APRIL 2018 Specific Plan CITY OF GLENDORA Final Environmental Impact Report Arrow Highway Specific Plan SCH# 2017041043 Prepared By: 1500 Iowa Avenue, Suite 110 Riverside, CA 92507 951-787-9222 www.migcom.com
This document is designed for double-sided printing to conserve natural resources.
City of Glendora Final Environmental Impact Report for the Arrow Highway Specific Plan State Clearinghouse No. 2017041043 April 2018
This document is designed for double-sided printing to conserve natural resources.
Table of Contents 1 Introduction... 1-1 2 Response to Comments... 2-1 3 Errata... 3-1 4 Public Circulation... 4-1 5 Updated Air Quality Modeling Data... 5-1 List of Tables Table 2-1 Draft EIR Public Comments... 2-1 Table 2-2 Updated Realistic Development Potential... 2-2 Table 2-3 Updated Maximum Development Potential... 2-3 Table 2-4 Change in Analyzed Development Potential... 2-4 Table 2-5 Change in Development Potential-Existing Conditions Compared to Updated Realistic... 2-4 Table 2-6 Draft EIR Comments and Responses... 2-6
This document is designed for double-sided printing to conserve natural resources.
1.0 INTRODUCTION This Final Environmental Impact Report (FEIR) has been prepared to comply with State California Environmental Quality Act (CEQA) Guidelines (Guidelines), including Sections 15086 (Consultation Concerning Draft EIR), 15088 (Evaluation of and Responses to Comments), and 15132 (Contents of Final Environmental Impact Report). As noted in Section 15089 (b) of the Guidelines, the focus of a FEIR should be on responses to comments on the Draft Environmental Impact Report (DEIR). In conformance with these guidelines, the Arrow highway Specific Plan EIR consists of the following Volumes: (1) Volume 1, The Draft EIR, which circulated for a 45-day State agency and public review and comment period beginning on January 18, 2018; and ending Monday March 5, 2018 at 5:00 pm. (2) Volume 2, The Final EIR, which includes a review of the Project Description, supplemental information and data used for revisions/ corrections to the Draft EIR, a list of all commenters on the Draft EIR during the Draft EIR public review period, City responses to all environmental points raised through written communications, and revisions to the Draft EIR (presented as Errata pages). The Final EIR will also include a public circulation record and revised Air Quality Modeling Data. None of the revisions to the Draft EIR represents a substantial increase in the severity of an identified significant impact or the identification of a new significant impact, mitigation, or alternative considerably different from those already considered in the Draft EIR. Certification of this Final EIR by the Glendora City Council must occur prior to final approval and certification of the Arrow Highway Specific Plan. Availability of EIR Materials All materials related to preparation of this EIR are available for public review at the following locations: City of Glendora Planning Department 116 East Foothill Boulevard Glendora, California 91741 Glendora Public Library 140 South Glendora Avenue Glendora, CA 91741 1-1 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS This section provides a list of all commenters on the Draft EIR during the Draft EIR public review period, identifies supplemental information and data that was utilized in updating and producing the Final EIR, and provides City responses to all environmental points raised through written communications. Supplemental information is divided into two categories: updated Specific Plan development potential and changes to the air quality modeling methodology. DRAFT EIR PUBLIC COMMENTS A total of five comment letters were received during the 45-day public review period. Table 1-5 (Draft EIR Public Comments) lists the name of the entity that commented as well as the name of the commenter and the date of the comment letter. A copy of the comment letters is provided at the end of this section Table 2-1 Draft EIR Public Comments Entity Commenter Name Date County of Los Angeles Fire Department Michael Y. Takeshiita February 7, 2018 South Coast Air Quality Management District Lijin Sun February 15, 2018 County Sanitation Districts of Los Angeles Adriana Raza February 22, 2018 California Department of Transportation Frances Lee March 1, 2018 City of San Dimas, Planning Fabiola Wong March 7, 2018 SUPPLEMENTAL INFORMATION Corrected Specific Plan Development Potential The development potential numbers contained in the Project Description of the Draft EIR for both the realistic and the maximum buildout scenario were not correct, and were overstated, and consequently resulted in an over-estimation of potential project impacts in the Draft EIR. Although outdated growth estimates were inadvertently included in the Project Description of the Draft EIR, correct growth estimates were used in the project s traffic analysis and the Transportation and Traffic Section of the Draft EIR. These correct growth estimates can be found on pages 4.10-11 through 4.10-13 of the Transportation and Traffic Section of the Draft EIR, and pages 22 through 24 of the Traffic Impact Analysis (TIA) which can be found in Appendix E of the Draft EIR. In order to provide consistency and accuracy throughout the Final EIR, revisions to incorporate the traffic analysis (e.g. correct) growth estimates have been made to the Project Description and other affected parts of the Draft EIR and are included in Section 4 Errata of this Final EIR. Although the growth estimate figures included in the Draft EIR were inaccurate, bringing forward the correct growth figures used for the TIA and the Transportation and Traffic section into the rest of the EIR does not increase the severity of impacts that were analyzed in the Draft EIR, nor would it result in creating any new impacts. The reasons for this are that the corrected growth estimates are substantially lower than those originally used in the Project Description. Provided below are a series of tables that illustrate the changes resulting from the corrected growth estimates. As shown in the last table (2-5) overall the proposed project would reduce non-residential (commercial, industrial, etc.) building area by a little over one-half million square feet and an increase of 284 dwellings as compared to existing conditions. Tables 2-2 (Updated Realistic Development Potential) and 2-3 (Updated Maximum Development Potential) show the updated development potential numbers for the proposed Specific Plan land uses. ARROW HIGHWAY SPECIFIC PLAN 2-1
FINAL ENVIRONMENTAL IMPACT REPORT Table 2-2 Updated Realistic Development Potential Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential 1.0 -- -- 6 16 C-R3 Corridor Medium/High- Density Residential 1.1 -- -- 9 26 C-BR Corridor Buffer Residential 10.6 -- -- 85 239 C-HR Corridor High-Density Residential 27.8 -- -- 278 781 Commercial Designations C-C3 Corridor Commercial 5.1 33,540 79 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 128,670 302 90 254 MU-I Office/ Light Industrial Mixed-Use 10.1 54,650 63 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 75,600 217 87 245 MU-T Transition Mixed-Use 8.2 34,880 99 49 137 Industrial Designations C-1 Corridor Industrial 8.7 95,200 109 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 422,540 869 604 1,698 2-2 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Table 2-3 Updated Maximum Development Potential Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential C-R3 Corridor Medium/High- Density Residential C-BR Corridor Buffer Residential C-HR Corridor High-Density Residential Commercial Designations 1.1 -- -- 15 41 1.0 -- -- 23 64 10.6 -- -- 212 596 27.8 -- -- 694 1,952 C-C3 Corridor Commercial 5.1 111,800 263 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 224,600 529 180 507 MU-I Office/ Light Industrial Mixed-Use 10.1 219,500 250 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 138,300 395 175 492 MU-T Transition Mixed-Use 8.2 94,200 271 113 319 Industrial Designations C-1 Corridor Industrial 8.7 190,400 216 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 978,800 1,924 1,412 3,971 ARROW HIGHWAY SPECIFIC PLAN 2-3
FINAL ENVIRONMENTAL IMPACT REPORT Table 2-4 (Change in Analyzed Development Potential) below presents the net change in development potential from the Draft EIR to the Final EIR. As is shown in Table 2-4, the revised development potential numbers for both the realistic and maximum buildout scenarios are less intense than the development potential numbers that were analyzed in the Draft EIR. The revised air quality modeling reflects the revised development potential numbers (see the Updated Air Quality Modeling Data section of this EIR). Revisions to the air quality modeling methodology, which are based on the reduction in development potential shown in Table 2-4, are discussed below. Table 2-5 (Change in Development Potential Existing Conditions Compared to Updated Realistic Buildout) shows the potential change in land use that would occur within the proposed Specific Plan area at Realistic Buildout. As shown in Table 2-5, the updated Realistic Buildout numbers would have the potential to result in a reduction of over 253,000 square feet of non-residential uses, and subsequently the potential for 806 less employees within the Planning Area. Conversely, the updated Realistic Buildout numbers would have the potential to result in increases in dwelling units and population. Development Scenario Table 2-4 Change in Analyzed Development Potential Area (ac.) Non-Residential Area (SF) Employees Dwelling Units Population Realistic Buildout Analyzed Realistic Buildout Potential Development Potential 106.1 647,810 1,368 739 2,079 Updated Realistic Buildout Potential Development Potential 106.1 422,540 869 604 1,698 Net Change 0-225,270-499 -135-381 Maximum Buildout Analyzed Maximum Buildout Potential Development Potential 106.1 1,412,700 2,768 1,611 4,531 Updated Maximum Buildout Potential Development Potential 106.1 978,800 1,924 1,412 3,971 Net Change 0-433,900-844 -199-560 * City of Glendora Land Use, 2016. Table 2-5 Change in Development Potential Existing Conditions Compared to Updated Realistic Buildout Development Scenario Area (ac.) Non-Residential Area (SF) Employees Dwelling Units Population Existing Conditions Development Potential 106.1 946,522 1,675 320 900 Updated Realistic Buildout Development Potential 106.1 422,540 869 604 1,698 Net Change Over Existing 0-523,982-806 284 798 * City of Glendora Land Use, 2016. 2-4 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Revisions to Air Quality Emissions Estimates Methodology The Draft EIR utilized the CalEEMod emissions modeler to estimate anticipated emissions from realistic and maximum buildout of the proposed Specific Plan, and determine air quality and greenhouse gas impacts. The emissions numbers in the Draft EIR were based on the trip generation rates in the project Traffic Impact Analysis and older development potential numbers. As mentioned above, these development potential numbers were updated during the Draft EIR scoping process (see Tables 2-1 through 2-4 above). However, the updated numbers were not analyzed in the Draft EIR. This was an oversight and has been corrected in this Final EIR. In response to comments submitted by SCAQMD, the emissions modeling from the Draft EIR was reviewed and it was discovered that several other data inputs were incorrect. The updated emissions estimates are presented in the Response to Comments and Errata sections of this Final EIR. In addition to updating the modeling to reflect the correct proposed land use development potential numbers, the following key changes to the modeling were made: 1. Emissions reduction values for three times daily watering, per SCAQMD Rule 403, were included in the model to account for fugitive dust emissions reductions resulting from implementation of Rule 403. 2. The model was updated to include emissions reduction benefits from AQMD Rule 445, which is aimed at reducing pollution from wood-burning fireplaces and other devices such as old wood stoves. Approved in March 2008 by the AQMD Governing Board, the regulation includes measures that eliminate wood-burning fireplaces from new construction and provisions beginning in November 2011 that could curtail the use of wood-burning fireplaces during periods of unhealthy air quality. 3. For operational impacts, a change in the analysis year was made from 2019 to 2040 to reflect the horizon year of the proposed Specific Plan, and construction date phases and equipment were phased out to account for operational impacts only. 4. Even though this is a Program EIR, an additional model was generated for impacts related to construction. This model included an analysis year of 2019 with an operational year of 2020. The construction date phase begins January 1, 2019 and ends December 31, 2019. The realistic development potential for the proposed land uses within the Planning Area was divided by the life of the proposed Plan (21 years), and doubled to create a worst-case construction year scenario. This modeling was also used for the Localized Significance Thresholds analysis that is provided in the Final EIR. As shown in the Response to Comment and Errata sections of the Final EIR, the results of the updated modeling indicate that the Specific Plan would not have a new or more severe air quality impact. ARROW HIGHWAY SPECIFIC PLAN 2-5
FINAL ENVIRONMENTAL IMPACT REPORT CITY RESPONSE TO COMMENTS The Draft EIR was circulated for a 45-day public review and comment period beginning January 18, 2018 and ending March 5, 2018. Five pieces of correspondence were received from public agencies during this time period: the Los Angeles County Fire Department, the South Coast Air Quality Management District (SCAQMD), the Sanitation Districts of Los Angeles County (LACSD), the California Department of Transportation (Caltrans), and the City of San Dimas. No members of the public submitted correspondence during the review period. The correspondence materials listed in Table 2-6 (Draft EIR Comments and Responses) were submitted to the City of Glendora concerning the Draft EIR. Copies of letters follow the table. Written responses to comments are also provided in Table 2-6 addressing each specific comment. Comment Table 2-6 Draft EIR Comments and Responses Response A. Los Angeles County Fire Department A1. Land Development Unit: The Land Development Unit is reviewing the proposed ARROW HIGHWAY SPECIFIC PLAN for access and water system requirements. The Land Development Unit s comments are only general requirements. Specific fire and life safety requirements will be addressed during the review of the plans. There may be additional requirements during this time. The development of this project must comply with all applicable code and ordinance requirements for construction, access, water mains, fire flows, and fire hydrants. A2. Access Requirements Public Streets: The public streets for this development shall be in compliance with County of Los Angeles title 21 Subdivision Code and the County of Public Works Standards. 1. Single-Family Residential a. Provide a minimum width of 34 feet for parallel parking on one side of the Fire Apparatus Access Road with through access and with one side of the roadway being designated No Parking Fire Lane. b. Provide a minimum width of 34 feet for parallel parking on both sides of the Fire Apparatus Access Road when the street is designed to be a cul-de-sac less than 700 feet in length. c. Provide a minimum width of 36 feet for parallel parking on both sides of the Fire Apparatus Access Road and/or on cul-de-sac design with a length of 701 feet to 1,000feet. d. A fire Department approved turning area shall be provided at the end of the cul-de-sac. 2. Multi-Family Residential, Commercial and Industrial a. A cul-de-sac shall not be more than 500 feet in length. b. A Fire department approved turning area shall be provided at the end of a cul-de-sac. Future development within the proposed Planning Area will be required to comply with all applicable code and ordinance requirements for construction, access, water mains, fire flows, and fire hydrants. Future development within the proposed Planning Area will be required to comply with all applicable code and ordinance requirements for public street access. 2-6 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment Table 2-6 Draft EIR Comments and Responses Response A3. Access Requirements Private Streets and Driveways: 1. All Fire Apparatus Access roads (fire Lanes) must be installed and maintained in a serviceable manner prior to and during the time of construction and shall be clear of all encroachments. 2. The dimensions of the approved Fire Apparatus Access Road shall be maintained as originally approved by the fire code official (fire code 503.2.2.1). 3. All on-site Fire department Access Roads shall be labeled as Private Driveway and Fire Lane on the site plan along with the widths clearly depicted on the plan. Labeling is necessary to assure the access availability for Fire Department use. The designation allows for appropriate signage prohibiting parking. 4. The Fire Apparatus Access roads and designated fire lanes shall be measured from flow line to flow line. 5. Fire Apparatus Access Roads Detached Single- Family Residential Units Only a. Provide a minimum width of 20 feet exclusive of shoulders and an unobstructed vertical clearance clear to sky Fire Department vehicular access to within 150 feet of all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building. b. The required 20-foot wide driving surface shall be increased to 26 feet when fire hydrants are required. The 26-foot width shall be maintained for a minimum of 25 linear feet on each side of the hydrant location. 6. Fire Apparatus Access Roads Multi-Family Residential, Commercial, and Industrial a. Provide a minimum unobstructed width of 26 feet exclusive of shoulders and an unobstructed vertical clearance clear to sky fire Department vehicular access to within 150 feet of all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building. b. Provide a minimum unobstructed width of 28 feet exclusive of shoulders and an unobstructed vertical clearance clear to sky Fire Department vehicular access to within 150 feet of all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building when the height of the building above the lowest level of the Fire Department vehicular access road is more than 30 feet high or the building is more than three stories. The access roadway shall be located a minimum of 15 feet and a maximum of 30 feet from the building and shall be positioned parallel to one entire side of the building. The side of the building on which the aerial Fire Apparatus Future development within the proposed Planning Area will be required to comply with all applicable code and ordinance requirements for private street and driveway access. ARROW HIGHWAY SPECIFIC PLAN 2-7
FINAL ENVIRONMENTAL IMPACT REPORT Comment Access Road is positioned shall be approved by the fire code official. i. The public street may be used for ladder truck access when the building wall is within 20 feet of the public street and there are no obstructions such as street parking, power and telephone lines, trees, etc. 7. If the Fire Apparatus Access road is separated by island provide a minimum unobstructed width of 20 feet exclusive of shoulders and an unobstructed vertical clearance clear to sky Fire department vehicular access to within 150 feet of all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building. 8. Dead-end Fire Apparatus Access Roads in excess of 150 feet in length shall be provided with and approved Fire Department turnaround. The dimensions of the turnaround with the orientation of the turnaround shall be properly placed in the direction of travel of the access roadway shall be noted on the plans. 9. Fire Department Access Roads shall be provided with a 32-foot centerline turning radius. Indicate the centerline, inside, and outside turning radii for each change in direction on the site plan. 10. Fire Apparatus Access Roads shall be designed and maintained to support the imposed load of fire apparatus weighing 75,000 pounds and shall be surfaced so as to provide all-weather driving capabilities. Fire Apparatus Access Roads having a grade of 10 percent or greater shall have a paved or concrete surface. 11. The gradient of Fire Department Access Roads shall not exceed 15 percent unless approved by the fire code official. 12. Provide approved signs or other approved notices or markings that include the words NO PARKING FIRE LANE. Signs shall have a minimum dimension of 12 inches wide by 18 inches high and have red letters on a white reflective background. Signs shall be provided for Fire Apparatus Access Roads to clearly indicate the entrance to such road, or prohibit the obstruction thereof and at intervals, as required by the Fire Inspector. 13. A minimum 5-foot wide approved firefighter access walkway leading from the Fire Department Access Road to all required openings in the building s exterior walls shall be provided for firefighting and rescue purposes. 14. Fire Apparatus Access Roads shall not be obstructed in any manner, including by the parking of vehicles, or the use of traffic calming devices, including but not limited to, speed bumps or speed humps. The Table 2-6 Draft EIR Comments and Responses Response 2-8 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment minimum widths and clearances established in Section 503.2.1 shall be maintained at all times. 15. Traffic Calming Devices, including but not limited to, speed bumps and speed humps, shall be prohibited unless approved by the fire code official. 16. Approved building address numbers, building numbers, or approved building identification shall be provided and maintained so as to be plainly visible and legible from the street fronting the property. The numbers shall contrast with their background, be Arabic numerals or alphabet letters, and be a minimum of 4 inches high with a minimum stroke width of 0.5 inch. 17. Multiple residential and commercial buildings having entrances to individual units not visible from the street or road shall have unit numbers displayed in groups for all units within each structure. Such numbers may be grouped in the wall of the structure or mounted on a post independent of the structure and shall be positioned to be plainly visible from the street or road as required by Fire Code 505.3 and in accordance with fire Code 505.1. 18. Gate Requirements a. The gated entrance design with single access point (ingress and egress) maintain the minimum required width of the Fire Apparatus Access Road clear to sky with all gate hardware is clear of the access way. b. Gated entrance design with separate access gates for ingress and egress shall provide minimum width of 20 feet clear to sky for each side. c. The keypad location shall be located a minimum of 50 feet from the public right-of-way. d. Provide a minimum 32-foot turning radius beyond the keypad prior to the gate entrance at a minimum width of 20 feet for turnaround purposes. e. The security gate shall be provided with an approved means of emergency operation and shall be maintained operational at all times and replaced or repaired when defective. Electric gate operators where provided, shall be listed in accordance with UL 325. Gates intended for automatic operation shall be designed, constructed, and installed to comply with the requirements of ASTM F220. Gates shall be of the swinging or sliding type. Construction of gates shall be of materials that allow manual operation by one person. f. The method of gate control shall be subject to review by the Fire Department prior to clearance to proceed to public hearing. g. All locking devices shall comply with the County of Los Angeles Fire Department Regulation 5, Table 2-6 Draft EIR Comments and Responses Response ARROW HIGHWAY SPECIFIC PLAN 2-9
