided in the Technical Advisory and also satisfies Caltrans’ VMT analysis requirements.

TPA Screening Criteria. TPA is an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program or applicable regional 55Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.
56Ibid.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-66
transportation plan. PRC Section 21064.3 defines a major transit stop as an existing rail or bus rapid transit station or the intersection of two or more major bus routes with a service interval of 15 minute or less during the morning and afternoon peak commute periods.

Development projects that are located within a TPA are presumed to have a less-thansignificant impact, absent substantial evidence to the contrary. This presumption may not be appropriate if:
 The development project has a floor area ratio of less than 0.75;  The development project includes more parking for use by residents, customers, or employees of the development project than required by the City;  The development project is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Southern California Association of Governments); or
 The development project replaces affordable residential units with a smaller number of moderate- or high-income residential units.

Although the project site is located within one-half mile of the bus stops for the Foothill Transit and the City’s Go West Shuttle lines, these bus stops are not major transit stops as defined by PRC Section 21064.3. Thus, the proposed project would not screen out of the VMT analysis based on the TPA screening criteria.

Low VMT Area Screening Criteria. Low VMT areas are areas in the City where VMT falls below the City’s adopted threshold of significance. Development projects that are located within areas that currently exhibit low VMT and incorporate similar features pertaining to density, land use mix, and transit availability would tend to exhibit similarly low VMT. In areas where the existing VMT generation already falls below the applicable thresholds and where development projects are likely to generate similar levels of VMT, projects may be screened out of preparing detailed VMT analysis. The City of West Covina has adopted a low VMT area screening criterion which may apply to residential, office, or other employment-related and mixed-use land use types.

The SCAG Travel Demand Forecasting Model was used to establish VMT performance for individual Traffic Analysis Zones (TAZ). The VMT values for each TAZ are then compared to the applicable City thresholds (i.e., VMT per capita, per employee, or per service population) to determine if the TAZ can be considered a low VMT area.

Based on the results of the SCAG Travel Demand Forecasting Model, which is provided in Appendix C of the Transportation Impact Study for the proposed project, the project site is located in a low VMT area. The project site is situated in a TAZ that currently exhibits

28.8 total VMT per service population, which is below the 29.56 total VMT per service population threshold for office project types. As the project site is located in a low VMT area, the project site satisfies the low VMT area screening criteria.57 Project Type Screening Criteria. Consistent with the OPR Technical Advisory, the City of West Covina has determined the following potential screening criteria for certain land development projects that may presume to result in a less than significant VMT impact as mentioned in the City’s Transportation Study Guidelines:
 Local-serving retail less than 50,000 square feet, including gas stations, banks, restaurants, shopping center
 Local-serving K-12 schools, local parks, daycare centers, etc. 57Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-67
 Local-serving hotels (e.g., non-destination hotels)
 Student housing projects or adjacent to college campuses  Local-serving assembly uses (places of worship, community organizations)  Community institutions (public libraries, fire stations, local government)  Affordable, supportive, or transitional housing
 Assisted living facilities, senior housing
 Projects generating less than 110 daily vehicle trips  Public parking garages and public parking lots
The proposed project would serve the local population and is considered a community institution, thereby shortening travel distances and reducing VMT. The proposed project satisfies the project type screening criteria.

VMT Summary. The proposed project does not satisfy the TPA screening criteria but satisfies the low VMT area and project type screening criteria. Therefore, the proposed project would screen out of further VMT analysis.

Summary
Implementation of Mitigation Measures T-1 and T-2 would support Policies 4.2, 4.3, and 4.5 of the City’s General Plan Circulation Element and, thus, the proposed project would not conflict with any program plan, ordinance or policy addressing the circulation system. The proposed project would maintain acceptable operations (LOS E or better) at the two study intersections. The proposed project is not expected to cause or contribute towards vehicle queuing which extends back into the I-10 freeway mainline travel lanes. Additionally, the proposed project would be screened out of the VMT analysis based on the low VMT area and project type screening criteria. Therefore, with implementation of Mitigation Measures T-1 and T-2, impacts would be less than significant.
b) Less-Than-Significant Impact. A significant impact would occur if the project was inconsistent with CEQA Guidelines Section 15064.3(b). CEQA Guidelines Section 15064.3 identifies VMT as a criteria for evaluating a project’s transportation impact. As discussed in Response to Checklist Question 3.17a, above, the proposed project satisfies the low VMT area and project type screening criteria. Therefore, the proposed project screens out of further VMT analysis. Therefore, the proposed project would not conflict with CEQA Guidelines Section 15064.3(b), and impacts would be less than significant. c) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would introduce design features or incompatible uses that would increase hazards. Access and circulation within the project site would be designed and constructed in conformance with all applicable City requirements. Walkways would be provided on the project site to connect the proposed project to the public sidewalks and bike routes. The walkways would minimize the extent of pedestrian and bicycle interaction with vehicles at the project site and would provide a comfortable, convenient, and safe environment.

The proposed project would not require the construction of any new roads or the modification of any existing roads or pedestrian pathways. However, use of the off-site parking lot would increase since the proposed project would reduce the number of on-site parking spaces and would require staff and visitors of the West Covina Medical Center to park at its off-site parking lot. As a result, more pedestrians would use the existing crosswalk at the Orange Avenue/Cameron Avenue intersection to access the project site. To provide greater visibility and safety to pedestrians and motorists, Mitigation Measure T-1 would be West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-68
implemented. This mitigation measure would convert the existing crosswalk at the Orange Avenue/Cameron Avenue intersection to white continental crosswalks.

According to Table 9-8 of the American Association of State Highway and Transportation Officials’ A Policy on Geometric Design of Highways and Streets, a design speed of 25 miles per hour would require a minimum stopping sight distance of 155 feet and an intersection sight distance of 240 feet for passenger cars. According to the Transportation Impact Study for the proposed project, when an existing motorist’s vehicle (i.e., front bumper) traveling along Orange Avenue is placed 15 feet from the edge of the travel way to the motorists’ eye, the project site provides a sight distance of 131 feet at the driveway for oncoming southbound approaching vehicles and 172 feet for oncoming northbound approaching vehicles. The minimum line of sight of 240 feet for passenger cars does not exist for the project site driveway. The Transportation Impact Study for the proposed project provides measures that would improve the line of sight between motorists at the project site driveway and motorists along Orange Avenue (assuming a north-south orientation for Orange Avenue). These measures include the following:
 Provide red curb markings and signages to prohibit on-street parking along the west side of Orange Avenue along the project site frontage;
 Remove the existing two-hour parking sign that is located to the north of the existing entrance canopy;
 Clear landscaping, signage, and objects that are taller than 36 inches in height;  Extend the existing red curb marking immediately south of the project site driveway be extended by approximately 40 feet to connect with the next southerly red curb marking on Orange Avenue; and
 Remove the two-hour parking sign to the north of the existing entrance canopy.58 While the minimum intersection sight distances are not met given the location of the existing driveway and the roadway curvature from the freeway off-ramp to Orange Avenue, the majority of visitors and staff parking would be provided at the off-site parking lot at the southwest corner of Orange Avenue/Cameron Avenue, while vehicles utilizing the Orange Avenue driveway on-site would primarily be staff and ambulances that are transporting patients. Due to the expected increased usage of the off-site parking lot, the Transportation Impact Study for the proposed project recommend the following to improve sight distance at the off-site parking lot:
 Install/refresh the red curb markings for 20 feet on either side of the two driveways for the off-site parking lot (i.e., at the Garvey Avenue South and Orange Avenue driveways); and  Install signs at the two driveways of the off-site parking lots indicating that the usage of the off-site parking lot is for the West Covina Medical Center staff and visitors only.59 Implementation of Mitigation Measure T-2 would ensure that the measures contained within the Transportation Impact Study for the proposed project be implemented to improve the line of sight at the on-site and off-site parking lots.

As discussed in Response to Checklist Question 3.17a, the proposed project is not expected to cause or contribute towards vehicle queuing that extends back into the I-10 freeway mainline travel lanes. Thus, the proposed project would not result in unsafe speed differentials 58 Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.
59 Linscott Law & Greenspan, Transportation Impact Study: West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024
West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-69
between adjacent lanes, and the proposed project is not anticipated to negatively influence safety on the state highway system.

Implementation of Mitigation Measure T-1 would be required to provide greater visibility and safety to pedestrians and motorists at the existing crosswalk at the Orange Avenue/Cameron Avenue intersection. Implementation of Mitigation Measure T-2 would be required to improve the line of sight between the project site and oncoming traffic. Therefore, with implementation of Mitigation Measures T-1 and T-2, a less than-significant impact related to transportation hazards would occur.
d) No Impact. A significant impact would occur if the proposed project would result in inadequate emergency access. The proposed project would be designed to accommodate emergency vehicles and would allow adequate emergency access to the project site in accordance with the City’s driveway standards and WCFD requirements. Additionally, the proposed drive aisles would be designed to meet the minimum width and turning dimensions as required by WCFD. The turnaround area in front of the proposed building would be designed to accommodate fire trucks. The proposed project design would also be reviewed by the City’s Planning Division, Building Division, and WCFD during the plan review process to ensure all applicable requirements are met. No roads would be closed by construction or operation of the proposed project. Emergency vehicles would be able to travel along roadways, and access to all surrounding properties would be maintained.

During construction, emergency vehicle access throughout the surrounding area would be maintained. As required by the California Vehicle Code (specifically Section 21806, Authorized Emergency Vehicles), “upon the immediate approach of an authorized emergency vehicle which is sounding a siren and which has at least one lighted lamp exhibiting red light that is visible, under normal atmospheric conditions, from a distance of 1,000 feet in front of a vehicle, the surrounding traffic shall, except as otherwise directed by a traffic officer, do the following:
(a) (1) Except as required under paragraph (2), the driver of every other vehicle shall yield the right-of-way and shall immediately drive to the right-hand edge or curb of the highway, clear of any intersection, and thereupon shall stop and remain stopped until the authorized emergency vehicle has passed.
(2) A person driving a vehicle in an exclusive or preferential use lane shall exit that lane immediately upon determining that the exit can be accomplished with reasonable safety. (b) The operator of every street car shall immediately stop the street car, clear of any intersection, and remain stopped until the authorized emergency vehicle has passed. (c) All pedestrians upon the highway shall proceed to the nearest curb or place of safety and remain there until the authorized emergency vehicle has passed.” If required, drivers of emergency vehicles are also trained to utilize center turn lanes, or travel in opposing through lanes to pass through crowded intersections or streets. Therefore, the proposed project would not result in inadequate emergency access, and no impact is expected.

