HomeMy WebLinkAboutAttachment E - CEQATo: Alfonso Hernandez, Principal Planner, City of Downey
From: Kent Norton, Senior Env. Planner, MIG Riverside
Subject: Foster Bridge & Bluff Residential Project – Response to Comments/Final MND/
Addendum Materials
Date: January 9, 2024
On November 22, 2023 the City of Downey issued an Initial Study/Mitigated Negative Declaration
(IS/MND) for a 30-day local public review period to comply with the requirements of the California
Environmental Quality Act (CEQA). As part of the CEQA process, the State Clearinghouse (SCH)
issued the following tracking number for this project: 2023110053. The following information is
considered a Response to Comments document for the IS/MND as well as an addendum as it
provides supplemental information that merely clarifies and does not change the analysis or
conclusions in the IS/MND.
1.Notice of Intent/Availability Circulation
The original NOI/A was issued for the project on November 21, 2023 but City staff noted several
minor corrections were needed so a revised NOI/A was issued and filed with the State Clearinghouse
on November 22, 2023. Any written comments received on the IS /MND from November 21 through
December 22 have been responded to in this memorandum (see below)
2.Response to Comments
The public comment period ended on December 22, 2023 and the City re received two (2) written
comments on the IS/MND, one from a concerned City resident living near the project and one from
the Los Angeles County Sanitation Districts (LACSD). The following provides the comments received
and provides responses to those comments as appropriate.
2.A Email from the Almazan Family dated November 28, 2023
Comment 1: We are the Almazan family living in the island next to the proposed project and we’d
like to share our opinion and concerns on the matter. We have lived on Glencliff Drive for the past
27 years, small quaint neighborhood and want to keep it that way. We believe the amount of homes
planned to be built is excessive for the small piece of land. This will greatly increase rush hour traffic
for a gated community, which means we won’t have access to it but they will have access to our
streets and leave their excess vehicles in front of our homes. With the average three bedroom home
we very much doubt this new community will have enough parking spaces for their residents.
Everyone knows people use their garages for storage rather than their cars, so where do you think
they park? Even if restrictions are imposed, they eventually end up in nearby streets. We have seen
this happen in too many neighborhoods. We hope the city of Downey takes our concerns serio
Attachment E - (Exhibit A)
City of Downey Response to Comments/Final MND Memo
Foster Bridge & Bluff Project
2 MIG, Inc.
protects the quality of life we have here rather than the monetary gain for the city. Sincerely, Javier
and Maria Almazan.
Response 1: It should first be noted the most recent changes to the State CEQA Guidelines
Appendix G (Initial Study Checklist) eliminated consideration of traffic congestion (level of service)
on local roadways and intersections, as well as parking provisions, as potential environmental impact
issues to be evaluated in an Initial Study. However, these issues still remain as planning and
engineering considerations during the City’s development review process, in addition to the CEQA
process. The City reviews all development plans to assure they provide the minimum parking spaces
required by the City Municipal Code, as well as adopted state and regional standards..
2.B Letter from Los Angeles County Sanitation Districts dated December 13, 2023
Comment 1: Patricia Horsley, an environmental planner with the facilities planning department of
the Los Angeles County Sanitation Districts (LACSD), requested the following information be
incorporated into the IS/MND:
The proposed project is located within the jurisdictional boundaries of District No. 2. We offer
the following comments regarding sewerage service:
1. The wastewater flow originating from the proposed project will discharge to a local sewer
line, which is not maintained by the Districts, for conveyance to the Districts’ Montebello Trunk,
located in Florence Place at Toler Avenue. The Districts’ 21 -inch diameter trunk sewer has a
capacity of 4.0 million gallons per day (mgd) and conveyed a peak flow of 1.1 mgd when last
measured in 2016.
2. The expected increase in average wastewater flow from the project, described in the NOI as
33-unit townhouse, is 8,156 gallons per day, after the church on the project site is demolished.
For a copy of the Districts’ average wastewater generation factors, go to www.lacsd.org, under
Services, then Wastewater Program and Permits and select Will Serve Program, and click on
the Table 1, Loadings for Each Class of Land Use link.
3. The wastewater generated by the proposed project will be treated at the A.K. Warren Water
Resource Facility (Warren Facility), formerly known as the Joint Water Pollution Control Plant,
located in the City of Carson, which has a capacity of 400 mgd and currently processes an
average flow of 243.1 mgd.
4. The Districts are empowered by the California Health and Safety Code to charge a fee to
connect facilities (directly or indirectly) to the Districts’ Sewerage System or to increase the
strength or quantity of wastewater discharged from connected facilit ies. This connection fee is
used by the Districts for its capital facilities. Payment of a connection fee may be required
before this project is permitted to discharge to the Districts’ Sewerage System. For more
information and a copy of the Connection Fee Information Sheet, go to www.lacsd.org, under
Services, then Wastewater (Sewage) and select Rates & Fees. In determining the impact to the
Sewerage System and applicable connection fees, the Districts will determine the user category
(e.g. Condominium, Single Family Home, etc.) that best represents the actual or anticipated
Attachment E - (Exhibit A)
City of Downey Response to Comments/Final MND Memo
Foster Bridge & Bluff Project
3 MIG, Inc.
use of the parcel(s) or facilities on the parcel(s) in the development. For more specific
information regarding the connection fee application procedure and fees, please contact the
Districts’ Wastewater Fee Public Counter at (562) 908 -4288, extension 2727.
5. In order for the Districts to conform to the requirements of the Federal Clean Air Act (CAA),
the capacities of the Districts’ wastewater treatment facilities are based on the regional growth
forecast adopted by the Southern California Association of Governments (SCAG). Specific
policies included in the development of the SCAG regional growth forecast are incorporated into
clean air plans, which are prepared by the South Coast and Antelope Valley Air Quality
Management Districts in order to improve air quality in the South Coast and Mojave Desert Air
Basins as mandated by the CAA. All expansions of Districts’ facilities must be sized and service
phased in a manner that will be consistent with the SCAG regional growth forecast for the
counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial. The
available capacity of the Districts’ treatment facilities will, therefore, be limited to levels
associated with the approved growth identified by SCAG. As such, this letter does not constitute
a guarantee of wastewater service but is to advise the City that the Districts intend to provide
this service up to the levels that are legally permitted and to inform the City of the currently
existing capacity and any proposed expansion of the Distric ts’ facilities.
Response 1: This information is hereby incorporated into Section 4.19, Utilities (c. Wastewater) of
the IS/MND. It does not change the determination of impact significance in Section 4.19.c regarding
sewer systems (i.e., less than significant impact with regulatory compliance including the permits
and processes outlined above in the LACSD letter). This additional information does not change the
analysis or conclusions (no mitigation) in the IS/MND regarding wastewater/sewer systems.
3. Traffic and Circulation Analysis (Revised)
An updated Traffic and Circulation Analysis was prepared for the project by Ganddini Group, Inc.
dated Nov 15, 2023 (original dated October 13, 2023). The updated report was included as Appendix
H-2 of the IS/MND. It should be noted the most recent changes to the State CEQA Guidelines
Appendix G (Initial Study Checklist) eliminated consideration of traffic congestion (level of service)
on local roadways and intersections, as well as parking, as potential environmental impact issues to
be evaluated in an Initial Study. However, these issues still remain as planning and engineering
considerations during the City’s development review process, in addition to the CEQA process.
4. Final Historical/Archaeological Resources Survey Report
The IS/MND included a preliminary (draft) historical/archaeological resources survey memorandum
prepared by CRM TECH dated October 13, 2023 as Appendix C-1. This report was considered
preliminary as it did not contain a formal written response from the State Native American Heritage
Commission (NAHC) regarding cultural resources listed in their archives. However, the City did
receive extensive information on local archaeological/Native American tribal resources from
Gabrieleno tribal representatives during the City’s Native American Consultation Process per SB 18
and AB 52, as outlined in Sections 4.5 and 4.18 of the IS/MND.
Attachment E - (Exhibit A)
City of Downey Response to Comments/Final MND Memo
Foster Bridge & Bluff Project
4 MIG, Inc.
On December 6, 2023, CRM TECH issued a revised (final) historical/archaeological resources survey
report which included NAHC archival information. This additional information supports the analysis
and conclusions in the IS/MND that the site and immediate surrounding area do not contain identified
historical or cultural resources or artifacts. However, information from local tribal representatives
still indicates Native American tribal resources may be present in the project area. Therefore, the
IS/MND recommended Mitigation Measures CUL-1 to retain a project archaeologist and TCR-1
through TCR-3 as recommended by the Gabrieleno tribe in their consultation with the City to address
tribal monitoring of grading, disposition of unanticipated resources during grading, and treating
human remains if found during grading.
The additional information in the revised CRM TECH report does not change the analysis,
conclusions, or mitigation in the IS/MND.
5. Revised Noise Mitigation Measure NOI-4
During circulation of the draft IS/MND for public review, MIG and City staff realized a modification
to Mitigation Measure NOI-1 was needed regarding the extent of the noise wall to reduce
construction noise impacts. The measure outlined in the IS/MND incorrectly indicated the noise
barrier would need to extend around the entire site. However, the noise assessment determined the
barrier was only needed along the north boundary of the site adjacent to the closest sensitive
receptor (one single family residence). The noise study concluded City noise standards would not
be exceeded at other sensitive receptor locations around the site without the barrier. Mitigation
Measure NOI-4 is hereby modified as shown below (deleted text is shown in strikeout, added text is
shown underlined):
NOI-4: Implement Construction Activity Noise Control Measures. The following
measures shall apply to project construction activities:
a. Demolition: Activities shall be sequenced to take advantage of existing shielding/noise
reduction provided by existing buildings or parts of buildings and methods that minimize
noise and vibration, such as sawing concrete blocks, prohibiting on -site hydraulic
breakers, crushing or other pulverization activities, shall be employed during project
construction.
b. Demolition, Site Preparation, Grading, and Foundation Work: During all demolition, site
preparation, grading, and structure foundation work activities, a physical noise barrier
shall be installed and maintained around the site perimeter to the maximum extent
feasible given site constraints and access requirements along the north boundary of the
project site. The noise barrier shall extend to a height of eight (8) feet above grade.
Potential barrier options capable of reducing construction noise levels could include, but
are not limited to:
i. A concrete, wood, or other barrier installed at-grade (or mounted to structures
located at-grade, such as a K-Rail), and consisting of a solid material (i.e., free of
openings or gaps other than weep holes) that has a minimum rated transmission
loss value of 20 dB.
Attachment E - (Exhibit A)
City of Downey Response to Comments/Final MND Memo
Foster Bridge & Bluff Project
5 MIG, Inc.
ii. Commercially available acoustic panels or other products such as acoustic barrier
blankets that have a minimum sound transmission class (STC) or transmission loss
value of 20 dB.
iii. Any combination of noise barriers and commercial products capable of achieving
required construction noise reductions during demolition, site preparation, grading,
and structure foundation work activities.
The noise barrier may be removed following the completion of building foundation work (i.e.,
it is not necessary once framing and typical vertical building construction begins provided no
other grading, foundation, etc. work is still occurring on -site).
Again, the noise study determined the noise barrier was only needed along the north boundary of
the site to comply with the City’s noise requirements. Therefore, this change does not result in any
significant noise impacts and no significant changes to the analysis of project noise impacts. This
change will be reflected in the Mitigation Monitoring and Reporting Program (MMRP) described below.
6. Mitigation Monitoring and Reporting Program (MMRP)
As described above, the noise study determined the noise barrier proposed in Mitigation Measure
NOI-4 was only needed along the north boundary of the site, rather than the entire site, to comply
with the City’s noise requirements. Therefore, the corrected measure will be incorporated into the
final IS/MND and MMRP (see attached).
7. Conclusion
This additional information, updated reports, and responses to written comments on the IS/MND do
not substantially change the data, analyses, conclusions, or mitigation measures considered in the
IS/MND (i.e., they do not identify any significant environmental impacts). The only minor revision
needed to the “draft” IS/MND is a modification to Mitigation Measure NOI-4 regarding the extent of
the noise wall to reduce construction noise impacts. Therefore, there are no “substantial revisions”
to the IS/MND required and no need to recirculate the IS/MND for additional public review per CEQA
Guidelines Section 15073.5.
Attachments: Comment Email 2.A and Letter 2.B
Revised Archaeo/Hist Report (Appdx C-1, 12-6-23)
Mitigation Monitoring Program (1-9-24)
Attachment E - (Exhibit A)
Mitigation Monitoring and Reporting Plan 1 City of Downey – Foster Bridge and Bluff Community Residential Project
Mitigation Monitoring and Reporting Progra m
Project: Foster Bridge and Bluff Community Residential Project (VTTM 84168) Date: January 9, 2024
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
AESTHETICS
AES-1: Enhanced Landscaping. Prior to issuance of the first occupancy
permit, the developer shall install enhanced landscaping along the northern
boundary of the site. Its purpose is to substantially block views and lighting
from the project site onto the residence at 7336 Foster Bridge Boulevard just
north of the site. The design and location of this enhanced landscaping,
primarily trees, shall be the responsibility of the City Planning Department.
Prior to
issuance of the
first certificate
of occupancy
Developer and
landscaping
contractor
City Planning staff
verify installation
prior to COO
issued
BIOLOGICAL RESOURCES
Nesting Bird Survey. To the extent feasible, construction activities shall be
scheduled to avoid the nesting season. If construction activities are scheduled
to take place outside the nesting season, all impacts to nesting birds protected
under the MBTA and California Fish and Game Code must be avoided. The
nesting season for most birds in Los Angeles County extends from February
1 through September 1.