FINAL ENVIRONMENTAL IMPACT REPORT Comment Compliance for Installation of Emergency Access Devices. 19. Additional Fire Apparatus Access Roads a. The fire code official is authorized to require more than one Fire Apparatus Access Road based on the potential for impairment of a single road by vehicle congestion, condition of terrain, climactic conditions, or other factors that could limit access. Such additional access must comply with Title 21 of the Los Angeles County Code. A4. Water System Requirements: 1. All required public fire hydrants shall be installed, tested, and accepted prior to the beginning of construction. 2. All private on-site fire hydrants shall be installed, tested, and approved prior to building occupancy. 3. All fire hydrants shall measure 6 x4 x2-1/2 brass or bronze conforming to current AWWA standard C503 or approved equal and shall be installed in accordance with the County of Los Angeles Fire Department Regulation 8. 4. Fire Hydrant Spacing a. Detached Single Family Residential i. Fire hydrant spacing shall be 600 feet with not portion of lot frontage shall be more than 450 feet via vehicular access from a public fire hydrant. ii. No portion of a structure should be placed on a lot where it exceeds 750 feet via vehicular access from a properly spaced public fire hydrant. iii. When cul-de-sac depth exceeds 450 feet on a residential street, hydrants shall be required at the corner and mid-block. iv. Additional hydrants will be required if hydrant spacing exceeds specified distances. b. Multi-Family Residential, Commercial and Industrial i. Fire hydrant spacing shall be every 300 feet with no portion of lot frontage shall be more than 200 feet via vehicular access from a public fire hydrant. ii. Additional hydrants will be required if hydrant spacing exceeds specified distances. iii. When cul-de-sac depth exceeds 200 feet on a commercial street, hydrants shall be required at the corner and mid-block. c. All on-site fire hydrants shall be installed a minimum of 25 feet from a structure or protected by a two (2) hour rated firewall. Exception: For fully sprinkled multi-family structures on-site hydrants may be installed a minimum of 10 feet from the structure. 5. Fire Flow Requirements a. The required fire flow for the public fire hydrants for Table 2-6 Draft EIR Comments and Responses Response Future development within the proposed Planning Area will be required to comply with all applicable code and ordinance requirements for the local water system. 2-10 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment single-family residential homes less than a total square footage of 3,600 feet is 1,250 gpm at 20 pounds psi residual pressure for 2 hours with on public fire hydrant flowing. Any single-family residential home 3,601 square feet or greater shall comply with Table B105.1 of the Fire code in Appendix B. b. The required fire flow for the public and private onsite fire hydrants for buildings other than singlefamily residential homes in this project will be determined with further plan review. The maximum fire flow for this development is 8,000 gpm at 20 pounds psi residual pressure for 5 hours. Three (3) public fire hydrants flowing simultaneously may be used to achieve the required fire flow. The total square footage of each proposed building along with the type of construction and written verification of an automatic fire sprinkler system is required to determine the exact fire flow. i. An approved automatic fire sprinkler system is required for the proposed buildings within this development. A5. Fuel Modification: 1. This property is located within the area described by the Fire Department as the Very High Hazard Severity Area. A Preliminary Fuel Modification Plan shall be submitted and approved prior to public hearing. For details, please contact the Department s Fuel Modification Unit, which is located at Fire Station 32, 605 North Angeleno Avenue, in the City of Azusa, CA, 91702-2904. They may be reached at (626) 969-5205. Table 2-6 Draft EIR Comments and Responses Response This comment has been noted. While parts of the City of Glendora are designated as being within a Very High Hazard Severity Area, the proposed Planning Area itself is not located in such an area. No changes to the EIR will be made as a result of this comment. A6. High Voltage Transmission Lines: 1. Structures and outdoor storage underneath High Voltage Transmission Lines (66 kilovolts or greater) shall comply with Fire Code 316.6 and County of Los Angeles Fire Department Regulation 27. Any proposed construction or land use within 100 feet of the drip line of High Voltage Transmission Lines shall be subject to review by the Fire Marshall. A7. Forestry Division Other Environmental Concerns: 1. The statutory responsibilities of the County of Los Angeles Fire Department s Forestry Division include erosion control, watershed management, rare and endangered species, vegetation, fuel modification for Very High Fire Hazard Severity Zones or Fire Zone 4, archaeological and cultural resources and the County Oak Tree Ordinance. The County of Los Angeles Fire Department s Forestry Division has no further All future development within the proposed Planning Area will comply with Fire Code 316.6 and County of Los Angeles Fire Department Regulation 27. No changes to the EIR will be made as a result of this comment. This comment has been noted. No changes to the EIR will be made as a result of this comment. ARROW HIGHWAY SPECIFIC PLAN 2-11
FINAL ENVIRONMENTAL IMPACT REPORT Comment comments regarding this subject. Table 2-6 Draft EIR Comments and Responses Response A8. Health Hazardous Materials Division: 1. The Health Hazardous Materials Division of the Los Angeles County Fire department has no comments or requirements for the project at this time. This comment has been noted. No changes to the EIR will be made as a result of this comment. B. South Coast Air Quality Management District B1. SCAQMD Staff s Summary of Project Description: The Lead Agency proposes to establish land use development policies, standards, and guidelines to support development of 40.9 acres of commercial use, 20.6 acres of public/institutional use, 13 acres of industrial use, 29.1 acres of residential use, and 8.6 acres of open space on 106 acres along a 2.73-mile portion of the Arrow Highway in the southern portion of the City of Glendora (Proposed Project). The Proposed Project is projected to include development of over 1.4 million square feet (SF) (maximum buildout) or 647,810 SF (Expected Buildout) of non-residential development, 1,611 dwelling units (DU) (maximum buildout) or 739 DU (expected buildout), and 8.6 acres of open space. The proposed project is expected to be developed over time with the horizon year of 2040. B2. SCAQMD Staff s Air Quality Analysis: Based on a review of the Air Quality Section, SCAQMD staff found that the air quality analysis was based on the expected buildout scenario because the Lead Agency determined that expected buildout estimates represent a more realistic potential scenario based on market assumptions, existing conditions, and other factors. The Lead Agency did not quantify construction emissions because it determined that the significance of future construction emissions cannot be determined at this time. However, the Lead Agency found The SCAQMD correctly summarizes the Specific Plan s maximum buildout development potential from the Draft EIR; however, as permitted by CEQA and clarified in Responses B5, B7, B8, B9, and B11 below, this EIR evaluates the potential impacts of the Specific Plan based on the Realistic Buildout scenario. As shown in the Errata section of the Final EIR, the City has revised the Draft EIR to include the following clarifying description of the realistic development scenario: The Specific Plan is estimated to support development of over 1.4 978,000 million square feet (SF) (maximum buildout) or 647,810 422,540 SF (expected buildout) of non-residential development, 1,611 1,412 dwelling units (DU) (maximum buildout) or 739 604 DU (expected buildout), and 8.6 acres of open space. The changes to the Project Description address overstate land use development numbers used in the Project Description and elsewhere in the Draft EIR. As shown in the Errata section of the Final EIR the City has modified the Draft EIR s impact analyses as necessary to reflect the revised land use numbers. A discussion of changes to the Project Description and the CalEEMod modeling is also provided in the New Information sub-section of the Errata section, and updated CalEEMod output files can be found in the revised Air Quality Modeling Data section (Section 7) of the FEIR. None of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR since the revised projected land use numbers in Project Description are low than the number in the DEIR.. The SCAQMD s summary of the Draft EIR s air quality analysis provided in Comment B2 is accurate. As explained in more detail in Responses B5, B7, B8, B9, and B11 below, the City has adequately evaluated the potential impacts of the Specific Plan under the Realistic Buildout scenario. In addition, as described in more detail in B6, the City has revised the Draft EIR to quantify and evaluate potential regional and local construction emissions associated with Specific Plan development; the results of this evaluation indicate the Specific Plan would 2-12 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment that with implementation of existing regulations, future projects within the proposed Specific Plan Planning Area will not result in exceedances of short-term construction-related criteria pollutant emissions thresholds. Impacts from construction will be less than significant. The Lead Agency quantified the Proposed Project s operational air quality emissions based on the expected buildout scenario and compared the emissions to SCAQMD s regional air quality CEQA significance thresholds for operation. After incorporating Mitigation Measure AQ-1, which requires implementation of Transportation Demand Management (TDM) strategies included in SCAG s 2012 RTP/SCS, the Lead Agency found that the Proposed Project s mitigated net operational emissions would exceed SCAQMD s regional CEQA significance thresholds for VOC and NOx emissions. The Lead Agency also quantified the Proposed Project s net operational emissions based on the maximum buildout scenario for a disclosure purpose, and found that those emissions would exceed SCAQMD s regional CEQA significance thresholds for VOC, NOx, CO,, and emissions. Table 2-6 Draft EIR Comments and Responses Response not result in construction emissions that exceed SCAQMD regional or local significance thresholds. Finally, as explained in Response to Comment B1, the City has updated the Draft EIR s impact analyses reflect the updated land use numbers for the Realistic Buildout scenario and none of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR. B3. SCAQMD s 2016 Air Quality Management Plan: On March 3, 2017, the SCAQMD s Governing Board adopted the 2016 Air Quality Management Plan (2016 AQMP), which was later approved by the California Air Resources Board on March 23, 2017. Built upon the progress in implementing the 2007 and 2012 AQMPs, the 2016 AQMP provides a regional perspective on air quality and the challenges facing the South Coast Air Basin. The most significant air quality challenge in the Basin is to achieve an additional 45 percent reduction in NOx emissions in 2023 and an additional 55 percent NOx reduction beyond 2031 levels for ozone attainment. B4. General Comments: SCAQMD staff has reviewed the Air Quality Analysis in the Draft EIR and is concerned about the methodology. Please see the attachment for more information. Additionally, as described in the 2016 AQMP, to achieve NOx emissions reductions in a timely manner is critical to attaining the National Ambient Air Quality Standard (NAAQS) for ozone before the 2023 and 2031 deadlines. SCAQMD is committed to attain the ozone NAAQS as expeditiously as practicable. The Proposed Project plays an important role in contributing to NOx emissions. Therefore, SCAQMD staff has comments on air quality mitigation measure and recommends additional mitigation measures to further reduce NOx emissions as well as ROG,, and emissions. Finally, the attachment includes recommendations to include The City has revised the Draft EIR to include an analysis of the proposed Specific Plan s consistency with the SCAQMD s 2016 AQMP. As shown in the Errata section of the Final EIR the updated AQMP consistency analysis does not identify any new or substantially more severe impacts than those identified in the Draft EIR.. Updates to the Draft EIR and responses to SCAQMD staff comments are described and shown in Responses B2 and B5 through B16, as well as in the Errata section of the Final EIR. The City has made a good faith, reasoned effort to address each comment in a detailed and specific manner. In addition, specific changes to the Project Description land use numbers and air quality modeling are described in the Errata section of the Final EIR. ARROW HIGHWAY SPECIFIC PLAN 2-13
FINAL ENVIRONMENTAL IMPACT REPORT Comment discussions on SCAQMD rules and regulations. Pursuant to California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(b), SCAQMD staff requests that the Lead Agency provide SCAQMD staff with written responses to all comments contained herein prior to the certification of the Final EIR. In addition, issues raised in the comments should be addressed in detail giving reasons why specific comments and suggestions are not accepted. There should be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice (CEQA Guidelines Section 15088(c)). Conclusory statements do not facilitate the purpose and goal of CEQA on public disclosure and are not meaningful or useful to decision makers and to the public who are interested in the Proposed Project. Further, when the Lead Agency makes the finding that the recommended mitigation measures are not feasible, the Lead Agency should describe the specific reasons for rejecting them in the Final EIR (CEQA Guidelines Section 15091). Table 2-6 Draft EIR Comments and Responses Response B5. Air Quality Analysis General: As described in the Project Description, the Lead Agency identified two buildout scenarios for the horizon year of 2040: expected and maximum. Since the expected buildout estimates represent a more realistic potential scenario based on market assumptions, existing conditions, and other factors, the environmental analysis in the Draft EIR was based on the expected buildout scenario. SCAQMD staff is concerned about using the expected buildout scenario to analyze the Proposed Project s environmental impacts, particularly the air quality impacts. 1. Under the expected buildout scenario, the Proposed Project s mitigated net operational air quality impacts would be significant only for VOC and NOx emissions (Table 4.2-5 in the Draft EIR). However, under the maximum buildout scenario, the Proposed Project s mitigated net operational air quality impacts would be significant for ROG, NOx,, and (Table 4.2-6 in the Draft EIR). Since the emissions under the maximum buildout scenario were included in the Draft EIR for disclosure purpose only and were not used for determining the level of significance, it may have foreclosed the range of potential feasible alternatives and air quality mitigation measures evaluated in the Draft EIR. To disclose a worst-case operational impact scenario in the Final EIR, SCAQMD staff recommends that the Lead Agency uses the maximum buildout scenario to determine the level of significance for the Proposed Project s operational impacts, unless the Lead Agency includes requirements and/or conditions, As previously stated in Response B1 above, the Lead Agency s analysis of Specific Plan air quality impacts was correctly based on the Realistic Buildout scenario. The Errata section of the Final EIR includes revisions that clarify and clearly indicate that Maximum Buildout scenario emissions were presented for information purposes only, and the Lead Agency is not basing any air quality significance determinations on the Maximum Buildout scenario. While the Lead Agency is not including the Maximum Buildout scenario for the purposes of providing an impact determination, it is included to provide further disclosure to the public. Furthermore, as stated in Response B2 above, the Lead Agency has updated the Draft EIR s impact analyses to reflect the revised land use numbers for the Realistic Buildout scenario and none of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR. Specifically, Tables 4.2-9 and 4.2-10 (previously Tables 4.2-5 and 4.2-6) of the Errata section of the Final EIR show that net operational emissions would not exceed SCAQMD regional CEQA significance thresholds. This determination was made for both the Realistic Buildout and the Maximum Buildout scenarios because neither scenario will create net emissions that will exceed SCAQMD regional CEQA significance thresholds. 2-14 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment documented in the Final EIR, to ensure that future development under the Proposed Project s maximum development scenario will not occur. Table 2-6 Draft EIR Comments and Responses Response B6. Air Quality Analysis Construction Impact Analysis: When specific development is reasonably foreseeable as a result of the goals, policies, and guidelines in the Proposed Project, the Lead Agency should identify any potential adverse air quality impacts and sources of air pollution that could occur using its best efforts to find out and a good-faith effort at full disclosure in the EIR. The degree of specificity will correspond to the degree of specificity involved in the underlying activity which is described in the EIR (CEQA Guidelines Section 15146). When quantifying air quality emissions, emissions from both construction (including demolition, if any) and operations should be calculated. 1. As shown in Table 3-1 and Table 3-2 in the Draft EIR, the Lead Agency has identified the expected and maximum development scenarios in terms of zoning designations, area in acreage, non-residential area in square feet, number of employees, number of dwelling units, and anticipated population. Therefore, the Lead Agency should use this information and its best efforts to identify construction activities that would be required to implement the expected and maximum development scenarios and quantify associated construction emissions, including emissions from any demolition activities. Otherwise, there is no substantial evidence to support the Lead Agency s finding that the Proposed Project s construction impacts would be less than significant. 2. Construction-related air quality impacts typically include, but are not limited to, emissions from the use of heavy-duty equipment from grading, earthloading/unloading, paving, architectural coatings, offroad mobile sources (e.g., heavy-duty construction equipment), and on-road mobile sources (e.g., construction worker vehicle trips, material transport trips). SCAQMD staff recommends that the Lead Agency quantify the Proposed Project s construction emissions and compare those emissions to SCAQMDs regional air quality CEQA significance thresholds for construction to determine the level of significance. The Lead Agency should use the current version of California Emission Estimator Model (CalEEMod) to quantify construction emissions. B7. Air Quality Analysis Interim Milestone Years: SCAQMD staff recommends that the Lead Agency include interim milestones years when analyzing construction impacts from the Proposed Project. The buildout year for the As noted by the SCAQMD in its remarks, future development supported by the Specific Plan would result in short-term construction-related criteria pollutant emissions that have the potential to have an adverse effect on air quality. As requested by the SCAQMD, the City has quantified the potential construction emissions associated with a average development year using the most recent version of the California Emissions Estimator Model (CalEEMod), Version 2016.3.2 and determined potential construction emissions levels would not exceed SCAQMD regional or localized significance thresholds. The Errata section of the Final EIR describes the methodology and assumptions used to quantify and compare emissions to SCAQMD emissions thresholds (e.g., Tables 4.2-5, 4.2-6, and 4.2-7 in the Errata Section). The SCAQMD has recommended the EIR include emissions estimates for interim milestone years such as 2020, 2025, 2030, and 2035 to ensure peak daily emissions are identified; however, such analysis is not ARROW HIGHWAY SPECIFIC PLAN 2-15