MITGATION MEASURES
T-1 The existing crosswalk at the Orange Avenue/Cameron Avenue intersection shall be converted to white continental crosswalks to provide greater visibility and safety to pedestrians and motorists.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-70
T-2 The applicant shall comply with all measures identified in the Transportation Impact Study for the proposed project. These measures include the following:
 Install red curb markings and signage to prohibit on-street parking along the west side of Orange Avenue along the project site frontage (assuming a north-south orientation for Orange Avenue). The existing red curb marking immediately south of the project site driveway shall be extended by approximately 40 feet to connect with the next southerly red curb marking on Orange Avenue.
 All existing red curb markings on Orange Avenue shall be refreshed for visibility.  Remove the existing two-hour parking sign that is located to the north of the existing entrance canopy.
 Trim the existing trees and bushes along the west side of the Orange Avenue/freeway off-ramp north of the project site driveway to maintain a clear line of sight between motorists and oncoming motorists.
 Install advance warning signs for southbound approaching vehicles coming from the freeway off-ramp on both sides of Orange Avenue to indicate the presence of an intersection/driveway further ahead (see Figure 2-4, Intersection Sight Distance at Project Driveway, of the Transportation Impact Study for the proposed project for the proposed signs and the location of these signs).
 Install/refresh the red curb markings for 20 feet on either side of the two driveways for the off-site parking lot (i.e., at the Garvey Avenue South and Orange Avenue driveways).
 Install signs at the two driveways of the off-site parking lots to indicate that the usage of the off-site parking lot is for the West Covina Medical Center staff and visitors only.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-71
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.18 TRIBAL CULTURAL RESOURCES. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code Section 5020.1(k)?
   
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.
   
a-b) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would cause a substantial adverse change in the significance of a tribal cultural resource. The project site is currently developed with a medical center, surface parking, and landscaping. As discussed in Response to Checklist Question 3.5a, the project site was evaluated as a potential historical resource in the City’s 2019 Historic Resource Inventory Update. The project site was evaluated according to the established designation criteria for listing in the National Register, California Register, and as a City of West Covina landmark or historic district. The DRP 523 form for the West Covina Medical Center indicates that the project site does not appear to be eligible for listing under any of the criteria for the National Register, California Register, or West Covina Landmark. 60 To date, no significant tribal cultural resources have been identified on the project site.

However, it is possible that tribal cultural resources could be discovered during ground disturbing activities. In accordance with Assembly Bill 52 (AB 52) requirements, California Native American tribes traditionally and culturally affiliated with the geographic area of the project site were notified of the proposed project on August 15, 2023. The Gabrieleno Band of Mission Indians - Kizh Nation responded and recommended that mitigation measures be imposed on the project site to ensure that any inadvertent discovery of tribal cultural resources encountered during ground-disturbing activities are properly documented, salvaged, and protected. Therefore, with implementation of Mitigation Measures TR-1 through TR-3, impacts related to the tribal cultural resources would be less than significant.

MITIGATION MEASURES
TR-1 The project applicant shall retain a Native American monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation (Kizh). The Native American monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the proposed project at all project locations (i.e., both on-site and any off-site locations that are included in the project description and/or required in connection with the proposed project, such as public improvement work). “Ground-disturbing activity,” as defined by the Kizh, includes, but 60City of West Covina, Historic Context Statement, 1945-1978 & Historic Resource Inventory Update, Attachment 4, December 2019, https://www.westcovina.org/departments/community-development/planningdivision/historic-preservation, accessed March 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-72
is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

The Native American monitor shall complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Kizh. Monitor logs shall identify and describe any discovered tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the lead agency upon written request.

On-site tribal monitoring shall conclude upon the latter of the following: (1) written confirmation to the Kizh from a designated point of contact for the project applicant that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the proposed project are complete; or (2) a determination and written notification by the Kizh or Native American monitor to the project applicant and lead agency that no future, planned construction activity and/or construction phase at the project site possesses the potential to impact tribal cultural resources.

TR-2 Upon discovery of any tribal cultural resources, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered tribal cultural resources has been fully assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all discovered tribal cultural resources in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

TR-3 Native American human remains are defined in PRC Section 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness.

Funerary objects, called associated grave goods in PRC Section 5097.98, are also to be treated according to this statute.

If Native American human remains and/or grave goods are discovered or recognized on the project site, construction activities shall be diverted at a minimum of 150 feet from the discovery and an exclusion zone shall be placed around the burial. PRC Section 5097.9 and Health and Safety Code Section 7050.5 shall be followed. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation halted until the coroner has determined the nature of the remains. Work shall continue to be diverted while the coroner determines whether the remains are Native American. If the County Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Native American Heritage Commission shall be contacted by telephone within 24 hours. If the finds are determined to be Native American, the coroner will notify the Native American Heritage Commission as mandated by state law, who will then appoint a Most Likely Descendent.

Human remains and grave/burial goods shall be treated alike per PRC Section 5097.98(d)(1) and (2). Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-73
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.19 UTILITIES AND SERVICE SYSTEMS. Would the project:
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?
   
a) Less-Than-Significant Impact. A significant impact would occur if the proposed project would require or result in the relocation or construction of new utilities facilities or service systems, which would cause significant environmental effects.

Water Supply. Water for the project site is served by Suburban Water Systems. Suburban Water Systems serves a population of about 300,000 through a water distribution system that includes 18 wells, 32 reservoirs, and more than 800 miles of pipeline. Their network of facilities pumps and distributes approximately 43,000 acre-feet of water annually.61,62 Groundwater comes from Suburban-owned wells in the Main San Gabriel Basin and Central Basin. The well water is disinfected and treated prior to entering the distribution system. Water supply is supplemented with water purchased mainly from member agencies of the Metropolitan Water District of Southern California, Covina Irrigated Company, and California Domestic Water Company. Suburban Water Systems is divided into two main service areas: San Jose Hills Service Area and the Whittier/La Mirada Service Area. The project site is located in the San Jose Hills Service Area.

According to the 2020 Urban Water Management Plan for Suburban Water Systems, Suburban Water Systems had an annual water demand of 45,389 acre-feet for a service area population of 298,367 in 2020, while the San Jose Hills Service Area had an annual water demand of 23,371 acre-feet for a service area population of 175,529. 61Suburban Water Systems, Final 2020 Urban Water Management Plan, June 2021, https://wuedata.water.ca.gov/public/uwmp_attachments/3673902213/Suburban%20Final%202020%20UWMP_2021- 06-30.pdf.
62One acre-foot is about 326,000 gallons, which meets the annual average indoor/outdoor water needs of one or two households.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-74
Tables 3-16, 3-17, and 3-18 show the 2020 Urban Water Management Plan projected water supply and demand in the San Jose Hills Service Area under normal year, single dry year, and multiple dry year conditions, respectively, through 2045. As shown, Suburban Water Systems is projected to meet future water demands in the San Jose Hills Service Area for normal, single-dry, and multiple-dry year conditions through 2045.63 TABLE 3-16: SAN JOSE HILLS NORMAL YEAR SUPPLY AND DEMAND COMPARISON Water
Supply/Demand
Year
2025 2030 2035 2040 2045
Supply Totals (afy) 34,200 34,200 34,200 34,200 34,200
Demand Totals (afy) 24,175 24,415 24,658 24,904 25,151
Difference (afy) 10,025 9,785 9,542 9,296 9,049
afy = acre-feet per year
SOURCE: Suburban Water Systems, Final 2020 Urban Water Management Plan, Table 3.23, June 2021.

TABLE 3-17: SAN JOSE HILLS SINGLE DRY YEAR SUPPLY AND DEMAND COMPARISON Water
Supply/Demand
Year
2025 2030 2035 2040 2045
Supply Totals (afy) 29,579 29,579 29,579 29,579 29,579
Demand Totals (afy) 25,535 25,782 26,032 26,283 26,538
Difference (afy) 4,044 3,797 3,547 3,295 3,041
afy = acre-feet per year
SOURCE: Suburban Water Systems, Final 2020 Urban Water Management Plan, Table 3.26, June 2021.

TABLE 3-18: SAN JOSE HILLS MULTIPLE DRY YEAR SUPPLY AND DEMAND COMPARISON Water
Supply/Demand
Year
2025 2030 2035 2040 2045

FIRST YEAR
Supply Totals (afy) 33,945 33,945 33,945 33,945 33,945
Demand Totals (afy) 24,374 24,610 24,848 25,088 25,331
Difference 9,571 9,336 9,098 8,857 8,614

SECOND YEAR
Supply Totals (afy) 32,893 32,893 32,893 32,893 32,893
Demand Totals (afy) 24,374 24,610 24,848 25,088 25,331
Difference 8,519 8,284 8,046 7,805 7,562

THIRD YEAR
Supply Totals (afy) 32,481 32,481 32,481 32,481 32,481
Demand Totals (afy) 24,374 24,610 24,848 25,088 25,331
Difference 8,107 7,872 7,634 7,393 7,150
FOURTH Year
Supply Totals (afy) 29,579 29,579 29,579 29,579 29,579
Demand Totals (afy) 24,374 24,610 24,848 25,088 25,331
Difference 5,205 4,969 4,731 4,491 4,248
63Suburban Water Systems, Final 2020 Urban Water Management Plan, June 2021, https://wuedata.water.ca.gov/ public/uwmp_attachments/3673902213/Suburban%20Final%202020%20UWMP_2021-06-30.pdf.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-75
TABLE 3-18: SAN JOSE HILLS MULTIPLE DRY YEAR SUPPLY AND DEMAND COMPARISON Water
Supply/Demand
Year
2025 2030 2035 2040 2045

FIFTH YEAR
Supply Totals (afy) 36,662 36,662 36,662 36,662 36,662
Demand Totals (afy) 24,374 24,610 24,848 25,088 25,331
Difference 12,289 12,053 11,815 11,574 11,331
afy = acre-feet per year
SOURCE: Suburban Water Systems, Final 2020 Urban Water Management Plan, Table 3.29, June 2021 The proposed project is estimated to increase water demand by approximately 40,470 gallons per day, or 45.3 afy, which represents 0.4 to 0.5 percent of the Suburban Water Systems’ available water supply for the San Jose Hills Service Area for a normal year from 2025 to 2045, 1.1 to 1.5 percent of the available water supply for a single-dry year from 2025 to 2045, and 0.4 to 1.1 percent of the available water supply for multiple-dry year.64 Sufficient water supplies would be available to serve the proposed project.