If it is not possible to schedule construction activities between September 1
and January 31, then a pre-construction survey for nesting birds will be
conducted by a qualified biologist to ensure that no nests would be disturbed
during project implementation. This survey will be conducted no more than 5
days prior to the initiation of any site disturbance activities and equipment
mobilization, including tree, shrub, or vegetation removal, fence installation,
grading, etc. If project activities are delayed by more than 5 days, an additional
nesting bird survey will be performed. During this survey, the biologist will
inspect all trees and other potential nesting habitats (e.g., trees and shrubs)
in and immediately adjacent to the impact area for nests. Active nesting is
present if a bird is building a nest, sitting in a nest, a nest has eggs or chicks
in it, or adults are observed carrying food to the nest. The results of the
survey(s) will be documented.
If an active nest is found sufficiently close to work areas to be disturbed by
these activities, the qualified biologist will determine the extent of a
construction-free buffer zone to be established around the nest (typically up
to 300 feet for raptors and up to 100 feet for other species), to ensure that no
nests of species protected by the Migratory Bird Treaty Act (MBTA) and
California Fish and Game Code will be disturbed during project
implementation. Within the buffer zone, no site disturbance and mobilization
of heavy equipment, including but not limited to equipment staging, fence
installation, clearing, grubbing, vegetation removal, demolition, and grading
will be permitted until the chicks have fledged.
No more than 3
days prior to the
start of any
ground
disturbance
City Planning
Department
Written proof of
survey prior to
issuance of a
grading permit
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 2 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
A qualified biologist is an individual who has a degree in biological sciences
or related resource management with a minimum of two seasonal years post-
degree experience conducting surveys for nesting birds. During or following
academic training, the qualified biologist will have achieved a high level of
professional experience and knowledge in biological sciences and special-
status species identification, ecology, and habitat requirements.
CULTURAL RESOURCES
CUL-1: Unanticipated Resources. In the event that archaeological
resources (sites, features, or artifacts) are exposed during construction
activities of the project, all construction work occurring within 100 feet of the
find shall immediately stop until a qualified archaeologist, meeting the
Secretary of the Interior’s Professional Qualification Standards, can evaluate
the significance of the find and determine whether or not additional study is
warranted. Depending upon the significance of the find under the California
Environmental Quality Act (CEQA: 14 CCR 15064.5(f): PRC Section
21083.2), the archaeologist may simply record the find and allow work to
continue. However, if the discovery proves significant under CEQA, additional
work, such as preparation of an archaeological treatment plan, testing, or data
recovery, may be warranted.
During and after
grading
City Planning
Department, project
archaeologist, and
consulting tribe(s) to
determine
disposition of any
unique archeological
resources
City Planning
Department to
document
continued
consultation as
needed with tribal
representatives
GEOLOGY/SOILS/PALEONTOLOGICAL RESOURCES
GEO-1: Supplemental Geotechnical Report. Prior to issuance of a grading
permit, the project proponent shall retain a qualified geotechnical consultant
to prepare a supplemental geotechnical investigation as recommended by the
“Geotechnical Due-Diligence Investigation” prepared by Albus & Associates,
Inc. dated February 6, 2023. The supplemental report shall be certified by the
City Engineer as adequate for the purposes of design, permitting, and
construction.
Prior to issuance
of a grading
permit
Qualified engineer
shall submit a
supplemental
geotechnical report
to the City
Engineering
Department
City Engineer shall
sign off on the
supplemental
report prior to
issuance of the
permit
GEO-2: Conduct Paleontological Sensitivity Training for Construction
Personnel. The project proponent must retain a professional paleontologist,
who meets the qualifications set forth by the Society of Vertebrate
Paleontology, to conduct a Paleontological Sensitivity Training for
construction personnel before commencement of excavation activities. The
training would include a handout and would focus on how to identify
paleontological resources that may be encountered during earthmoving
activities, and the procedures to be followed in such an event; the duties of
paleontological monitors; notification and other procedures to follow upon
discovery of resources; and the general steps a qualified professional
paleontologist would follow in conducting a salvage investigation if one is
necessary.
Prior to the start
of grading or
clearing the site
Developer shall
retain a qualified
paleontologist to
conduct training of
grading and clearing
staff regarding
paleontological
resources
Project
paleontologist shall
prepare a brief
report to the City
Planning
Department
summarizing their
training efforts.
GEO-3: Conduct Periodic Paleontological Spot Checks During Grading
and Earth-Moving Activities. The project proponent must retain a
During grading Project
paleontologist shall
Project
paleontologist shall
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 3 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
professional paleontologist, who meets the qualifications set forth by the
Society of Vertebrate Paleontology, to conduct periodic Paleontological Spot
Checks beginning at depths below six feet from the surface to determine if
construction excavations extend into older Quaternary deposits. After the
initial Paleontological Spot Check, further periodic checks would be
conducted at the discretion of the qualified paleontologist. If the qualified
paleontologist determines that construction excavations have extended into
the older Quaternary deposits, construction monitoring for Paleontological
Resources are required. The project proponent must retain a qualified
paleontological monitor, who would work under the guidance and direction of
a professional paleontologist, who meets the qualifications set forth by the
Society of Vertebrate Paleontology. The paleontological monitor must be
present during all construction excavations (e.g., grading, trenching, or
clearing/grubbing) into the older Pleistocene alluvial deposits. Multiple earth-
moving construction activities may require multiple paleontological monitors.
The frequency of monitoring is based on the rate of excavation and grading
activities, proximity to known paleontological resources and/or unique
geological features, the materials being excavated (native versus artificial fill
soils), and the depth of excavation, and if found, the abundance and type of
paleontological resources and/or unique geological features encountered.
Full-time monitoring can be reduced to part-time inspections if determined
adequate by the qualified professional paleontologist.
conduct
unannounced
checks of project
clearing and grading
to assure proper
procedures of GEO-
2 are being followed
prepare a brief
report to the City
Planning
Department
summarizing the
results of their
monitoring efforts
GEO-4: Cease Ground-Disturbing Activities and Implement Treatment
Plan if Paleontological Resources Are Encountered. In the event that
paleontological resources and or unique geological features are unearthed
during ground-disturbing activities, ground-disturbing activities the
paleontological monitor may halt or divert away from the vicinity of the find so
that the find can be evaluated. A buffer area of at least 50 feet must be
established around the find where construction activities are not allowed to
continue until an appropriate paleontological treatment plan is approved by
the project proponent and the City. Work is allowed to continue outside of the
buffer area. The project proponent and City would coordinate with a
professional paleontologist, who meets the qualifications set forth by the
Society of Vertebrate Paleontology, to develop an appropriate treatment plan
for the resources. Treatment may include implementation of paleontological
salvage excavations to remove the resource along with subsequent laboratory
processing and analysis or preservation in place. At the paleontologist’s
discretion and to reduce construction delay, the grading and excavation
contractor would assist in removing rock samples for initial processing.
During grading If summoned to the
site or observes
paleontological
resources, the
project
paleontologist shall
immediately halt
grading to evaluate
the find and
determine
appropriate action
based on the find
and notify the City
Planning
Department
immediately of the
discovery
Once notified, the
Planning
Department shall
monitor any
recovery activities
in consultation with
the project
paleontologist
GEO-5: Prepare Report Upon Completion of Monitoring Services. If
paleontological resources are found, upon completion of the activities
identified under Mitigation Measure GEO-4, the professional paleontologist
Within 45 days
of the
Paleontologist shall
prepare a summary
report of monitoring
The Planning
Department shall
confirm in email or
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 4 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
would prepare a report summarizing the results of the monitoring and
salvaging efforts, the methodology used in these efforts, and a description of
the fossils collected and their significance. The report would be submitted to
the project proponent, the City, the Natural History Museums of Los Angeles
County, and representatives of other appropriate or concerned agencies to
signify the satisfactory completion of the project and required mitigation
measures.
completion of
grading
activities, any
resources found,
and the disposition
of any resources
writing the receipt
of the project
paleontologist’s
report(s).
HAZARDS/HAZARDOUS MATERIALS
HAZ-1: Inadvertent Hazmat Discovery. Prior to issuance of a grading
permit, the project proponent shall retain a qualified environmental
professional (QEP) experienced with remediating hazardous materials from
infill urban construction sites. The QEP must be on-call and summoned to the
site immediately if any potentially hazardous materials are found during
grading. Grading must be halted within 100 feet of an area that appears to
contain hazardous materials. The QEP will halt grading as necessary to
effectively identify the potential contaminated materials, including directing
any sampling and laboratory testing that may be required.
If soils are found to be contaminated at levels that are only slightly in excess
of applicable residential standards, the QEP shall exercise professional
discretion and have the option to coordinate with the grading contractor and
developer to either remove contaminated soil and/or mix the contaminated
soil with clean soil from either onsite or offsite to dilute any contaminants to
below applicable exposure standards for residential development.
Remediated areas must be retested to assure potential contaminant levels
are below applicable residential standards. The results of any testing shall be
provided to the City or other agencies as appropriate and no further action is
needed. Any contaminated soil that must be removed from the site shall be
done by a licensed contractor and hauled to a landfill approved for such
materials. This measure shall be implemented to the satisfaction of the City
Community Development Department.
Prior to issuance
of a grading
permit
During grading
Developer shall
retain a QEP and
provide written proof
to the City Planning
Department
Upon notification or
observing the
discovery of any
unknown materials
during grading, the
Project QEP shall
halt work in that
area and determine
the identify of the
material(s).
If any hazardous
materials are found,
the QEP will
coordinate with the
City, developer, and
LA County Fire
Department, Health
Hazardous Materials
Division (CUPA) if
necessary to
determine the
appropriate
disposition for the
materials.
HAZ-2: ACMs and LBP Survey. Prior to demolition of any structures on the
project site, the developer shall retain qualified licensed environmental
contractor(s) to survey the existing onsite church building and any related
structures for asbestos-containing materials (ACMs) and Lead-Based Paints
Prior to issuance
of a demolition
permit
Developer shall
retain qualified
personnel to survey
the church buildings
Developer shall
document results of
ACM and LBP
survey and what, if
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 5 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
(LBPs). If the survey finds the presence of any ACMs or LBPs on the site, the
contractor(s) shall follow all relevant guidance from affected regulatory
agencies (e.g., CalEPA, SCAQMD, DTSC, County Health Department, etc.)
in terms of safe removal and disposal of the contaminated materials as
appropriate. The contractor(s) shall prepare and submit a final report to the
City Community Development Department within 30 days after completion of
demolition/removal for ACMs and LBPs on the project site.
for ACMs and LBP
and conduct
appropriate
remediation of such
materials are found
any, remediation
was conducted.
Demolition permit
shall not be issued
until the City
Planning
Department
concurs with its
findings
NOISE
NOI-1: Notify Residential Land Uses of Planned Construction Activities.
This notice shall be provided at least two (2) weeks prior to the start of any
construction activities, describe the noise control measures to be
implemented by the project, and include the name and phone number of the
designated contact for the project proponent and the City of Downey
responsible for handling construction-related noise complaints (per MM NOI-
5). This notice shall be provided to the owner/occupants of residential dwelling
units within 500 feet of construction work areas.
At least two (2)
weeks prior to
the start of any
construction
activities
Developer shall
provide verifiable
notice to local
residential neighbors
within 200 feet of the
project boundaries
of the start of
construction
Developer shall
provide copies of
notices, mailing
lists, methods of
delivery, and
confirmation of
receiving the
notices
NOI-2: Restrict Work Hours. All construction-related work activities,
including material deliveries, shall be subject to the requirements of City
Municipal Code Section 4.50.100. Construction activities, including deliveries,
shall occur only during the hours of 7 AM to 7 PM Monday to Friday and 9 AM
to 6 PM on Saturday, Sunday, and holidays. The project proponent
representative and/or its contractor shall post a sign at all entrances to the
construction site informing contractors, subcontractors, other workers, etc. of
this requirement
During any
construction-
related activities
on the site
Developer shall
certify to the City
they are enforcing
the City’s work hour
restrictions, post
appropriate signs,
and place work hour
limits on
construction plans
City Inspectors as
appropriate to
monitor work hour
limits as necessary
NOI-3: Construction Equipment Selection, Use, and Noise Control
Measures. The following measures shall apply to construction equipment
used at the project site:
a. Contractors shall use the smallest size equipment capable of safely
completing work activities.
b. Construction staging shall occur as far away from residential land uses as
possible given site and active work constraints.
c. Electric hook-ups shall be provided for stationary equipment (e.g., pumps,
compressors, welding sets). If it is not feasible to provide an electric hook-
up, the project proponent shall ensure mitigation measures 3a and 3d are
implemented.
d. All stationary noise generating equipment shall be shielded and located
as far as possible from residential land uses given site and active work
constraints. Shielding may consist of existing vacant structures or a three-
Prior to and
during any
construction
activities on the
site
Developer shall
certify in writing they
will implement these
procedures during
all work activities.
Notes shall be
placed on
construction plans to
this effect and
initialed by all sub-
contractors
City Inspectors
shall verify this
compliance with
unannounced
inspections during
work activities
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 6 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
or four-sided enclosure provided the structure/enclosure breaks the line
of sight between the equipment and the receptor and provides for proper
ventilation and equipment operation.
e. Heavy equipment engines shall be equipped with standard noise
suppression devices such as mufflers, engine covers, and
engine/mechanical isolators, mounts, and be maintained in accordance
with manufacturer’s recommendations during active construction
activities.
f. Pneumatic tools shall include a suppression device on the compressed
air exhaust.
g. No radios or other amplified sound devices shall be audible beyond the
property line of the construction site.