FINAL ENVIRONMENTAL IMPACT REPORT Comment Proposed Project is 2040. The overall emission rates of vehicles, trucks, and equipment are generally higher in earlier years as more stringent emission standards and technologies have not been fully implemented and fleets have not fully turned over. It is also likely that the Proposed Project may not be at peak capacity in earlier years, and peak daily emissions may occur in a few years after the project is implemented. Therefore, SCAQMD staff recommends that the Lead Agency include interim milestone years (i.e., year 2020, year 2025, year 2030, and year 2035) in the Air Quality Analysis to ensure the peak daily emissions are identified and adequately disclosed in the Final EIR. The interim milestone years, which were already used in Appendix F, Urban Water Management Plan Update, to the Draft EIR, will also assist in the demonstration of progress over time from implementing air quality-related mitigation measures and policies included in the Draft EIR. Table 2-6 Draft EIR Comments and Responses Response necessary for the Arrow Highway Specific Plan EIR for several reasons. As shown in Table 4.2-9 of the Errata section of the Final EIR, mobile sources account for the majority (between 70-90%) of the proposed project s maximum daily NOx emissions under both the existing (2017) and build-out conditions (2040). Therefore, it is reasonable to presume that mobile sources, i.e., vehicle trips, would be the primary contributor to peak daily emissions estimates regardless of the analysis year selected. For vehicle emissions in 2020, 2025, 2030, or 2035 to exceed the build-out year vehicle emissions projections, emissions on a per unit basis in the first few years of development would have to be substantially higher than emissions on a per unit basis in the build-out year, or there would have to be an accelerated level of development (such that buildout occurs before 2040). Existing evidence indicates that motor vehicle emissions on a per unit basis in the first few years of development would not be substantially higher than emissions in 2040. This is because the modeling conducted for the EIR already incorporates the state s latest low emission vehicle standards (LEV III), which were adopted in 2012 and apply to 2015 to 2025 model years. For example, EMFAC2014 vehicle exhaust emission factors for NOx were compared for 2017 to 2025 model year vehicles, as well as year 2030 and year 2040 model year vehicles. The emission factors were generated for gasoline-powered passenger vehicles and light duty trucks travelling at 25 miles per hour (mph), 35 mph, and 45 mph. Beginning in 2018, the vehicle exhaust emission factors at these speeds drop by about 10% per year through 2022 (i.e., 2018 model year emission factors are approximately 10% less than 2017 model year emission factors), before tapering off and remaining constant after 2025 (i.e., the model assumes the same emission factors for model year 2025 as for model years 2030, 2035, etc.). This means that beginning in approximately 2023, the total emissions generated from motor vehicle trips are primarily dependent on the total amount of development, and not emission factors. This information is not meant to be exhaustive or entirely comprehensive; vehicle emissions and the potential overall emissions generated by implementation of the Specific Plan are dependent on many factors (e.g., fleet mix, age of fleet, specific development types and square footages, changes in regulatory requirements, etc.). Rather it is only meant to be indicative of the fact that, for the largest source of emissions considered in the EIR, emissions on a per unit basis would not be substantially higher in the initial years of Specific Plan implementation 2-16 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment Table 2-6 Draft EIR Comments and Responses Response than in year 2040. Therefore, it is unlikely that a higher potential emissions scenario would exist in any of the interim year analyses suggested by the SCAQMD. The growth associated with the Specific Plan would be contingent on a variety of market and other factors. It cannot be known with any certainty whether the projected 2040 development scenario for the DEIR would be achieved in 2040, earlier than 2040, or later than 2040. The growth projection in the Arrow Highway Specific Plan and the FEIR is the City s best, most reasonable estimate of future growth and the emissions associated with that growth. Even if there were a sudden uptick in development in the earlier years of Specific Plan implementation, such development would not have substantially higher emissions on a per unit basis (as described above) and would be subject to second tier, project-level, CEQA review and, if necessary, project-level mitigation to reduce potential adverse impacts. B8. Air Quality Analysis Localized Significance Thresholds Analysis: Based on the information in the environmental settings and a review of aerial maps, SCAQMD staff found that the Proposed Project is potentially surrounded by sensitive receptors. Therefore, SCAQMD staff recommends that the Lead Agency use its best efforts to evaluate localized air quality impacts to disclose the potential impacts on nearby sensitive receptors from construction activities that will occur in close proximity. The SCAQMD s guidance for performing a localized air quality analysis can be found at the SCAQMD website. In the event that the Lead Agency finds, after the analysis, that the Proposed Project would exceed SCAQMD s localized air quality CEQA significance thresholds, mitigation measures are required pursuant to CEQA Guidelines Section 15126.4. B9. Air Quality Analysis Overlapping Construction and Operational Activities: In the Draft EIR, the Lead Agency stated that the Proposed Project would accommodate new residential and commercial uses that will operate up to and likely through the Specific Plan horizon year of 2040. However, the Lead Agency did not analyze a scenario where construction activities overlap with operational activities. Since implementation of the Proposed Project is expected to take place over time, an overlapping construction and operation scenario is reasonably foreseeable, unless the Lead Agency includes requirements and/or conditions in the Final EIR that will prohibit overlapping construction and operational activities. Therefore, to analyze a worst-case impact scenario that is reasonably foreseeable at the time the Draft EIR is prepared, SCAQMD staff recommends that the Lead Agency identify the overlapping years, combine As explained in the response to Comment B6, City has quantified the potential construction emissions associated with an average development year using the most recent version of the California Emissions Estimator Model (CalEEMod), Version 2016.3.2 and determined potential construction emissions levels would not exceed SCAQMD regional or localized significance thresholds. As explained on page 4.2-18 of the Draft EIR, the proposed Specific Plan would not directly result in construction of any development or infrastructure. Nonetheless, to disclose the potential level of emissions that could occur with a likely construction project, the Final EIR presents construction emissions evaluation based on the average annual level of development necessary to reach the realistic build-out projections contained in the Specific Plan. It is not possible to know the size, type, location, timing or number of projects under construction at any given time. The number of different permutations that could occur with respect to construction and operational activity is innumerable; however, the City notes that, as shown in the Errata Section of the Final EIR, the project s combined construction and operational emissions would not exceed ARROW HIGHWAY SPECIFIC PLAN 2-17
FINAL ENVIRONMENTAL IMPACT REPORT Comment construction emissions (including emissions from demolition) with operational emissions, and compare the combined emissions to SCAQMD s air quality CEQA operational thresholds of significance to determine the level of significance in the Final EIR. In the event that the Lead Agency, after revising the Air Quality analysis, finds that the Proposed Project s air quality impacts would be significant, mitigation measures will be required pursuant to CEQA Guidelines Section 15126.4. For more information on potential mitigation measures as guidance to the Lead Agency, please see Comment No. 10 and visit SCAQMD s CEQA Air Quality Handbook website. Table 2-6 Draft EIR Comments and Responses Response SCAQMD thresholds because the implementation of the Specific Plan would result in an operational air quality benefit (a net reduction in emissions). Since this EIR is a Program EIR for a project that would be implemented over a 21-year period, and at this time there are no specifics knowable with respect to future scale, timing and duration of individual construction activities, attempting to estimate potential future combined emissions that could occur would be an exercise in speculation. The SCAQMD has separate and distinct thresholds of significance for construction, i.e., short-term emissions, and operational, i.e., long-term emissions, and the EIR appropriately compares each individual activity to the corresponding threshold. B10. Air Quality Analysis Health Risk Assessment (HRA) Analysis: In the Draft EIR, the Lead Agency stated that industrial uses exist in places within the Planning Area of the Proposed Project. The Lead Agency also stated that actual levels of risk can only be determined through site-specific analysis and specialized air pollutant modeling, based on an actual relationship between and industrial emission source and a specific residential site. Such assessments might determine that there are less than significant health risks, or that there could be some significant level of exposure to pollutants that need to be mitigated through siting, site design, or operational restrictions. Subsequently the Lead Agency concluded that potential health impacts from the Proposed Project due to exposure to toxic air contaminants will be less than significant because the Proposed Project would implement General Plan policies, which require proposed developments to prepare an air quality analysis, and existing regulations that regulate and monitor toxic emitters. As shown in 2.E., 2.H., 2.L., and 2.M. of the Errata section of the Final EIR includes additional information and disclosure of existing sources of Toxic Air Contaminants emissions, as well as the potential for the project to generate TAC emissions. The Errata also includes additional qualitative analysis of potential health risks and hazards resulting from project implementation. This new information and analyses do not indicate that the implementation of the proposed Specific Plan would result in significant adverse health risks. The Lead Agency has fully analyzed the proposed project s potential health impacts. Due to the uncertainty surrounding the nature of future, source-specific emissions, the distance between potential future sources and individual receptors, and the nature of the characteristics that will lead to dispersion of potential pollutants, a quantitative HRA would be speculative and is therefore not necessary at this time. SCAQMD staff is concerned that the Proposed Project s health impacts were not analyzed in the Draft EIR, and yet the Lead Agency concluded that the Proposed Project s health impacts will be less than significant. One of the basic CEQA policies is to inform government decision makers and the public about the potential significant environmental effects of proposed activities (CEQA Guidelines Section 15002(a)(1)). A finding that the Proposed Project s health impacts are less than significant is appropriate if the finding is supported by substantial evidence in the record. Here, the Lead Agency has not conducted the HRA analysis, and there is no quantitative or qualitative analysis on how General Plan policies and existing regulations will reduce health impacts to less than significant. As such, there is no substantial evidence in the record to support the Lead Agency s conclusion that the Proposed Project s health impacts will be less than significant. SCAQMD staff recommends that the Lead Agency use its best efforts to 2-18 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment conduct a HRA analysis to disclose potential health impacts due to exposure to toxic air contaminants in the Final EIR. Information about the Proposed Project that is needed for conducting a HRA analysis is already available in the Draft EIR. CEQA does not require technical perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at full disclosure. A court does not pass upon the correctness of an EIR s environmental conclusions, but only determines if the EIR is sufficient as an informational document (CEQA Guidelines Section15(i)). Preparing the CEQA analysis necessarily involves some degree of forecasting. While forecasting the unforeseeable is not possible, an agency must use its best efforts to find out and disclose all that it reasonably can (CEQA Guidelines Section 15144). In section 3.0, Project Description, in the Draft EIR, the Lead Agency identified the expected and maximum development scenarios in terms of zoning designations, area in acreage, non-residential area in square feet, number of employees, number of dwelling units, and anticipated population. Also shown in Exhibits 3-4, 3-7, 3-8, 3-9, 3-10, and 3-11 were the urban design framework, proposed land uses, two development districts, mobility plan, and greenway trails for the Proposed Project. Therefore, there is sufficient information with regard to the Proposed Project s development kind, size, intensity, and location that the Lead Agency can and should use for conducting a HRA analysis in the Final EIR. Table 2-6 Draft EIR Comments and Responses Response B11. Air Quality Analysis Inconsistent Conclusions: After a review of the conclusions for Impact 4.2B and Impact 4.2C on Page 4.2-21 and Page 4.2-22, respectively, SCAQMD staff found that they were inconsistent with the conclusion on Page 4.2-25. For Impact 4.2B and Impact 4.2C, the Lead Agency had the same conclusions, stating with implementation of Mitigation Measure AQ-1 and adherence to the City s standard CEQA review process, impacts will be less than significant. (Emphasis added). When the Lead Agency discussed the level of significance after incorporating Mitigation Measure AQ-1 for Impact 4.2B and Impact 4.2C on Page 4.2-25, the Lead Agency stated that Impacts 4.2B and 4.2C would remain significant and unavoidable with adherence to existing regulation and implementation of Mitigation Measures AQ-1. (Emphasis added). Therefore, SCAQMD staff recommends that the Lead Agency correct the inconsistent conclusions in the Final EIR. As stated in the Draft EIR, the determination made for Impact 4.2.B (Page 4.2-18) and 4.2.C (Page 4.2-22) that impacts would be less than significant was correct as presented in the Draft EIR. However, SCAQMD staff is correct in noting on Page 4.2-25 (Level of Significance with Mitigation Incorporated) of the Draft EIR that impacts were determined to remain significant and unavoidable with implementation of Mitigation Measure AQ-1. However, this conclusion was incorrect, and has been changed in 2.N. of the Errata. As discussed in Response B2, B5, and B6 above, an analysis of potential future construction emissions during Realistic Buildout of the Specific Plan shows that emissions of criteria pollutants during construction will be below CEQA criteria pollutant significance thresholds and localized significance thresholds (See Tables 4.2-5, 4.2-6, and 4.2-7 of the Errata). In addition, Tables 4.2-9 and 4.2-10 (previously Tables 4.2-5 and 4.2-6) of the Errata section of the Final EIR show that net operational emissions would not exceed SCAQMD regional CEQA significance thresholds for any criteria pollutant. As such, Mitigation Measure AQ-1 has ARROW HIGHWAY SPECIFIC PLAN 2-19
FINAL ENVIRONMENTAL IMPACT REPORT Comment Table 2-6 Draft EIR Comments and Responses Response been removed from the Final EIR and is no longer required to reduce operational impacts to less than significance because impacts will remain less than significant. B12. Recommended Changes to Existing Mitigation Measure AQ-1: The Lead Agency proposed to incorporate Mitigation Measure AQ-1 to reduce the Proposed Project s operational air quality impacts. As shown in Table 1 of the Draft EIR, Mitigation Measure AQ-1 requires implementation of nine transportation demand management (TDM) strategies included in SCAG s 2012 RTP/SCS. SCAQMD staff is concerned about Mitigation Measure AQ-1. First, it is not clear what assumptions and criteria that the Lead Agency used for quantifying emission reductions from implementing this Mitigation Measure. Second, Mitigation Measure AQ-1 lacks specific details. For example, for TDM strategies 1 and 2, there are no specific details about where and how many bicycle parking (racks, lockers, or bike station), showers, and lockers will be implemented within the Proposed Project s Planning Area. Another example is TDM strategy 6 what is the maximum parking for the Proposed Project s Planning Area or what criteria (e.g., square footage or floor area ratio) will the Lead Agency will to determine parking maximums. In general, formulation of mitigation measures should not be deferred until some future time. However, in some situations, deferral of the specific details of mitigation may be allowable under CEQA when it is impractical or infeasible to fully formulate the details of a mitigation measure at the time or project approval. When deferring specifics of mitigation measures, the Lead Agency should specify performance standards which would mitigate the significant effect of the project (CEQA Guidelines Section 15126.4). Deferral of mitigation details may be improper where performance standards are not specified, and Lead Agency does not provide an explanation for why such standards are impractical or infeasible to provide at the time of certification of the EIR. Since the TDM strategies in Mitigation Measure AQ-1 do not include specific details, the Lead Agency should, at a minimum, develop and incorporate performance standards for each TDM strategies in the Final EIR. B13. The Lead Agency proposes to' implement applicable City of Glendora General Plan goals and policies to improve air quality through the reduction of total air emissions, education of the public on pollution control measures, and encouraging the best use of available technologies. SCAQMD staff recommends that the Lead Agency incorporate the following considerations before implementing Air Quality Policies 3.2, 4.2, and 7.3 for the As shown in 1.A., 1.B., 2.C., 2.D., 2.E., 2.I., 2.J., and 2.K. of the Errata, and as discussed in detail in Response B1 to B3, B5 to B7, B10, and B11 the Lead Agency has updated the Draft EIR s impact analyses to reflect the revised land use numbers for the Realistic Buildout scenario and none of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR. Specifically, Tables 4.2-9 and 4.2-10 (previously Tables 4.2-5 and 4.2-6) of the Errata section of the Final EIR show that net operational emissions would not exceed SCAQMD regional CEQA significance thresholds. This determination was made for both the Realistic Buildout and the Maximum Buildout scenarios because neither scenario will create net emissions that will exceed SCAQMD regional CEQA significance thresholds. Accordingly, Mitigation Measure AQ-1 is no longer required to reduce impacts to less than significant levels and has been removed from the EIR. As explained in Response B1, the analysis of the maximum buildout scenario is intended for the purpose of fully disclosing information to the public and is not used for making impact determinations. Since the implementation of the proposed Specific Plan would not result in significant air quality impacts, and Draft EIR Mitigation Measure AQ-1 is no longer included in the EIR, no further response to this comment is required. The SCAQMD has provided the City with certain considerations regarding the implementation of existing General Plan policies, as well as additional information regarding the limits and enforceability of high efficiency filters capable of reducing indoor exposure to TACs. This additional information does not materially change the analyses or findings of the Draft EIR for several reasons. 2-20 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Proposed Project. Comment Table 2-6 Draft EIR Comments and Responses 1. Air Quality Policy 3.2 requires "avoidance of placing residential and other sensitive receptors in close proximity to businesses (commercial or industrial) that emit toxic or harmful air contaminants to the greatest extent possible." In the event that high efficiency or enhanced filtration units are installed at residential and other sensitive receptors to minimize health impacts from exposures to toxic air contaminants such as DPM emissions, SCAQMD staff recommends that the Lead Agency consider their limits and ensure that they are enforceable throughout the lifetime of the Proposed Project. Detailed consideration is italicized as follows: Limits to High Efficiency or Enhanced Filtration Units SCAQMD staff recommends that the Lead Agency consider the limitations of the high efficiency or enhanced filtration units. For example, in a study that SCAQMD conducted to investigate filters 23 a cost burden is expected to be within the range of $120 to $240 per year to replace each filter. In addition, because the filters would not have any effectiveness unless the HVAC system is running, there may be increased energy costs to the resident. It is typically assumed that the filters operate 100 percent of the time while residents are indoors, and the analysis in the Draft EIR does not account for the times when the residents have their windows or doors open or are in common space areas of the project. In addition, these filters have no ability to filter out any toxic gases from vehicle exhaust. The presumed effectiveness and feasibility of any filtration units should therefore be evaluated in more detail prior to assuming that they will sufficiently alleviate near roadway exposures to DPM emissions. The evaluation should be included as a mandatory requirement as part of Policy AQ-3.2 or as a new air quality policy in the Final EIR. Enforceability of High Efficiency or Enhanced Filtration Units To ensure that high efficiency or enhanced filtration units are enforceable throughout the lifetime of the Proposed Project as well as effective in reducing exposures to DPM emissions, SCAQMD staff recommends that the Lead Agency provide additional details on future operational and maintenance implementation and monitoring of filters in the Final EIR. At a minimum, the Final EIR should provide detailed information about the responsible implementing and enforcement agency (or entity); recommended schedules for Response First, as a point of clarification, the City is not amending or revising existing General Plan policies pertaining to the control and/or reduction of air pollutant emissions and associated air quality impacts. Thus, changes to existing GP policies are outside the scope of the analysis presented in the Arrow Highway Specific Plan EIR. In addition, the Draft EIR, as revised by this Final EIR (see 2.M. of the Errata), includes a qualitative assessment of potential health risks that concludes the implementation of the Specific Plan would not generate or expose existing receptors to substantial TAC concentrations or significant TAC-related health risks (see Response B10). The City may consider the information provided by the SCAQMD on high efficiency filters during subsequent project level environmental reviews, as appropriate and necessary for the specific project being evaluated. Second, the Draft EIR evaluated the potential for the implementation of the proposed Specific Plan to result in new residences sited near a high-volume freeway or other sources of air pollution. As explained on page 4.2-23 of the Draft EIR, there are no high-volume roadways within 500 feet of the planning area. In addition, 2.N. of the Errata includes a qualitative analysis of potential health risks that indicates the proposed Specific Plan would not expose new sensitive receptors to substantial adverse health risks from any other source of air pollution. Finally, the City will continue to implement General Plan Policy 7.3 and support the SCAQMD s efforts to require compliance with applicable rules and regulations. A reference to General Plan Policies AQ-3.2, AQ-4.2 and AQ-7.3 is included in 2.N. of the Errata in the updated discussion of Toxic Air Contaminants., ARROW HIGHWAY SPECIFIC PLAN 2-21