The estimated water demand of the proposed project would be typical for a medical center and is not expected to exceed available supplies or the available capacity within the distribution infrastructure that would serve the project site. Prior to the issuance of a building permit, the applicant would be required to verify that the City’s water system can accommodate the proposed project’s fire flows and all potable water demand. Additionally, water used for irrigation and landscaping purposes would be required to comply with the City’s Water Efficient Landscaping Ordinance (WCMC Chapter 26, Article III, Division 5) and the Planning Commission Guidelines for Water Efficient Landscaping. The estimated water demand of the proposed project is not expected to exceed available supplies or the available capacity within the distribution infrastructure that would serve the project site. Adequate water supplies would be available to the proposed project, and new or expanded water facilities would not be required. Therefore, impacts related to water supply infrastructure would be less than significant.

Wastewater. Wastewater generated from the project site is collected by sewer pipelines that are maintained by the City. Wastewater collected by the City is then directed to the Sanitation Districts of Los Angeles County (LACSD) trunk sewer pipelines where wastewater is conveyed to the LACSD San Jose Creek Water Reclamation Plant (SJCWRP). SJCWRP treats approximately 53.6 million gallons per day (mgd) of wastewater and has the capacity to treat up to 100 mgd of wastewater, which leaves an available capacity of 46.4 mgd.65
Wastewater generation is typically estimated to be approximately 90 percent of water usage.

This estimate accounts for outdoor uses, such as landscape irrigation, where water does not become wastewater, as well as consumptive uses. The proposed project is estimated to generate approximately 36,423 gallons per day of wastewater, which is less than 0.1 64Based on a water demand of 570 gallons per bed per day for hospitals (Healthcare Design, “Hospitals Can Tap into Savings through Water Conservation,” https://healthcaredesignmagazine.com/architecture/saving-watersaving-money/#:~:text=U.S.%20hospitals%20are%20water%20hogs,per%20staffed%20bed%2C%20per%20day, accessed August 2023).
65Los Angeles County Sanitation Districts, San Gabriel River Watershed Project to Reduce River Discharge in Support of Increased Recycled Water Reuse, https://files.ceqanet.opr.ca.gov/89269- 2/attachment/HNWjbgzSSydtx6C6GMyB0t8xWaW3cPilsA6z7m1lX7AXtQ13GbQ722U2K9pockBuyShwuBHlrqzc_r390, accessed August 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-76
percent of the available capacity at SJCWRP.66 SJCWRP would have adequate available capacity to serve the proposed project, and the proposed project would not cause SJCWRP to exceed wastewater treatment requirements of the LARWQCB. Thus, new or expanded wastewater treatment facilities would not be required, and impacts would be less than significant.

Stormwater Drainage. Existing stormwater runoff from the project site generally flows south and southwest towards Orange Avenue. Surface runoff from the project site is currently collected by an existing catch basin located in the driveway on the project site and off-site on Orange Avenue, west of Cameron Avenue. A catch basin is also located on Cameron Avenue adjacent to the project site. The proposed project would increase the amount of impervious surfaces on the project site compared to existing conditions. The existing catch basin on the project site would be replaced with a new catch basin at a similar location.

Another catch basin would be installed at the northeastern portion of the project site. The proposed project would also install a stormwater infiltration tank on the project site. New storm drain lines would be installed to connect the new on-site catch basins to the stormwater infiltration tank to capture stormwater on-site. Runoff that are not captured onsite would continue to flow off-site into the existing catch basin on Orange Avenue. With the installation and operation of the on-site catch basins and stormwater infiltration tank, stormwater runoff leaving the project site would not substantially increase compared to existing conditions. Construction of the proposed on-site storm drainage infrastructure are within the limits identified for the proposed project and, thus, the potential impacts associated with the proposed storm drain lines have been considered in the respective sections of this IS/MND.

The proposed project would also be subject to the latest requirements of the NPDES permit program, LARWQB, and applicable pollution control and stormwater drainage measures. As the proposed project would not cause a substantial increase in the peak flow rates or volumes that would exceed the drainage capacity of existing stormwater drainage facilities, new or expanded stormwater drainage facilities beyond those that would be installed by the proposed project would not be required, and impacts would be less than significant.

Electric Power and Natural Gas. Energy use associated with operation of the proposed project would be similar to the existing medical center, requiring electricity and natural gas for lighting, medical and other electronic equipment, and natural gas for interior and exterior building lighting, HVAC, machinery, refrigeration, appliances, security systems, and more. The proposed project would be served by Southern California Edison for electricity, and SoCalGas for natural gas. The project site is in a developed, urbanized portion of the City of West Covina that is served by existing electrical power and natural gas services. The proposed project would use the existing electricity and natural gas connections for the existing medical center.

Additionally, no substantial electrical or natural gas infrastructure is present on or adjacent to the project site that would need to be relocated to accommodate the proposed project.

Therefore, impacts associated with electric power and natural gas facilities would be less than significant.

Telecommunications. Telecommunication services include phone, television, and internet providers. The project site is in a developed, urbanized portion of the City of West Covina that is served by existing telecommunications services. The proposed project would use the same telecommunications services as the existing medical center. Upgrades and/or relocation of 66Water demand for a hospital is 570 gallons per bed per day for hospitals (Healthcare Design, “Hospitals Can Tap into Savings through Water Conservation,” https://healthcaredesignmagazine.com/architecture/saving-watersaving-money/#:~:text=U.S.%20hospitals%20are%20water%20hogs,per%20staffed%20bed%2C%20per%20day, accessed August 2023).

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-77
existing telecommunications infrastructure may be required for the proposed project. Any potential upgrades or relocation of telecommunications infrastructure would be limited to onsite telecommunications distribution and minor off-site work associated with connections to the existing system. No upgrades to off-site telecommunications systems are anticipated to occur as a result of the proposed project. Any work that may affect services to the existing telecommunications lines would be coordinated with service providers and is not expected to cause significant environmental effects. Therefore, impacts would be less than significant. b) Less-Than-Significant Impact. A significant impact would occur if the proposed project would increase water usage such that the project site would not have enough water supplies during normal, dry and multiple dry years. As discussed in Response to Checklist Question

3.19a, the proposed project would increase water demand by approximately 45.3 afy, which represents 0.4 to 0.5 percent of the Suburban Water Systems’ available water supply for the San Jose Hills Service Area for a normal year from 2025 to 2045, 1.1 to 1.5 percent of the available water supply for a single-dry year from 2025 to 2045, and 0.4 to 1.1 percent of the available water supply for multiple-dry year. Sufficient water supplies would be available to serve the proposed project during normal, single dry, and multiple dry years. Additionally, water used for irrigation and landscaping purposes would be required to comply with the City’s Water Efficient Landscaping Ordinance (WCMC Chapter 26, Article III, Division 5) and the Planning Commission Guidelines for Water Efficient Landscaping. The estimated water demand of the proposed project is not expected to exceed available supplies or the available capacity within the distribution infrastructure that would serve the project site. Therefore, impacts on water supplies would be less than significant. c) Less-Than-Significant Impact. A significant impact would occur if the proposed project’s wastewater demand exceeds the capacity of the project site’s wastewater treatment provider.

As discussed in Response to Checklist Question 3.19a, wastewater on the project site is treated at the SJCWRP, and the SJCWRP has sufficient remaining available treatment capacity to adequately serve the proposed project. The proposed project is estimated to generate approximately 36,423 gallons per day of wastewater, which is less than 0.1 percent of the available capacity at SJCWRP. It is anticipated that the amount of wastewater that would be generated by the proposed project would be met, and no new entitlements or resources would be required to meet the proposed project’s expected wastewater needs.

Therefore, less-than-significant impacts would occur.
d-e) Less-Than-Significant Impact. A significant impact would occur if the proposed project would generate solid waste in excess of state or local standards, in excess of the capacity of local infrastructure, impair the attainment of solid waste reduction goals, or would not comply with federal, state, and local management and reduction statutes and regulations related to solid waste. The City of West Covina is served by Athens Services, which is a private waste hauler contracted by the City to provide solid waste collection and recycling services to residents and businesses. Solid waste collected by Athens Services is not directly disposed of at landfills serving the City but is transported to the Athens Servicesowned Materials Recovery Facility (MRF) in the City of Industry. Solid waste received at the MRF is sorted, and all recyclable materials found are removed and recycled. The City of Industry MRF can process 5,000 tons of mixed materials each day.67 The remaining solid waste that cannot be recycled is sent to the Victorville Sanitary Landfill. The Victorville 67City of West Covina, 2016 General Plan Update and Downtown Plan and Code Final Environmental Impact Report, December 2016.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-78
Sanitary Landfill has a max permitted throughput of 3,000 tons per day, a max permitted capacity of 93,400,000 cubic yards, and a remaining capacity of 79,400,000 cubic yards.68 Assuming a solid waste generation factor of 16 pounds per bed per day for hospitals,69 the proposed project would generate approximately 1,136 pounds of solid waste per day, which represent less than 0.1 percent of the permitted daily intake capacity at the Victorville Sanitary Landfill. The proposed project can be adequately served by the City’s solid waste provider.

Construction and operations of the proposed project would comply with all applicable standards and regulations related to solid waste reduction. The applicant of the proposed project would be required to comply with PRC Section 41780.01(a), which states that it is California’s policy goal to reduce, recycle, or compost at least 75 percent of solid waste generated by 2020, and annually thereafter. The applicant of the proposed project would also be required to comply with CalGreen Code Section 4.408, which requires that at least 65 percent of demolition and construction debris be diverted from landfills by recycling and/or salvage for reuse. WCMC Chapter 7, Article XVI (Reduction, Reuse and Recycling of Construction and Demolition Debris) requires applicants of projects that involves 1,000 square feet or more of construction and demolition material to divert construction and demolition debris to reduce landfill waste. The proposed project would be required to comply with WCMC Chapter 7, Article XVI since it would involve more than 1,000 square feet of construction. As the proposed project can be adequately served by the City’s solid waste provider and would comply with applicable regulations related to solid waste, less-thansignificant impacts would occur. 68CalRecycle, Victorville Sanitary Landfill (36-AA-0045), https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1870?siteID=2652, accessed September 2023. 69CalRecycle, Estimated Solid Waste Generation Rates,
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates, accessed September 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-79
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.20 WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?    
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose
project occupants to pollutant concentrations
from a wildfire or the uncontrolled spread of a
wildfire?
   
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or that
may result in temporary or ongoing impacts to
the environment?
   