NOI-4: Implement Construction Activity Noise Control Measures. The
following measures shall apply to project construction activities:
a. Demolition: Activities shall be sequenced to take advantage of existing
shielding/noise reduction provided by existing buildings or parts of
buildings and methods that minimize noise and vibration, such as sawing
concrete blocks, prohibiting on-site hydraulic breakers, crushing or other
pulverization activities, shall be employed during project construction.
b. Demolition, Site Preparation, Grading, and Foundation Work: During all
demolition, site preparation, grading, and structure foundation work
activities, a physical noise barrier shall be installed and maintained
around the site perimeter to the maximum extent feasible given site
constraints and access requirements along the north boundary of the
project site*. The noise barrier shall extend to a height of eight (8) feet
above grade. Potential barrier options capable of reducing construction
noise levels could include, but are not limited to:
i. A concrete, wood, or other barrier installed at-grade (or mounted to
structures located at-grade, such as a K-Rail), and consisting of a
solid material (i.e., free of openings or gaps other than weep holes)
that has a minimum rated transmission loss value of 20 dB.
ii. Commercially available acoustic panels or other products such as
acoustic barrier blankets that have a minimum sound transmission
class (STC) or transmission loss value of 20 dB.
iii. Any combination of noise barriers and commercial products capable
of achieving required construction noise reductions during
demolition, site preparation, grading, and structure foundation work
activities.
During all
project
construction
activities as
appropriate
Developer shall
certify to the City
these measures will
be implemented by
all contractors and
sub-contractors on
the site
City Inspectors
shall verify this
compliance with
unannounced
inspections during
work activities
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 7 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
iv. The noise barrier may be removed following the completion of
building foundation work (i.e., it is not necessary once framing and
typical vertical building construction begins provided no other
grading, foundation, etc. work is still occurring on-site).
NOI-5: Prepare a Construction Noise Complaint Plan. The project proponent
shall prepare a Construction Noise Complaint Plan that shall:
a. Identify the name and/or title and contact information (including phone
number and email) for a designated project and City representative
responsible for addressing construction-related noise issues.
b. Includes procedures describing how the designated project
representative will receive, respond, and resolve construction noise
complaints.
c. At a minimum, upon receipt of a noise complaint, the project
representative shall notify the City contact, identify the noise source
generating the complaint, determine the cause of the complaint, and take
steps to resolve the complaint.
Prior to issuance
of any permit for
any construction
activities
Developer, in
consultation with
their noise
consultant, shall
prepare a CNCP for
review and approval
by the City Planning
Department
The City Planning
Department shall
approve the CNCP
prior to issuance of
any work permits
for the project
Tribal Cultural Resources
TCR-1: Tribal Monitor. The project applicant/lead agency shall retain a
Native American Monitor from or approved by the Gabrieleño Band of Mission
Indians – Kizh Nation. The monitor shall be retained prior to the
commencement of any “ground-disturbing activity” for the subject project at
all project locations (i.e., both on-site and any off-site locations that are
included in the project description/definition and/or required in connection with
the project, such as public improvement work). “Ground-disturbing activity”
shall include, but is not limited to, demolition, pavement removal, potholing,
auguring, grubbing, tree removal, boring, grading, excavation, drilling, and
trenching.
A copy of the executed monitoring agreement shall be submitted to the lead
agency prior to the commencement of any ground-disturbing activity, or the
issuance of any permit necessary to commence a ground-disturbing activity.
The monitor will complete daily monitoring logs that will provide descriptions
of the relevant ground-disturbing activities, the type of construction activities
performed, locations of ground-disturbing activities, soil types, cultural-related
materials, and any other facts, conditions, materials, or discoveries of
significance to the Tribe. Monitor logs will identify and describe any
discovered TCRs, including but not limited to, Native American cultural and
historical artifacts, remains, places of significance, etc., (collectively, tribal
cultural resources, or “TCR”), as well as any discovered Native American
(ancestral) human remains and burial goods. Copies of monitor logs will be
Prior to issuance
of a grading
permit
During grading
Developer shall
submit written
verification of NA
tribal monitoring
agreement(s)
Tribal monitor(s) to
observe grading and
confirm completion
to the City Planning
Department
Planning
Department verify
signed
agreement(s) in
place
Planning
Department confirm
receipt of tribal
completion notice
Attachment E (Exhibit B)
Mitigation Monitoring and Reporting Plan 8 City of Downey – Foster Bridge and Bluff Community Residential Project
Impact Category/
Mitigation Measures
Implementation
Timing
Responsible
Monitoring Party
Monitoring/
Reporting Method
Compliance
Verification
provided to the project applicant/lead agency upon written request to the
Tribe.
On-site tribal monitoring shall conclude upon the latter of the following (1)
written confirmation to the Kizh from a designated point of contact for the
project applicant/lead agency that all ground-disturbing activities and phases
that may involve ground-disturbing activities on the project site or in
connection with the project are complete; or (2) a determination and written
notification by the Kizh to the project applicant/lead agency that no future,
planned construction activity and/or development/construction phase at the
project site possesses the potential to impact Kizh TCRs.
TCR-2: Unanticipated Discoveries. Upon discovery of any Tribal Cultural
Resources (TCRs), all construction activities in the immediate vicinity of the
discovery shall cease (i.e., not less than the surrounding 50 feet) and shall
not resume until the discovered TCR has been fully assessed by the Kizh
monitor and/or Kizh archaeologist. The Kizh will recover and retain all
discovered TCRs in the form and/or manner the Tribe deems appropriate, in
the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate,
including for educational, cultural and/or historic purposes.
During grading Tribal monitor(s)
and/or archaeologist
communicate
discovery of
resources within one
hour of discovery to
Planning
Department
Planning
Department confirm
tribal notification
and consult with
monitoring tribe as
to the disposition of
the discovered
resource
TCR-3: Human Remains. Native American human remains are defined in
PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of
decomposition or skeletal completeness. Funerary objects, called associated
grave goods in Public Resources Code Section 5097.98, are also to be
treated according to this statute. If Native American human remains and/or
grave goods are discovered or recognized on the project site, then Public
Resource Code 5097.9 as well as Health and Safety Code Section 7050.5
shall be followed. Human remains and grave/burial goods shall be treated
alike per California Public Resources Code section 5097.98(d)(1) and (2).
Preservation in place (i.e., avoidance) is the preferred manner of treatment
for discovered human remains and/or burial goods. Any discovery of human
remains/burial goods shall be kept confidential to prevent further disturbance.
During grading Tribal monitor(s)
and/or archaeologist
communicate
discovery of remains
within one hour of
discovery to
Planning
Department
Planning
Department confirm
tribal notification
and consult with
monitoring tribe as
to the disposition of
the discovered
remains
* This minor change was made to correct an inaccurate statement in the draft IS/MND noise section that the proposed constructio n noise barrier was needed around the entire site since the noise
study determined the barrier was actually needed only on the north side of the site to meet City noise standards. This change is documented in the Final IS/MND Memo dated January 9, 2024.
Attachment E (Exhibit B)
Foster Bridge and Bluff Residential Project
Draft Initial Study and
Mitigated Negative Declaration
Lead Agency:
City of Downey
Community Development Department
11111 Brookshire Avenue
Downey, California 92041
Contact: Alfonso Hernandez
ashernandez@downeyca.org
Applicant:
The Olson Company
3020 Old Ranch Parkway, Suite 100
Seal Beach, California 90740
Contact: Steven Armanino
sarmanino@theolsonco.com
Prepared by:
MIG, Inc.
1650 Spruce Street, Suite 106
Riverside, CA 92507
Contact: Kent Norton
knorton@migcom.com
Public Review Draft
November 21, 2023
Exhibit E (Attachment C)
- This document is designed for double -sided printing.-
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project i
City of Downey
Table of Contents
1 Introduction ............................................................................................................................. 1
1.1 – Purpose of CEQA .................................................................................................... 1
1.2 – Public Comments .................................................................................................... 2
1.3 – Availability of Materials ............................................................................................ 3
1.4 -- History of the Site …………………………………………………………..……………..3
2 Project Description................................................................................................................... 5
2.1 – Project Title ............................................................................................................. 5
2.2 – Lead Agency Name and Address ............................................................................ 5
2.3 – Contact Person and Phone Number ........................................................................ 5
2.4 – Project Sponsor’s Name and Address ..................................................................... 5
2.5 – Project Location....................................................................................................... 5
2.6 – General Plan Land Use Designation ........................................................................ 6
2.7 – Zoning District ......................................................................................................... 6
2.8 – Surrounding Land Uses ........................................................................................... 6
2.9 – Environmental Setting ............................................................................................. 7
2.10 – Project Description .................................................................................................. 7
2.11 – Required Approvals ............................................................................................... 10
2.12 – Other Public Agency Whose Approval is Required ................................................ 10
3 Environmental Determination ................................................................................................. 33
3.1 – Environmental Factors Potentially Affected ........................................................... 33
3.2 – Determination ........................................................................................................ 33
4 Evaluation of Environmental Impacts ..................................................................................... 35
4.1 – Aesthetics .............................................................................................................. 35
4.2 – Agriculture and Forest Resources ......................................................................... 38
4.3 – Air Quality .............................................................................................................. 40
4.4 – Biological Resources ............................................................................................. 48
4.5 – Cultural Resources ................................................................................................ 51
4.6 – Energy ................................................................................................................... 53
4.7 – Geology and Soils ................................................................................................. 55
4.8 – Greenhouse Gas Emissions .................................................................................. 60
4.9 – Hazards and Hazardous Materials......................................................................... 65
4.10 Hydrology and Water Quality ................................................................................. 70
4.11 – Land Use and Planning ......................................................................................... 76
4.12 – Mineral Resources ................................................................................................ 77
4.13 – Noise ..................................................................................................................... 78
4.14 Population and Housing ........................................................................................ 90
4.15 Public Services ...................................................................................................... 91
4.16 Recreation ............................................................................................................. 95
4.17 Transportation and Traffic ..................................................................................... 96
4.18 – Tribal Cultural Resources .................................................................................... 101
4.19 – Utilities and Service Systems .............................................................................. 105
4.20 – Wildfire ................................................................................................................ 112
4.21 – Mandatory Findings of Significance ..................................................................... 114
5 Mitigation Summary ............................................................................................................. 119
6 References ......................................................................................................................... 126
6.1 List of Preparers .................................................................................................. 126
6.2 Persons and Organizations Consulted ................................................................ 126
6.3 Bibliography ........................................................................................................ 127
Exhibit E (Attachment C)
Table of Contents
ii Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
List of Tables
Table 2.8-1 Existing Land Uses ........................................................................................................... 6
Table 2.10-1 Project Construction Activities ....................................................................................... 10
Table 4.3-1 South Coast Air Basin (Non-Desert) Attainment Status ................................................... 41
Table 4.3-2 Regional Construction Emissions.................................................................................... 43
Table 4.3-3 Regional Operational Emissions ..................................................................................... 44
Table 4.3-4 LST Construction Emissions ........................................................................................... 45
Table 4.3-5 LST Operational Emissions............................................................................................. 46
Table 4.8-1 Project Greenhouse Gas Emissions ............................................................................... 62
Table 4.8-2 Project Consistency with Key GHG Reducing Attributes (2022 Scoping Plan) ................ 63
Table 4.13-1 Potential Project Construction Equipment Noise Levels ................................................ 81
Table 4.13-2 Caltrans’ Vibration Criteria for Building Damage ........................................................... 86
Table 4.13-3 Vibration Criteria for Human Response ......................................................................... 86
Table 4.13-4 Potential Project Construction Vibration Levels ............................................................. 87
Table 4.14-1 SCAG Growth Projections for Downey .......................................................................... 90
Table 4.15-1 Local School Enrollments.............................................................................................. 93
Table 4.15-2 School Capacities vs. Projected Enrollment .................................................................. 93
Table 4.17-1 Project Trip Generation ................................................................................................. 98
Table 4.17-2 Range of Local Daily Trip Screening Thresholds in the Region 103
Table 4.17-3 Daily Trip Threshold that Exceed GHG Emissions Threshold ..................................... 100
Table 4.19-1 Projected City Water Demand and Supply (acre -feet/year) ......................................... 106
Table 4.19-2 Single Dry Year Supply and Demand Scenario ........................................................... 110
Table 4.19-3 Multiple Dry Year Supply and Demand Scenario ........................................................ 110
List of Exhibits
Exhibit 1 Regional Location ............................................................................................................... 11
Exhibit 2 Project Area Map ................................................................................................................ 13
Exhibit 3 Site Photographs................................................................................................................. 15
Exhibit 4 General Plan Designations .................................................................................................. 19
Exhibit 5 Zoning Designations ........................................................................................................... 21
Exhibit 6 Conceptual Site Plan ........................................................................................................... 23
Exhibit 7 Project Elevations ............................................................................................................... 25
Exhibit 8 Open Space Plan ................................................................................................................ 27
Exhibit 9 Landscape Plan .................................................................................................................. 29
Exhibit 10 Wall and Fence Plan ......................................................................................................... 31
List of Appendices
Appendix A Air Quality & GHG & Energy Impact Report
Appendix B Biological Resources Information
Appendix C Cultural Resources Assessment
Appendix D Geotechnical Report
Appendix E Phase I Environmental Site Assessment
Appendix F Preliminary Low Impact Development Plan
Appendix G Noise and Vibration Analysis
Appendix H Traffic Study
Appendix I Tribal Consultation Information
Appendix J Utility Information
Appendix K Project Plans
Exhibit E (Attachment C)
iii
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 1
City of Downey
1 Introduction
The City of Downey (“Lead Agency” or “City”) received an application from The Olson Company (“project
proponent”) to construct a 33-unit townhouse development (the “project” or “proposed project”) on a
1.29-acre site located at 7360 Foster Bridge Boulevard (Assessor’s Parcel Number: 6358-015-058) in
the northwestern portion of the City of Downey, California. The application for the Foster Bridge and
Bluff Community Residential P roject includes Vesting Tentative Tract Map No. 84168, a General Plan
Amendment, a Zone Change, and a Site Plan Review analyzing the architecture, landscaping,
circulation of the new proposed design, and demolition of the existing onsite church and parking lot.