FINAL ENVIRONMENTAL IMPACT REPORT Comment Table 2-6 Draft EIR Comments and Responses replacing the high efficiency or enhanced filtration units; ongoing monitoring schedules; ongoing cost sharing strategies, if any, for replacing the high efficiency or enhanced filtration units; disclosure on increased energy costs for running the HVAC system to prospective residents; criteria for assessing progress in installing and replacing the enhanced filtration units; and process for evaluating the effectiveness of the enhanced filtration units. Enforceability should be made a mandatory requirement as part of Policy AQ-3.2 or as a new air quality policy in the Final EIR. 2. Air Quality Policy 4.2 requires that sensitive receptors are separated, buffered, and protected from significant sources of pollution to the greatest extent possible. SCAQMD staff recommends that the Lead Agency consider the guidance regarding residence sited near a high-volume freeway or other sources of air pollution. Detailed consideration is italicized as follows: Guidance Regarding Residences Sited Near a High- Volume Freeway or Other Sources of Air Pollution SCAQMD staff recognizes that there are many factors Lead Agencies must consider when making local planning and land use decisions. To facilitate stronger collaboration between Lead Agencies and the SCAQMD to reduce community exposure to source-specific and cumulative air pollution impacts, the SCAQMD adopted the Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning in 2005. This Guidance Document provides suggested policies that local governments can use in their General Plans or through local planning to prevent or reduce potential air pollution impacts and protect public health. SCAQMD staff recommends that the Lead Agency review this Guidance Document as a tool when making local planning and land use decisions. This Guidance Document is available on SCAQMD s website at: http://www.aqmd.gov/docs/default-source/planninglairqualitv-guidance/complete-guidance-document.pdf Additional guidance on siting incompatible land uses (such as placing homes near freeways or other polluting sources) can be found in the California Air Resources Board's (CARB) Air Quality and Land Use Handbook: A Community Health Perspective, which can be found at: http://www.arb.ca.gov/ch/handbook.pdf 3. Air Quality Policy 7.3 supports the SCAQMD's efforts to require stationary air pollution sources, such as Response 2-22 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment Table 2-6 Draft EIR Comments and Responses gasoline stations, restaurants with charbroilers and deep fat fryers, to comply with and exceed applicable SCAQMD rules and control measures. Detailed consideration is italicized as follows: SCAQMD Permits If any subsequent development or activities implemented under the Proposed Project require a permit from SCAQMD, SCAQMD is a Responsible Agency. For more information on permits, please visit SCAQMD webpage at: http://www.aqmd.gov/home/permits Questions on permits can be directed to SCAQMD's Engineering and Permitting staff at (909) 396-3385. Response B14. Additional Recommended Mitigation Measures: CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized during project construction and operation to minimize or eliminate these impacts. SCAQMD staff recommends that the Lead Agency incorporate the following mitigation measures in the Final EIR to further reduce emissions, particularly from NOx, VOC, and particulate matters. Additional information on potential mitigation measures as guidance to the Lead Agency is available on the SCAQMD CEQA Air Quality Handbook website. a. Require all off-road diesel-powered construction equipment meet or exceed Tier 4 off-road emissions standards. A copy of the fleet's tier compliance documentation, and CARB or SCAQMD operating permit shall be provided to the Lead Agency at the time of mobilization of each applicable unit of equipment. In the event that all construction equipment cannot meet the Tier 4 engine certification, the Lead Agency must demonstrate through future study with written findings supported by substantial evidence before using other technologies/strategies. Alternative strategies may include, but would not be limited to, reduction in the number and/or horsepower rating of construction equipment and/or limiting the number of individual construction project phases occurring simultaneously. b. Require the use of 2010 model year diesel haul trucks that conform to 20 10 EPA truck standards or newer diesel haul trucks (e.g., material delivery trucks and soil import/export) during construction and operation, and if the Lead Agency determines that 20 10 model year or newer diesel haul trucks are not feasible, the Lead Agency shall use trucks that meet EPA 2007 model year NOx emissions requirements, at a minimum. c. Require that 240-Volt electrical outlets or Level 2 As described in Response B1 and B12, the Lead Agency has updated the Draft EIR s impact analyses to reflect the revised land use numbers for the Realistic Buildout scenario and none of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR. The Errata section of the Final EIR presents the updated air quality impact analysis. Specifically, Tables 4.2-5 to 4.2-7 and Tables 4.2-9 and 4.2-10 (previously Tables 4.2-5 and 4.2-6 in the Draft EIR) show that the implementation of the proposed Specific Plan would not generate construction or net operational emissions that exceed any SCAQMD regional or localized CEQA significance thresholds. Since the implementation of the proposed Specific Plan would not result in significant air quality impacts, and Draft EIR Mitigation Measure AQ-1 is no longer included in the EIR, no further response to this comment is required. ARROW HIGHWAY SPECIFIC PLAN 2-23
FINAL ENVIRONMENTAL IMPACT REPORT Comment Table 2-6 Draft EIR Comments and Responses chargers be installed in parking lots that would enable charging of NEVs and/or battery powered vehicles. Vehicles that can operate at least partially on electricity have the ability to substantially reduce the significant NOx and ROG impacts from this project. It is important to make this electrical infrastructure available when the project is built so that it is ready when this technology becomes commercially available. The cost of installing electrical charging equipment onsite is significantly cheaper if completed when the project is built compared to retrofitting an existing building. Therefore, SCAQMD staff recommends the Lead Agency require the Proposed Project be constructed with the appropriate infrastructure to facilitate sufficient electric charging for vehicles to plug-in. d. Maximize use of solar energy including solar panels; installing the maximum possible number of solar energy arrays on the building roofs and/or on the Project site to generate solar energy for the facility. e. Limit parking supply and unbundle parking costs. f. Maximize the planting of trees in landscaping and parking lots. g. Use light colored paving and roofing materials. h. Install light colored "cool" roofs and cool pavements. i. Require use of electric or alternatively fueled sweepers with HEPA filters. j. Require use of electric lawn mowers and leaf blowers. k. Utilize only Energy Star heating, cooling, and lighting devices, and appliances. l. Use of water-based or low VOC cleaning products. To further reduce particulate matter from the Proposed Project, SCAQMD staff recommends that the Lead Agency include the following mitigation measures in the Final EIR. a. Suspend all soil disturbance activities when winds exceed 25 mph as instantaneous gusts or when visible plumes emanate from the site and stabilize all disturbed areas. b. Appoint a construction relations officer to act as a community liaison concerning on-site construction activity including resolution of issues related to generation. c. Sweep all streets at least once a day using SCAQMD Rule 1186, 1186.1 certified street sweepers or roadway washing trucks if visible soil materials are carried to adjacent streets (recommend water sweepers with reclaimed water). d. Apply water three times daily, or non-toxic soil stabilizers according to manufacturers' specifications, to all unpaved parking or staging areas, unpaved road surfaces, or to areas where soil is disturbed. Response B15. Compliance with SCAQMD Rule 403, Rule 403(e), and All references to SDCAPCD have been removed. A 2-24 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Rule 1113: Comment Table 2-6 Draft EIR Comments and Responses a. The Lead Agency discussed that the Proposed Project is subject to SDCAPCD Rule 55 regulating fugitive dust. Since the Proposed Project, in its entirety, is located within SCAQMD, the Proposed Project is subject to SCAQMD rule regulating fugitive dust. Therefore, the Lead Agency should include a discussion to demonstrate how the Proposed Project will comply with SCAQMD Rule 403. Dust, in the Final EIR. Compliance with SCAQMD Rule 403 will reduce particulate matters from the Proposed Project. b. In addition to the discussion on general compliance with SCAQMD Rule 403 in the Final EIR, and since the Proposed Project is a large operation of approximately 106 acres (50-acre sites or more of disturbed surface area; or daily earth-moving operations of 3,850 cubic yards or more on three days in any year) in the South Coast Air Basin. The Lead Agency is required to comply with SCAQMD Rule 403(e) - Additional Requirements for Large Operations, which includes requirements to provide Large Operation Notification Form 403 N, appropriate signage, additional dust control measures, and employment of a dust control supervisor that has successfully completed the Dust Control in the South Coast Air Basin training class. Therefore, SCAQMD recommends that the Lead Agency include a discussion to demonstrate specific compliance with SCAQMD Rule 403(e) in the Final EIR. Compliance with SCAQMD Rule 403(e) will further reduce particulate matters from the Proposed Project. c. The Lead Agency discussed that the Proposed Project is subject to SDCAPCD Rule 67.0.1 regulating VOC content of architectural coating. Since the Proposed Project, in its entirety, is located within SCAQMD, the Proposed Project is subject to SCAQMD rule regulating architectural coating. Therefore, the Lead Agency should include a discussion to demonstrate how the Proposed Project will comply with SCAQMD Rule 1113, Architectural Coating, in the Final EIR. Compliance with SCAQMD Rule 403 will reduce VOC emissions from the Proposed Project. Response description of applicable SCAQMD rules and regulations has been included in 2.A. of the Errata. This SCAQMD comment does not identify new significant impacts, substantially increase the severity of impacts, identify new feasible alternatives that would reduce significant impacts, nor identify inadequacies in the analysis. No further response is required. B16. Other Comment: According to the Notice of Availability (Notice) for the Proposed Project, the Draft EIR is available for a 45-day public review and comment period beginning Thursday, January 18, 2018 and ending Monday, March 5. 2018. (Emphasis added). However, the Notice also says that "any persons wishing to comment on the Draft EIR may provide written comments [...] by Monday February 26. SCAQMD staff is accurate in pointing out the mistake in the NOA stating that any persons wishing to comment on the Draft EIR may provide written comments by Monday February 26, 2018. The correct text should have read: The DEIR is available for public review and comment for forty-five (45) days commencing ARROW HIGHWAY SPECIFIC PLAN 2-25
FINAL ENVIRONMENTAL IMPACT REPORT Comment 2018." (Emphasis added). Pursuant to CEQA Guidelines Section 15087, the notice of availability of a Draft EIR should include, among others, the starting and ending dates for the review period during which the lead agency will receive comments. Since there are two publicly noticed comment ending dates, the Lead Agency should correct the comment ending date in the Notice. C. Sanitation Districts of Los Angeles County Table 2-6 Draft EIR Comments and Responses Response Thursday, January 18, 2018 and ending Monday, March 5, 2018 at 5:00 pm. Any person wishing to comment on the DEIR may provide written comments to the City during the public review period, care of Jeff Kugel, Planning Director, by Monday March 5, 2018. The Lead Agency will correct the comment ending date in the NOA per SCAQMD s request. It should be noted that this typo did not preclude any public agency from submitting comments on the Draft EIR. C1. The Sanitation Districts of Los Angeles County (Districts) received a Draft Environmental Impact Report (DEIR) for the subject project on January 19, 2018. The specific plan area is located within the jurisdictional boundaries of District No. 22. We offer the following comments: C2. Environmental Setting, page 4.11-1, second Wastewater paragraph - The wastewater generated by the City of Glendora (City) is treated at one or more of the following: the Joint Water Pollution Control Plant located in the City of Carson, which has a capacity of 400 million gallons per day (mgd) and currently produces an average flow of 256.4 mgd; the San Jose Creek Water Reclamation Plant (WRP) located adjacent to the City of Industry, which has a capacity of 100 mgd and currently processes an average flow of 65.1 mgd; the Whittier Narrows WRP located near the City of South El Monte, which has a capacity of 15 mgd and currently produces an average recycled water flow of 7.3 mgd; and/or the Los Coyotes WRP located in the City of Cerritos, which has a capacity of 37.5 mgd and currently produces an average recycled water flow of20.5 mgd. Adjust accordingly throughout the document. C3. Environmental Impacts, page 4.11-12, first paragraph from the top - The Districts are empowered by the California Health and Safety Code to charge a fee for the privilege of connecting (directly or indirectly) to the Districts' Sewerage System for increasing the strength or quantity of wastewater discharged from connected facilities. This connection fee is a capital facilities fee that is imposed in an amount sufficient to construct an incremental expansion of the Sewerage System to accommodate proposed projects. Payment of a connection fee will be required before a permit to connect to the sewer is issued. For more information and a copy of the Connection Fee Information Sheet, go to www.lacsd.org, Wastewater & Sewer Systems, click on Will Serve Program, and search for the appropriate link. This is an informational comment. No changes to the EIR have been made as a result of this comment. As shown in the Errata section of the Final EIR, the wastewater treatment information provided by SDLAC has been incorporated into the text. No further changes have been made as a result of this comment. As shown in the Errata section of the Final EIR, information pertaining to connection fees provided by SDLAC has been incorporated into the text. No further changes have been made as a result of this comment. 2-26 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment Table 2-6 Draft EIR Comments and Responses Response C4. Environmental Impacts, page 4.11-12, second paragraph from the top - In order to estimate the volume of wastewater a project will generate, go to www.lacsd.org, Wastewater & Sewer Systems, click on Will Serve Program, and click on the Table 1, Loadings for Each Class of Land Use link for a copy of the Districts' average wastewater generation factors. C5. Wastewater Collection, Treatment, and Disposal, page 6-27, second paragraph- The information states, "During FY 2013-14, approximately 76 percent of treated water at the SJCWRP is reused in a recycled water project." That percentage has increased significantly during FY 2016-17, currently over 97 percent of the recycled water produced at the San Jose Creek WRP is beneficially reused. C6. All other information concerning Districts' facilities and sewerage service contained in the document is current. This is an informational comment. A conservative estimate of wastewater generation was provided in Table 4.11-2 of the Draft EIR. These estimates are based on the City of Los Angeles Sewer System Management Plan guidance for calculating sewer flow. No changes to the EIR have been made as a result of this comment. This is an informational comment and has been noted. Because the percentage of treated water was underestimated in the Draft EIR, no change to the severity of an impact would occur and no changes to the EIR have been made as a result of this comment. This comment has been noted. No changes to the EIR have been made as a result of this comment. D. California Department of Transportation D1. Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The Arrow Highway Specific Plan identifies long-term vision and objectives for land use development and public improvements along a 2.73 mile portion of Arrow Highway in the southern portion of the City of Glendora. D2. Upon reviewing the Draft Environmental Impact Report (DEIR), Caltrans has the following comments: In general Caltrans supports specific plans designed to create an urban form that fosters a safer, pleasant, and convenient pedestrian experience. With respect to complete streets elements, the DEIR notes there are challenges to implementing such measures because of multi-jurisdictional ownership along Arrow Highway. We encourage the lead agency to collaborate with its adjacent local partners to make necessary active transportation improvements possible, especially if there is existing excess width that can be allocated to efficient and sustainable transportation modes and accommodate better bikeways or other active transportation improvements. This is an introductory comment. No changes to the EIR have been made as a result of this comment. This comment has been noted. The Lead Agency will collaborate with adjacent local partners to make necessary active transportation improvements possible, especially if there is existing excess width that can be allocated to efficient and sustainable transportation modes and accommodate better bikeways or other active transportation improvements. No changes to the EIR have been made as a result of this comment. E. City of San Dimas E1. We appreciate the opportunity to provide comments on the Draft Environmental Impact Report for the Arrow Highway Specific Plan. The City of San Dimas is closest to As previously stated in Response B1 above, the Lead Agency s analysis of Specific Plan impacts was based on the Realistic Buildout scenario. The Errata section of the ARROW HIGHWAY SPECIFIC PLAN 2-27
FINAL ENVIRONMENTAL IMPACT REPORT Comment the Project Area-East of the Specific Plan. The City has concerns with the lack of full disclosure of potential impacts of the maximum growth scenario allowed under the Arrow Highway Specific Plan and environmental impacts that the Project may have in Glendora and surrounding communities. The DEIR attempts to provide "a self-mitigated Specific Plan" perspective of the Project even when ground level view and review is needed. Table 2-6 Draft EIR Comments and Responses Response Final EIR includes revisions that clarify and clearly indicate that Maximum Buildout scenario emissions were presented for information purposes only, and the Lead Agency is not basing any air quality significance determinations, or any of the significance determinations for any other parts of the EIR on the Maximum Buildout scenario. The City has fully disclosed all potential impacts based on the Realistic Scenario. The EIR has demonstrated all potential impacts of the project would be less than significant and, therefore, no mitigation measures are included, nor are they necessary to comply with CEQA. In addition, just as E2. Section 15064(d) of the CEQA Guidelines states that, "in evaluating the significance of the environmental effect of a project, the lead agency shall consider direct physical changes in the environment which may be caused by the project and reasonably foreseeable indirect physical changes in the environment which may be caused by the project." The "programmatic" nature of this DEIR should not allow for a lack of detailed analyses. CEQA requires that a program EIR provides an in-depth analysis of a large project, looking at effects "as specifically and comprehensively as possible" (CEQA Guidelines Section 15168(aL (c) (5)). Because it looks at the big picture, a program level EIR must provide "more exhaustive consideration" of effect and alternative than an EIR for an individual action and must consider "cumulative impacts that might be slighted by a case-by-case analysis." CEQA Guidelines Sections 15168(b}(1) and (2). It is especially important the environmental review of a Specific Plan be thorough because CEQA specifically exempts future projects from CEQA review to the extent they are consistent with the Specific plan, refer to CEQA Guidelines Section 15183{1). A "program" or "first tier" EIR is expressly not a tool to be used for deferring analysis of significant impacts. It is instead an opportunity to analyze impacts common to a series of smaller projects in order to avoid repetitious analyses. Therefore, it is of particular importance that the DEIR for this Project analyze the overall impact for the complete level of development it would authorize under the Specific Plan, rather than when specific, individual projects are proposed at a later time. The Lead Agency has fully considered the direct physical changes in the environment that may be caused by the project and reasonably foreseeable indirect physical changes in the environment that may be caused by the project. The Maximum Theoretical Buildout assumes that each parcel within the Specific Plan area will redevelop to the maximum intensity or density allowed during the Plan's implementation period. It does not provide for the reduction of development potential as a result of implementing site design requirements (setbacks, required open space, etc.), height limitations, parking, and other development standards. As such, the Maximum Theoretical Buildout is an unrealistic development scenario that will never be constructed regardless of the planning period. The Realistic Buildout evaluates the likelihood of the project area's parcels to redevelop during the planning period; estimates probable site development potentials based on the proposed development standards and guidelines; and adjusts the land use "splits" for mixed-use, commercial, and residential based on market analysis, specific to the proposed project. As such, the Realistic Buildout is just that, it is a refined estimate of the proposed project's development potential. The Realistic Buildout provides a sound planning basis to analyze the proposed projects' impacts without unrealistically overstating impacts. With respect to CEQA Guidelines Section 15168(a) and 15168(c)(5), the EIR is in accordance with subsection (a) and with respect to subsection (c)(5) it does not conflict with the narrative in this subsection. In addition, the commenter does not indicate how the DEIR conflicts with these specific provisions of CEQA. With respect to CEQA Guidelines Section 15168(b)(1) and (2) which provides information describing the advantages of using a Program EIR, the DEIR is not in conflict. In fact, 2-28 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS Comment Table 2-6 Draft EIR Comments and Responses Response the DEIR provides a thorough evaluation of project effects, alternatives (See Section 5.0 of the DEIR), and potential cumulative impacts (See Section 6.0 of the DEIR). With respect to the reference CEQA Guidelines Section 15183(1) it is not clear what the commenter is referencing since the most recent (2018) CEQA Guidelines do not include a subsection 15183(1). Section 15183 is entitled Projects Consistent With a Community Plan or Zoning. In any event the Commenter s assertion that this section specifically exempts future projects from CEQA review if consistent with the Specific Plan is not correct. In fact, the word exempt does not show up anywhere in Section 15183. Section 15183 actually lays out the ground rules for the environmental review of project level proposals that fall under the umbrella of a certified program level EIR. Section 15183(a) states: CEQA mandates that projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces the need to prepare repetitive environmental studies. In addition, Subsection 15183(b) clearly contemplates the need for project level environmental review for development proposal because it indicates that an agency would evaluate potential project affects through an initial study or other analysis to determine whether potential project impacts were adequately evaluated in a programlevel EIR. E3. The DEIR should accurately disclose the impact of the maximum intensity and density allowed by the Specific Plan it proposes to adopt. The Draft EIR does not identify and analyze numerous potential impacts and, in most of the cases, defers that analysis to future study as part of project review and permitting (Air Quality, Greenhouse Gas Emissions, and Traffic). The approach improperly defers analysis to future mitigation. While this approach may be necessary in cases where it is not possible to assess impacts at the program level, such analysis is possible in this case and, therefore, required. Even at the program level, the EIR preparers can anticipate that these impacts could occur, quantify the impacts, and identify detailed mitigation measures. Otherwise, the DEIR does not conduct the Approval of the Specific Plan does not exempt the City of Glendora from their environmental review responsibilities under CEQA. As shown in the Errata section of this Final EIR, and as explained in more detail in Responses B5, B7, B8, B9, and B11 above, the City has adequately evaluated the potential impacts of the Specific Plan under the Realistic Buildout scenario. In addition, as described in more detail in Response B6, the City has revised the Draft EIR to quantify and evaluate potential regional and local construction emissions associated with Specific Plan development; the results of this evaluation indicate that construction emissions would not exceed SCAQMD regional or local significance thresholds. Finally, as explained in Response to Comment B1, the City has revised the Draft EIR s impact analyses to reflect ARROW HIGHWAY SPECIFIC PLAN 2-29