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
   
a) No Impact. A significant impact would occur if the proposed project would be located in or near a state responsibility area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ) and would substantially impair an adopted emergency response plan or emergency evacuation plan. A fire hazard severity zone is a mapped area developed by CalFire that designates zones with varying degrees of fire hazard (i.e., moderate, high, and very high). Areas that are designated as Very High or High Fire Hazard Severity Zones are the most likely to experience wildfire. The project site is not located in or near a state responsibility area or in a VHFHSZ, as identified by CalFire. The nearest fire hazard zone (including VHFHSZ) is located approximately 2.6 miles southeast of the project site.70 Additionally, the proposed project would not involve activities that would expose people or structures to the risk of loss, injury, or death involving wildland fires. Therefore, the project site would not be subject to severe wildfires or wildfires of greater concern.

As discussed in Response to Checklist Question 3.9f, the project site is adjacent to the I-10 freeway, a freeway disaster route. Additionally, the project site is identified as a critical facility in the City’s NHMP. The proposed project does not involve any uses or features that would interfere with the NHMP or designated disaster routes near the project site. The proposed project would be designed to accommodate emergency access to the project site.

The driveway would be designed to meet the minimum width and turning dimension requirements of WCFD. Furthermore, the proposed building would be constructed to meet the current City’s Fire Code and building code requirements for fire safety. The applicant would be required to submit project plans to WCFD and incorporate WCFD fire protection and suppression features that are appropriate for the proposed project.

Emergency access to the project site and the surrounding uses would be maintained during construction and operations of the proposed project and would not interfere with the NHMP or any evacuation routes. As the project site is not located in a VHFHSZ and would not impair an adopted emergency response plan or emergency evacuation plan, no impact would occur. 70California Department of Forestry and Fire Protection, California Fire Hazard Severity Zone Viewer, https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414, accessed May 2023.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-80
b) No Impact. A significant impact would occur if the proposed project would be located in or near a state responsibility area or land classified as VHFHSZ and would exacerbate wildfire risks that would expose project occupants to pollutant concentrations for a wildfire or the uncontrolled spread of a wildfire. As discussed in Response to Checklist Question 3.20a, the proposed project is not located in or near a state responsibility area or in a VHFHSZ.

The project site is in an urbanized area. The southern California region, including the City of West Covina, is susceptible to strong wind gusts that typically have little to no accommodating precipitation, which are known as windstorms. The City is typically affected by the Santa Ana winds, which are generally warm, offshore dry winds that originate from the east or northeast.71 Because southern California is generally a windstorm susceptible region, much of this region encounters winds capable of spreading wildfire and wildfire pollutants. However, areas that are especially susceptible to exacerbating such fire risks are those that receive high gusts of wind and are within a fire hazard severity zone and has been a historically burn area. The project site is not within a fire hazard severity zone or a historic burn area.72 As a result, it is unlikely that the proposed project would expose project occupants to uncontrolled spread of a wildfire or pollutant concentrations from wildfire.

Therefore, no impact would occur.
c) No Impact. A significant impact would occur if the proposed project would be located in or near a state responsibility area or land classified as VHFHSZ and would require the installation or maintenance of infrastructure that may exacerbate the risk of fire or ongoing impacts to the environment. As discussed in Response to Checklist Question 3.20a, the project site is not located in or near a state responsibility area or in a VHFHSZ. The project site would be adequately served by existing facilities and utilities and would not require additional installation or maintenance of roads, fuel breaks, emergency water sources, or power lines. Thus, the proposed project would not require installation or maintenance of associated structures that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. Furthermore, the proposed project would adhere to relevant building design codes, including the City’s Fire Code. Therefore, no impact would occur.
d) No Impact. A significant impact would occur if the proposed project would be located in or near a state responsibility area or land classified as VHFHSZ and would expose people or structures to significant risks after a wildfire, such as downslope or downstream flooding or landslides. As discussed in Response to Checklist Question 3.20a, the proposed project is not located in or near a state responsibility area or in a VHFHSZ. Thus, people or structures would not be exposed to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Therefore, no impact would occur.
71City of West Covina, Natural Hazard Mitigation Plan: Section 10: Windstorm, https://www.westcovina.org/departments/fire/disaster-preparedness/natural-hazard-mitigation-plan/section-10- windstorm, accessed May 2023.
72Ibid.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-81
Potentially
Significant
Impact
Less-ThanSignificant
Impact with
Mitigation
Incorporated
Less-ThanSignificant
Impact No Impact

3.21 MANDATORY FINDINGS OF SIGNIFICANCE. Would the project:
a) Does the project have the potential to degrade
the quality of the environment, substantially
reduce the habitat of fish or wildlife species,
cause a fish or wildlife population to drop below
self-sustaining levels, threaten to eliminate a
plant or animal community, reduce the number
or restrict the range of a rare or endangered
plant or animal or eliminate important examples
of the major periods of California history or
prehistory?
   
b) Does the project have impacts which are
individually limited, but cumulatively
considerable? (Cumulatively considerable
means that the incremental effects of an
individual project are considerable when viewed
in connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects).
   
c) Does the project have environmental effects
which cause substantial adverse effects on
human beings, either directly or indirectly?
   
a) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project would have the potential to degrade the quality of the environment; substantially reduce, threaten, or eliminate fish, plant, or wildlife habitats or population, including rare or endangered species; or eliminate historical, archaeological, or paleontological resources. The preceding analyses conclude that no significant unmitigated impacts to the environment would occur. The proposed project is located within a highly urbanized area, and the project site is currently developed with medical offices and a medical hospital. As discussed in Response to Checklist Question 3.1c, the proposed project would remove 38 trees, of which 25 trees are classified as significant trees. The proposed project would be required to comply with the City’s Preservation, Protection and Removal of Trees Ordinance, which require any significant trees that would be removed to be replaced with trees of comparable species, size, and conditions as the existing trees. If it is not possible to relocate the existing trees or provide replacement trees on or off the project site, the applicant would be required to provide payment of the proper restitution value of the trees, or donation of boxed trees to the City to be used elsewhere in the City. As it is not possible for the applicant to relocate or replace the existing 25 trees that would be removed by the proposed project, the applicant would be required to plant replacement trees off site, provide payment for the restitution value of the trees, or to donate box trees to the City.

Construction of the proposed project has the potential to affect the health or structural integrity, encroach the dripline, encroach the optimal tree protection zone, and/or encroach the structural rooting radius of 15 trees that would remain on the project site. After construction, 4 of these trees may be at increased risk of failure during atypical weather events that produce high winds and oversaturated soils. Mitigation Measure A-1 would be implemented to ensure that the trees to remain on the project site would not be adversely affected by the proposed project.

Additionally, the applicant would be required to comply with the City’s landscape requirements. Compliance with Mitigation Measure A-1; the City’s Preservation, Protection and Removal of Trees Ordinance; the City’s landscaping requirements; and other applicable West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-82
regulations that governs scenic quality, the proposed project would not degrade the visual character or quality of the project site and its surrounding area.

As discussed in Section 3.4, Biological Resources, of this IS/MND, the project site does not contain suitable habitat for special-status wildlife species (including rare, threatened, and endangered species) and no special-status species were identified or have a high likelihood of occurring on the project site. Additionally, the project site does not contain any riparian habitat or features necessary to support riparian habitat. The proposed project would not 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, or reduce the number or restrict the range of a rare or endangered plant or animal. Although the proposed project would remove trees on the project site, which may provide nesting habitat for birds, Mitigation Measure BR-1 would be implemented to ensure that nesting birds would not be adversely affected by the proposed tree removal.

As discussed in Response to Checklist Question 3.5a, no historic resources are located on the project site. Similarly, no archaeological, paleontological, and tribal cultural resources are known to exist on the project site (Response to Checklist Questions 3.5b and 3.18a-b).

However, it is possible that unanticipated archaeological, paleontological, or tribal cultural resources may be encountered during ground disturbance activities, and Mitigation Measures CR-1, GS-1, and TR-1 through TR-3 would reduce the potential for the destruction of any significant archaeological, paleontological, and tribal cultural resources.

As discussed in Response to Checklist Questions 3.17a and c, Mitigation Measures T-1 Mitigation Measure T-2 would improve safety along Orange Avenue, at the Orange Avenue/Cameron Avenue intersection and would support Policies 4.2, 4.3, 4.5 of the City’s General Plan Circulation Element.

With implementation of Mitigation Measures A-1, BR-1, CR-1, GS-1, T-1, T-2, and TR-1 through TR-3, the proposed project would not degrade the quality of the environment, substantially reduce the habitat of wildlife species, cause wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of major periods of California history or prehistory. Therefore, impacts would be less than significant with implementation of mitigation measures. b) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project, in conjunction with related projects, would result in impacts that are less than significant when viewed separately but significant when viewed together.

Table 3-19 provides a list of related projects that are near the project site.

TABLE 3-19: CUMULATIVE PROJECTS
Location Description Status
Distance from
Project Site (miles)
1600 W. Cameron Ave. 84-unit townhomes Under Construction 0.1 1024 W. Workman
Ave.
119-unit townhomes Under Construction 0.9
1115 S. Sunset Ave. Queen of the Valley Expansion –
108,361-square-foot medical
office building
Under Construction 0.3
1920 Pacific Lane 7-unit townhomes Proposed 0.2
SOURCE: City of West Covina, 2023; Linscott, Law & Greenspan, 2024.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-83
The environmental topic areas that were found to have no impact are not expected to cause the proposed project to make any contributions to potential cumulative impacts because a no impact conclusion means that the proposed project would have no contribution to that particular environmental topic area. Similarly, the environmental topic areas that were found to have a less-than-significant impact are not expected to cause the proposed project to significantly contribute to cumulative impacts since the proposed project’s contribution to that particular environmental topic area is not large enough to contribute to significant cumulative impacts.

As discussed in this Initial Study, the proposed project would have either no impact or lessthan-significant impacts to Agriculture and Forestry Resources, Air Quality, Energy, GHG Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, Transportation, Utilities and Service Systems, and Wildfire. Impacts in these issue areas are generally limited to the proposed project, and the proposed project would not contribute to a significant cumulative impact.

Potential impacts to Aesthetics; Migratory Wildlife; and Archaeological, Paleontological, and Tribal Cultural Resources; Noise (construction); and Transportation would be reduced to less than significant levels with implementation of mitigation measures. The following analysis evaluates whether the proposed project would contribute to significant cumulative impacts in these environmental topic areas.