The project requires review under the California Environmental Quality Act (CEQA) (Public Resources
Code Sections 21000 et seq.) and the CEQA Guidelines (14 California Code of Regulations Sections
15000, et seq.).
This Initial Study was prepared to assess the short -term, long-term, and cumulative environmental
impacts that could result from approval of the proposed project. This report was prepared to comply
with CEQA Guidelines Section 15063 (d) which requires an Initial Study to include the following:
▪ A description of the project, including the location of the project (see Section 2)
▪ Identification of the environmental setting (see Section 2.10)
▪ Identification of environmental effects by use of a checklist, matrix, or other methods, provided
that entries on the checklist or other form are briefly explained to indicate that there is some
evidence to support the entries (see Section 4)
▪ Discussion of ways to mitigate significant effects identified, if any (see Section 4)
▪ Examination of whether the project is compatible with existing zoning, plans, and other
applicable land use controls (see Section 4.1 1)
▪ The name(s) of the person(s) who prepared or participated in the preparation of the Initial Study
(see Section 6)
1.1 – Purpose of CEQA
CEQA is intended to implement the following:
“The Legislature finds and declares as follows:
a) The maintenance of a quality environment for the people of this state now and in the future is a
matter of statewide concern.
b) It is necessary to provide a high-quality environment that at all times is healthful and pleasing to the
senses and intellect of man.
c) There is a need to understand the relationship between the maintenance of high -quality ecological
systems and the general welfare of the people of the state, including their enjoyment of the natural
resources of the state.
d) The capacity of the environment is limited, and it is the intent of the Legislature that the government
of the state take immediate steps to identify any critical thresholds for the health and safety of the
people of the state and take all coordinated actions necessary to prevent such thresholds being
reached.
e) Every citizen has a responsibility to contribute to the preservation and enhancement of the
environment.
f) The interrelationship of policies and practices in the management of natural resources and waste
disposal requires systematic and concerted efforts by public and private interests to enhance
environmental quality and to control environmental pollution.
Exhibit E (Attachment C)
1 – Introduction
2 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
g) It is the intent of the Legislature that all agencies of the state government which regulate activities
of private individuals, corporations, and public agencies which are found to affect the quality of the
environment, shall regulate such activities so that major consideration is given to preventing
environmental damage, while providing a decent home and satisfying living environment for every
Californian.
The Legislature further finds and declares that it is the policy of the State to:
a) Develop and maintain a high -quality environment now and in the future, and take all action
necessary to protect, rehabilitate, and enhance the environmental quality of the state.
b) Take all action necessary to provide the people of this state with clean air and water, enjoyment of
aesthetic, natural, scenic, and historic environmental qualities, and freedom from excessive noise.
c) Prevent the elimination of fish or wildlife species due to man's activities, insure that fish and wildlife
populations do not drop below self -perpetuating levels, and preserve for future generations
representations of all plant and animal communities and examples of the major periods of California
history.
d) Ensure that the long -term protection of the environment, consistent with the provision of a decent
home and suitable living environment for every Californian, shall be the guiding criterion in public
decisions.
e) Create and maintain conditions under which man and nature can exist in productive harmony to
fulfill the social and economic requirements of present and future generations.
f) Require governmental agencies at all levels to develop standards and procedures necessary to
protect environmental quality.
g) Require governmental agencies at all levels to consider qualitative factors as well as economic and
technical factors and long -term benefits and costs, in addition to short -term benefits and costs and
to consider alternatives to proposed actions affectin g the environment.”
A concise statement of legislative policy, with respect to public agency consideration of projects for
some form of approval, is found in CEQA Section 21002 significant effects. The Legislature further finds
and declares that in the event specific economic , social, or other conditions make such project
alternatives or such mitigation measures infeasible, individual projects may be approved in spite of one
or more significant effects thereof.
1.2 – Public Comments
Written comments from all public agencies and individuals are invited regarding the information
contained in this IS/MND. Such comments should explain any perceived deficiencies in the assessment
of impacts, identify the information that is purportedly lacking in the Initial Study or indicate where the
information may be found. All comments on the IS/MND must be provided before the close of the 30 -
day public review period and are to be submitted to:
Alfonso Hernandez, Principal Planner
Community Development Department
City of Downey
11111 Brookshire Avenue
Downey, California 90241
Phone: (562) 904-7154
Email: asherhandez@downeyca.org
Following a 30-day period of circulation and public review of the IS/MND, all written comments will be
considered by the City of Downey prior to taking action on the project adopting the IS/MND.
Exhibit E (Attachment C)
1 – Introduction
Foster Bridge and Bluff Residential Project 3
City of Downey
1.3 – Availability of Materials
All materials related to the preparation of this Initial Study are available for public review at the City Hall,
The Columbia Space Center, the City Library, and the Barbara J. Riley Center or available on the City’s
website homepage:
https://www.downeyca.org/our-city/departments/community-development/housing-
division/public-document-review
To request an appointment to review these materials at City Hall, please contact Alfonso Hernandez,
Principal Planner, via telephone at (562) 904-7154 or via email at asherhandez@downeyca.org
City Hall – 11111 Brookshire Avenue, Downey, Ca. 90241
Columbia Space Center – 12400 Columbia Way, Downey, CA 90242
City Library – 11121 Brookshire Ave #586, Downey, CA 90241
Barbara J. Riley Center – 7810 Quill Dr, Downey, CA 90242
1.4 – History of the Site
The project site was undeveloped or in agricultural use between 1896 and 1902. From the 1920s to the
mid-1950s, it was developed with agricultural orchards and a rural farmhouse. The existing church was
developed in stages, beginning in the late -1950s and expanded to its current configuration with a paved
asphalt parking lot around it by 1989. The construction of the church coincides with the time when the
Rio Hondo River was realigned and channelized to the southeast of the site, rerouting it from its original
course northeast of the site. Today, the church parking lot sits approximately 4 -6 feet higher in elevation
than the adjoining residence to the north. It is likely that fill material originating from the river
channelization process was placed on the site at that time, raising its elevation.
Exhibit E (Attachment C)
1 – Introduction
4 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 5
City of Downey
2 Project Description
2.1 – Project Title
Foster Bridge and Bluff Community Residential Project (VTTM 84168)
2.2 – Lead Agency Name and Address
City of Downey
Community Development Department
11111 Brookshire Avenue
Downey, California 92041
2.3 – Contact Person and Phone Number
Alfonso Hernandez, Principal Planner
ashernandez@downeyca.org
Phone: (562) 904-7154
2.4 – Project Sponsor’s Name and Address
The Olson Company
3020 Old Ranch Parkway, Suite 100
Seal Beach, California 90740
Contact: Steven Armanino
sarmanino@theolsonco.com
(562) 596-4770
2.5 – Project Location
The project site is located on 1.29 acres at the northwest corner of Foster Bridge Boulevard and Suva
Street in the northwestern portion of the City of Downey (See Exhibit 1, Regional Context Map). South
Bluff Road also runs along the southeast point of the property forming a five -legged intersection (See
Exhibit 2, Project Vicinity Map ). The site is adjacent to the Rio Hondo River and Trail (across South
Bluff Road) to the south. The City of Bell Gardens is located northwest of the site and the self-storage
facility northwest of the site is divided between the two cities . The site is located 0.9 mile west of the I-
5 Freeway and 1.8 miles east of the I -710 Freeway. Various views of the project site and surrounding
area are provided in Exhibit 3, Site Photographs.
Address: 7360 Foster Bridge Boulevard
Latitude/Longitude: 33o 57’ 57” North / 118o 08’ 11” West
Assessor Parcel Number: 6358-015-058
TRS Listing: Township 2 South Range 12 West Section 00 (Lot 40)(SBBM)
USGS 7.5” Topographic Map: Southgate
Thomas Bros. Map: LA County, Page 706 (Downey)
Exhibit E (Attachment C)
2 – Project Description
6 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
2.6 – General Plan Land Use Designation
The Land Use Element of the City’s General Plan designates the project site as Low Density Residential
(LDR) which allows up to 8.9 dwelling units/acre. The project is requesting a General Plan Amendment
to change the site’s land use designation to Medium Density Residential (MDR) which allows up to 24
units/acre. The density of the proposed project is 20.6 units per gross acre (See Exhibit 4, General Plan
Designations).
2.7 – Zoning District
The City of Downey Municipal Code (CDMC) zoning regulations designate the project site as R-1 6,000
which is a single-family detached residential designation. The project proposes to change the site’s
zoning designation to Multi-Family Residential Ownership Zone (R-3-0). The project also includes a
density Bonus for three moderate income level townhouse units in addition to 30 market rate townhouse
units.
The density of the project as proposed is 20.6 units per gross acre while the R -3-O zone allows up to
approximately 22 units/acre. According to the City Zoning Code, the R -3-O zone is intended to provide
“for the development of multiple -family ownership type housing in selected areas compatible with the
neighborhood environment. Such areas are envisioned as being located and designed to be
complementary to adjacent uses and providing sufficient opportunities for ownership in multiple -family
housing” (See Exhibit 5, Zoning Designations).
2.8 – Existing and Surrounding Land Uses
The project site currently supports an operating church (“TLG I House”) with a parking lot but no school
or pre-school uses. Adjacent land uses include single family homes to the north and across Foster
Bridge Boulevard to the east, the Rio Hondo Channel to the southeast, apartments to the southwest
across Suva Street, and a self-storage facility to the northwest. Surrounding uses are summarized in
Table 2.8-1 (Existing Land Uses). The locations of surrounding land uses are shown in Exhibit 2, Project
Area Map, and views of the site and surrounding area are shown in Exhibit 3, Site Photographs. The
self-storage facility to the northwest is split between Downey and the City of Bell Gardens to the west.
Table 2.8-1
Existing Land Uses
Direction General Plan Designation Zoning
District
Existing
Land Use
Project Site
Existing
Proposed
Low Density Residential (LDR)
Medium Density Residential (MDR)
R-1-6,000
R-3-0
Church
Townhomes
North Low Density Residential (LDR) R-1-6,000 SFR homes
South Low Density Residential (LDR)
Open Space (OS)
R-1-6,000
R-1-6,000
Apartments
Rio Hondo River
East Low Density Residential (LDR) R-1-6,000 SFR homes
West Low Density Residential (LDR) R-1-6,000 Self Storage
Sources: Google Earth, City General Plan and Zoning maps SFR = single family residential
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 7
City of Downey
2.9 – Environmental Setting
The City of Downey occupies approximately 12.8 square miles and is located in the southeastern part
of Los Angeles County. The City is surrounded by the cities of Pico Rivera to the north, Santa Fe Springs
to the northeast, Norwalk to the east, Bellflower and Paramount to the south, South Gate to the
southwest and west, and Commerce to the northwest. The City of Downey is located approximately 13
miles northeast of the Ports of Los Angeles and Long Beach. There are four freeways that provide direct
access to Downey: Interstate I-605 (San Gabriel River Freeway), which crosses the eastern portion of
the City; I-5 (Santa Ana Freeway), which crosses the northern portion of the City; the I -105 intersection,
which crosses the southern part of the City; and I -710 (Long Beach Freeway), which does not cross the
City but is located west of the City and accessible via three major streets: Florence Avenue, Firestone
Boulevard, and Imperial Highway (City of Downey 2005).
The City is generally bounded by the Rio Hondo River channel to the west, Telegraph Road to the north,
the San Gabriel River channel to the east, and Gardendale Street and Foster Road to the south. Most
of the City was developed during the housing boom in the 1950s and 1960s. The City is a fully developed
community with older buildings and very few vacant properties. Since residential uses occupy more
than half of the City’s land area, Downey is known mainly as a bedroom community. However, the City
also provides a mix of other land uses such as open space, commercial, and manufacturing. Residential
uses are located throughout the City but predominantly located to the north, east, and west. Commercial
uses are scattered throughout the north, east, south, and west portions of the City, while manufacturing
uses are primarily concentrated in the southeastern portion of the City.
The City and the project site are within the South Coast Air Basin which has experienced poor air quality
over the years due to climate and weather conditions and decades of growth (i.e., urban development
and increased vehicle use). Air quality in the Basin is monitored by the South Coast Air Quality
Management District.
The City is situated on a broad alluvial valley largely built up by sedimentation from runoff out of the
San Gabriel Mountains, including from the nearby Rio Hondo River just south east of the site. The City
is fully urbanized, and does not support native plants or animals although some animals may travel
along the Rio Hondo River channel just southeast of the project site, especially at night. The area only
has wildlife that is very tolerant of human activity such as small to medium -sized mammals, reptiles,
and song birds.
The project area is urbanized and has a low risk from wildfires although smaller localized urban fires
may still occur. The surrounding area does contain some commercial and industrial uses which result
in some risks from hazardous materials, transportation accidents, etc. Noise levels in the City are
generally moderate depending on distance from nearby freeways and rail lines.
Public services and utilities in the City are provided by a number of agencies, mainly the City and County
(e.g., police, fire, wastewater treatment, flood control), as well as some private companies (water, solid
waste collection).
2.10 – Project Description
The Foster Bridge and Bluff Community Project in the City of Downey proposes 33 multi -family
townhouses on 1.29 acres at the northwest corner of Foster Bridge Boulevard and Suva Street. South
Bluff Road also runs along the southeast point of the property forming a five -legged intersection. The
proposed gated townhouse development is adjacent to the Rio Hond o River and Trail (across South
Exhibit E (Attachment C)
2 – Project Description
8 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Bluff Road) to the south. The project site slopes gently down to the east with elevations ranging from
140 feet above mean sea level (amsl) along the western boundary down to 133 feet amsl along the
eastern boundary. At present 83% of the site is covered by impervious surfaces. Land use
approvals/entitlements for the project include:
• Vesting Tentative Tract Map 84168 to establish 33 condominium units and a Site Plan review to
consider the project's architecture and improvements ;
• General Plan Amendment from Low Density Residential (LDR, up to 8.9 units/acre) to Medium
Density Residential (MDR, up to 24 units/acre);
• Zone Change from R-1 6,000 to Multi-Family Residential Ownership Zone (R-3-0); and
• Density Bonus for three moderate income level units in addition to the 30 market rate units.