FINAL ENVIRONMENTAL IMPACT REPORT Comment necessary evaluations and impermissibly defers them, which will likely deprive the public of any opportunity to review these impacts. Table 2-6 Draft EIR Comments and Responses Response the updated land use numbers for the Realistic Buildout scenario and none of the changes made to the EIR s Air Quality analysis result in new or more severe impacts than identified in the Draft EIR. Moreover, as previously stated in Response B1 above, the Lead Agency s analysis of Specific Plan impacts was correctly based on the Realistic Buildout scenario. The Errata section of the Final EIR includes revisions that clarify and clearly indicate that Maximum Buildout scenario emissions were presented for information purposes only, and the Lead Agency is not basing any air quality or other significance determinations on the Maximum Buildout scenario. The Maximum Buildout Scenario is not used in evaluate any of the potential project impacts, and will not be used to evaluate any future project-level proposal with the Arrow Highway Specific Plan. The potential impacts of the Specific Plan are clearly laid out in the EIR. The contention by the commenter that the Lead Agency is deferring analysis or mitigation is unfounded and unsubstantiated. Also see Response E-2, above. E4. The City of San Dimas requests that notification of future development within the Arrow Highway Specific Plan, especially projects within the Project Area- East be provided to allow review and input from the City. In addition, since a detailed project level analysis for the Arrow Highway Specific Plan is being deferred, the City is concerned regarding housing projects that might qualify for an exemption but, if completed, would have a significant effect on the environment due to unusual circumstances or cumulative impacts of successive projects. As previously stated, the City is concerned these impacts and related mitigations will not be properly addressed when project level analysis is conducted at a later time. The City of Glendora is not deferring analysis or mitigation (see discussion under response to comment E3, above). The City of Glendora will continue to notify the City of San Dimas of discretionary projects within the Arrow Highway Specific Plan, in accordance with State law and City noticing requirements. Analysis is not being deferred and approval of the Specific Plan does not create any special exemptions, beyond what would otherwise already be permitted under CEQA and the CEQA Guidelines. See Responses E-1 through E-3, above. 2-30 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS COMMENT A COUNTY OF LOS ANGELES FIRE DEPARTMENT (TAKESHITA) ARROW HIGHWAY SPECIFIC PLAN 2-31
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FINAL ENVIRONMENTAL IMPACT REPORT COMMENT B SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SUN) 2-40 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS ARROW HIGHWAY SPECIFIC PLAN 2-41
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2.0 RESPONSE TO COMMENTS COMMENT C LOS ANGELES COUNTY SANITATION DISTRICTS (RAZA) ARROW HIGHWAY SPECIFIC PLAN 2-51
FINAL ENVIRONMENTAL IMPACT REPORT 2-52 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS COMMENT D CALIFORNIA DEPARTMENT OF TRANSPORTATION (LEE) ARROW HIGHWAY SPECIFIC PLAN 2-53
FINAL ENVIRONMENTAL IMPACT REPORT COMMENT E CITY OF SAN DIMAS (WONG) 2-54 CITY OF GLENDORA
2.0 RESPONSE TO COMMENTS ARROW HIGHWAY SPECIFIC PLAN 2-55
3.0 ERRATA This section identifies revisions to the Arrow Highway Specific Plan Draft EIR to incorporate clarifications prepared in response to comments or minor errors corrected through subsequent review. Additions are shown in underline. Deletions are shown in strikethrough. None of the revisions to the Draft EIR represents a substantial increase in the severity of an identified significant impact or the identification of a new significant impact, mitigation, or alternative considerably different from those already considered in the Draft EIR. ARROW HIGHWAY SPECIFIC PLAN 3-1
FINAL ENVIRONMENTAL IMPACT REPORT Draft EIR Volume I Section 2.0: Executive Summary The following revisions are made to Section 2.0 (Executive Summary) pages 2-1 through 2-13: The Specific Plan is estimated to support development of over 1.4 978,000 million square feet (SF) (maximum buildout) or 647,810 422,540 SF (expected buildout) of non-residential development, 1,611 1,412 dwelling units (DU) (maximum buildout) or 739 604 DU (expected buildout), and 8.6 acres of open space. Table 2-1 (Existing Planning Area Land Uses) summarizes existing land use in the Planning Area. Table 1-1 2-2 (Realistic Development Potential) summarizes the Specific Plan s estimated development under realistic conditions. Table 1-2 2-3 (Maximum Development Potential) summarizes the Specific Plan s estimated maximum development potential. TABLE 2-1 EXISTING PLANNING AREA LAND USES Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations Single Family Residential 5.5 -- -- 17 48 Multi Family Residential 11.8 -- -- 163 458 Mobile Homes and Trailer Parks 11.8 -- -- 140 394 Commercial Designations Retail Stores and Commercial Services 19.3 291,078 685 -- -- Food Service/Bar 5.7 47,937 160 -- -- Service Station/Gas Station 9.6 130,883 374 -- -- Other Commercial 0.3 4,937 12 -- -- General Office Use 6.0 83,129 196 -- -- Institutional/ Utility Designations Institutional 8.9 140,077 -- -- -- Public Facility 2.2 19,963 -- -- -- Utility and Flood Control 9.5 8,202 -- -- -- Industrial Designations Light Industrial 13.0 218,300 249 -- -- Parking Parking 1.1 2,016 -- -- -- Vacant Vacant 1.4 -- -- -- -- 106.1 946,522 1,675 320 900 3-2 CITY OF GLENDORA
3.0 ERRATA TABLE 2-1 2-2 REALISTIC DEVELOPMENT POTENTIAL Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential C-R3 Corridor Medium/High- Density Residential* C-BR Corridor Buffer Residential C-HR Corridor High-Density Residential Commercial Designations 1.0 -- -- 7 6 20 16 1.1 -- -- 9.17 9 26 10.6 -- -- 85 239 27.8 -- -- 333 278 937 781 C-C3 Corridor Commercial* 5.1 33,540 78.92 79 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 228,480 128,670 538 302 119 90 335 254 MU-I Office/ Light Industrial Mixed-Use 11.1 10.1 64,520 54,650 78 63 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 135,120 75,600 386 217 126 87 354 245 MU-T Transition Mixed-Use 7.2 8.2 43,400 34,880 124 99 60 49 168 137 Industrial Designations C-1 Corridor Industrial 8.7 142,750 95,200 163 109 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 647,810 422,540 1,368 869 739 604 2,079 1,698 * City of Glendora Land Use, 2016 ARROW HIGHWAY SPECIFIC PLAN 3-3
FINAL ENVIRONMENTAL IMPACT REPORT TABLE 2-2 2-3 MAXIMUM DEVELOPMENT POTENTIAL Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential C-R3 Corridor Medium/High- Density Residential* C-BR Corridor Buffer Residential C-HR Corridor High-Density Residential Commercial Designations 1.0 1.1 -- -- 15 41 1.1 -- -- 23 64 10.6 -- -- 212 596 27.8 -- -- 833 694 2,342 1,952 C-C3 Corridor Commercial* 5.1 111,800 263 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 370,800 224,600 896 529 198 180 558 507 MU-I Office/ Light Industrial Mixed-Use 11.1 10.1 322,600 219,500 391 250 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 225,200 138,300 643 395 210 175 591 492 MU-T Transition Mixed-Use 7.2 8.2 86,800 94,200 148 271 120 113 338 319 Industrial Designations C-1 Corridor Industrial 8.7 285,500 190,400 36 216 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 1,412,700 978,800 2,768 1,924 1,611 1,412 4,531 3,971 * City of Glendora Land Use, 2016 3-4 CITY OF GLENDORA
3.0 ERRATA 1. Draft EIR Volume I Section 3.0: Project Description 1.A. The following INCLUSIONS are made to Section 3.0 (Project Description) page 3-1, last paragraph: Table 3-1 (Existing Planning Area Land Uses) summarizes existing land use in the Planning Area. TABLE 3-1 EXISTING PLANNING AREA LAND USES Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations Single Family Residential 5.5 -- -- 17 48 Multi Family Residential 11.8 -- -- 163 458 Mobile Homes and Trailer Parks 11.8 -- -- 140 394 Commercial Designations Retail Stores and Commercial Services 19.3 291,078 685 -- -- Food Service/Bar 5.7 47,937 160 -- -- Service Station/Gas Station 9.6 130,883 374 -- -- Other Commercial 0.3 4,937 12 -- -- General Office Use 6.0 83,129 196 -- -- Institutional/ Utility Designations Institutional 8.9 140,077 -- -- -- Public Facility 2.2 19,963 -- -- -- Utility and Flood Control 9.5 8,202 -- -- -- Industrial Designations Light Industrial 13.0 218,300 249 -- -- Parking Parking 1.1 2,016 -- -- -- Vacant Vacant 1.4 -- -- -- -- 106.1 946,522 1,675 320 900 1.B. The following revisions are made to Section 3.0 (Project Description) pages 3-4 through 3-5: The Specific Plan is estimated to support development of over 1.4 978,000 square feet (SF) (maximum buildout) or 647,810 422,540 SF (expected buildout) of non-residential development, 1,611 1,412 dwelling units (DU) (maximum buildout) or 739 604 DU (expected buildout), and 8.6 acres of open space. Table 3-1 3-2 (Realistic Development Potential) summarizes the Specific Plan s estimated realistic development (see Exhibit 3-7, Proposed Land Use). Table 3-2 3-3 (Maximum Development Potential) summarizes the Specific Plan s development if the zoning classifications were built to their maximum development potential. ARROW HIGHWAY SPECIFIC PLAN 3-5
FINAL ENVIRONMENTAL IMPACT REPORT TABLE 3-1 3-2 REALISTIC DEVELOPMENT POTENTIAL Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential C-R3 Corridor Medium/High- Density Residential* C-BR Corridor Buffer Residential C-HR Corridor High-Density Residential Commercial Designations 1.0 -- -- 7 6 20 16 1.1 -- -- 9.17 9 26 10.6 -- -- 85 239 27.8 -- -- 333 278 937 781 C-C3 Corridor Commercial* 5.1 33,540 78.92 79 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 228,480 128,670 538 302 119 90 335 254 MU-I Office/ Light Industrial Mixed-Use 11.1 10.1 64,520 54,650 78 63 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 135,120 75,600 386 217 126 87 354 245 MU-T Transition Mixed-Use 7.2 8.2 43,400 34,880 124 99 60 49 168 137 Industrial Designations C-1 Corridor Industrial 8.7 142,750 95,200 163 109 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 647,810 422,540 1,368 869 739 604 2,079 1,698 * City of Glendora Land Use, 2016 3-6 CITY OF GLENDORA
3.0 ERRATA TABLE 3-2 3-3 MAXIMUM DEVELOPMENT POTENTIAL Non-Residential Zone Land Use Zone Area (ac.) Employees Dwelling Units Population Area (SF) Residential Designations C-R2 Corridor Medium-Density Residential C-R3 Corridor Medium/High- Density Residential* C-BR Corridor Buffer Residential C-HR Corridor High-Density Residential Commercial Designations 1.0 1.1 -- -- 15 41 1.1 -- -- 23 64 10.6 -- -- 212 596 27.8 -- -- 833 694 2,342 1,952 C-C3 Corridor Commercial* 5.1 111,800 263 -- -- Mixed-Use Designations MU-CC Commercial Core/ Mixed-Use 13.7 370,800 224,600 896 529 198 180 558 507 MU-I Office/ Light Industrial Mixed-Use 11.1 10.1 322,600 219,500 391 250 -- -- MU-NC Neighborhood Commercial/ Mixed-Use 11.2 225,200 138,300 643 395 210 175 591 492 MU-T Transition Mixed-Use 7.2 8.2 86,800 94,200 148 271 120 113 338 319 Industrial Designations C-1 Corridor Industrial 8.7 285,500 190,400 36 216 -- -- Open Space Designations OS-T Open Space/ Trail 8.6 -- -- -- -- Development Potential 106.1 1,412,700 978,800 2,768 1,924 1,611 1,412 4,531 3,971 * City of Glendora Land Use, 2016 ARROW HIGHWAY SPECIFIC PLAN 3-7
FINAL ENVIRONMENTAL IMPACT REPORT 2. Draft EIR Volume I Section 4.2: Air Quality 2.A. The following text revisions are made adding the following text to Section 4.2 (Air Quality) page 4.2-14, first paragraph: SCAQMD RULES AND REGULATIONS The SCAQMD adopts rules that establish permissible air pollutant emissions and governs a variety of business, processes, operations, and products to implement the AQMP and the various federal and State air quality requirements. In general, rules that would be applicable during buildout of the updated Specific Plan, include: Rule 401 (Visible Emissions) prohibits discharge into the atmosphere from any single source of emission for any contaminant for a period or periods aggregating more than three minutes in any one hour that is as dark or darker in shade than that designated as No. 1 on the Ringelmann Chart, as published by the U.S. Bureau of Mines. Rule 402 (Nuisance) prohibits discharges of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. Rule 403 ( Dust) prohibits emissions of fugitive dust from any grading activity, storage pile, or other disturbed surface area if it crosses the project property line or if emissions caused by vehicle movement cause substantial impairment of visibility (defined as exceeding 20 percent opacity in the air). Rule 403 requires the implementation of Best Available Control Measures and includes additional provisions for projects disturbing more than five acres and those disturbing more than fifty acres. Rule 1113 (Architectural Coatings) establishes maximum concentrations of VOCs in paints and other applications and establishes the thresholds for low-voc coatings. Rule 1403 (Asbestos Emissions from Demolition/Renovation Activities) specifies work practice requirements to limit asbestos emissions from building demolitions and renovation activities, including the removal and associated disturbance of asbestos containing materials. The requirements for demolition and renovation activities include asbestos surveying, notification, asbestos containing materials removal procedures and time schedules, asbestos containing materials handling and cleanup procedures, and storage, disposal, and land filling requirements for asbestos containing waste materials. 2.B. The following revisions are made to Table 4.2-3 in Section 4.2 (Air Quality), page 4.2-17: TABLE 4.2-3 PROJECT AIR QUALITY MONITORING SUMMARY 2014-2016 SCAQMD MAXIMUM DAILY EMISSIONS THRESHOLDS (LBS/DAY) 2.C. The following revisions are made to Section 4.2 (Air Quality), page 4.2-18, AQMP Consistency: A significant impact could occur if the proposed project conflicts with or obstructs the implementation of the South Coast Air Basin 2012 2016 Air Quality Management Plan. Conflicts and obstructions that hinder implementation of the AQMP can delay efforts to meet attainment deadlines for criteria pollutants and existing compliance with applicable air quality standards. Pursuant to the methodology provided in Chapter 12 of the 1993 SCAQMD CEQA 3-8 CITY OF GLENDORA
3.0 ERRATA Air Quality Handbook, consistency with the South Coast Air Basin 2012 2016 Air Quality Management Plan (AQMP) is affirmed when a project (1) does not increase the frequency or severity of an air quality standards violation or cause a new violation is consistent with the growth assumptions in the AQMP; and (2) is consistent with the growth assumptions in the AQMP does not increase the frequency or severity of an air quality standards violation, or cause a new one. Evaluating consistency with the AQMP requires comparison of the growth projections for the realistic buildout scenario of the proposed Specific Plan and the population, housing, and employment projections of the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) that are used in the AQMP. Consistency review is presented below herein: Consistency Criterion 1 refers to the growth forecasts and associated assumptions included in the 2016 AQMP. The 2016 AQMP was designed to achieve attainment for all criteria air pollutants within the basin while still accommodating growth in the region. Projects that are consistent with the AQMP growth assumptions would not interfere with attainment of air quality standards because this growth is included in the projections used to formulate the AQMP. The 2016 RTP/SCS population and employment projections for the City of Glendora, as well as the increase in population and employment that would occur with the implementation of the Arrow Highway Specific Plan, are shown in Table 4.2-4 (RTP/SCS and Specific Plan Growth Assumptions) below. As shown in Table 4.2-4, implementation of the proposed Specific Plan would not exceed the growth assumptions contained in the AQMP. Thus the Specific Plan would be consistent with AQMP Consistency Criterion 1. TABLE 4.1-4 RTP/SCS AND SPECIFIC PLAN GROWTH ASSUMPTIONS RTP/SCS Growth Assumption Specific Plan Metric 2012 2040 Net Growth Population 50,500 54,300 3,800 798 Employment 20,000 23,000 3,000-806 Source: SCAG, 2016. 1. Construction activities will occur concurrently with growth within the Specific Plan Planning Area. Typical development projects within the Specific Plan area will be exempt or subject to special situation conditions that will eliminate or substantially reduce environmental review in the future. These projects are presumed to have no significant impact on the environment pursuant to State law. Construction-related air quality impacts for typical residential and commercial development would be be less than significant, with mitigation incorporated, and would result in short-term construction emissions that are less than the CEQA significance thresholds established by the SCAQMD. Typical residential and commercial activities will not result in operational emissions that will exceed the daily threshold for NOX and particulate matter emissions, thus, while the project will contribute incrementally to increases in the frequency and severity of air quality standards violations for which the area is nonattainment, its contribution will not be considerable. 2. The CEQA Air Quality Handbook indicates that consistency with AQMP growth assumptions must be analyzed for new or amended General Plan elements, Specific Plans, and significant projects. Significant projects include airports, electrical generating facilities, petroleum and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and off-shore drilling facilities; therefore, the proposed project is not defined as significant. The proposed project includes a Specific Plan that will modify the land use designation of numerous parcels in the Planning Area; therefore, the project requires consistency analysis with the AQMP. 2.D. The following revisions are made to Section 4.2 (Air Quality), page 4.2-19, AQMP Consistency: Population The proposed Specific Plan includes land use designations that support development of up to 604 dwelling units accommodating a population of up to 1,698 residents at realistic buildout. This represents an increase of 284 dwelling units and 798 residents over existing conditions within the Planning Area. According to SCAG estimates, the ARROW HIGHWAY SPECIFIC PLAN 3-9
FINAL ENVIRONMENTAL IMPACT REPORT City of Glendora is anticipated to have a population of 54,300 residents in the year 2040. This represents an increase of 1,692 3,800 residents over the 2017 2012 population of 52,608 50,500 (DOF, 2017). The Specific Plan does not include excessive housing units that could lead to additional growth beyond 1,692 residents forecasted between 2017 and 2040. Impacts related to substantial population growth will be less than significant. The realistic buildout scenario of that includes the potential for an additional 284 dwelling units characterizes the anticipated scenario for providing opportunities for population growth in the area. As such, future residential development proposals in the Planning Area will be sufficient to provide for a portion of the City s housing demand while not inducing substantial growth and will not require future environmental review regarding this issue. Housing The proposed Specific Plan will allow for up to 284 additional households over existing conditions. SCAG growth projections indicate that up to 1,700 new dwelling units will be necessary to meet population demand in the City of Glendora between 2012 and 2040. Therefore, the 284 additional dwelling units generated by the proposed Specific Plan will not exceed the projected amount by 2040 and will contribute nearly a quarter of the necessary housing units needed to accommodate long-term growth. As a result, project-generated households will have a less than significant impact. Employment The proposed Specific Plan has the capacity to support up to 422,540 gross square feet of non-residential commercial space at realistic buildout- primarily retail, entertainment, and service operations. Using the Employment Density Study prepared for the SCAG region (SCAG 2001), the proposed Specific Plan could support up to 1,300 employees at one employee per 325 square feet for retail and service uses, which represents a net decrease over existing conditions. The SCAG RTP indicated that the City had 20,000 jobs in 2012 and is projected to increase to 23,000 jobs by 2040 for a net increase of 3,000 jobs. The increase number of jobs anticipated at completion of realistic buildout created by the proposed Project is within the growth assumptions estimated by SCAG and, thus, project-generated employment will have a less than significant impact. Consistency Criterion 2 refers to the CAAQS. SCAQMD has identified CO as the best indicator pollutant for determining whether air quality violations would occur since it is most directly related to automobile traffic, the emissions of which have been modeled by the SCAQMD to determine future air quality conditions. The CO hotspot analysis described below (see Section 4.2.D) indicates that the Specific Plan update would not result in a localized CO hotspot and, therefore, would not cause or contribute to an existing or projected air quality violation. As such, potential impacts with respect to consistency with the SCAQMD AQMP would be less than significant and no mitigation is required. Based on the consistency analysis above, the project will not conflict with the AQMP by resulting in a significant and unavoidable impact related to air quality standards; therefore, a cumulatively considerable impact would not occur. 2.E. The following revisions are made to Section 4.2 (Air Quality), page 4.2-20 through 4.2-22, Criteria Pollutant Emissions: An Air Quality and Climate Change Assessment air quality analysis, prepared by MIG, identified sources of criteria pollutant emissions that will result from construction and operation of the project. The assessment includes forecasting emissions generated by the proposed Specific Plan and evaluates the effects of those emissions, if any, and if any potentially significant impacts may occur. Although future projects occurring within the Planning Area would be guided by the goals and policies outlined in the Arrow Highway Specific Plan and the City s General Plan, the City s adoption of the proposed Specific Plan update would not authorize nor permit any individual projects to move forward at this time. Given the relatively small size of most parcels in the planning area, it is unlikely individual development projects would have a substantial effect on air quality throughout the Basin, or increase the frequency of or contribute substantially to an existing air quality violation. Nonetheless, the City has prepared an air quality analysis that focuses on the nature and magnitude of the change in the air quality environment due to implementation 3-10 CITY OF GLENDORA