As with the proposed project, related projects would be required to comply with the City’s zoning and other regulations that govern scenic quality and would not degrade the visual character and quality of the surrounding area. The proposed project and other related projects would be required to comply with the City’s Preservation, Protection and Removal of Trees Ordinance. As with the proposed project, related projects that would involve tree removal would also be required to conduct a tree survey. As discussed in Response to Checklist Question 3.1c, construction of the proposed project has the potential to negatively affect the health and structural integrity, encroach into the dripline and/or the optimal tree protection zone, and/or affect the structural rooting radius of trees that would remain on the project site. The proposed project would implement Mitigation Measure A-1 to ensure that the proposed project would not adversely affect trees that would remain on the project site.

With implementation of Mitigation Measure A-1, the proposed project’s effect on visual character and quality would be reduced to a level that would not be cumulatively considerable.

While development of related projects, when combined with the proposed project, have the potential to uncover or disturb known or previously unknown archaeological, paleontological, and tribal cultural resources, Mitigation Measures CR-1, and TR-1 through TR-3 would reduce proposed project impacts on archaeological and tribal cultural resources to less than significant levels. Mitigation Measure GS-1 would reduce proposed project impacts on paleontological resources to less than significant levels. Therefore, the proposed project’s effect on archaeological, paleontological, and tribal cultural resources would be reduced to a level that would not be cumulatively considerable.

The proposed project would be located on the same property as the existing West Covina Medical Center, which includes medical facilities that are sensitive to increased noise levels.

These facilities, which are owned and operated by the applicant, may experience short-term disruptive noise events during construction of the proposed project. Mitigation Measure N1 would reduce construction noise levels at noise sensitive uses. Construction noise impacts are localized to a project site and sensitive receptors within the immediate vicinity of the project site. The nearest related project is approximately 510 feet south of the project site.

West Covina Medical Center Behavioral Health Building Addition 3.0 Initial Study Checklist & Evaluation Initial Study/Mitigated Negative Declaration
taha 2022-079 3-84
If construction of the proposed project were to occur at the same time as related projects, it is not likely that noise generated from construction of the proposed project and the related projects would result in the exposure of sensitive receptors to excessive construction noise due to the localized nature of noise impacts. Therefore, with implementation of Mitigation Measure N-1, the proposed project’s effect on construction noise would be reduced to a level that would not be cumulatively considerable.

The proposed project would increase the use of the off-site parking lot that is part of the West Covina Medical Center. As a result, more pedestrians would use the existing crosswalk at the Orange Avenue/Cameron Avenue intersection to access the project site. Mitigation Measure T-1 would be implemented to provide greater visibility and safety to pedestrians and motorists. Additionally, the project site driveway does not have an adequate line of sight.

Implementation of Mitigation Measure T-2 would improve the line of sight between the project site and oncoming traffic. The nearest related project is located approximately 510 feet south of the project site on Cameron Avenue. The additional vehicles from this and other nearby related project, in combination with the proposed project, is not expected to result in cumulatively considerable impacts related to transportation plans and transportation hazards with implementation of Mitigation Measures T-1 and T-2.

None of the environmental topic areas that would result in less-than-significant impacts with implementation of mitigation measures would cause the proposed project to contribute to significant cumulative impacts. Therefore, the proposed project would not have impacts that are individually limited but cumulatively considerable. Impacts would be less than significant. c) Less-Than-Significant Impact with Mitigation Incorporated. A significant impact may occur if the proposed project has the potential to cause substantial adverse effects on human beings, either directly or indirectly. As discussed throughout this IS/MND, the proposed project would have less-than-significant impacts (with and without incorporation of mitigation measures) or no impacts on the environment. The proposed project would have a less-than-significant impact with implementation of mitigation measures for the following environmental topic areas: Aesthetics; Migratory Wildlife; and Archaeological, Paleontological, and Tribal Cultural Resources; and Noise (construction). The proposed project would have less-than-significant impacts or no impacts for all other environmental topic areas. All potential impacts of the proposed project have been identified and mitigation measures have been prescribed, where applicable, to reduce all potential impacts to less than significant levels. Upon implementation of mitigation measures included in this IS/MND and compliance with existing regulations, the proposed project would not have the potential to result in substantial adverse impacts on human beings either directly or indirectly.

Therefore, a less-than-significant impact is anticipated with incorporation of the mitigation measures identified in this IS/MND.

West Covina Medical Center Behavioral Health Building Addition 4.0 List of Preparers & Sources Consulted Initial Study/Mitigated Negative Declaration
taha 2022-079 4-1

4.0 LIST OF PREPARERS AND SOURCES CONSULTED
This section identifies the lead agency and the consultant team members who participated in the preparation of this IS/MND. This section also documents all the sources and references used in the preparation of this IS/MND.

4.1 LEAD AGENCY
City of West Covina
Community Development Department
Planning Division
1444 West Garvey Avenue South
West Covina, CA 91790
Contact: Jo-Anne Burns, Deputy Community Development Director (626) 939-8422

4.2 INITIAL STUDY PREPARERS
Terry A. Hayes Associates Inc.
3535 Hayden Avenue, Suite 350
Culver City, CA 90232
Contact: Teresa Li, AICP, Senior Planner
Kevin Ferrier, Senior Planner
Sam Silverman, Senior Associate
Anders Sutherland, Air Quality/Greenhouse Gas
Kieran Bartholow, Noise
Henry Hapov, GIS Specialist
Natasha Mapp, Document Production

4.3 SOURCES CONSULTED
Albus & Associates, Inc., Geotechnical Investigation, Proposed Behavioral Health Building Addition, West Covina Medical Center, 725 South Orange Avenue, West Covina, Los Angeles County, California, April 6, 2023.

California Air Resources Board, Global Warming Potentials, https://www.arb.ca.gov/cc/inventory/background/gwp.htm, accessed October 16, 2023.

California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/DLRP/CIFF/, accessed March 2023.

California Department of Conservation, Earthquake Zone of Required Investigation, https://maps.conservation.ca.gov/cgs/EQZApp/app/, accessed March 2023.

California Department of Conservation, Well Finder.
https://maps.conservation.ca.gov/doggr/wellfinder/#openModal/-117.93414/34.05815/13, accessed March 2023.

California Department of Fish and Game Code Sections 86 and 3513.

West Covina Medical Center Behavioral Health Building Addition 4.0 List of Preparers & Sources Consulted Initial Study/Mitigated Negative Declaration
taha 2022-079 4-2
California Department of Fish and Wildlife, California Natural Diversity Database, https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data#43018408-cnddb-in-bios, accessed April 2023.

California Department of Forestry and Fire Protection, California Fire Hazard Severity Zone https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414, accessed May 2023.

California Department of Transportation, California State Scenic Highway System Map, https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e 8057116f1aacaa, accessed March 2023.

California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Figure 4-1 A-Weighted Baseline FHWA (Federal Highway Administration) TNM (Traffic Noise Model) REMEL (Reference Energy Mean Emission Level) Curves, September 2013.

California Department of Water Resources, SGMA Basin Prioritization Dashboard, https://gis.water.ca.gov/app/bp-dashboard/final/, accessed May 2023.

California Department of Water Resources, Division of Safety of Dams, California Dam Breach Inundation Maps, https://fmds.water.ca.gov/webgis/?appid=dam_prototype_v2, accessed May 2023.

CalRecycle, Estimated Solid Waste Generation Rates,
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates, accessed September 2023.

CalRecycle, Victorville Sanitary Landfill (36-AA-0045), https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1870?siteID=2652, accessed September 2023.

Center for Biological Diversity v. California Department of Fish and Wildlife, 62 Cal. 4th 204, November 30, 2015.

City of West Covina, City of West Covina Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment, September 2020.

City of West Covina, Energy Action Plan, 2011.

City of West Covina, Fire Department, https://www.westcovina.org/departments/fire, accessed August 2023.

City of West Covina, Historic Context Statement, 1945-1978 & Historic Resource Inventory Update, December 2019, available at
https://www.westcovina.org/departments/community-development/planningdivision/historic-preservation, accessed March 2023.

City of West Covina, Natural Hazard Mitigation Plan,
https://www.westcovina.org/departments/fire-/disaster-preparedness/natural-hazaardmitigation-plan/section-3-risk-assessment/#Map%20#3, accessed May 2023.

City of West Covina, West Covina Downtown Plan & Code, adopted December 2016, available at https://www.westcovina.org/departments/community-development/planningdivision/zoning/downtown-plan.

City of West Covina, West Covina General Plan, adopted December 2016, available at https://www.westcovina.org/home/showpublisheddocument/17689/637109880132000000 West Covina Medical Center Behavioral Health Building Addition 4.0 List of Preparers & Sources Consulted Initial Study/Mitigated Negative Declaration
taha 2022-079 4-3
City of West Covina, West Covina Municipal Code, available at https://library.municode.com/ca/west_covina/codes/code_of_ordinances.

City of West Covina, 2016 General Plan Update and Downtown Plan and Code Final Environmental Impact Report, December 2016.

County of Los Angeles Department of Public Works, Disaster Routes, http://dpw.lacounty.gov/dsg/disasterroutes/map/West%20Covina.pdf, accessed May 2023.

Cowan, James P., Handbook of Environmental Acoustics, 1994.

Department of Toxic Substances Control, EnviroStor, https://www.envirostor.dtsc.ca.gov/public/, accessed May 2023.

Department of Toxic Substances Control, GeoTracker,
https://geotracker.waterboards.ca.gov/profile_report?global_id=T0603726822&mytab=esidat a&subcmd=edfsummarytable#esidata, accessed May 2023.

Edgewood High School, Edgewood High School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year),
https://drive.google.com/file/d/1Eh6FyjFcBsbAWih4ohZ6_2SGKaGMfQzZ/view, accessed August 2023.

Federal Emergency Management Agency, FEMA Flood Map Service Center, https://msc.fema.gov/portal/search?AddressQuery=725%20s%20orange%20ave%2C%20 west%20covina#searchresultsanchor, accessed May 2023.

Federal Endangered Species Act Section 3(19).

Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.

Healthcare Design, “Hospitals Can Tap into Savings through Water Conservation,” https://healthcaredesignmagazine.com/architecture/saving-water-savingmoney/#:~:text=U.S.%20hospitals%20are%20water%20hogs,per%20staffed%20bed%2C %20per%20day., accessed August 2023).

Linscott, Law, & Greenspan Engineers, Transportation Impact Study : West Covina Medical Center – Behavioral Health Addition Project, September 17, 2024.

Los Angeles County Sanitation Districts, San Gabriel River Watershed Project to Reduce River Discharge in Support of Increased Recycled Water Reuse, https://files.ceqanet.opr.ca.gov/89269-
2/attachment/HNWjbgzSSydtx6C6GMyB0t8xWaW3cPilsA6z7m1lX7AXtQ13GbQ722U2K9 pockBuyShwuBHlrqzc_r390, accessed August 2023.