• Site Plan Review for review of the architecture, landscaping, and circulation of the site.
The density of the proposed project is 20.6 units per gross acre while the R-3-O zone allows up to
approximately 22 units/acre. According to the City Zoning Code, the R -3-O zone is intended to provide
“for the development of multiple -family ownership type housing in selected areas compatible with the
neighborhood environment. Such areas are envisioned as being located and designed to be
complementary to adjacent uses and providing sufficient opportunities for ownership in multiple -family
housing”. The layout of the project site is shown in Exhibit 6, Site Plan. It should be noted that 30 of the
proposed townhomes will be market rate units while 3 of the units will quali fy for the City’s density bonus
under its inclusionary zoning program for affordable housing.
Architecture
Construction of the proposed project includes the demolition of the existing onsite church and parking
lot. The proposed multi-family townhouse development includes five different unit designs. Plan 1 is a
1188 square foot (sq. ft.), 3-bedroom, 3-bathroom, tandem townhouse. Three of the new units will use
this plan type, all of which will be located in Building 4 of the proposed project. Plan 2 is a 1477 sq. ft.
3-bedroom, 3-bathroom tandem townhouse. Twelve of the proposed units will utilize this plan type, all
of which will be located in Buildings 1 and 2, facing Foster Bridge Boulevard and Suva Street
respectively. Two of those 12 units will utilize an alternate design (Plan 2alt) where the units do not
“interlock” with the neighboring Plan 4 townhouses. This is visualized in Exhibit 6, Site Plan. The other
10 units do, however, interlock with their surrounding units. All five of the units located in Building 3 in
the center of the development will utilize Plan 3 ; a 1600 sq. ft. 3-bedroom, 2.5-bathroom townhouse.
Plan 4 is a 1657 sq. ft. 3-bedroom, 3.5-bathroom townhouse. These 10 units feature an “interlock” layout
and will interlock with Plan 2 units in Buildings 1 and 2. Plan 5 is a 1792 sq. ft. 3 bedroom, 3.5 bathroom
townhouse. All three of the units utilizing this design will be located in Building 4 and will interlock with
Plan 1 units also a part of the structure. The layout and building locations of the project are shown in
Exhibit 6, Site Plan. The maximum building height for the proposed project is 36 feet, or 3 stories. The
height and appearance of design features of the proposed townhouses are shown in Exhibit 7, Building
Elevations.
Circulation and Parking
Vehicle access to the project will be provided via two gated entrances developed during project
construction. The gated entrance located at the northeastern corner of the project site off of Foster
Bridge Boulevard will be 26 f eet wide and is accessible by vehicles and pedestrians. The entrance
provides access to a roadway within the development that splits in and weaves throughout the project
site. The roadway will border the north side of Building 4 and will run along the western side of building
one, splitting again. One branch will narrow to 25 feet and run west, providing vehicle access to
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 9
City of Downey
Buildings 2 and 3. The original roadway meets the south gated entrance facing Suva Street. This gate
is only accessible to emergency vehicles and is typically closed. There will be 71 total parking spaces
provided (2.5 spaces/unit), 66 of those spaces are garage spaces, and the remaining 5 being guest
spaces. Vehicle access in and around the project site is shown in Exhibit 6, Site Plan.
Open Space and Landscaping
Total open space area within the project site will be 6,958 sq uare feet with 4,389 square feet of that will
consisting of private open spaces. These include uncovered patios and yards, covered front porches,
and uncovered and covered decks. The remaining 2,569 sq uare feet of open space will constitute
common space, which will be divided into two areas; Open Space A and B. Open Space A will be
located at the northwestern corner of the project site and will be 192 sq uare feet in size. Open Space B
will take up the central walkways intersecting Buildings 3 and 4 and will be 2,377 sq uare feet in size.
Approximately 7,772 square feet of the project site will be landscaped. Landscaping of the project area
will include trees, shrubbery, and groundcover. The open space layout is shown in Exhibit 8, Open
Space Plan. The proposed landscaping and layout is shown in Exhibit 9, Landscape Plan.
Walls and Fences
Walls and fencing in and around the project would consist of two types, as well as pilasters connecting
the structures.
• Along the eastern perimeter of the project site, a six-foot tall block wall as measured from the
highest adjacent grade. Block walls will also feature adjacent to both gated entrances to the
development at the planned south and the northeastern gated vehicle entrances. The gated
entrance located at the northeastern corner of the project site off of Foster Bridge Boulevard is
a community gate accessible by vehicle s and pedestrians. The gate located at the south of the
proposed project off of Suva Street is only accessible to emergency vehicles and is typically
closed. Both gates will be connected to the block walls by pilasters.
• Four-foot. tall stucco block walls are included for private patios. These walls are featured at all
private patios at Buildings 1, 2, 4, and one additional private patio at the easternmost unit of
Building 3.
The project will also include a three-foot high community entry sign monument with night lights and
medium sized boulders will feature at the southern corner of the proposed project, at the intersection of
Bluff Road, Foster Bridge Boulevard, and Suva Street.
The location of the various walls and fencing are shown on Exhibit 10, Wall and Fence Plan.
Utilities
Water and sewer services are provided by the City of Downey. Electrical services would be provided
by Southern California Edison. All utility connections will be located underground.
Grading and Construction
Project construction will involve site preparation, grading, building construction, paving, and
architectural coating construction activities. Project construction is assumed to begin in early -2024 and
last approximately 12 months. Construction will first involve demolition of the existing onsite church and
parking lot. Development will then involve grading, building construction, paving, and application of
architectural coatings. Table 2.10-1 (Project Construction Activities) shows the length of time to
complete the various phases of construction along with a list of typical equipment to be used during
each phase. The project engineer and the grading plan indicate earthwork on the site will be generally
Exhibit E (Attachment C)
2 – Project Description
10 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
balanced with little onsite cut and fill anticipated. The grading plan indicates there will be 7,000 cubic
yards (cy) of over-excavation due to the presence of unconsolidated fill. Other earthwork will involve
2,500 cy of cut/fill and approximately 4,500 cy will need to be imported after removal and compaction
of the unconsolidated fill materials.
Table 2.10-1
Project Construction Activities
Construction Phase Duration
(Days)(A) Typical Equipment Used(B)
Demolition 20 Dozer, Tractor/Loader/Backhoe,
Concrete/Industrial Saw
Site Preparation 2 Grader, Dozer, Tractor/Loader/Backhoe
Grading 4 Grader, Dozer, Backhoe
Building Construction 200 Crane, Forklift, Backhoe, Generator, Welder
Paving 10 Paver, Roller, Paving Equipment
Architectural Coating 10 Air Compressor
Source: MIG 2023a
(A) Days refers to total active workdays in the construction phase, not calendar days.
(B) The typical equipment list does not reflect all equipment that would be used during the construction phase.
Not all equipment would operate eight hours per day each workday.
2.11 – Required Approvals
The City of Downey is the only land use authority for this project requiring the following approvals:
• Vesting Tentative Tract Map 84168
• General Plan Amendment
• Zone Change
• Density Bonus
• Site Plan Review
• Mitigated Negative Declaration
2.12 – Other Public Agencies Whose Approval is Required
None.
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 11
City of Downey
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project (17005) 12
City of Downey
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 13
City of Downey
Exhibit 1
Project Area Map
Exhibit E (Attachment C)
2 – Project Description
14 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 15
City of Downey
Exhibit 2
Site Photographs
Exhibit E (Attachment C)
2 – Project Description
16 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 17
City of Downey
Exhibit E (Attachment C)
2 – Project Description
18 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 19
City of Downey
Exhibit 3
General Plan Designations
Exhibit E (Attachment C)
2 – Project Description
20 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 21
City of Downey
Exhibit 4
Zoning Designations
Exhibit E (Attachment C)
2 – Project Description
22 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 23
City of Downey
Exhibit 5
Conceptual Site Plan
Exhibit E (Attachment C)
2 – Project Description
24 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 25
City of Downey
Exhibit 6
Project Elevations
Exhibit E (Attachment C)
2 – Project Description
26 Initial Study and Mitigated Negative Declaration
Public Review Draft November
2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
2 – Project Description
Foster Bridge and Bluff Residential Project 27
City of Downey
Exhibit 7
Project Elevations
Exhibit E (Attachment C)
2 – Project Description
28 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 29
City of Downey
Exhibit 8
Project Elevations
Exhibit E (Attachment C)
2 – Project Description
30 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project 31
City of Downey
Exhibit 9
Project Elevations
Exhibit E (Attachment C)
2 – Project Description
32 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project (17005) 33
City of Downey
3 Environmental Determination
3.1 – Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one
impact that is a ‘Potentially Significant Impact’ or ‘Less than Significant with Mitigation Incorporated’ as indicated
by the checklist analysis on the following pages.
Aesthetics □ Agriculture / Forest
Resources □ Air Quality / Energy
Biological Resources Cultural/Tribal Resources Geology / Soils/ Paleo
□ Greenhouse Gas
Emissions Hazards / Hazardous
Materials □ Hydrology / Water
Quality
□ Land Use / Planning □ Mineral Resources Noise
□ Population / Housing □ Public Services / Recreation □ Wildfire
□ Transportation/Traffic □ Utilities / Service Systems Mandatory Findings of
Significance
3.2 – Determination
□
I find that the proposed project COULD NOT have a significant effect on the environment, and a
NEGATIVE DECLARATION would be prepared.
I find that although the proposed project could have a significant effect on the environment, there
would not be a significant effect in this case because revisions in the project have been made by or
agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION would be prepared.
□
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
□
I find that the proposed project MAY have a ‘potentially significant impact’ or ‘potentially significant
unless mitigated’ impact on the environment, but at least one effect 1) has been adequately analyzed
in an earlier document pursuant to applicable legal standards, and 2) has been addressed by
mitigation measures based on the earlier analysis as described on attached sheets. An
ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain
to be addressed.
□
I find that although the proposed project could have a significant effect on the environment, because
all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE
DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant
to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are
imposed upon the proposed project, nothing further is required.
Exhibit E (Attachment C)
3 – Determination
34 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
This Page is Intentionally Left Blank.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project (17005) 35
City of Downey
4 Evaluation of Environmental Impacts
4.1 – Aesthetics
Except as provided in Public Resources Code Section 21099, would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect
on a scenic vista? □ □ □
b) Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within view from a state
scenic highway?
□ □ □
c) In non-urbanized areas,
substantially degrade the existing
visual character or quality of
public views of the site and its
surroundings? (Public views are
those that are experienced from a
publicly accessible vantage point).
If the project is in an urbanized
area, would the project conflict
with applicable zoning and other
regulations governing scenic
quality?
□ □ □
d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
□ □ □
a) No Impact. Scenic vistas can be impacted by development in two ways. First, a structure may be
constructed that blocks the view of a vista. Second, the vista itself may be altered (i.e., development on
a scenic hillside). There are no scenic vistas identified in the City of Downey General Plan (Downey
Vision 2025).1 The proposed project is located on a developed site within a fully developed area visually
dominated by residential land uses and surface streets. Th e project site is not considered to be within
or to comprise a portion of a scenic vista.
The project site is comprised of one parcel that is developed with a church and parking lot that will be
demolished as part of project construction with 33 townhouse units organized in four buildings with a
maximum height of 36 feet (3 stories). See Exhibit 3, Site Photographs, Exhibit 6, Site Plan, and Exhibit
7, Building Elevations.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
36 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
The project will be a gated community with an automated gated entry at the northeast corner of the site
off of Foster Bridge Boulevard. The site is bounded by single family residential uses adjacent to the
north and across Foster Bridge Boulevard to the east. There is also an apartment complex southwest
of the site across Suva Street. The general area has views of the San Gabriel Mountains approximately
15 miles to the north when the air is clear. The Rio Hondo Channel is southeast of the site across Bluff
Road but is a concrete channel at this location so it provides limited views. However, there is a multi -
use trail along the west side of the channel for bicyclists and pedestrians. The site currently contains a
one-story church building and surface parking lot so the new project townhouse buildings will
incrementally reduce public views to the north from Suva Street and private views from the apartment
complex southwest of the project site. However, the evaluation of impacts to scenic vistas under CEQA
only addresses views from public locations such as roads, sidewalks, and public facilities such as parks.
Due to the lack of scenic public views and vistas in the surrounding area, the proposed project would
result in no significant impacts with respect to views of a scenic vista.
b) No Impact. The Project is not adjacent to a designated state scenic highway or eligible state scenic
highway as identified on the California Scenic Highway Mapping System 2. The streets in the project
vicinity are not listed in the City of Downey General Plan for consideration as scenic highways. The
closest State scenic highway is the Angeles Crest Highway (State Route 2), located approximately 20
miles north of the project site.2 The project site is located in a fully developed, urbanized area, and
contains no scenic resources. Therefore, no impact to scenic resources visible from a state scenic
highway would occur.
c) Less than Significant with Mitigation Incorporated. The project site is in an urban area. The
Land Use Element of the City’s General Plan indicates the project site currently has a General Plan
land use designation of Low Density Residential (LDR) which allows up to 8.9 units/acre. Under this
designation, up to 11 units could currently be built on the project site. The project is requesting a General
Plan Amendment to change the site’s land use designation to Medium Density Residential (MDR) which
allows up to 24 units/acre while the density of the proposed project is 20.6 units/acre.