3.0 ERRATA and realistic buildout of the proposed Specific Plan. The SCAQMD has not adopted plan-level significance thresholds. The SCAQMD and/or CARB monitor levels of criteria air pollutant concentrations in ambient air to evaluate attainment of CAAQS and NAAQS; the significance of the net change in criteria air pollutant emissions that the implementation of the Specific Plan could emit during construction and operation is evaluated below by comparing the potential levels of emissions from these activities against the SCAQMD s regional and localized significance thresholds. Construction Emissions The proposed Specific Plan would not directly result in construction of any development or infrastructure; however, future development supported by the Specific Plan would result in short-term construction-related criteria pollutant emissions. Short-term criteria pollutant emissions would occur during site preparation, grading, building construction, paving, and architectural coating activities associated with specific new development projects. Emissions would occur from use of equipment, worker, vendor, and hauling trips, and disturbance of onsite soils (fugitive dust). Pursuant to existing CEQA requirements, short-term, project-specific construction-related emissions will be analyzed as development proposals are submitted. Development of future projects within the Planning Area would be subject to SDCAPCD Rule 55 regulating fugitive dust and Rule 67.0.1 regulating the VOC content of architectural coating, the City s standard CEQA review process, and would be required to assess project-specific emissions in relation to the screening-level thresholds. Other mitigation will be applied, where necessary, and typically includes installation of diesel particulate filters on older construction equipment, limitations on idling, and limitations on hauling distances and or daily trips. Therefore, with implementation of existing regulations, future projects within the proposed Specific Plan Planning Area will not result in exceedances of short-term construction-related criteria pollutant emissions thresholds. Impacts from construction will be less than significant. Implementation of the Arrow Highway Specific Plan would lead to construction of new uses and redevelopment of existing occupied buildings. These development activities would generally involve demolition, site preparation, grading, building construction, paving, and architectural coating (i.e., painting) activities. dust (PM 10 ) emissions would typically be greatest during building demolition, site preparation, and grading due to the disturbance of soils and transport of material. NOx and other emissions would also result from the combustion of diesel fuels used to power off-road heavy-duty pieces of equipment (e.g., backhoes, bulldozers, excavators, etc.) and worker, vendor, and other construction-related vehicle trips. The types and quantity of equipment, as well as duration of construction activities, would be dependent on project specific conditions. Larger projects would require more equipment over a longer timeframe than required for smaller projects; however, specific information is not available for future projects at this time because buildout of the Specific Plan is expected to occur over 21 years and the location, type, and timing of construction determined by market demand. Realistic Buildout Scenario To determine if the construction of a typical project could result in a significant air quality impact, construction emissions were modeled using CalEEMod V. 2016.3.2. CalEEMod utilizes construction survey data to estimate construction phase lengths and equipment needs based on the area of a project site. Due to the uncertainty of timing and methods of construction activities that would occur under the proposed Specific Plan, it was conservatively (i.e. likely to overestimate) assumed that a maximum of approximately 10 percent of the Specific Plan development could be under construction in any given year, as shown in Table 6-7 (Specific Plan Build-Out, Average, and Worst-Case Construction Emissions). This is considered a conservative assumption because it represents a doubling of the overall average activity that could occur over a 20-year build-out period. ARROW HIGHWAY SPECIFIC PLAN 3-11
FINAL ENVIRONMENTAL IMPACT REPORT TABLE 4.2-5 SPECIFIC PLAN BUILDOUT, AVERAGE, AND WORST-CASE CONSTRUCTION EMISSIONS Buildout Average Year (21 Worst-Case Year (10% of Buildout) (A) Plan Activity Estimate (A) Years) Building Demolition 420,000 sf 20,000 sf 40,000 sf New Construction General Office Building 15,750 750 1,500 User Defined Commercial 272,690 12,985 25,970 General Light Industry 134,100 6,386 12,771 User Defined Recreational 374,616 17,839 35,677 Apartments Low Rise 94,000 4,476 8,952 Apartments Mid Rise 419,000 19,952 39,904 Condo/Townhomes 6,000 286 571 Single Family Housing 153,000 7,285 14,571 1,889,156 89,959 179,916 Source: City of Glendora, 2017. (A) The build-out values in this table do not represent the total development square footage that would exist in the Plan s horizon year (2040). Rather, these values are estimates of the total demolition and new square footage that would be constructed by 2040. The values do not include remodeling of existing buildings, which would not result in significant construction emissions. (B) The acreage associated with this development square footage was calculated to be 10.11 acres. Construction scheduling was based on CalEEMod defaults and a worst-case construction scenario, and CalEEMod default equipment was used in the model run. Construction emissions were estimated based on activity in year 2019. Due to the changeover in construction fleets as old equipment is replaced with newer, cleaner equipment, it is anticipated that maximum daily emissions would decrease as development occurs beyond 2019. Modeled construction emissions are presented in Table 4.2-6 (Specific Plan Construction Emissions Estimates). It is mandatory for all construction projects in the SCAB to comply with SCAQMD Rule 403 Dust; this compliance is included in the CalEEMod emissions estimates presented in the Table 4.2-6. TABLE 4.2-6 SPECIFIC PLAN CONSTRUCTION EMISSIONS ESTIMATES Maximum Daily Emissions (lbs/day) ROG NO X CO SO 2 (A) (B) Season Summer 2019 55.55 54.59 34.27 0.06 8.58 5.49 Winter 2019 55.55 54.59 34.19 0.06 8.58 5.49 SCAQMD Threshold 75 100 550 150 150 55 Threshold Exceeded? Source: MIG, 2018. (A) (B) No No No No No No emissions estimates include both exhaust (3.2 lbs/day) and dust (2.6 lbs/day) emissions. dust emissions include application of control measures as required by SCAQMD Rule 403, including watering exposed areas three times (3x) daily and cleaning paved roads. emissions estimates include both exhaust (3.0 lbs/day) and dust (0.8 lbs/day) emissions. dust emissions include application of fugitive dust control measures as required by SCAQMD Rule 403, including watering exposed areas three times (3x) daily. As shown in Table 4.2-6, the maximum daily construction emissions associated with implementation of the Specific Plan would be below the SCAQMD s regional pollutant thresholds for all pollutants. Thus, this impact would be less than significant. 3-12 CITY OF GLENDORA
3.0 ERRATA Localized Significance Thresholds Analysis for Construction The Specific Plan s maximum daily construction emissions from Realistic Buildout are compared against the SCAQMD s-recommended LSTs in Table 4.2-7 (Construction Emissions Localized Significance Thresholds Analysis). The LSTs are for SRA 9 (East San Gabriel Valley) in which the City of Glendora and the Specific Plan area are located. Based on the use of one grader, one rubber tired dozer, two crawler tractors, two excavators, and two scrapers during the grading construction phase, construction emissions were estimated against the SCAQMD s thresholds for a 3-acre project size. Because SCAQMD s LST screening tables are for one-, two-, and five-acre project scenarios, linear regression was used to estimate LSTs for a three-acre site to more accurately reflect the proposed realistic buildout scenario. According to the SCAQMD s Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, the maximum number of acres disturbed on the peak day of use per crawler tractor, grader, and rubber tired dozer is 0.5 acres per 8 hour day, while the maximum number of acres disturbed on the peak day of use per scraper is 1 acre per 8 hour day (SCAQMD, 2016c). This approach to construction LST is considered conservative (i.e., likely to overestimate) because it assumes the default amount of equipment used during the modeled plan development scenario would be operated at the same site and in close proximity to sensitive receptor locations. A receptor distance of 25 meters was used to evaluate impacts at sensitive residential receptor locations for construction activities (to account for schools and residential areas that border the Specific Plan). It should be noted that the results summarized in Table 4.2-7 incorporate fugitive dust control requirements consistent with SCAQMD Rule 403 (e.g., site watering 3x). This impact would be less than significant. TABLE 4.2-7 CONSTRUCTION EMISSIONS LOCALIZED SIGNIFICANCE THRESHOLDS ANALYSIS Construction Phase (B) Maximum On-Site Pollutant Emissions (lbs/day) (A) NO X CO PM 10 PM 2.5 Demolition 35.78 22.06 1.79 1.67 Site Preparation 43.24 19.76 8.38 5.43 Grading 54.52 33.38 5.33 3.41 Building Construction 35.21 27.91 2.09 1.97 Paving 15.24 14.66 0.82 0.76 Architectural Coatings 1.84 1.84 0.13 0.13 SCAQMD LST Threshold (C) 167 1,194 9.42 5.73 Threshold Exceeded? No No No No Source: MIG, 2018. (A) (B) (C) Emissions estimated using CalEEMod, V 2016.3.2. Estimates are based on default model assumptions unless otherwise noted in this report. Emissions presented are worst-case emissions and may reflect summer or winter emissions levels. In general, due to rounding, there is no difference between summer and winter emissions levels for the purposes of this table. LST threshold is based on 3.0-acre project size (using linear regression) and 25-meter receptor distance. Pursuant to the SCAQMD s Final Localized Significance Threshold Methodology (SCAQMD 2008, page 3-3), the threshold for a 25-meter receptor distance was evaluated. 2.F. The following revisions are made to Section 4.2 (Air Quality), page 4.2-23, Operational Emissions: As shown in Table 4.2-3 above, the SCAQMD has established daily screening level recommended CEQA thresholds of significance for the operation of land uses within the SCAB. ARROW HIGHWAY SPECIFIC PLAN 3-13
FINAL ENVIRONMENTAL IMPACT REPORT 2.G. The following revisions are made to Section 4.2 (Air Quality), page 4.2-23, Operational Emissions: Table 4.2-5 4.2-8 (Existing Conditions Operational Emissions) shows the current emissions produced by area sources, energy demand, and mobile emissions. TABLE 4.2-4 4.2-8 EXISTING CONDITIONS OPERATIONAL EMISSIONS VOC NOX CO SO2 Existing Emissions lb/day Area Source Emissions 113.59 6.95 189.43 0.42 24.59 24.59 Energy Source Emissions 0.37 3.30 2.24 0.02 0.26 0.26 Mobile Source Emissions 19.98 96.45 270.77 0.86 67.18 18.62 Emissions 135.95133.9 115.66106.7 491.17462.4 1.321.30 92.1092.02 43.5443.47 4 1 4 Project-Level Threshold 55 55 550 150 150 55 Threshold Exceeded? YES YES NO NO NO NO 2.H. The following revisions are made to Section 4.2 (Air Quality), page 4.2-23, Realistic Buildout Scenario: Realistic Buildout Scenario As shown in Table 4.2-8 above, the Specific Plan area currently exceeds thresholds for daily operational emissions of ROG and NO X under existing conditions. 2.I. The following revisions are made to Section 4.2 (Air Quality), pages 4.2-24 through 4.2-25, Realistic Buildout Scenario: In spite of this fact, Table 4.2-5 4.2-9 (Specific Plan Realistic Buildout Net Long Term Operational Emissions Estimates) is included with a summary of potential operational emissions at completion of realistic buildout compared to existing conditions. CalEEMod output files are included as Appendix C (Air Quality and Climate Change Modeling Data) of this report. As shown in Table 4.2-4 above, the Specific Plan area currently exceeds thresholds for daily operational emissions of ROG and NO X under existing conditions. Moreover, a As shown in Table 4.2-9 below, realistic buildout of the Specific Plan would continue to exceed daily operational significance thresholds for ROG result in a net reduction and of VOC and NO X compared to existing conditions. However, it should be noted that SCAQMD does not promulgate a program-level numeric threshold for which to compare daily or annual emissions. SCAQMD s screening-level thresholds are meant for the analysis of emissions from specific development projects and are not meant for analysis of land use programs such as the proposed Specific Plan. As the purpose of the screening-level thresholds is to evaluate project-specific emissions, it is not appropriate to compare total net emissions that could occur at Specific Plan build out to the screening-level thresholds to determine significance. Moreover, because existing land uses and densities within the Planning Area create ROG and NO X emissions in excess of SCAQMD thresholds, Realistic Buildout of the proposed Specific Plan will not create any new impacts or exceedances. It should be noted that the modeling assumes compliance with SCAQMD s Healthy Hearths Program and includes reductions in vehicle trips as shown in the Project Traffic Impact Analysis. Therefore, realistic buildout of the project will not create any new unavoidable operational criteria pollutant emissions impacts related to operational emissions. and i Impacts will be less than significant. 3-14 CITY OF GLENDORA
3.0 ERRATA TABLE 4.2-5 4.2-9 SPECIFIC PLAN REALISTIC BUILDOUT NET LONG TERM OPERATIONAL EMISSIONS ESTIMATES VOC NOX CO SO2 lb/day Area Source Emissions 113.59 6.95 189.43 0.42 24.59 24.59 Energy Source Emissions 0.37 3.30 2.24 0.02 0.26 0.26 Mobile Source Emissions 19.98 96.45 270.77 0.86 67.18 18.62 Existing Conditions 135.95133.9 4 115.66106.7 1 491.17462.4 4 1.321.30 92.1092.02 43.5443.47 Area Source Emissions 34.81 9.59 53.53 0.06 1.01 1.01 Energy Source Emissions 0.34 2.96 1.58 0.02 0.24 0.24 Mobile Source Emissions 4.71 29.89 64.93 0.38 41.64 11.23 Realistic Buildout 192.1439.86 68.8542.43 483.62120.0 1.250.45 83.8642.88 54.7912.48 4 Net Change -94.08-64.27-342.4-0.85-49.14-30.99 Project-Level Threshold 55 55 550 150 150 55 Threshold Exceeded? YESNO YESNO NO NO NO NO Localized Significance Thresholds Analysis for Operation The Specific Plan s maximum daily operational emissions are compared against the SCAQMD s recommended LSTs in Table 4.2-10 (Realistic Buildout Operational Emissions Localized Significance Thresholds Analysis). The LSTs are for SRA 9 (East San Gabriel Valley) in which the City of Glendora and the Specific Plan area are located. A receptor distance of 25 meters was used to evaluate impacts at sensitive residential receptor locations for operational activities. As shown in Table 4.2-10, the total emissions from all on-site operational activities within the planning area would be below the SCAQMD s recommended LST threshold for a one-acre project for emissions of NOx, CO, PM 10, and PM 2.5. When the total on-site emissions occurring in the Plan Area under build-out conditions (year 2040) are distributed by the total planning area (106 net acres) the average emissions per site are below the SCAQMD s oneacre LSTs for operation. Therefore, the emissions occurring within one acre of the planning area would not subject a sensitive receptor within 25 meters of the planning area to criteria air pollutant emissions exceeding the LSTs. The use of one-acre LSTs at a distance of 25 meters is considered a conservative approach, since they are the lowest LST values applicable within the planning area. TABLE 4.2-10 REALISTIC BUILDOUT OPERATION EMISSIONS LOCALIZED SIGNIFICANCE THRESHOLDS ANALYSIS Maximum On-Site Pollutant Emissions (lbs/day) (A) NO X CO PM 10 PM 2.5 Emissions Source (B) Area Emissions 9.59 53.53 1.01 1.01 Energy Emissions 2.96 1.58 0.24 0.24 On-Site Mobile Emissions (C) 29.89 64.93 41.64 11.23 On-Site Emissions in Plan Area 42.43 120.04 42.88 12.48 Average Emissions Per Acre 0.02 1.13 0.40 0.12 SCAQMD LST Threshold (D) 89 623 2 1 Threshold Exceeded? No No No No Source: MIG, 2018 and SCAQMD 2009, 2016c. (A) See Table 4.2-9. (B) Emissions presented are worst-case emissions and may reflect summer or winter emissions levels. In general, due to rounding, there is no difference between summer and winter emissions levels for the purposes of this table. (C) on-site emissions are equal to 10% of the total mobile emissions estimated in Table 4.2-9. (D) LST threshold is based on 1.0-acre project size and 25-meter receptor distance. ARROW HIGHWAY SPECIFIC PLAN 3-15
FINAL ENVIRONMENTAL IMPACT REPORT 2.J. The following revisions are made to Section 4.2 (Air Quality), page 4.2-25 through 4.2-26, Maximum Buildout Scenario: Maximum Buildout Scenario (For Information Purposes Only) For the sake of disclosure, the maximum buildout scenario was also modeled for operational impacts. The maximum buildout of the Planning Area is based on an analysis of existing conditions that will persist through the life of the proposed Specific Plan plus full potential development of the Planning Area. However, this does not present a realistic estimate of how the proposed project will be built out over time. The expected buildout estimates represent a more realistic potential scenario based on market assumptions, existing conditions, and other factors. As such, the realistic buildout scenario was used instead of the maximum buildout scenario for the analysis in this EIR. Maximum buildout of the proposed Specific Plan would provide development capacity for up to an additional 1,092 dwelling units and up to 3,071 new residents. Maximum buildout of the proposed Specific Plan would also include approximately 32,278 additional square feet of non-residential floor area within the Planning Area. The maximum development scenario represents an extreme case whereby the most intense permitted uses are operational within the Planning Area. Table 4.2-6 4.2-11 (Specific Plan Maximum Buildout Net Operational Emissions) identifies the maximum net increase in criteria pollutant emissions at full buildout of the proposed Specific Plan. As shown in Table 4.2-11, maximum buildout of the Specific Plan would result in a net reduction of all criteria pollutant emissions except. However, the increase in that can be expected under the maximum buildout scenario is within the recommended CEQA thresholds of significance for the operation of land uses within the SCAB. Impacts will be less than significant. TABLE 4.2-6 4.2-11 SPECIFIC PLAN MAXIMUM BUILDOUT NET OPERATIONAL EMISSIONS VOC NOX CO SO2 lb/day Existing 135.95133.9 115.66106.7 491.17462.4 1.321.30 92.1092.02 43.5443.47 4 1 4 Maximum Buildout 466.2582.88 176.06103.1 1,217.70288 3.171.11 212.25105.2 137.5430.53 2.52 0 Net Change -51.06-3.5-173.92-0.19 +13.18-12.94 Project-Level Threshold 55 55 550 150 150 55 Threshold Exceeded? YESNO YESNO YESNO NO YESNO YESNO As shown in Table 4.2-6 above, maximum buildout of the Specific Plan would exceed daily operational significance thresholds for ROG, NO X, PM 10, and PM 2.5. As mentioned above, the SCAQMD does not promulgate a program-level numeric threshold for which to compare daily or annual emissions. Because the Specific Plan would not allow any specific development project, the significance of potential project operations within the Planning Area cannot be fully determined at this time. SCAQMD guidance recognizes that operational impacts from land development projects typically result from increased traffic. Typical mitigation that would reduce emissions related to vehicular traffic includes transportation demand management (TDM) measures, which refers to a variety of strategies to improve transportation efficiency. SCAG provides a reference for cities to integrate TDM into the planning and development process (SCAG RTP/SCS 2012). One strategy for implementation of TDM measures identified by SCAG includes the Complete Streets concept, where the design concepts and principles of roadway design focus on the design for use by all potential users including transit, bicyclists, pedestrians, and cars. Specific TDM measures that can be implemented at the project level include the following (SCAG RTP/SCS 2012): Secure bicycle parking (racks, lockers, or bike station) Showers and lockers Site design that facilitates transit use, walking, and cycling. This includes transit stops, bike and pedestrian pathways, landscaping, benches and awnings, lighting, etc. 3-16 CITY OF GLENDORA
3.0 ERRATA Off-site amenities such as sidewalk improvements, bike network improvements, transit station improvements, improved transit service, transit shelters, roadway and streetscape improvements, intersection improvements, etc. On-site amenities that reduce the need to drive by requiring or encouraging a mix of uses (cafes, drug stores, groceries, banks, post office, services, gyms and childcare) into major developments so workers don t need to use cars during the day. Parking maximums Unbundled parking Priority parking for HOVs Market rate parking TDM strategies that can be implemented by employers include incentivizing and subsidizing carpool, transit, and vanpool, allowing flexible work hours, providing a commuter information center, and providing secure bicycle facilities, showers, and locker facilities on site. To reduce mobile emissions as the Planning Area develops, Mitigation Measure AQ-1 has been included. Mitigation Measure AQ-1 requires that future development projects implement TDM measures. Although Mitigation Measure AQ-1 would result in decreased operational emissions, until future development projects are proposed, project-specific criteria pollutant emissions can be evaluated, and projectspecific mitigation measures can be applied, long-term operational impacts cannot be fully assessed. However, as maximum buildout of the Planning Area is not anticipated as a result of project implementation, and traffic will actually decrease under the Realistic Buildout scenario (see chapter on Traffic and Transportation), impacts are anticipated to be less than significant. Implementation of the proposed Specific Plan does not authorize any specific development project. Development of future projects within the Planning Area would be subject to the City s standard CEQA review process and would be required to assess project-specific emissions in relation to the screening-level thresholds and SCAQMD guidelines as described above. Moreover, future projects within the Specific Plan Planning Area will be required to implement TDM measures as described in Mitigation Measure AQ-1. Although no specific development projects would occur as a result of implementation of the proposed Specific Plan, the potential for a future project facilitated by the Specific Plan to result in operational emissions in excess of project-level thresholds cannot be determined. Future projects would be required to analyze project-specific and cumulative air quality impacts as part of the standard environmental review process and apply mitigation, if necessary. With implementation of Mitigation Measure AQ-1 and adherence to the City s standard CEQA review process, impacts will be less than significant. 2.K. The following revisions are made to Section 4.2 (Air Quality), page 4.2-27, Cumulative Emissions Impacts: Construction Emissions Implementation of the proposed Specific Plan does not authorize the construction of any specific development project. Development of future projects within the Planning Area would be subject to the City s standard CEQA review process and would require assessment of project-specific emissions in relation to the screening-level thresholds and SCAQMD guidelines, as described above. The significance of future construction emissions cannot be determined at this time. Moreover, although no specific development projects would occur as a result of implementation of the proposed Specific Plan, construction of two future projects simultaneously within the Planning Area could occur. However, impacts from individual projects would be required to be analyzed on a case-by-case basis. Therefore, impacts will be less than significant. Operational Emissions Implementation of the proposed Specific Plan does not authorize any specific development project. Development of future projects within the Planning Area would be subject to the City s standard CEQA review process and would be required to assess project-specific emissions in relation to the screening-level thresholds and SCAQMD guidelines as described above. Moreover, future projects within the Specific Plan Planning Area will be required to implement TDM ARROW HIGHWAY SPECIFIC PLAN 3-17