Migratory Bird Treaty Act, 16 United States Code Chapter 7, Subchapter II, Section 703.

Monte Vista Elementary School, Monte Vista Elementary School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year), https://drive.google.com/file/d/1OzIpS_shfj3hmvWHTudF2kZNJY-XTj-m/view, accessed August 2023.

Rincon Consultants, Inc., West Covina Medical Center at 725 and 741 Orange Ave: Arborist Report and Tree Protection Plan, July 2023.

South Coast Air Quality Management District, Air Quality Analysis Guidance Handbook, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook, accessed January 2024.

West Covina Medical Center Behavioral Health Building Addition 4.0 List of Preparers & Sources Consulted Initial Study/Mitigated Negative Declaration
taha 2022-079 4-4
South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.

South Coast Air Quality Management District, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October 2008.

South Coast Air Quality Management District, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, 2008.

South Coast Air Quality Management District, Final Localized Significance Threshold Methodology Appendix C Mass Rate Lookup Tables, October 21, 2009.

South Coast Air Quality Management District, Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15, September 28, 2010, www.aqmd.gov/docs/defaultsource/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008- 2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, accessed October 2023.

South Coast Air Quality Management District, SCAQMD Air Quality Significance Thresholds – Mass Daily Thresholds, April 2019.

Suburban Water Systems, Final 2020 Urban Water Management Plan, June 2021, available at https://wuedata.water.ca.gov/public/uwmp_attachments/3673902213/Suburban%20Final %202020%20UWMP_2021-06-30.pdf.

Walnut Grove Intermediate School, Walnut Grove Intermediate School: 2021-2022 School Accountability Report Card (Published During the 2022-2023 School Year), https://drive.google.com/file/d/1BKS0LVdz4yivta56JITKJ0zkHsBTPLLg/view, accessed August 2023.

Appendix A
Air Quality and Greenhouse Gas Emissions
Calculations
West Covina Medical Center Detailed Report, 3/4/2024
1 / 98
West Covina Medical Center Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

2.6. Operations Emissions by Sector, Mitigated

3. Construction Emissions Details

3.1. Site Preparation (2025) - Unmitigated

3.2. Site Preparation (2025) - Mitigated
West Covina Medical Center Detailed Report, 3/4/2024
2 / 98

3.3. Grading (2025) - Unmitigated

3.4. Grading (2025) - Mitigated

3.5. Building Construction (2025) - Unmitigated

3.6. Building Construction (2025) - Mitigated

3.7. Building Construction (2026) - Unmitigated

3.8. Building Construction (2026) - Mitigated

3.9. Paving (2026) - Unmitigated

3.10. Paving (2026) - Mitigated

3.11. Paving (2027) - Unmitigated

3.12. Paving (2027) - Mitigated

3.13. Architectural Coating (2026) - Unmitigated

3.14. Architectural Coating (2026) - Mitigated

3.15. Architectural Coating (2027) - Unmitigated

3.16. Architectural Coating (2027) - Mitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
West Covina Medical Center Detailed Report, 3/4/2024
3 / 98

4.1.2. Mitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.2. Electricity Emissions By Land Use - Mitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.2.4. Natural Gas Emissions By Land Use - Mitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.3.2. Mitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.4.2. Mitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.5.2. Mitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
West Covina Medical Center Detailed Report, 3/4/2024
4 / 98

4.6.2. Mitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.7.2. Mitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.8.2. Mitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.9.2. Mitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated West Covina Medical Center Detailed Report, 3/4/2024
5 / 98

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources
West Covina Medical Center Detailed Report, 3/4/2024
6 / 98

5.9.1. Unmitigated

5.9.2. Mitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.1.2. Mitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.10.4. Landscape Equipment - Mitigated

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.11.2. Mitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.12.2. Mitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated
West Covina Medical Center Detailed Report, 3/4/2024
7 / 98

5.13.2. Mitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.14.2. Mitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.15.2. Mitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
West Covina Medical Center Detailed Report, 3/4/2024
8 / 98

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

6.4.1. Temperature and Extreme Heat

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures
West Covina Medical Center Detailed Report, 3/4/2024
9 / 98

8. User Changes to Default Data
West Covina Medical Center Detailed Report, 3/4/2024
10 / 98

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name West Covina Medical Center
Construction Start Date 1/6/2025
Operational Year 2027
Lead Agency City of West Covina
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 1.80
Precipitation (days) 22.4
Location 34.07149996134895, -117.94444172083607
County Los Angeles-South Coast
City West Covina
Air District South Coast AQMD
Air Basin South Coast
TAZ 4958
EDFZ 7
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.21

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
West Covina Medical Center Detailed Report, 3/4/2024
11 / 98
Medical Office
Building

42.0 1000sqft 0.39 42,000 4,167 — — —
Other Asphalt
Surfaces

22.0 1000sqft 0.51 22,041 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Construction C-9 Use Dust Suppressants
Energy E-7* Require Higher Efficacy Public Street and Area Lighting * Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.69 1.47 6.05 23.3 0.01 0.18 3.23 3.40 0.16 0.76 0.92 — 4,909 4,909 0.21 0.17 13.1 4,978 Mit. 1.69 1.47 6.05 23.3 0.01 0.18 3.23 3.40 0.16 0.76 0.92 — 4,909 4,909 0.21 0.17 13.1 4,978 %
Reduced
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.68 26.7 8.66 20.8 0.01 0.36 3.23 3.40 0.33 1.06 1.40 — 4,737 4,737 0.21 0.18 0.34 4,795 Mit. 1.68 26.7 8.66 20.8 0.01 0.36 3.23 3.40 0.33 1.02 1.35 — 4,737 4,737 0.21 0.18 0.34 4,795 West Covina Medical Center Detailed Report, 3/4/2024
12 / 98
%
Reduced
— — — — — — — — — 4% 3% — — — — — — —
Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.02 1.73 4.06 13.0 0.01 0.11 2.01 2.12 0.10 0.47 0.57 — 2,914 2,914 0.13 0.11 3.35 2,953 Mit. 1.02 1.73 4.06 13.0 0.01 0.11 1.95 2.07 0.10 0.46 0.57 — 2,914 2,914 0.13 0.11 3.35 2,953 %
Reduced
— — — — — — 3% 3% — 1% 1% — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.19 0.32 0.74 2.37 < 0.005 0.02 0.37 0.39 0.02 0.09 0.10 — 483 483 0.02 0.02 0.56 489 Mit. 0.19 0.32 0.74 2.37 < 0.005 0.02 0.36 0.38 0.02 0.08 0.10 — 483 483 0.02 0.02 0.56 489 %
Reduced
— — — — — — 3% 3% — 1% 1% — — — — — — —
Exceeds
(Daily
Max)
— — — — — — — — — — — — — — — — — —
Threshol
d
— 75.0 100 550 150 — — 150 — — 55.0 — — — — — — —
Unmit. — No No No No — — No — — No — — — — — — —
Mit. — No No No No — — No — — No — — — — — — —
Exceeds
(Average
Daily)
— — — — — — — — — — — — — — — — — —
Threshol
d
— 75.0 100 550 150 — — 150 — — 55.0 — — — — — — —
Unmit. — No No No No — — No — — No — — — — — — —
Mit. — No No No No — — No — — No — — — — — — —

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) West Covina Medical Center Detailed Report, 3/4/2024
13 / 98
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.69 1.47 6.05 23.3 0.01 0.18 3.23 3.40 0.16 0.76 0.92 — 4,909 4,909 0.21 0.17 13.1 4,978 2026 1.52 1.31 5.67 22.1 0.01 0.16 3.23 3.38 0.14 0.76 0.90 — 4,837 4,837 0.20 0.17 11.9 4,905 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.68 1.46 8.66 20.8 0.01 0.36 3.23 3.40 0.33 1.06 1.40 — 4,737 4,737 0.21 0.18 0.34 4,795 2026 1.52 26.7 5.80 19.8 0.01 0.16 3.23 3.38 0.14 0.76 0.90 — 4,668 4,668 0.20 0.17 0.31 4,724 2027 0.37 26.7 2.79 4.31 0.01 0.06 0.69 0.76 0.06 0.09 0.14 — 706 706 0.03 0.01 0.01 710 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 1.02 0.89 4.06 13.0 0.01 0.11 2.01 2.12 0.10 0.47 0.57 — 2,914 2,914 0.13 0.11 3.35 2,953 2026 0.93 1.73 3.70 12.4 0.01 0.10 1.96 2.06 0.09 0.45 0.54 — 2,850 2,850 0.12 0.10 3.06 2,887 2027 < 0.005 0.05 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.38 1.38 < 0.005 < 0.005 < 0.005 1.39 Annual — — — — — — — — — — — — — — — — — —
2025 0.19 0.16 0.74 2.37 < 0.005 0.02 0.37 0.39 0.02 0.09 0.10 — 483 483 0.02 0.02 0.56 489 2026 0.17 0.32 0.68 2.27 < 0.005 0.02 0.36 0.38 0.02 0.08 0.10 — 472 472 0.02 0.02 0.51 478 2027 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 < 0.005 0.23

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.69 1.47 6.05 23.3 0.01 0.18 3.23 3.40 0.16 0.76 0.92 — 4,909 4,909 0.21 0.17 13.1 4,978 2026 1.52 1.31 5.67 22.1 0.01 0.16 3.23 3.38 0.14 0.76 0.90 — 4,837 4,837 0.20 0.17 11.9 4,905 West Covina Medical Center Detailed Report, 3/4/2024
14 / 98
Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.68 1.46 8.66 20.8 0.01 0.36 3.23 3.40 0.33 1.02 1.35 — 4,737 4,737 0.21 0.18 0.34 4,795 2026 1.52 26.7 5.80 19.8 0.01 0.16 3.23 3.38 0.14 0.76 0.90 — 4,668 4,668 0.20 0.17 0.31 4,724 2027 0.37 26.7 2.79 4.31 0.01 0.06 0.22 0.28 0.06 0.04 0.10 — 706 706 0.03 0.01 0.01 710 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 1.02 0.89 4.06 13.0 0.01 0.11 1.95 2.07 0.10 0.46 0.57 — 2,914 2,914 0.13 0.11 3.35 2,953 2026 0.93 1.73 3.70 12.4 0.01 0.10 1.91 2.00 0.09 0.45 0.54 — 2,850 2,850 0.12 0.10 3.06 2,887 2027 < 0.005 0.05 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.38 1.38 < 0.005 < 0.005 < 0.005 1.39 Annual — — — — — — — — — — — — — — — — — —
2025 0.19 0.16 0.74 2.37 < 0.005 0.02 0.36 0.38 0.02 0.08 0.10 — 483 483 0.02 0.02 0.56 489 2026 0.17 0.32 0.68 2.27 < 0.005 0.02 0.35 0.37 0.02 0.08 0.10 — 472 472 0.02 0.02 0.51 478 2027 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 < 0.005 0.23