The zoning designation of the site is R-1 6,000 which is a single-family detached residential designation.
The project proposes to change the site’s zoning designation to Multi -Family Residential Ownership
Zone (R-3-0). According to the City Zoning Code, the R-3-O zone is intended to provide “for the
development of multiple -family ownership type housing in selected areas compatible with the
neighborhood environment. Such areas are envisioned as being located and designed to be
complementary to adjacent uses and provid ing sufficient opportunities for ownership in multiple -family
housing”. This owner-occupied townhouse project is also proposed as a buffer between the owner-
occupied single family uses to the north and east to the rental apartments to the southwest and the non-
residential light industrial uses to the west.
The site is bounded by low density single family residential uses adjacent to the north and across Foster
Bridge Boulevard to the east. There is also an apartment complex southwest of the site across Suva
Street. The single-family homes are mainly one-story structures while the apartment buildings are two-
story structures. The project would be consistent with local General Plan and zoning designations with
approval of the General Plan Amendment and Zone Change.
The only potential area of visual conflict would be with the single -family residence to the north due to
its close proximity to the project site (45 feet from the residence to the northern -most building). The
Project Landscape Plan (Exhibit 9) shows shrubs to be planted along the northern perimeter wall,
however, these may not be tall enough to block views of the new 3 -story buildings from the adjacent
residence. Therefore, Mitigation Measure AES -1 is recommended to help minimize any visual impacts
from the project on the adjacent residence s.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 37
City of Downey
With the proposed entitlements, the proposed project would not conflict with the applicable General
Plan or zoning requirements regulating the height, setbacks, open space, and other aesthetic
aspects of development. The proposed project site is located in an urbanized area and there are
no regulations governing scenic quality in the City of Downey. With implementation of Mitigation
Measure AES-1, visual impacts of the project would be reduced to less than significant levels.
d) Less Than Significant Impact. Excessive or inappropriately directed lighting can adversely impact
night-time views by reducing the ability to see the night sky and stars. Glare can be caused by
unshielded or misdirected lighting sources. Reflective surfaces (e.g., polished metal) can also cause
glare. Impacts associated with glare range from simple nuisance to potentially dangerous situations
(e.g., if glare is directed into the eyes of motorist s). There are lighting sources adjacent to the project
site, including free-standing streetlights, light fixtures on buildings, and pole -mounted lights. The
proposed project includes exterior security lighting and interior building lighting throughout the site. The
following City of Downey Municipal Code (CDMC) sections deal with various forms of lighting: Section
9520, Outdoor Lighting; Section 9933.5, Street Lighting; and Section 9624, Lighting and Design
Standards.
These CDMC sections require outdoor lighting to be arranged so as to reflect light away from any other
property. The proposed project would be required to comply with these requirements. Complying with
these regulations would make the project’s lighting impacts less than significant. In addition,
implementation of Mitigation Measure AES-1 will further reduce potential lighting conflicts due to the
proximity of the northern -most building of the Project to the existing residence just north of the project
site.
Sources of daytime glare are typically concentrated in commercial areas and are often associated with
retail uses with extensive glass surfaces. Glare results from development that contain s reflective
materials such as hi-efficiency window glass, highly polished surfaces, and expanses of pavement. The
proposed project site is located in an area that developed mainly with residential uses. The proposed
townhomes include design features that would result in minimal use of glare -inducing materials. With
regulatory compliance (i.e., CDMC), potential reflective glare impacts of the project would be less than
significant and no mitigation is required.
Mitigation Measures
AES-1 Enhanced Landscaping. Prior to issuance of the first occupancy permit, the developer shall
install enhanced landscaping along the northern boundary of the site . Its purpose is to
substantially block views and lighting from the project site onto the residence at 7336 Foster
Bridge Boulevard just north of the site. Th e design and location of this enhanced
landscaping, primarily trees, shall be the responsibility of the City Planning Department.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
38 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.2 – Agriculture and Forest Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead
agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model
(1997) prepared by the California Department of Conservation as an optional model to use in
assessing impacts on agriculture and farmland. In determining whether impacts to forest resources,
including timberland, are significant environmental effects, lead agencies may refer to information
compiled by the California Department of Forestry and Fire Protection regarding the state’s
inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy
Assessment project; and forest carbon measurement methodology provided in F orest Protocols
adopted by the California Air Resources Board. Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on
the maps prepared pursuant to the
Farmland Mapping and Monitoring
Program of the California Resources
Agency, to non-agricultural use?
□ □ □
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract? □ □ □
c) Conflict with existing zoning for, or
cause rezoning of, forest land (as
defined in Public Resources Code
section 12220(g)), timberland (as
defined by Public Resources Code
section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104 (g))?
□ □ □
d) Result in loss of forest land or
conversion of forest land to non -forest
use? □ □ □
e) Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non -forest
use?
□ □ □
a) No Impact. The proposed project is located in a fully developed, largely residential, suburbanized area
that does not contain any agricultural or forest uses. The map of Important Farmland in California (2023)
prepared by the Department of Conservation does not identify the project site as containing Prime
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 39
City of Downey
Farmland, Unique Farmland, or Farmland of Statewide Importance.3 The City of Downey is located in
an area that is mapped as “Urban and Built-Up Land” with no land considered as Prime Farmland,
Unique Farmland, or Farmland of Statewide Importance within the City. In addition, the General Plan
does not identify any areas for agriculture use within the City. Therefore, there would be no conversion
of Prime Farmland, Unique Farmland, and Farmland of Statewide Importance to a non -agricultural use
as a result of this project. No impact would occur.
b) No Impact. No Williamson Act (agricultural preserve) contracts through Los Angeles County are
active for the project site.4 In addition, the project site is zoned for residential uses which does not permit
agricultural uses. Therefore, there would be no conflict with existing zoning for agricultural use or a
Williamson Act contract. No impact would occur.
c) No Impact. CEQA Section 12220(g) identifies forest land as land that can support 10-percent native
tree cover of any species, including hardwoods, under natural conditions, and that allows for
management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity,
water quality, recreation, and other public benefits. The project site and surrounding properties are not
currently being managed or used for forest land as identified in CEQA Section 12220(g). The project
site has already been graded and developed with a church and parking lot with no substantial native
vegetation onsite. Therefore, developing this project would have no impact on any timberland zoning.
d) No Impact. The project site is land that has been previously developed with a church with limited
ornamental landscaping; thus, there would be no loss of forest land or conversion of forest land to non -
forest use as a result of this project. No impact would occur.
e) No Impact. The site has been previously developed for a church within an urban/suburban
environment. The project site is surrounded by residential uses and a self-storage facility. None of the
surrounding uses contain existing forest resources. Therefore, development of this project would not
change the existing environment in a manner that would result in the conversion of forest land to a non-
forest use. No impact would occur.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
40 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.3 – Air Quality
Where available, the significance criteria established by the applicable air quality management or
air pollution control district may be relied upon to make the following determinations. Would the
Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct
implementation of the applicable air
quality plan? □ □ □
b) Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
Project region is non-attainment
under an applicable federal or state
ambient air quality standard?
□ □ □
c) Expose sensitive receptors to
substantial pollutant
concentrations? □ □ □
d) Result in other emissions (such as
those leading to odors) adversely
affecting a substantial number of
people?
□ □ □
An Air Quality Impact Report5 was prepared for the proposed project by MIG, dated September 20,
2023 (Appendix A). The report estimates the potential air quality emissions for the proposed project and
evaluates project emissions against applicable South Coast Air Quality Management District
(SCAQMD)-recommended California Environmental Quality Act (CEQA) significa nce thresholds for
construction and operation. A Vehicle Miles Traveled Screening Assessment6 was prepared for the
proposed project by Ganddini Group, dated November 15, 2023 (Appendix H) that provided trip
generation data for the Air Quality Study.
a) Less than Significant Impact. The proposed project is located within the South Coast Air Basin
(Basin), where efforts to attain state and federal air quality standards are governed by the South Coast
Air Quality Management District (SCAQMD). Both the State of California and the federal government
have established health-based ambient air quality standards (AAQS) for seven air pollutants (known as
criteria pollutants). These pollutants include ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2),
sulfur dioxide (SO2), inhalable particulate matter with a diameter of 10 microns or less (PM10), fine
particulate matter with a diameter of 2.5 microns or less (PM 2.5), and lead (Pb). The state has also
established AAQS for additional pollutants. The AAQS are designed to protect the health and welfare
of the populace within a reasonable margin of safety. Where the state and federal standards differ,
California AAQS (CAAQS) are more stringent than the national AAQS (NAAQS).
The U.S. Environmental Protection Agency (U.S. EPA), California Air Resources Board (CARB), and
the SCAQMD assess the air quality of an area by measuring and monitoring the amount of pollutants
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 41
City of Downey
in the ambient air and comparing pollutant levels against NAAQS and CAAQS. Based on these
comparisons, regions are classified into one of the following categories:
• Attainment. A region is “in attainment” if monitoring shows ambient concentrations of a specific
pollutant are less than or equal to NAAQS or CAAQS. In addition, an area that has been re -
designated from nonattainment to attainment is classified as a “maintenance area” for 10 years
to ensure that the air quality improvements are sustained.
• Nonattainment. If the NAAQS or CAAQS are exceeded for a pollutant, the region is designated
as nonattainment for that pollutant. It is important to note that some NAAQS and CAAQS require
multiple exceedances of the standard in order for a region to be classified as nona ttainment.
Federal and state laws require nonattainment areas to develop strategies, plans, and control
measures to reduce pollutant concentrations to levels that meet, or attain, standards.
• Unclassified. An area is unclassified if the ambient air monitoring data is incomplete and does
not support a designation of attainment or nonattainment.
Table 4.3-1 (South Coast Air Basin - Non-Desert - Attainment Status), summarizes the Basin’s
attainment status for criteria air pollutants. The Basin is currently in nonattainment for state and federal
ozone, state PM10, and state and federal PM2.5 standards.
Table 4.3-1
South Coast Air Basin (Non-Desert) Attainment Status
Pollutant State Designation Federal Designation
O3 (1-hr) Nonattainment Nonattainment
O3 (8-hr) Nonattainment Nonattainment
PM10 Nonattainment Attainment (Maintenance)
PM2.5 Nonattainment Nonattainment
CO Attainment Attainment (Maintenance)
NO2 Attainment Attainment
SO2 Attainment Attainment
Pb -- Nonattainment (Partial)
Hydrogen Sulfide Attainment --
Sulfates Attainment --
Vinyl Chloride Attainment --
Sources: Table 2, MIG 2023a, SCAQMD, 2018
A project that conflicts with or obstructs the implementation of the SCAQMD South Coast Air Basin
2022 Air Quality Management Plan (AQMP) could hinder implementation of the AQMP, delay efforts to
meet attainment deadlines, and/or interfere with SCAQMD efforts to maintain compliance with, and
attainment of, applicable air quality standards. Pursuant to the methodology provided in Chapter 12 o f
the SCAQMD CEQA Air Quality Handbook7, consistency with the AQMP is affirmed if the project:
1) Is consistent with the growth assumptions in the AQMP; and
2) Does not increase the frequency or severity of an air quality standard, violation, or cause a
new one.
Consistency Criterion 1 refers to the growth forecasts and associated assumptions included in the 2022
AQMP. The 2022 AQMP was designed to achieve attainment for all criteria air pollutants within the
Basin while still accommodating growth in the region. P rojects that are consistent with the AQMP growth
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
42 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
assumptions would not interfere with attainment of air quality standards, because this growth is included
in the projections used to formulate the AQMP. The proposed project would generate approximately 33
new residential units. The existing General Plan would allow 12 units on the 1.29 -acre site (8.9
units/acre max.). The project proposes 33 units which is 22 more units than would be allowed under the
existing General Plan and zoning. The SCAG 2020 RTP/SCS growth projections for the City of Downey
are +1,500 new households and +5,900 residents between 2016 and 2045 (SCAG, 2020). The
incremental growth that would result from the project represents 1.5% of City growth anticipated by
SCAG over the next 20 years. Therefore, the growth represented by he proposed project would not
exceed the growth assumptions contained in the AQMP.
Consistency Criterion 2 refers to the CAAQS. In developing its CEQA significance thresholds, the
SCAQMD considered the emission levels at which a project’s individual emissions would be
cumulatively considerable (SCAQMD, 2003; page D-3). As shown in Table 4.3-2 (Regional Construction
Emissions), in Section 4.3(b) below, the proposed project would not generate construction or
operational emissions in excess of SCAQMD criteria air pollutant thresholds. For the reasons described
above, the proposed project would not conflict with the SCAQMD 2022 AQMP.
b) Less than Significant Impact. A project may have a significant impact if project -related emissions
exceed federal, state, or regional standards or thresholds, or if project -related emissions would
substantially contribute to existing or projected air quality violations. The proposed project would
generate both short-term construction emissions and long -term operational emissions. As described in
more detail below, the proposed project would not generate emissions levels that exceed SCAQMD -
recommended pollutant thresholds.
Construction Emissions
Construction of the proposed project would generate equipment exhaust and dust emissions from
demolition activities, ground disturbing activities such as site preparation and grading, and the use of
gasoline- and diesel-fuel combustion in on- and off-site heavy duty construction equipment, worker
vehicle trips, vendor vehicle trips, and haul truck trips, ground disturbing activities. The proposed
project’s potential construction emissions were modeled using CalEEMod, Version 2022.1.1. The
project grading plan indicates there will be 7,000 cubic yards (cy) of over -excavation due to the presence
of unconsolidated fill on the site. Other earthwork will involve 2,500 cy of cut/fill and approximately 4,500
cy will need to be imported after removal and compaction of the unconsolidated fill materials. The
construction phases, duration, and the type and amount of equipment used during construction was
generated using CalEEMod default assumptions, and modified to reflect the following project-specific
characteristics:
• The demolition of approximately 8,480 square -foot of existing building square footage (i.e.,
existing onsite church) was added to the model run;
• Fugitive dust control measures were incorporated into the model consistent with requirements
contained in SCAQMD Rule 403, Fugitive Dust.