FINAL ENVIRONMENTAL IMPACT REPORT measures as described in Mitigation Measure AQ-1. Although no specific development projects would occur as a result of implementation of the proposed Specific Plan, the potential for a future project facilitated by the Specific Plan to result in operational emissions in excess of project-level thresholds cannot be determined at this time. Future projects would be required to analyze project-specific and cumulative air quality impacts as part of the standard environmental review process and apply mitigation, if necessary. With implementation of Mitigation Measure AQ-1 and adherence to the City s standard CEQA review process, impacts will be less than significant. The basin currently is designated non-attainment for State and/or federal standards for ozone, PM 10, and PM 2.5 (see Table 4.2-1). As discussed Impact 4.2.A and 4.2 B, implementation of the proposed Specific Plan would not result in construction or operational emissions of criteria air pollutants that exceed SCAQMD thresholds of significance. In developing its CEQA significance thresholds, the SCAQMD considered the emission levels at which a project s individual emissions would be cumulatively considerable (SCAQMD 2; page D-3). The SCAQMD considers projects that result in emissions that exceed its CEQA significance thresholds to result in individual impacts that are cumulatively considerable and significant. Since the proposed Specific Plan would not individually exceed any SCAQMD CEQA significance thresholds, it would result in less than significant cumulative air quality impacts. 2.L. The following revisions are made to Section 4.2 (Air Quality), page 4.2-28, Carbon Monoxide Hot Spots: The analysis demonstrated that even the most congested intersections in the SCAB would not experience a CO hot spot. The CO hot spots analysis for these intersections indicated that the average 1-hour CO concentrations predicted by the models would be no more than 7.7 ppm, which is 38.5 percent of the 1-hour CO CAAQS of 20 ppm. Moreover, under the Realistic Buildout scenario of the Proposed Specific Plan, vehicle trips would be reduced compared to existing conditions and could not result in or contribute to a CO hot spot. The proposed Specific Plan would not authorize any specific construction; however, future development projects constructed pursuant to Specific Plan land use policies could potentially expose sensitive receptors to temporary, localized pollutant concentrations in excess of air quality standards, even if the broader region is in attainment. Examples include emissions of fugitive dust and vehicle and machinery exhaust during large-scale grading activities and roadway construction. Under limited circumstances, large-scale construction activities could result in emissions of fugitive dust, nitrogen oxides, and other criteria pollutants that could exceed SCAQMD daily thresholds of significance and thereby could result in a significant impact. Emissions of fugitive dust near sensitive receptors are a primary concern because, unlike gaseous pollutants that quickly rise and affect the upper atmosphere, particulate matter tends to remain close to the ground. 2.M. The following revisions are made to Section 4.2 (Air Quality), page 4.2-28, Toxic Air Contaminants: Toxic Air Contaminants TACs are defined by the California Health and Safety Code as air pollutants which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health. The CARB established monitoring stations within Los Angeles County to estimate background excess cancer risks associated with exposure to ambient levels of TACs. Some industrial land uses have the potential to generate substantial toxic air contaminant (TAC) concentrations that could adversely affect sensitive receptors. Such emissions could be produced by a variety of interior processes and outdoor activities that generate emissions of TACs. Of particular concern with industrial development is diesel particulate matter (DPM), which is composed of a complex mixture of substances emitted from diesel sources and is estimated to account for the greatest amount of risk to sensitive receptors. Heavy-duty trucks that utilize diesel fuel emit DPM, which is responsible for most of the airborne cancer risk from TACs in California (SCAQMD 2012). The Planning Area currently consists of residential and commercial uses, which are not uses that are considered to contribute excessive TAC emissions. However, the Planning Area does contain some light industrial uses and the proposed Specific Plan would allow for some industrial uses that would result in increased trips by heavy-duty trucks. Therefore, implementation of the Specific Plan could 3-18 CITY OF GLENDORA
4.0 ERRATA facilitate the placement of housing near roadways that generate elevated levels of DPM. The proposed Specific Plan land use plan includes a Corridor Industrial (C-I) land use category that permits varying degrees of manufacturing, processing, and distribution activities. Future businesses of these types that may be developed within the designated industrial areas could result in emissions of a variety of toxic air contaminants. The Tanner Bill requires implementation of risk reduction measures for toxic contaminant releases with cancer risks that are equal to or greater than 25 cases per million and the SCAQMD has established a TAC emissions cancer risk threshold of equal to or greater than 10 per million. For example, common facilities within the District that have a cancer risk of approximately 10 cases per million include forges, refineries, fuel distribution and storage facilities, and heavy plating facilities. Common facilities with a cancer risk of approximately 25 per million or more include aircraft manufacturing, large plating and machining facilities, and chemical manufacturing. Facilities of these types are not anticipated to be developed within the proposed Planning Area; however, if such a facility is proposed within the Planning Area, it would be required by existing law to implement risk reduction measures. Since industrial land uses exist in places within the Planning Area, and the proposed Specific Plan would allow for development of light industrial uses, much of the Planning Area may be affected by any potential substantial industrial emission source that currently exists or may be developed in the future regardless of wind direction. This does not mean that existing residences in the Planning Area are currently exposed to significant health risks; this is intended simply as a guideline for estimating where there is the most potential for exposure of sensitive receptors to substantial toxics concentrations generated within areas of industrial uses. Actual levels of risk can only be determined through site-specific analysis and specialized air pollutant modeling, based on an actual relationship between an industrial emission source and a specific residential site. Such assessments might determine that there are less than significant health risks, or that there could be some significant level of exposure to pollutants that need to be mitigated through siting, site design, or operational restrictions. General Plan policies for proposed developments to prepare an air quality analysis, which would include health risk assessments where appropriate, would address any potential impact that could occur in these identified areas or any other area of the Planning Area. With implementation of General Plan policies and existing regulations that regulate and monitor toxic emitters, potential health impacts to sensitive receptors due to exposure to toxic air contaminants will be less than significant.according to the Air Quality and Land Use Handbook, ARB recommends that sensitive land uses not be located within 500 feet of highways or major arterials having average annual daily traffic (AADT) that exceeds 100,000 vehicles. This is due to the concentration of pollutants that accumulate in this proximity to freeways and other major arterials. No non-freeway roadways within the Planning Area either currently or over the long term are projected to have an AADT that exceeds 100,000 vehicles. I-10, SR-57, and I-210 currently have and will likely continue to have AADTs that exceed 100,000. 1 Based on ARB guidelines, a significant impact could occur if the Specific Plan would permit new residential or other sensitive uses within 500 feet of these highways. Because the Planning Area is located well in excess of 500 feet from any of these highways, significant impacts to sensitive receptors from heavy traffic roadway criteria pollutants would be less than significant. Implementation of the Arrow Highway Specific Plan could expose existing and new sensitive receptors to substantial concentrations of criteria air pollutants and TAC emissions that pose adverse health effects. However, as described in more detail below, these impacts would be less than significant given the level of development expected to occur, the standard environmental review practices that development projects would be subject to, and implementation of existing General Plan policies. Implementation of the Arrow Highway Specific Plan would generate emissions, including emissions of DPM (a TAC), during construction activities that would occur intermittently over the approximately 21-year build-out period associated with the Specific Plan. As shown in Table 4.2-7, emissions of construction-related criteria air pollutants ARROW HIGHWAY SPECIFIC PLAN 3-19
FINAL ENVIRONMENTAL IMPACT REPORT would be below SCAQMD LSTs and would not result in substantial pollutant concentrations. The Arrow Highway corridor is an existing, developed area within the City of Glendora. The proposed Specific Plan does encourage light industrial uses and adaptively reuse of existing structures as new businesses move into the area over the next approximately 21 years. Sensitive receptors are generally located along the perimeter of the Planning Area, set back from Arrow Highway. The majority of the parcels within the Specific Plan are located along Arrow Highway and are not adjacent to sensitive land uses. Therefore, potential construction activities (and associated emissions) occurring under the Specific Plan would generally be located away from sensitive land uses. Construction activities, by nature, are short-term. Therefore, since development projects would be short-term and scattered throughout the Specific Plan area (i.e., not consistently located adjacent to or near sensitive land uses), sensitive receptors would be exposed to construction-related DPM emissions for a limited time only. Potential adverse health risks from DPM emissions are evaluated assuming a constant exposure to emissions over a 70-year lifetime, 24 hours a day, 7 days a week. Since receptors would be exposed to DPM emissions for a few months to a year out of a 70 year lifetime, DPM emissions from construction activities are considered a less than significant impact. Implementation of the Specific Plan would also generate long-term emissions, primarily associated with area and mobile sources that would combust natural gas or gasoline (and which are not a source of DPM). As shown in Table 4.2-10, emissions of operations-related criteria air pollutants would be below SCAQMD LSTs and would not result in substantial pollutant concentrations. In addition to LSTs, the SCAQMD also recommends projects that generate or attract vehicular trips, especially heavy-duty diesel-fueled vehicles, perform a mobile source HRA in accordance with their Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis document. Although the proposed Specific Plan update is not anticipated to result in such projects, specific emissions reductions may be required for projects involving or attracting the use of heavy-duty diesel trucks to ensure such projects would not adversely affect nearby sensitive receptor locations. This would be determined during the review of future, site-specific development proposals, and the implementation of standard review procedures would ensure projects to not result in significant health risks from diesel-fueled trucks. Under the State s Air Toxics Hot Spots Information and Assessment Act (AB 2588) the SCAQMD is required to prepare an annual report of activities related to facilities that emit TACs, such as the Service King Paint & Body located at 153 East Arrow Highway. This permitted facility has the potential to emit ammonia at levels that are not considered to pose a risk or hazard to the public. Implementation of the Specific Plan would not result in the exposure of new or existing sensitive receptors to significant sources of TAC emissions. There are few significant sources of TAC emissions within 500 feet of the planning area boundary. The Specific Plan does include new primary residential units. However, such units would not be exposed to emissions over a 70-year lifetime, 24 hours a day, 7 days a week. Furthermore, as described above, the General Plan includes policies to guard against exposure to TACs (Policy AQ-3.2 and AQ-4.2) and unhealthful levels of air pollution (Policy AQ-7.3). This may include avoiding the placement of sensitive receptors in close proximity to businesses (commercial or industrial) that emit toxic or harmful air contaminants, providing adequate buffers from sources of emissions consistent with recommendations in CARB s Air Quality and Land Use Handbook, the implementation of controls on new emissions sources, and other measures tailored to future development proposals. Implementation of these policies during review of individual development projects would ensure construction and operational emissions from future projects do not expose existing or new sensitive receptors to substantial pollutant concentrations or significant adverse health effects. Potential impacts with respect to exposure of sensitive receptors to substantial pollutant concentrations would be less than significant. 3-20 CITY OF GLENDORA
3.0 ERRATA 2.N. The following revisions are made to Section 4.2 (Air Quality), page 4.2-31, Mitigation Measures: AQ-1 Future development within the Planning Area shall implement feasible Transportation Demand Management (TDM) measures subject to the review and approval of the Planning Division. Should it be determined that TDM measures would not be feasible for a specific development, written justification shall be submitted to the Planning Division as part of the City s standard development and environmental review process. TDM measures include, but are not limited to the following: Secure bicycle parking (racks, lockers, or bike station) Showers and lockers Site design that facilitates transit use, walking, and cycling. This includes transit stops, bike and pedestrian pathways, landscaping, benches and awnings, lighting, etc. Off-site amenities such as sidewalk improvements, bike network improvements, transit station improvements, improved transit service, transit shelters, roadway and streetscape improvements, intersection improvements, etc. On-site amenities that reduce the need to drive by requiring or encouraging a mix of uses (cafes, drug stores, groceries, banks, post office, services, gyms and childcare) into major developments so workers don t need to use cars during the day. Parking maximums Unbundled parking Priority parking for HOVs Market rate parking None required. 2.O. The following revisions are made to Section 4.2 (Air Quality), page 4.2-31, Level of Significance with Mitigation Incorporated: Impacts 4.2.B and 4.2.C would remain significant and unavoidable with adherence to existing regulation and implementation of Mitigation Measures AQ-1. Not applicable. 2.P. The following revisions are made to Section 4.2 (Air Quality), page 4.2-31, End Notes: 1 CalTrans Traffic and Vehicle Data Systems Unit. 2014 All Traffic Volumes on CSHS. http://trafficcounts. dot.ca.gov/docs/2014_aadt_volumes.pdf [August 14, 2017]. ARROW HIGHWAY SPECIFIC PLAN 3-21
FINAL ENVIRONMENTAL IMPACT REPORT 3. Draft EIR Volume I Section 4.4: Greenhouse Gas Emissions 3.A. The following revisions are made to Section 4.4 (Greenhouse Gas Emissions) page 4.4-3, second paragraph: The draft 2017 Climate Change Scoping Plan Update was approved in November 2017 and is currently available for public review. The 2017 Scoping Plan update identifies an increased need for coordination among state, regional, and local governments to realize the potential for GHG emissions reductions that can be gained from local land use decisions. The update notes that emissions reductions targets set by more than one hundred local jurisdictions in the state could realize emissions reductions up to 45 MMTCO 2 E by 2020 and 83 MMTCO 2 E by 2050. The 2017 Scoping Plan update includes a recommended plan-level efficiency threshold of six metric tons or less per capita by 2030 and no more than two metric tons by 2050. On December 14, 2017 CARB adopted the second update to the Scoping Plan, the 2017 Climate Change Scoping Plan Update (2017 Scoping Plan Update). The primary objective of the 2017 Scoping Plan Update is to identify the measures needed to achieve the mid-term GHG reduction target for 2030 (i.e., reduce emissions by 40 percent below 1990 levels by 2030), as established under Executive Order B-30-15 and SB 32. The 2017 Scoping Plan Update identifies an increasing need for coordination among state, regional, and local governments to achieve the GHG emissions reductions that can be gained from local land use planning and decisions. It notes emission reduction targets set by more than one hundred local jurisdictions in the state could result in emissions reductions of up to 45 MMTCO 2 E and 83 MMTCO 2 E by 2020 and 2050, respectively. To achieve these goals, the 2017 Scoping Plan Update includes a recommended plan-level efficiency threshold of six metric tons or less per capita by 2030 and no more than two metric tons by 2050. The major elements of the 2017 Scoping Plan Update framework include: Implementing and/or increasing the standards of the Mobile Source Strategy, which includes increasing zero emission vehicle (ZEV) buses and trucks; Low Carbon Fuel Standard (LCFS), with an increased stringency (18 percent by 2030); Implementation of SB 350, which expands the RPS to 50 percent and doubles energy efficiency savings by 2030; California Sustainable Freight Action Plan, which improves freight system efficiency, utilizes near-zero emissions technology, and deployment of ZEV trucks; Implementing the proposed Short-Live Climate Pollutant Strategy, which focuses on reducing CH 4 and hydrocarbon emissions by 40 percent and anthropogenic black carbon emissions by 50 percent by the year 2030; Continued implementation of SB 375; Post-2020 Cap-and-Trade Program that includes declining caps; 20 percent reduction in the GHG Emissions from refineries by 2030; and Development of a Natural and Working Lands Action Plan to secure California s land base as a net carbon sink. 3.B. The following revisions are made to Section 4.4 (Greenhouse Gas Emissions) page 4.4-6, last paragraph: The draft 2017 Scoping Plan update identified a plan-level efficiency target of 6.0 MTCO2E for year 2030 and 2.0 MTCO2E for year 2050. The SCAQMD recommendation is less conservative with a 6.6-MTCO2E target for 2020 but 3-22 CITY OF GLENDORA
3.0 ERRATA aligns with the Scoping Plan target of an estimated 4.7 MTCO2E per service population in year 2030 consistent with showing substantial progress towards the 2050 target. For project-level and focused programmatic proposals, a narrower emissions inventory is used that does not include emissions sources by which the project has no means or nexus to reduce emissions or whereby the emissions source is not relevant to the project (e.g. emissions from cargo ships in a community with no port). Regarding typical land use projects, the greatest source of emissions that cannot effectively be reduced directly are from mobile source. Vehicle emissions and feasible, affectable reduction strategies must be formulated at the state and federal levels and implemented by vehicle and parts manufacturers to improve technological efficiencies. Local land use decisions have some part in reducing mobile source emissions through reductions in vehicle miles traveled and through the strategic approval of industrial projects that generate high volumes of truck traffic. These gains, however, are less than the achievements realized by technological improvements and are generally inconsequential in terms of project efficiency to meet per capita standards or business-as-usual reduction requirements. Using this approach, the state s 1990 emissions inventory for the land use sector is 267 MMTCO2E. The 1990 emissions inventory without inclusion of passenger or light-duty vehicle emissions is 158 MMTCO2E. The 1990 emissions inventory without on-road vehicle sources is 129 MMTCO2E. These translate to respective year 2020 efficiency standards of 4.7, 2.8, and 2.3. The breadth of efficiency standards under varying scenarios are summarized in Table 4.4-1 (Project-Level Efficiency Standards). TABLE 4.4-2 PROJECT-LEVEL EFFICIENCY STANDARDS Emissions (MTCO2e) Per Service Population Target Year Service Population (millions) Land Use Only Land Use without Light-Duty Vehicles Land Use without All Vehicles 2020 56.45 4.7 2.8 2.3 2030 61.53 2.6 1.5 1.3 2035* 63.37 2.2 1.3 1.1 2050 70.71 0.8 0.4 0.4 Source: AEP 2016 * Calculated linearly to identify path of substantial progress A numerical threshold for determining the significance of greenhouse gas emissions in the South Coast Air Basin (Basin) has not been established by the South Coast Air Quality Management District (SCAQMD). As an interim threshold based on guidance provided in the CAPCOA CEQA and Climate Change handbook, a non-zero threshold approach based on Approach 2 of the handbook has been used. Threshold 2.5 (Unit-Based Thresholds Based on Market Capture) establishes a numerical threshold based on capture of approximately 90 percent of emissions from future development. The latest threshold developed by SCAQMD using this method is 3,000 metric tons carbon dioxide equivalent (MTCO2E) per year. This threshold is based on the review of 711 CEQA projects. This analysis evaluates the Arrow Highway Specific Plan s potential GHG emissions against the SCAQMD s Tier 3 screening level of 3,000 MTCO2e per year for all land uses types. 3.C. The following revisions are made to Section 4.4 (Greenhouse Gas Emissions) page 4.4-8, second paragraph, Program Level Evaluation: Program-Level Evaluation Evaluation of GHG emissions from the planning area is accomplished through evaluating the ratio of areawide, cumulative emissions to the population served by the program to the ratio of statewide emissions to the state population for land use sources identified in the state emissions inventory. This ratio is known as an efficiency standard as it normalizes disparate values to comparable indices of relative emissions levels. Bulk emissions are ARROW HIGHWAY SPECIFIC PLAN 3-23