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.17 2.96 1.49 17.0 0.04 0.05 3.29 3.34 0.05 0.83 0.88 255 4,680 4,935 25.7 0.17 12.0 5,640 Mit. 2.17 2.96 1.49 17.0 0.04 0.05 3.29 3.34 0.05 0.83 0.88 255 4,680 4,935 25.7 0.17 12.0 5,640 %
Reduced
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.66 2.49 1.58 13.0 0.04 0.05 3.29 3.33 0.04 0.83 0.88 255 4,520 4,774 25.7 0.17 1.36 5,471 West Covina Medical Center Detailed Report, 3/4/2024
15 / 98
Mit. 1.66 2.49 1.58 13.0 0.04 0.05 3.29 3.33 0.04 0.83 0.88 255 4,520 4,774 25.7 0.17 1.36 5,471 % Reduced
——————————————————
Average
Daily
(Max)
——————————————————
Unmit. 1.99 2.79 1.61 15.2 0.04 0.05 3.24 3.29 0.04 0.82 0.87 255 4,568 4,822 25.7 0.18 5.80 5,524 Mit. 1.99 2.79 1.61 15.2 0.04 0.05 3.24 3.29 0.04 0.82 0.87 255 4,568 4,822 25.7 0.18 5.80 5,524 % Reduced
——————————————————
Annual
(Max)
——————————————————
Unmit. 0.36 0.51 0.29 2.78 0.01 0.01 0.59 0.60 0.01 0.15 0.16 42.1 756 798 4.26 0.03 0.96 915 Mit. 0.36 0.51 0.29 2.78 0.01 0.01 0.59 0.60 0.01 0.15 0.16 42.1 756 798 4.26 0.03 0.96 915 % Reduced
——————————————————
Exceeds
(Daily
Max)
——————————————————
Threshol d— 55.0 55.0 550 150—— 150—— 55.0———————
Unmit.— No No No No—— No—— No———————
Mit.— No No No No—— No—— No———————
Exceeds
(Average
Daily)
——————————————————
Threshol d— 55.0 55.0 550 150—— 150—— 55.0———————
Unmit.— No No No No—— No—— No———————
Mit.— No No No No—— No—— No———————
West Covina Medical Center Detailed Report, 3/4/2024
16 / 98

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.64 1.48 1.17 13.9 0.03 0.02 3.28 3.31 0.02 0.83 0.85 — 3,566 3,566 0.16 0.13 11.0 3,621 Area 0.50 1.47 0.02 2.79 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.5 11.5 < 0.005 < 0.005 — 11.5 Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 2.17 2.96 1.49 17.0 0.04 0.05 3.29 3.34 0.05 0.83 0.88 255 4,680 4,935 25.7 0.17 12.0 5,640 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.63 1.46 1.28 12.7 0.03 0.02 3.28 3.31 0.02 0.83 0.85 — 3,417 3,417 0.16 0.14 0.28 3,463 Area — 1.01 — — — — — — — — — — — — — — — —
Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 1.66 2.49 1.58 13.0 0.04 0.05 3.29 3.33 0.04 0.83 0.88 255 4,520 4,774 25.7 0.17 1.36 5,471 Average
Daily
— — — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
17 / 98
Mobile 1.62 1.45 1.30 13.1 0.03 0.02 3.24 3.26 0.02 0.82 0.84 — 3,457 3,457 0.16 0.14 4.73 3,508 Area 0.34 1.32 0.02 1.91 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.84 7.84 < 0.005 < 0.005 — 7.87 Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 1.99 2.79 1.61 15.2 0.04 0.05 3.24 3.29 0.04 0.82 0.87 255 4,568 4,822 25.7 0.18 5.80 5,524 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.30 0.26 0.24 2.39 0.01 < 0.005 0.59 0.59 < 0.005 0.15 0.15 — 572 572 0.03 0.02 0.78 581 Area 0.06 0.24 < 0.005 0.35 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.30 1.30 < 0.005 < 0.005 — 1.30 Energy 0.01 < 0.005 0.05 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 174 174 0.02 < 0.005 — 175 Water — — — — — — — — — — — 1.67 5.68 7.35 0.17 < 0.005 — 12.9 Waste — — — — — — — — — — — 40.5 0.00 40.5 4.05 0.00 — 142 Refrig. — — — — — — — — — — — — — — — — 0.18 0.18
Vegetatio
n
— < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.92 2.92 — — — 2.92 Total 0.36 0.51 0.29 2.78 0.01 0.01 0.59 0.60 0.01 0.15 0.16 42.1 756 798 4.26 0.03 0.96 915

2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.64 1.48 1.17 13.9 0.03 0.02 3.28 3.31 0.02 0.83 0.85 — 3,566 3,566 0.16 0.13 11.0 3,621 Area 0.50 1.47 0.02 2.79 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.5 11.5 < 0.005 < 0.005 — 11.5 Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 West Covina Medical Center Detailed Report, 3/4/2024
18 / 98
Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 2.17 2.96 1.49 17.0 0.04 0.05 3.29 3.34 0.05 0.83 0.88 255 4,680 4,935 25.7 0.17 12.0 5,640 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.63 1.46 1.28 12.7 0.03 0.02 3.28 3.31 0.02 0.83 0.85 — 3,417 3,417 0.16 0.14 0.28 3,463 Area — 1.01 — — — — — — — — — — — — — — — —
Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 1.66 2.49 1.58 13.0 0.04 0.05 3.29 3.33 0.04 0.83 0.88 255 4,520 4,774 25.7 0.17 1.36 5,471 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 1.62 1.45 1.30 13.1 0.03 0.02 3.24 3.26 0.02 0.82 0.84 — 3,457 3,457 0.16 0.14 4.73 3,508 Area 0.34 1.32 0.02 1.91 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.84 7.84 < 0.005 < 0.005 — 7.87 Energy 0.03 0.02 0.29 0.24 < 0.005 0.02 — 0.02 0.02 — 0.02 — 1,051 1,051 0.10 0.01 — 1,056 Water — — — — — — — — — — — 10.1 34.3 44.4 1.04 0.03 — 77.8 Waste — — — — — — — — — — — 244 0.00 244 24.4 0.00 — 855 Refrig. — — — — — — — — — — — — — — — — 1.07 1.07
Vegetatio
n
— < 0.005 0.01 — < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 17.6 17.6 — — — 17.6 Total 1.99 2.79 1.61 15.2 0.04 0.05 3.24 3.29 0.04 0.82 0.87 255 4,568 4,822 25.7 0.18 5.80 5,524 Annual — — — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
19 / 98
Mobile 0.30 0.26 0.24 2.39 0.01 < 0.005 0.59 0.59 < 0.005 0.15 0.15 — 572 572 0.03 0.02 0.78 581 Area 0.06 0.24 < 0.005 0.35 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.30 1.30 < 0.005 < 0.005 — 1.30 Energy 0.01 < 0.005 0.05 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 174 174 0.02 < 0.005 — 175 Water — — — — — — — — — — — 1.67 5.68 7.35 0.17 < 0.005 — 12.9 Waste — — — — — — — — — — — 40.5 0.00 40.5 4.05 0.00 — 142 Refrig. — — — — — — — — — — — — — — — — 0.18 0.18
Vegetatio
n
— < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.92 2.92 — — — 2.92 Total 0.36 0.51 0.29 2.78 0.01 0.01 0.59 0.60 0.01 0.15 0.16 42.1 756 798 4.26 0.03 0.96 915

3. Construction Emissions Details

3.1. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.24 0.20 1.93 2.92 < 0.005 0.07 — 0.07 0.06 — 0.06 — 432 432 0.02 < 0.005 — 434 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.41 0.41 — 0.06 0.06 — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
20 / 98
Onsite < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.57 0.57 < 0.005 0.06 0.06 — 8.48 8.48 < 0.005 < 0.005 < 0.005 8.91 truck
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.02 0.21 0.32 < 0.005 0.01 — 0.01 0.01 — 0.01 — 47.4 47.4 < 0.005 < 0.005 — 47.5 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.05 0.05 — 0.01 0.01 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 0.93 0.93 < 0.005 < 0.005 < 0.005 0.98 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.84 7.84 < 0.005 < 0.005 — 7.87 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.15 0.15 < 0.005 < 0.005 < 0.005 0.16 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.29 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 65.5 65.5 < 0.005 < 0.005 0.01 66.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 West Covina Medical Center Detailed Report, 3/4/2024
21 / 98
Hauling 0.04 0.01 0.67 0.25 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 — 527 527 0.03 0.08 0.03 552 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.29 7.29 < 0.005 < 0.005 0.01 7.39 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 57.7 57.7 < 0.005 0.01 0.06 60.5 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.21 1.21 < 0.005 < 0.005 < 0.005 1.22 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.55 9.55 < 0.005 < 0.005 0.01 10.0

3.2. Site Preparation (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.24 0.20 1.93 2.92 < 0.005 0.07 — 0.07 0.06 — 0.06 — 432 432 0.02 < 0.005 — 434 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.41 0.41 — 0.06 0.06 — — — — — — —
Onsite
truck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.09 0.09 < 0.005 0.01 0.01 — 8.48 8.48 < 0.005 < 0.005 < 0.005 8.91 West Covina Medical Center Detailed Report, 3/4/2024
22 / 98
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.02 0.21 0.32 < 0.005 0.01 — 0.01 0.01 — 0.01 — 47.4 47.4 < 0.005 < 0.005 — 47.5 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.05 0.05 — 0.01 0.01 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.93 0.93 < 0.005 < 0.005 < 0.005 0.98 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.84 7.84 < 0.005 < 0.005 — 7.87 Dust
From
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Demolitio
n
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.15 0.15 < 0.005 < 0.005 < 0.005 0.16 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.29 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 65.5 65.5 < 0.005 < 0.005 0.01 66.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.04 0.01 0.67 0.25 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 — 527 527 0.03 0.08 0.03 552 West Covina Medical Center Detailed Report, 3/4/2024
23 / 98
Average — — — — — — — — — — — — — — — — — —
Daily
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.29 7.29 < 0.005 < 0.005 0.01 7.39 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 57.7 57.7 < 0.005 0.01 0.06 60.5 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.21 1.21 < 0.005 < 0.005 < 0.005 1.22 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.55 9.55 < 0.005 < 0.005 0.01 10.0