The proposed project’s maximum daily unmitigated construction emissions are shown in Table 4.3-2,
Regional Construction Emissions. As shown in Table 4.3-2, the proposed project’s maximum daily
unmitigated construction emissions would be well below the SCAQMD’s regional pollutant thresholds
for all pollutants. Therefore, the construction of the proposed project would not generate construction -
related emissions that exceed SCAQMD CEQA thresholds. Construction impacts would be less than
significant and no mitigation is required. However, it should be noted the project is still required to
comply with a variety of SCAQMD rules and regulations on construction emissions (e.g., Rule 403
regarding fugitive dust).
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 43
City of Downey
Table 4.3-2
Regional Construction Emissions
Season and Year Maximum Daily Emissions (lbs./day)
ROG NOX CO SO2 PM10 PM2.5
Summer 2024 1.2 9.7 12.0 <0.1 0.7 0.4
Winter 2024 33.0 16.1 17.0 <0.1 3.6 2.1
SCAQMD CEQA Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Source: MIG, 2023 (see Appendix A) and SCAQMD 2020.
Operational Emissions
Once operational, the proposed project would generate emissions from the following sources:
• “Area” Sources. The proposed project would generate emissions from small area sources,
including landscaping equipment, the use of consumer products (e.g., paints, cleaners, and
fertilizers) that result in the evaporation of chemicals into the atmosphere during product us e.
• Mobile Sources. The proposed project would generate emissions from vehicles traveling to and
from the project site.
The proposed project’s operational emissions were also estimated using CalEEMod, V. 2022.1.1. The
modeling is based on the project’s first full year of operations (assumed to be 2025), using default data
assumptions generated by CalEEMod, modified as neces sary to reflect the following project-specific
context, information, and details:
• Project-specific land use information (i.e., lot acreage, building square footage, etc.) was applied
to the model;
• Project-specific weekday trip generation rates were applied to the model (Ganddini Group,
2023).
• Area Sources: Hearths were updated to be electric to reflect the project’s all electric building
design.
• Energy Use and Consumption: Natural gas consumption was removed and electricity annual
consumption was increased using the U.S. Energy Information Administration (US EIA) energy
conversion calculator to reflect the project’s all electric building design. N atural gas water and
space heating sources were removed since the project would be all -electric (US EIA 2023).
The proposed project’s maximum daily unmitigated operational emissions are shown in Table 4.3-3
(Regional Operational Emissions). As shown in Table 4.3-3, the proposed project’s maximum daily,
unmitigated operational criteria air pollutant emissions would be well below the SCAQMD’s -
recommended regional criteria air pollutant thresholds. Therefore, project operation would not generate
criteria air pollutant emissions levels that exceed SCAQMD regional CEQA thresholds. This impact
would be less than significant and no mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
44 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Table 4.3-3
Regional Operational Emissions
Emission Source
Maximum Daily Pollutant Emissions (Pounds Per Day)(A)
ROG NOx CO SO2 PM10 PM2.5
Area Sources 1.4 <0.1 1.9 <0.1 <0.1 <0.1
Energy Demand(B) 0 0 0 0 0 0
Mobile Sources 0.8 0.6 6.2 <0.1 1.3 0.3
Total Daily Emissions(C) 2.1 0.6 8.0 <0.1 1.3 0.3
SCAQMD CEQA Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Source: Table 4, MIG, 2023a (see Appendix A)
(A) Emissions presented are worst-case emissions and may reflect summer or winter emissions levels. Maximum daily
ROG, CO, SOX emissions occur during the summer. Maximum daily NOX emissions occur during the winter. In
general, due to rounding, there is no difference between summer and winter PM10 and PM2.5 emissions levels for
the purposes of this table
(B) Energy demand related air quality emissions estimated to be 0 due to the project being all-electric.
(C) Totals may not equal due to rounding.
Cumulative Impacts
The Basin is currently designated non -attainment for State and/or federal standards for ozone, PM10,
and PM2.5. As discussed in the preceding subsections, the proposed project 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. 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 project would
not individually exceed any SCAQMD CEQA significance thresholds, it would also not result in a
cumulatively considerable increase in regulated, nonattainment pollutants.
c) Less than Significant Impact. The proposed project would generate both short -term construction
emissions and long-term operational emissions that could impact sensitive residential receptors
located near the project; however, as described in more detail below, the proposed project would not
generate short-term or long-term emissions that exceed SCAQMD-recommended localized
significance thresholds or result in other substantial pollutant concentrations.
In addition to regional CEQA thresholds, the SCAQMD has also developed Local Significance
Thresholds (LSTs) that represent the maximum emissions from a project that are expected to cause
or contribute to an exceedance of the most stringent applicable feder al or state ambient air quality
standards, which would result in significant adverse localized air quality impacts.
Construction Emissions
The project’s maximum daily construction emissions are compared against the SCAQMD’s -
recommended LSTs thresholds in Table 4.3-4 (LST Construction Emissions). Consistent with the
SCAQMD’s LST methodology, the emissions included in the construction LST analysis are on -site
emissions only. The LST thresholds are for source receptor area (SRA) 5, the SRA in which the
proposed project is located, and are conservat ively based on a receptor distance of 25 meters (82
feet), the closest LST receptor distance thresholds recommended for use by the SCAQMD, and a
project size of 1.0 acre. These thresholds are considered conservative because the proposed project
size is approximately 1.3 acres.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 45
City of Downey
As shown in Table 4.3-4 (LST Construction Emissions), the proposed project’s construction emissions
would not exceed the SCAQMD’s recommended construction LSTs. Project construction, therefore,
would not generate criteria air pollutant emissions levels that exceed SCAQMD local CEQA
thresholds. Impacts would be less than significant and no mitigation is required. However, it should
be noted the project is still required to comply with a variety of SCAQMD rules and regulations on
construction emissions (e.g., Rule 403 regarding fugitive dust).
Table 4.3-4
LST Construction Emissions
Construction Phase(A)
Maximum Daily Emissions (Pounds per Day)
NOX CO PM10 PM2.5
Demolition 16.1 17.0 1.2 0.7
Site Preparation 13.7 13.4 3.2 1.8
Grading 15.9 16.1 3.6 2.0
Building Construction 9.7 12.0 0.7 0.4
Paving 5.0 7.3 0.4 0.3
Architectural Coating 0.9 1.5 0.1 <0.1
SCAQMD LST Threshold(B) 83 673 5 4
Threshold Exceeded? No No No No
Source: Table 5, MIG 2023a (see Appendix A) and SCAQMD 2009
(A) Emissions presented are worst-case emissions and may reflect summer or winter emission levels. In general, due
to rounding, there is no difference between summer and winter emission levels for the purposes of this table.
(B) The LST thresholds are conservatively based on 1.0-acre project size and 25-meter receptor distance for SRA 5.
Operational Emissions
Typically, operations related to LSTs become a concern when there are substantial on -site stationary
or on-site mobile sources (e.g., heavy duty or idling trucks) that could impact surrounding receptors,
which is not the case for the proposed project. Nonetheless, the proposed project’s maximum daily
operational emissions are compared against the SCAQMD’s -recommended LSTs in Table 4.3-4 and
4.3-5.
The project’s maximum daily operational emissions are compared against the SCAQMD’s -
recommended LSTs in Table 4.3-5 (LST Operational Emissions). Consistent with the SCAQMD’s LST
methodology, the emissions included in the operational LST analysis are onsite emissions only, and
the LST thresholds against which these onsite emissions are compared are based on the project size,
in acres. The LST thresholds are for SRA 11 (South San Gabriel Valley), the SRA in which the project
is located and are based on a receptor distance of 82 feet (approximately 25 meters), the closest LST
receptor distance threshold recommended for use by the SCAQMD. As shown in Table 4.3-5, proposed
project’s on-site operational emissions would not exceed the SCAQMD’s recommended operational
LSTs. Project operation, therefore, would not generate criteria air pollutant emissions levels that exceed
SCAQMD local CEQA thresholds. Impacts will be less than significant and no mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
46 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Table 4.3-5
LST Operational Emissions
Emissions
Maximum Daily Emissions (Pounds per Day)(A)
NOX CO PM10(B) PM2.5(B)
Area Sources 1.0 6.1 0.1 0.1
Energy Sources 0.0 0.0 0.0 0.0
Mobile Sources(A) 2.3 24.7 <0.1 <0.1
Total Emissions(B) 3.3 30.8 0.1 0.1
SCAQMD LST Threshold(C) 121 1,031 2 2
Threshold Exceeded? No No No No
Source: MIG 2023 (see Appendix A).
(A) Mobile source emissions estimates reflect potential onsite vehicle emissions only and were derived by
assuming 2% of operational mobile source emissions in Table 4 will occur onsite.
(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) LST threshold is based on a 2.0-acre project size and 25-meter (82-foot) receptor distance.
Sensitive Air Quality Receptors/Health Risks
The SCAQMD identifies sensitive receptors as populations more susceptible to the effects of air
pollution than the general population. Some people are more affected by air pollution than others.
Sensitive air quality receptors include specific subsets of t he general population that are susceptible to
poor air quality and the potential adverse health effects associated with poor air quality. Both CARB
and the SCAQMD consider residences, schools, parks and playgrounds, childcare centers, athletic
facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement
homes to be sensitive air quality land uses and receptors (SCAQMD 2017a; CARB 2005). The potential
sensitive air quality receptors adjacent or in close proximity to the perimeter of the project area (i.e.,
within 1,250 feet) include:
• The single-family residential land uses on Foster Bridge Boulevard that border or are in close
proximity to the project site (the closest of which is adjacent to the northern property line);
• Other single-family residences southeast of the project along Guatemala Avenue;
• The Rio Hondo Bike Path, which is approximately 120 feet south of the project site, that runs
adjacent to Bluff Road;
• Suva Elementary School, approximately 1,250 feet northwest of the project site.
In addition to criteria air pollutants, the U.S. EPA and CARB have classified certain pollutants as
Hazardous Air Pollutants (HAPs) (by U.S. EPA) or Toxic Air Contaminants (TACs) (by CARB),
respectively. These pollutants can cause severe health effects at very low concentrations (non-cancer
effects), and many are suspected or confirmed carcinogens (i.e., can cause cancer). People exposed
to HAPs/TACs at sufficient concentrations and durations may have an increased chance of getting
cancer or experiencing other serious health effects. These health effects can include damage to the
immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental,
respiratory, and/or other health problems.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 47
City of Downey
A portion of the PM10 and PM2.5 emissions generated during construction of the project would be diesel
particulate matter, or DPM, a known TAC. The proposed project’s construction activities would not
expose adjacent residential receptors to substantial levels of DPM that would pose a substantial
adverse health risk for several reasons. First, the proposed project does not involve substantial
earthmoving or grading activities that would require large amounts of heavy-duty equipment associated
with the highest DPM emissions. This is because the proposed project site is already developed and
only approximately 1.3 acres in size. Second, potential long -term adverse health risks from DPM are
evaluated assuming a co nstant exposure to emissions over a 70 -year lifetime, 24 hours a day, seven
days a week, with increased risks generally associated with increased proximity to emissions sources.
Since construction activities would only generate DPM emissions on an intermit tent, short-term basis
(lasting approximately 12 months), DPM emissions from construction activities would be unlikely to
result in adverse health effects to existing sensitive receptors that exceed the SCAQMD’s significance
criteria. In 2019, the SCAQMD established the following thresholds of significance for projects that
generate TAC emissions: Maximum Incremental Cancer Risk ≥ 10 in 1 million; Cancer Burden > 0.5
excess cancer cases (in areas ≥ 1 in 1 million); Chronic & Acute Hazard Index ≥ 1.0 (projec t increment).
There is no current evidence to suggest the presence of asbestos -containing materials (ACMs) in the
existing church building. However, if ACMs were present, then demolition, removal, and transport of
building materials containing ACMs could result in airborne emissions of asbestos resulting in exposure
of workers or the environment to a hazardous material. In accordance with Section 112 of the Federal
Clean Air Act, the U.S. EPA establishes National Emission Standards for Hazardous Air Pollutants
(NESHAP). If necessary, the project would comply with SCAQMD Rule 1403, which is the enforcing
rule of the Asbestos NESHAP, and sets forth requirement s for asbestos surveying, notification, removal
procedures, and storage, disposal, and land filling requirements for asbestos containing waste
materials. Regulatory compliance with SCAQMD Rule 1403 would ensure the proposed project does
not expose sensitive receptors to asbestos containing material s. For additional information on ACMs
and other impacts related to hazardous materials, see Section 4.9, Hazards and Hazardous Materials.