FINAL ENVIRONMENTAL IMPACT REPORT divided by the service population, so called because only those directly accommodated by the project are accounted for (e.g., residents and employees). The planning area currently has consists of over 946,000 square feet of non-residential land uses, 320 dwelling units, 900 residents and 1,675 employees for a service population of 2,575. Table 4.4-2 shows existing greenhouse gas emissions within the Planning Area as well as service population efficiency. As shown in Table 4.4-2, the Planning Area currently has an efficiency of 1.9 MTCO 2 e under existing conditions. TABLE 4.4-3 EXISTING CONDITIONS GREENHOUSE GAS EMISSIONS Vehicle Scenario (MTCO2e) Emissions (MTCO2e) Adjusted (MTCO2e) SP (persons) Efficiency Existing Conditions 15,988.30 11,093.81 4,894.49 2,575 1.9 GHG Emissions (MT/YR) Source CO 2 CH 4 N 2 O * Area 104.72 0.11 0.00 108.08 Energy 3,224.01 0.12 0.03 3,237.14 Mobile 10,806.55 0.58 0.00 10,821.02 Solid Waste 297.59 17.59 0.00 737.27 Water/Wastewater 684.92 3.92 0.10 812.01 15,117.80 22.31 0.13 15,715.52 * MTCO2E/YR Note: Slight variations may occur due to rounding. 3.D. The following revisions are made to Section 4.4 (Greenhouse Gas Emissions) page 4.4-8, realistic buildout greenhouse gas emissions inventory: Realistic Buildout Greenhouse Gas Emissions Inventory Emissions from realistic buildout of the Specific Plan planning area were modeled to determine short-term construction and annual operational GHG emissions from the planning area at the 20 21-year horizon (20352040). Table 4.4-3 (Construction Greenhouse Gas Emissions) summarizes the estimated yearly emissions from construction activities. Carbon dioxide emissions from construction equipment and worker/vendor trips were estimated utilizing CalEEMod. Construction activities are short-term and cease to emit greenhouse gases upon completion, unlike operational emissions that are continuous year after year until operation of the use ceases. Because of this difference, SCAQMD recommends in its draft threshold to amortize construction emissions over a 30-year operational lifetime. This normalizes construction emissions so that they can be grouped with operational emissions in order to generate a precise project GHG inventory. Realistic buildout of the proposed Specific Plan is estimated to provide housing for up to 798 additional residents. However, realistic buildout would actually reduce the capacity of employment in the planning area by up to 806 employees (see Section 4.9, Population and Housing, of this EIR). Therefore, realistic buildout would result in a total net decrease in service population of 8 persons over existing conditions, for a total service population of 2,567 TABLE 4.4-3 CONSTRUCTION GREENHOUSE GAS EMISSIONS GHG Emissions (MT/YR) CO 2 CH 4 N 2 O * Construction Year 2019 575.99 0.13 0.00 579.11 Amortized ^ 19.20 0.00 0.00 19.30 * MTCO2E 3-24 CITY OF GLENDORA
3.0 ERRATA Note: Slight variations may occur due to rounding and variations in modeling software ^ Amortized over 30-years A summary of the project s net long-term greenhouse gas emissions is included for realistic buildout of the proposed Specific Plan are included in Table 4.4-3 4.4-4 (Realistic Buildout Net Greenhouse Gas Emissions) (Operational Greenhouse Gas Emissions). As shown in Table 4.4-3 4.4-4, total and adjusted MTCO 2 e is actually less under the realistic buildout scenario than under existing conditions. This results in an efficiency of 1.1 MTCO2e under the realistic buildout scenario, which results in a net decrease of project GHG emissions over the 20-year horizon period; however to show substantial progress towards achieving the AB 32 target in year 2050, the project must achieve an estimated efficiency of 0.9 MTCO 2 e by year 2040; thus, project GHG emissions would be consistent with AB 32 targets. Furthermore, existing regulatory requirements associated with the State CALGreen requirements for energy and water demand efficiency and solid waste diversion would further reduce GHG emissions during buildout and operation of the proposed Specific Plan. Therefore, impacts would be less than significant. TABLE 4.4-3 4.4-4 REALISTIC BUILDOUT NET GREENHOUSE GAS EMISSIONS OPERATIONAL GREENHOUSE GAS EMISSIONS GHG Emissions (MT/YR) CO 2 CH 4 N 2 O * Source Area 122.36 0.01 0.00 123.27 Energy 2,031.37 0.07 0.02 2,040.09 Mobile 5,629.26 0.20 0.00 5,634.38 Solid Waste 105.16 6.22 0.00 260.54 Water/Wastewater 420.64 2.40 0.06 498.44 8,308.80 8.90 0.09 8,556.72 * MTCO2E/YR Note: Slight variations may occur due to rounding. Table 4.4-5 (Greenhouse Gas Emissions Inventory) below summarizes the yearly estimated greenhouse gas emissions from construction and operation. The total yearly carbon dioxide equivalent emissions for the proposed project are estimated at 8,576.02 MTCO2E. Yearly carbon dioxide equivalent emissions for existing operations are an estimated 15,715.52 MTCO2E. Net emissions from project operations will decrease by 7,139.5 MTCO2E. Therefore, the project does not result in a significant impact. Impacts will be less than significant. TABLE 4.4-5 GREENHOUSE GAS EMISSIONS INVENTORY GHG Emissions (MT/YR) CO 2 CH 4 N 2 O * Source Existing 15,117.80 22.31 0.13 15,715.52 Construction 19.20 <1 0.00 19.30 Operation 8,308.80 8.90 0.09 8,556.72 Proposed 8,576.02 Net -7,139.5 * MTCO2E/YR Note: Slight variations may occur due to rounding ^ Construction impacts amortized over 30-years ARROW HIGHWAY SPECIFIC PLAN 3-25
FINAL ENVIRONMENTAL IMPACT REPORT 3.E. The following revisions are made to Section 4.4 (Greenhouse Gas Emissions) page 4.4-8, Maximum buildout greenhouse gas emissions inventory: Maximum Buildout Greenhouse Gas Emissions Inventory For purposes of disclosure, the maximum buildout scenario was also modeled to determined potential greenhouse gas emissions. Maximum buildout of the proposed Specific Plan is estimated to provide housing for up to 3,071 additional residents and 249 additional employees for a potential service population of 3,320. Efficiency calculations for maximum buildout of the proposed Specific Plan are included in Table 4.4-4. As shown in Table 4.4-4 4.4-6, total yearly carbon dioxide equivalent emissions for maximum buildout of the proposed project are estimated at 21,111.10 MTCO2E. Yearly carbon dioxide equivalent emissions for existing operations are an estimated 15,715.52 MTCO2E. Net emissions from project operations will increase by 5,414.88 MTCO2E. maximum buildout of the propose Specific Plan would result in an efficiency of 2.3 MTCO2e by year 2035. This results in a net increase in efficiency for the proposed service population over existing conditions. However, the maximum buildout of the Planning Area is based on an analysis of existing conditions that will persist through the life of the proposed Specific Plan plus full potential development of the Planning Area. This does not present a realistic estimate of how the proposed project will be built out over time. The expected buildout estimates represent a more realistic potential scenario based on market assumptions, existing conditions, and other factors. As such, the realistic buildout scenario was used instead of the maximum buildout scenario for the analysis in this EIR. Therefore, maximum buildout of the Planning Area is not anticipated and impacts would be less than significant. TABLE 4.4-4 4.4-6 MAXIMUM BUILDOUT NET GREENHOUSE GAS EMISSIONS Vehicle Scenario (MTCO2e) Emissions (MTCO2e) Adjusted (MTCO2e) SP (persons) Efficiency Existing Conditions 15,988.30 11,093.81 4,894.49 2,575 1.9 Maximum Buildout 26,423.33 18,891.60 7,531.73 3,320 2.3 Net Increase 10,435.03 7,797.79 2,637.24 745 0.4 GHG Emissions (MT/YR) Source CO 2 CH 4 N 2 O * Existing 15,117.80 22.31 0.13 15,715.52 Construction 19.20 <1 0.00 19.30 Operation 20,495.66 22.07 0.21 21,111.10 Maximum 21,130.40 Net 5,414.88 * MTCO2E/YR Note: Slight variations may occur due to rounding ^ Construction impacts amortized over 30-years 3-26 CITY OF GLENDORA
3.0 ERRATA 4. Draft EIR Volume I Section 4.9: Population and Housing 4.A. The following revisions are made to Section 4.9 (Population and Housing) page 4-9-1, fourth paragraph (Population): In 2017, the Planning Area has 320 housing units and is estimated to support 938 900 residents (2.93 persons per household) (DOF 2017). 4.B. The following revisions are made to Section 4.9 (Population and Housing) page 4-9-2, Population and Housing: In 2017, the Planning Area has 320 housing units and is estimated to support 938 900 residents (2.93 persons per household) (DOF 2017). The proposed Specific Plan would support up to 2,079 1,698 residents at realistic buildout, representing a proposed net increase of up to 1,141 798 new residents, and resulting in a city-wide population of 53,749 53,406 when added to the 2017 DOF estimate of 52,608. The SCAG Regional Growth Forecast projects an estimated population of 54,300 in Glendora by the year 2040. Therefore, based on the current and projected numbers, realistic build out of the proposed Specific Plan would be within the population growth forecasts for the City of Glendora as projected by SCAG. According to DOF, the City of Glendora had a housing stock of 18,204 as of January 1, 2017. SCAG s Regional Growth Forecast projects that the number of households in Glendora will increase to 18,900 by the year 2040, resulting in a remaining capacity of 696 households. The Planning Area currently has 320 residential dwelling units. The proposed Specific Plan would support up to 739 604 residential units at realistic build out, representing a proposed net increase of up to 419 284 residential units within the city, and resulting in a total housing supply citywide of up to 18,623 18,488 units. Therefore, based on the current and projected numbers, build-out of the proposed Specific Plan would be within the housing growth forecasts for the City of Glendora as projected by SCAG. 4.C. The following revisions are made to Section 4.9 (Population and Housing) page 4-9-3, Employment: Realistic buildout of the proposed Specific Plan would result in a net decrease of up to 298,712 523,982 square feet of nonresidential use (retail, office, restaurants, and auto related). According to the economic benefits analysis prepared for the Specific Plan, build out could result in a net decrease of approximately 307 806 jobs within the Planning Area (see Appendix D). According to SCAG s Regional Growth Forecast, Glendora had an estimated employment base of 20,000 in 2012. The Regional Growth Forecast projects that the Glendora employment base will increase to 23,000 by the year 2040. The estimated net decrease of 307 806 jobs at Specific Plan build out would be well within the projected employment growth for Glendora. ARROW HIGHWAY SPECIFIC PLAN 3-27
FINAL ENVIRONMENTAL IMPACT REPORT 5. Draft EIR Volume I Section 4.11: Utilities and Service Systems 5.A. The following revisions are made to Section 4.11 (Utilities and Service Systems) page 4-11-1, third paragraph: Wastewater in Glendora is collected via the City s sewer collection system, which is tied into the Sanitation Districts of Los Angeles County s (LACSD) regional trunk sewers and is treated at one or more of the following LACSD s water reclamation and treatment plants: the Joint Water Pollution Control Plant located in the City of Carson, which has a capacity of 400 million gallons per day (mgd) and currently produces an average flow of 256.4 mgd; the San Jose Creek Water Reclamation Plant (WRP) located adjacent to the City of Industry, which has a capacity of 100 mgd and currently processes an average flow of 65.1 mgd; the Whittier Narrows WRP located near the City of South El Monte, which has a capacity of 15 mgd and currently produces an average recycled water flow of 7.3 mgd; and/or the Los Coyotes WRP located in the City of Cerritos, which has a capacity of 37.5 mgd and currently produces an average recycled water flow of 20.5 mgd. 5.B. The following revisions are made to Section 4.11 (Utilities and Service Systems) page 4-11-12, second paragraph: The Districts are empowered by the California Health and Safety Code to charge a fee for the privilege of connecting (directly or indirectly) to the Districts' Sewerage System for increasing the strength or quantity of wastewater discharged from connected facilities. This connection fee is a capital facilities fee that is imposed in an amount sufficient to construct an incremental expansion of the Sewerage System to accommodate proposed projects. Payment of a connection fee will be required before a permit to connect to the sewer is issued. 3-28 CITY OF GLENDORA
3.0 ERRATA 6. Draft EIR Volume I Section 5.0: Alternatives 6.A. The following revisions are made to Section 5.0 (Alternatives) page 5-2, first paragraph: Build out Realistic buildout under the proposed Arrow Highway Specific Plan could result in a total of 2,079 604 residential dwelling units (an increase of 1,759 284 residential units relative to existing conditions). 6.B. The following revisions are made to Table 5-3 in Section 5.0 (Alternatives) page 5-3 (Net Summer Criteria Pollution Emissions (lbs/day)): TABLE 5-4 NET SUMMER CRITERIA POLLUTANT EMISSIONS (LBS/DAY) ROG NOX CO SO2 Alternative lbs/day Existing Conditions Proposed Specific 466.251739.86 172.493342.43 1,217.6958120.04 3.17410.45 212.239542.88 137.535112.48 Plan Realistic Buildout 1 No Project 135.95133.94 115.66106.71 491.17462.44 1.321.30 92.1092.02 43.5443.47 2 Alternative Location N/A N/A N/A N/A N/A N/A 3 Reduced Commercial 447.695649.16 187.086146.58 1,251.841128.34 3.29270.50 110.385548.00 140.016813.87 Development Potential 4 Reduced Residential Development Potential 391.132630.18 59.598824.56 44.164661.78 0.11630.25 20.846020.75 12.35636.33 6.C. The following revisions are made to Table 5-4 in Section 5.0 (Alternatives) page 5-3 (Daily Trips): TABLE 5-5 DAILY TRIPS Daily Vehicle Trips Weekday Alternative Existing Conditions 9,070.40 Proposed Specific Plan 13,130.2417,134 1 No Project 9,070.40 2 Alternative Location Not Applicable 3 Reduced Commercial Development Potential 4 Reduced Residential Development Potential 14,804.5714,817.6 9,966.6915,655 ARROW HIGHWAY SPECIFIC PLAN 3-29
FINAL ENVIRONMENTAL IMPACT REPORT 7. Draft EIR Volume I Section 6.0: Long Term Effects 7.A. The following revisions are made to Section 6.0 (Long Term Effects) page 6-2, third paragraph: Mitigation Measure AQ-1 would result in decreased operational emissions. 7.B. The following revisions are made to Section 6.0 (Long Term Effects) page 6-6, Population and Housing: The proposed Arrow Highway Specific Plan would accommodate up to 739 284 new dwelling units at project realistic build out. 7.C. The following revisions are made to the text on Page 6-10 (Mobile Sources) and to Table 6-2 (Net Mobile Source Demand-Gasoline) on page 6-11, Section 6.0: Calculations for total annual mobile source fuel consumption under existing conditions and at Specific Plan build out are provided in Table 6-2 (Net Mobile Source Demand Gasoline). Mobile sources at realistic buildout of the Arrow Highway Specific Plan would result in a net increase decrease in operational demand of approximately 34,652,613.50 171,276,331.50 additional gallons of gasoline per year. TABLE 6-6 NET MOBILE SOURCE DEMAND - GASOLINE Trip Type Annual Vehicle Miles Fuel Economy Demand EXISTING CONDITIONS Commercial 7,333,112 10,605,417 38.7 283,791,434.4 10,429,637.90 Industrial 5,088,948 38.7 196,942,287.6 Residential 3,675,337.4 6,586,230.00 38.7 142,235,557.38 254,190,501.00 Existing Operational Gasoline Demand (gal) 622,969,279.4 861,562,426.50 REALISTIC SPECIFIC PLAN BUILD OUT Commercial 425,185 38.7 16,454,659.5 Industrial 3,126,101 38.7 120,980,108.7 Residential 13,441,527.77 14,285,564.00 38.7 520,187,124.699 552,851,326.80 Realistic Specific Plan Build Out Operational Gasoline Demand (gal) 657,621,892.90 690,286,095.00 MAXIMUM SPECIFIC PLAN BUILD OUT Commercial 1,700,738 38.7 6,5818,560.6 65,818,560.00 Industrial 8,086,835 38.7 312,960,514.5 Residential 33,693,283.91 38.7 1,303,930,087.21 1,303,930,052.10 Maximum Specific Plan Build Out Operational Gasoline Demand (gal) 1,682,709,162.31 1,682,709,127.20 Net Operational Gasoline Demand (gal) (Realistic Buildout) 34,652,613.50 171,276,331.50 3-30 CITY OF GLENDORA
3.0 ERRATA 7.D. The following revisions are made to the text on Page 6-11 (Electricity and Natural Gas Use) and to Table 6-3 (Direct Energy Demand) on page 6-11, Section 6.0: Electricity and natural gas would be required to provide energy to future residential and commercial uses for indoor and outdoor lighting, office equipment, building cooling and heating, kitchen operations, and water heating. All new development and redevelopment would be subject to current California Building Code (CBC) requirements for building energy efficiency. Energy demand was estimated using CalEEMod default calculations without consideration of CBC efficiency requirements. Projected annual existing and Arrow Highway Specific Plan build out energy demand projections are summarized in Table 6-3 (Direct Energy Demand). Realistic buildout of the Arrow Highway Specific Plan would result in net decreases in demand of 3,700,502.60 3,563,612.60 kilowatt hours per year (kwh/yr) of electricity and 1,472,514.60 520,210.60 thousand British Thermal Units per year (kbtu/yr) of natural gas without consideration of CBC efficiencies. TABLE 6-3 DIRECT ENERGY DEMAND Electricity Demand kwh/yr Natural Gas Demand kbtu/yr Existing Conditions 8,006,793.00 12,609,294.00 12,057,430.00 Specific Plan Realistic Build Out 4,306,290.40 11,136,779.40 11,537,219.40 Specific Plan Maximum Build Out 11,321,015.00 28,674,714.00 28,674,714.00 Net Operational Demand (Realistic Buildout) -3,700,502.60-1,472,514.60 520,210.60 7.E. The following revisions are made to the text on Page 6-12 (Water and Wastewater) and to Table 6-4 (Indirect Energy Demand) on page 6-12, Section 6.0: Pursuant to the water conservation measures identified in the City of Glendora s municipal code, landscape efficiency standards would continue to be regulated for new development by the City of Glendora General Plan Policy CON 1.1 through CON 1.5. Water demand for buildout of the proposed Specific Plan was estimated using CalEEMod default values, without consideration of efficiencies required pursuant to the City of Glendora requirements for indoor and outdoor water demand reductions. Indirect electricity demand for water and wastewater treatment and conveyance under existing conditions and Arrow Highway Specific Plan build out without consideration of efficiencies is detailed in Table 6-4 (Indirect Electricity Demand). At the Arrow Highway Specific Plan maximum realistic build out, net increase in water and wastewater treatment and conveyance would require approximately 448,779.6 301,889.62 kwh/yr of electricity. ARROW HIGHWAY SPECIFIC PLAN 3-31
FINAL ENVIRONMENTAL IMPACT REPORT TABLE 6-4 INDIRECT ELECTRICITY DEMAND Source MGY Supply Treat Distribute EXISTING CONDITIONS Water 162.213241 58.50 1,577,848.19 569,065.26 18,005.67 6,493.90 Wastewater 55.48 47.71 -- 106,022.30 SPECIFIC PLAN REALISTIC BUILD OUT Water 205.244895 38.99 1,996,417.15 379,226.63 22,782.18 4,327.55 Wastewater 115.50 55.05 -- 220,720.51 SPECIFIC PLAN MAXIMUM BUILD OUT Water 248.27655 88.197 2,414,986.10 857,892.23 27,558.69 9,789.86 Wastewater 175.52 65.52 -- 335,418.72 206,335.24 74,416.67 1,802,189.09 649,975.85 -- 106,022.30 91,169.98 91,169.98 Existing Indirect Demand (kwh/yr) 1,908,211.34 741,145.84 116,946.97 49,591.47 2,136,270.43 33,145.66 -- 220,720.51 110.55 110.55 Specific Plan Realistic Build Out Indirect Demand (kwh/yr) 2,356,990.94 439,256.21 27,558.69 112,186.58 2,470,351.756 979,868.693 -- 335,418.72 7,272.72 7,272.72 Specific Plan Maximum Build Out Indirect Demand (kwh/yr) 2,805,769.96 245,995.58 Net Indirect Demand (kwh/yr) (Realistic Buildout) 448,779.60 301,889.62 3-32 CITY OF GLENDORA
4.0 PUBLIC CIRCULATION NOTICE OF AVAILABILITY AND DISTRIBUTION The Notice of Availability (NOA) was distributed to all agencies on the standard notification list maintained by the City of Glendora, Community Development Department, via Certified Mail (see below) and was posted to the San Gabriel Valley Examiner. The NOA and Notice of Completion (NOC) were sent to the State Clearinghouse for distribution to State agencies. STANDARD NOTIFICATION MAILING LIST Agency Address City State Zip Southern California Gas Company 1981 W. Lugonia Ave. Redlands CA 92373 LA County Sanitation Districts 1955 Workman Mill Rd. Whittier CA 90607 Main San Gabriel Watermaster 725 North Azusa Avenue Azusa CA 91702 Charter Oak Unified School District 20240 Cienega Ave. Covina CA 91723 USDA Forest Service 110 North Wabash Avenue Glendora CA 91741 City of Azusa 213 East Foothill Boulevard Azusa CA 91702 California Department of Fish and Game 4949 View Ridge Avenue San Diego CA 92123 LA County Health Services 5050 Commerce Drive Baldwin Park CA 91706 City of Covina 125 East College Covina CA 91723 Citrus Community College 1000 West Foothill Boulevard Glendora CA 91741 Caltrans District 7 (Env. Planning) 100 S. Main Street Los Angeles CA 90012 City of San Dimas 245 East Bonita Avenue San Dimas CA 91773 Municipal Water District of Los Angeles Fifth Floor Rm.V55-113 Los Angeles CA 90012 Southern California Edison 800 West Cienega Avenue San Dimas CA 91773 LA County Fire Department 5823 Rickenbacker Road Commerce CA 90 Three Valleys Municipal Water District 1021 E. Miramar Ave. Claremont CA 91711 MTA CEQA Review Coordinator 1 Gateway Plaza, Stop 99-23-2 Los Angeles CA 90012 LA County Public Works Land Dev. Dept. PO Box 1460 Alhambra CA 91802 Southern California Association of Govt s 818 W. Seventh St., 12 th Floor Los Angeles CA 90017 LA County Department of Regional Planning 320 West Temple Street Los Angeles CA 90012 South Coast Air Quality Management District 21865 East Copley Drive Diamond Bar CA 91765 Covina Valley Unified Schools 519 East Badillo Avenue Covina CA 91723 Azusa Unified School District 546 South Citrus Avenue Azusa CA 91702 Bonita Unified School District 115 West Allen Avenue San Dimas CA 91773 Glendora Unified School District 500 North Loraine Avenue Glendora CA 91741 Local Agency Formation Commission 500 W. Temple Ave. Rm. 383 Los Angeles CA 90012 Fish and Wildlife Service 6010 Hidden Valley Road Carlsbad CA 92009 Torres Martinez Desert Cahuilla Indians P O Box 1160 Thermal CA 92274 Caltrans Aeronautics Program P. O. Box 942784 Sacramento CA 94274 Gabrieleno/Tongva Tribal Council P. O. Box 693 San Gabriel CA 91778 Gabrieleno-Kitz Nation PO Box 393 Covina CA 91723 ARROW HIGHWAY SPECIFIC PLAN 4-1
FINAL ENVIRONMENTAL IMPACT REPORT 4-2 CITY OF GLENDORA
4.0 PUBLIC CIRCULATION ARROW HIGHWAY SPECIFIC PLAN 4-3