3.3. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.08 0.91 8.60 8.32 0.01 0.36 — 0.36 0.33 — 0.33 — 1,429 1,429 0.06 0.01 — 1,434 Dust
From
Material
Movement
— — — — — — 1.92 1.92 — 0.98 0.98 — — — — — — —
Onsite
truck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.57 0.57 < 0.005 0.06 0.06 — 8.48 8.48 < 0.005 < 0.005 < 0.005 8.91 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.12 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 19.6 19.6 < 0.005 < 0.005 — 19.6 West Covina Medical Center Detailed Report, 3/4/2024
24 / 98
Dust
From
Material
Movement
— — — — — — 0.03 0.03 — 0.01 0.01 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.12 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.24 3.24 < 0.005 < 0.005 — 3.25 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.02 0.02 < 0.005 < 0.005 < 0.005 0.02 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.04 0.44 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 98.3 98.3 < 0.005 < 0.005 0.01 99.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.37 1.37 < 0.005 < 0.005 < 0.005 1.38 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 < 0.005 0.23 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 West Covina Medical Center Detailed Report, 3/4/2024
25 / 98
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.4. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.08 0.91 8.60 8.32 0.01 0.36 — 0.36 0.33 — 0.33 — 1,429 1,429 0.06 0.01 — 1,434 Dust
From
Material
Movement
— — — — — — 1.92 1.92 — 0.98 0.98 — — — — — — —
Onsite
truck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.09 0.09 < 0.005 0.01 0.01 — 8.48 8.48 < 0.005 < 0.005 < 0.005 8.91 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.12 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 19.6 19.6 < 0.005 < 0.005 — 19.6 Dust
From
Material
Movement
— — — — — — 0.03 0.03 — 0.01 0.01 — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.12 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.24 3.24 < 0.005 < 0.005 — 3.25 West Covina Medical Center Detailed Report, 3/4/2024
26 / 98
Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.02 0.02 < 0.005 < 0.005 < 0.005 0.02 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.04 0.44 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 98.3 98.3 < 0.005 < 0.005 0.01 99.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.37 1.37 < 0.005 < 0.005 < 0.005 1.38 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 < 0.005 0.23 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
27 / 98
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.52 0.43 4.63 6.43 0.01 0.17 — 0.17 0.16 — 0.16 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.52 0.43 4.63 6.43 0.01 0.17 — 0.17 0.16 — 0.16 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.30 0.25 2.69 3.74 0.01 0.10 — 0.10 0.09 — 0.09 — 731 731 0.03 0.01 — 734 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.05 0.49 0.68 < 0.005 0.02 — 0.02 0.02 — 0.02 — 121 121 < 0.005 < 0.005 — 121 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.15 1.03 1.04 16.7 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,318 3,318 0.14 0.11 12.1 3,368 Vendor 0.02 0.01 0.38 0.19 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 333 333 0.01 0.05 0.91 348 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 West Covina Medical Center Detailed Report, 3/4/2024
28 / 98
Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Worker 1.14 1.02 1.15 14.2 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,145 3,145 0.15 0.12 0.31 3,185 Vendor 0.02 0.01 0.39 0.19 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 333 333 0.01 0.05 0.02 347 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.66 0.59 0.72 8.64 0.00 0.00 1.80 1.80 0.00 0.42 0.42 — 1,855 1,855 0.08 0.07 3.05 1,880 Vendor 0.01 0.01 0.23 0.11 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 194 194 0.01 0.03 0.23 202 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.12 0.11 0.13 1.58 0.00 0.00 0.33 0.33 0.00 0.08 0.08 — 307 307 0.01 0.01 0.51 311 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.04 33.5 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.6. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.52 0.43 4.63 6.43 0.01 0.17 — 0.17 0.16 — 0.16 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
29 / 98
Off-Road
Equipment

0.52 0.43 4.63 6.43 0.01 0.17 — 0.17 0.16 — 0.16 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.30 0.25 2.69 3.74 0.01 0.10 — 0.10 0.09 — 0.09 — 731 731 0.03 0.01 — 734 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.05 0.49 0.68 < 0.005 0.02 — 0.02 0.02 — 0.02 — 121 121 < 0.005 < 0.005 — 121 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.15 1.03 1.04 16.7 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,318 3,318 0.14 0.11 12.1 3,368 Vendor 0.02 0.01 0.38 0.19 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 333 333 0.01 0.05 0.91 348 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.14 1.02 1.15 14.2 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,145 3,145 0.15 0.12 0.31 3,185 Vendor 0.02 0.01 0.39 0.19 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 333 333 0.01 0.05 0.02 347 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.66 0.59 0.72 8.64 0.00 0.00 1.80 1.80 0.00 0.42 0.42 — 1,855 1,855 0.08 0.07 3.05 1,880 Vendor 0.01 0.01 0.23 0.11 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 194 194 0.01 0.03 0.23 202 West Covina Medical Center Detailed Report, 3/4/2024
30 / 98
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.12 0.11 0.13 1.58 0.00 0.00 0.33 0.33 0.00 0.08 0.08 — 307 307 0.01 0.01 0.51 311 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.04 33.5 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.50 0.42 4.38 6.40 0.01 0.15 — 0.15 0.14 — 0.14 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.50 0.42 4.38 6.40 0.01 0.15 — 0.15 0.14 — 0.14 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.29 0.25 2.60 3.80 0.01 0.09 — 0.09 0.08 — 0.08 — 746 746 0.03 0.01 — 748 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
31 / 98
Off-Road
Equipment

0.05 0.05 0.47 0.69 < 0.005 0.02 — 0.02 0.02 — 0.02 — 123 123 0.01 < 0.005 — 124 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.00 0.88 0.93 15.5 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,252 3,252 0.13 0.11 11.0 3,300 Vendor 0.02 0.01 0.36 0.17 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 327 327 0.01 0.05 0.88 342 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.00 0.88 1.04 13.2 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,083 3,083 0.14 0.11 0.29 3,120 Vendor 0.02 0.01 0.38 0.18 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 327 327 0.01 0.05 0.02 342 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.59 0.52 0.67 8.21 0.00 0.00 1.83 1.83 0.00 0.43 0.43 — 1,855 1,855 0.08 0.07 2.82 1,880 Vendor 0.01 0.01 0.22 0.10 < 0.005 < 0.005 0.05 0.06 < 0.005 0.01 0.02 — 194 194 0.01 0.03 0.23 203 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.11 0.09 0.12 1.50 0.00 0.00 0.33 0.33 0.00 0.08 0.08 — 307 307 0.01 0.01 0.47 311 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.04 33.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.8. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e West Covina Medical Center Detailed Report, 3/4/2024
32 / 98
Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.50 0.42 4.38 6.40 0.01 0.15 — 0.15 0.14 — 0.14 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.50 0.42 4.38 6.40 0.01 0.15 — 0.15 0.14 — 0.14 — 1,258 1,258 0.05 0.01 — 1,262 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.29 0.25 2.60 3.80 0.01 0.09 — 0.09 0.08 — 0.08 — 746 746 0.03 0.01 — 748 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.05 0.47 0.69 < 0.005 0.02 — 0.02 0.02 — 0.02 — 123 123 0.01 < 0.005 — 124 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.00 0.88 0.93 15.5 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,252 3,252 0.13 0.11 11.0 3,300 Vendor 0.02 0.01 0.36 0.17 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 327 327 0.01 0.05 0.88 342 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 West Covina Medical Center Detailed Report, 3/4/2024
33 / 98
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.00 0.88 1.04 13.2 0.00 0.00 3.14 3.14 0.00 0.74 0.74 — 3,083 3,083 0.14 0.11 0.29 3,120 Vendor 0.02 0.01 0.38 0.18 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 327 327 0.01 0.05 0.02 342 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.59 0.52 0.67 8.21 0.00 0.00 1.83 1.83 0.00 0.43 0.43 — 1,855 1,855 0.08 0.07 2.82 1,880 Vendor 0.01 0.01 0.22 0.10 < 0.005 < 0.005 0.05 0.06 < 0.005 0.01 0.02 — 194 194 0.01 0.03 0.23 203 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.11 0.09 0.12 1.50 0.00 0.00 0.33 0.33 0.00 0.08 0.08 — 307 307 0.01 0.01 0.47 311 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.04 33.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.15 0.13 1.21 1.91 < 0.005 0.04 — 0.04 0.04 — 0.04 — 296 296 0.01 < 0.005 — 297 Paving — 0.03 — — — — — — — — — — — — — — — —
West Covina Medical Center Detailed Report, 3/4/2024
34 / 98
Onsite < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.57 0.57 < 0.005 0.06 0.06 — 8.34 8.34 < 0.005 < 0.005 < 0.005 8.76 truck
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.02 0.14 0.22 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 34.8 34.8 < 0.005 < 0.005 — 34.9 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 0.98 0.98 < 0.005 < 0.005 < 0.005 1.03 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 5.76 5.76 < 0.005 < 0.005 — 5.78 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.16 0.16 < 0.005 < 0.005 < 0.005 0.17 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 64.2 64.2 < 0.005 < 0.005 0.01 65.0 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.65 7.65 < 0.005 < 0.005 0.01 7.76 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.27 1.27 < 0.005 < 0.005 < 0.005 1.28 West Covina Medical Center Detailed Report, 3/4/2024
35 / 98
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Paving (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.15 0.13 1.21 1.91 < 0.005 0.04 — 0.04 0.04 — 0.04 — 296 296 0.01 < 0.005 — 297 Paving — 0.03 — — — — — — — — — — — — — — — —
Onsite
truck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.09 0.09 < 0.005 0.01 0.01 — 8.34 8.34 < 0.005 < 0.005 < 0.005 8.76 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.02 0.14 0.22 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 34.8 34.8 < 0.005 < 0.005 — 34.9 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.98 0.98 < 0.005 < 0.005 < 0.005 1.03 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 5.76 5.76 < 0.005 < 0.005 — 5.78 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.16 0.16 < 0.005 < 0.005 < 0.005 0.17 West Covina Medical Center Detailed Report, 3/4/2024
36 / 98
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 64.2 64.2 < 0.005 < 0.005 0.01 65.0 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.65 7.65 < 0.005 < 0.005 0.01 7.76 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.27 1.27 < 0.005 < 0.005 < 0.005 1.28 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

West Covina City CouncilApril 15, 2025

West Covina City Council
April 15, 2025