CO Hotspot Analysis
A CO hotspot is an area of localized CO pollution that is caused by severe vehicle congestion on major
roadways, typically near high volume intersections. Several screening procedures have been developed
by air districts throughout the state to assess whether a project may result in a CO impact. For example,
the Bay Area Air Quality Management District (BAAQMD) developed a screening threshold in 2010
which states that any project involving an intersection experiencing 44,000 vehicles per hour would
require detailed analysis. Additionally, the SCAQMD’s 2003 AQMP and 1992 Federal Attainment Plan
for Carbon Monoxide demonstrated that CO levels were below the CAAQS at an intersection with a
daily traffic volume of up to approximately 100,000 vehicles per day. The proposed project would add
approximately 331 new vehicle trips to the roadway system per day (see Appendix G). The worst-case
hourly intersection volume in the project vicinity would be relatively unaffected by the project, which is
projected to add a total of 20 trips during the AM peak hour and 25 trips during the PM peak hour. This
is well below the BAAQMD screening threshold, and surrounding roadway segments would not have
traffic volumes exceeding 100,000 vehicles per day. The proposed project would not cause intersection
volumes to exceed any daily (100,000) or hourly (44,000) screening vehicle volumes maintained by the
SCAQMD and other regional air districts and, therefore, would not result in significant CO
concentrations. Impacts would be less than significant and mitigation is not required.
d) Less than Significant Impact. According to the SCAQMD CEQA Air Quality Handbook, land uses
associated with odor complaints include agricultural operations, wastewater treatment plants, landfills,
and certain industrial operations (such as manufacturing uses that produce chemicals, pape r, etc.). The
proposed project does not include such sources but would result in the construction of a new townhome
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
48 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
facility that could generate odors related to vehicle parking and refuse collection (e.g., oils, lubricants,
fuel vapors, short-term waste odors). These activities would not generate sustained odors that would
affect substantial numbers of people. Potential impact with respect to odors wou ld be less than
significant.
4.4 – Biological Resources
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect,
either directly or through habitat
modifications, on any species
identified as a candidate, sensitive,
or special status species in local or
regional plans, policies, or
regulations, or by the California
Department of Fish and Game or
U.S. Fish and Wildlife Service?
□ □ □
b) Have a substantial adverse effect
on any riparian habitat or other
sensitive natural community
identified in local or regional plans,
policies, regulations, or by the
California Department of Fish and
Game or US Fish and Wildlife
Service?
□ □ □
c) Have a substantial adverse effect
on federally protected wetlands as
defined by Section 404 of the
Clean Water Act (including, but not
limited to, marsh, vernal pool,
coastal, etc.) through direct
removal, filling, hydrological
interruption, or other means?
□ □ □
d) Interfere substantially with the
movement of any native resident or
migratory fish or wildlife species or
with established native resident or
migratory wildlife corridors, or
impede the use of native wildlife
nursery sites?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 49
City of Downey
e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
□ □ □
f) Conflict with the provisions of an
adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan?
□ □ □
a ) Less Than Significant Impact. The project site is a developed property occupied by a church
and parking lot in the far northwest corner of the City. The project site and surrounding area are fully
developed and not identified as critical habitat for any threatened or endangered species of plant or
animal. The California Natural Diversity Database (CNDDB)8 shows no record of any occurrence of
any sensitive plant, animal, terrestrial natural community, or aquatic community on the project site9
or in the immediate surrounding area, including the Rio Hondo Channel. The most current CNDDB
data for the Southgate USGS 7.5-minute quadrangle indicates there are four listed or otherwise
sensitive plant species present in the surrounding region, including several species typical of vernal
pool habitat. The CNDDB list also shows ten listed or protected animal species in the region,
including burrowing owl and several bird species found in riparian habitat (Appendix B). The site
contains no vegetation, habitat, or resources that would support any of these listed, sensitive, or
protected species of plants or animals. Landscaping currently exists onsite, including a number of
mature landscaped Ficus and palm trees. However, ornamental vegetation is not typically native
habitat for any species identified as a candidate, sensitive, or special status species.
The only plants onsite are landscaped or non-native weedy species. The site is completely covered
with man-made structures/surfaces and there are no drainage features, wetlands, or water features
present. The only wildlife on site would be those native species tolerant of regular human activity
including small mammals, reptiles, and songbirds.
Considering the highly developed nature of the project site and lack of native habitat, it is reasonable
to conclude the proposed project would not result in any significant impacts to sensitive species or
their habitats. The highly disturbed nature of the site and surrounding habitat would not provide
substantial habitat for any of the sensitive species known to occur within one mile of the project site.
Therefore, the proposed project would not have a substantial adverse effect on any species
identified as a candidate, sensitive, or special -status species in local or regional plans by the
California Department of Fish and Wildlife (CDFW) or U.S. Fish and Wildlife Service (USFWS).
Impacts would be less than significant and no mitigation is required.
b) No Impact. As outlined in Threshold 4.4.a above, no natural or man-made water features occur
within the project site and no riparian vegetation is present on or adjacent to the site, including the nearby
concrete-lined Rio Hondo Channel, that could provide habitat for wildlife.10 Therefore, the project would
not have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. No impact would
occur.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
50 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
c) No Impact. As outlined in Threshold 4.4.a above, no wetlands occur on the project site.11
Therefore, the project would not have a substantial adverse effect on federally protected wetlands
as defined by Section 404 of the Clean Water Act. No impact would occur.
d) Less than Significant with Mitigation Incorporated. According to the General Plan, the City
does not maintain any designated wildlife corridors and the project site is surrounded by developed
residential and industrial properties.
The Federal Migratory Bird Treaty Act (MBTA; 16 USC Sections 703–711) and California Fish and
Game Code (CFGC) Sections 3503, 3503.5, and 3513 extend protection to a number of avian
species that may occur on or in the vicinity of the project site. The project site contains a number of
landscaped trees (mainly Ficus and palms) that may possibly provide habitat for nesting birds. The
project plan calls for all trees and vegetation to be removed from the site. If the onsite vegetation
contained nests for avian species protected by these regulations, there is a potential for a significant
impact in this regard. Therefore, Mitigation Measure BIO-1 (nesting bird survey) has been
recommended to determine if any onsite vegetation contains nesting birds and if present, restricts
construction activities until young birds have fledged from the next. This measure will ensure impacts
to nesting/migratory birds are less than significant. With mitigation incorporated, impacts to wildlife
corridors or migrating animals would be less than significant.
e) Less than Significant Impact. The only biological resource on the site is the existing trees
and landscaping, and the City has no local regulation regarding removal of these materials.
Construction of the proposed project would result in the removal of non-native landscaping shrubs
and tree species from the site. Development of the proposed project will install new landscaping
and trees on the site. Therefore, the project will not conflict with any local regulations related to trees
or other biological resources. Impacts would be less than significant.
f) No Impact. No Habitat Conservation Plan, Natural Community Conservation Plan or other
biological plan are associated with the project site or the immediate surrounding urbanized area.12
Therefore, the project would not conflict with the provisions of an adopted Habitat Conservation
Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan. No impact would occur.
Mitigation Measures
BIO-1 Nesting Bird Survey. To the extent feasible, construction activities shall be scheduled to
avoid the nesting season. If construction activities are scheduled to take place during the
nesting season, all impacts to nesting birds protected under the MBTA and California Fish
and Game Code must be avoided. The nesting season for most birds in Los Angeles County
extends from February 1 through September 1.
If it is not possible to schedule construction activities between September 1 and January 31,
then a pre-construction survey for nesting birds will be conducted by a qualified biologist to
ensure that no nests would be disturbed during project implementation. Th is survey will be
conducted no more than 5 days prior to the initiation of any site disturbance activities and
equipment mobilization, including tree, shrub, or vegetation removal, fence installation,
grading, etc. If project activities are delayed by more than 5 days, an additional nesting bird
survey will be performed. During this survey, the biologist will inspect all trees and other
potential nesting habitats (e.g., trees and shrubs) in and immediately adjacent to the impact
area for nests. Active nesting is present if a bird is building a nest, sitting in a nest, a nest
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 51
City of Downey
has eggs or chicks in it, or adults are observed carrying food to the nest. The results of the
survey(s) will be documented.
If an active nest is found sufficiently close to work areas to be disturbed by these activities,
the qualified biologist will determine the extent of a construction -free buffer zone to be
established around the nest (typically up to 300 feet for raptors an d up to 100 feet for other
species), to ensure that no nests of species protected by the Migratory Bird Treaty Act
(MBTA) and California Fish and Game Code will be disturbed during project implementation.
Within the buffer zone, no site disturbance and mo bilization of heavy equipment, including
but not limited to equipment staging, fence installation, clearing, grubbing, vegetation
removal, demolition, and grading will be permitted until the chicks have fledged.
A qualified biologist is an individual who has a degree in biological sciences or related
resource management with a minimum of two seasonal years post -degree experience
conducting surveys for nesting birds. During or following academic training, the quali fied
biologist will have achieved a high level of professional experience and knowledge in
biological sciences and special-status species identification, ecology, and habitat
requirements.
4.5 – Cultural Resources
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change
in the significance of a historical
resource as defined in Section
15064.5?
□ □ □
b) Cause a substantial adverse change
in the significance of an
archaeological resource pursuant to
Section 15064.5?
□ □ □
c) Disturb any human remains,
including those interred outsides of
formal cemeteries? □ □ □
a) Less than Significant Impact. In the 1800’s, Downey was one of many towns to spring up in the
Los Angeles Basin. The city derived its name from John Gately Downey, an Irish immigrant who had
come to California during the 1849 Gold Rush. He helped build the economic foundation of Southern
California which transitioned from open cattle range to an agricultural district of small farms. In
November 1859, Downey and his former drugstore partner, James McFarland, bought the 17,602 -acre
Rancho Santa Gertrudes. In 1873, a 96-acre parcel of the plot became the central district of a
community called “Downey City” as a result of the favorable climate, fertile soil, and abundant water
sources. In April of 1874, the Southern Pacific Railroad was extended through Downey which brought
new residents from back East and delivered agricultural and other goods throughout the country. By
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
52 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
the early 1900’s, the downtown Downey area contained a Sunkist packing plant, a department store,
banks, restaurants and mercantile shops. Downey remained largely agrarian until the development of
the local aircraft industry during the post -World War II years, with light industry and tract homes
replacing orange groves. The city was one of the first suburban “planned communities” with quality
homes, schools and retail centers. By the beginning of the 21st century, Downey provided a balance of
housing, commerce, and jobs for local residents and employees.
A Cultural Resources Assessment (CRA) was prepared for the project site 13 by CRM TECH dated
October 13, 2023 that included historic and archaeological resources According to the General Plan1
and the CRA13, the project area has no facilities that satisfy any of the criteria for historic resources
defined in CEQA Guidelines Section 15064.5. The CRA noted that components of the onsite church
building were constructed from the late 1950’s to 1989, so it was at least possible that the structure may
have historical value. To answer that question, CRM TECH undertook a preliminary evaluation of the
church building and determined it did not meet the criteria for a historical resource under CEQA CRM
TECH concluded the site did not have any structures eligible for listing in the National or California
Registers under any of the significance criteria. Therefore, the project would not result in an adverse
change in the significance of a historical resource as defined in CEQA Section 15064.5. During its
historical assessment, CRM TECH documented the architectural features of the church building using
the required California Department of Parks and Recreation (DPR) Form 523 to help determine if a
property meets the defined criteria of historical, architectural, archeological, or cultural significance. The
DPR 523 Form is designed to collect enough information to make a preliminary determination of
eligibility. The form collects basic information such as location, classification, function, a brief physical
description and evaluation of the property’s integrity and associations. With this documentation,
potential impacts to historical resources will be less than significant and no mitigation is required.
b) Less than Significant with Mitigation Incorporated. A Cultural Resources Assessment (CRA)
was prepared for the project site by CRM TECH that included the evaluation of archaeological
resources. The draft CRA indicated that no cultural resource surveys have been conducted in the project
area, but Native American tribes have occupied the Los Angeles Basin for thousands of years. Given
the developed, urbanized nature of the project site and vicinity, previously undiscovered archaeological
resources are not anticipated to be uncovered during project grading. However, it should be noted that
local Native American tribes, most notably the Gabrieleño Band of Mission Indians-Kizh Nation, have
expressed concern regarding the likelihood of finding tribal artifacts or resources during grading
generally anywhere within their traditional tribal boundaries which includes the City of Downey (see also
Section 4.18, Tribal Cultural Resources).
In the event that archaeological resources , most likely related to the Gabrieleño Band of Mission
Indians-Kizh Nation, are discovered during ground-disturbing activities, Mitigation Measure CUL-1 has
been recommended to ensure that buried archaeological and/or tribal resources are properly treated if
found during project grading. With implementation of the recommended mitigation, potential impacts to
archaeological resources would be less than significant.
c) Less than Significant with Mitigation Incorporated. No known human remains are anticipated to
be located on or beneath the project site. However, in the unlikely event that human remains are
uncovered during ground disturbing activities, the contractor is required to halt work in the immediate
area of the find and to notify the County Coroner, in accordance with Health and Safety Code Section
7050.5, who must then determine whether the remains are of forensic interest. If the Coroner, with the
aid of a supervising archaeologist, determines that the remains are or appear to be of a Native
American, they must contact the Native American Heritage Commission for further investigations and
proper recovery of such remains, if necessary. Mitigation Measure CUL-1 will help ensure that human
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 53
City of Downey
remains are properly treated in accordance with existing regulations. With incorporation of mitigation,
impacts related to the discovery of buried human remains would be less than significant.
Mitigation Measures
CUL-1 Unanticipated Resources. In the event that archaeological resources (sites, features, or
artifacts) are exposed during construction activities of the project, all construction work
occurring within 100 feet of the find shall immediately stop until a qualified archaeologist,
meeting the Secretary of the Interior’s Professional Qualification Standards, can evaluate
the significance of the find and determine whether or not additional study is warranted.
Depending upon the significance of the find under the California Environmental Qua lity Act
(CEQA: 14 CCR 15064.5(f): PRC Section 21083.2), the archaeologist may simply record
the find and allow work to continue. However, if the discovery proves significant under
CEQA, additional work, such as preparation of an archaeological treatment p lan, testing, or
data recovery, may be warranted.
4.6 – Energy
Would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or unnecessary
consumption of energy resources,
during project construction or
operation?
□ □ □
b) Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency? □ □ □
An Air Quality, Greenhouse Gas, and Energy Impact Analysis was prepared for the proposed project
by MIG, dated September 20, 2023 (see Appendix A). The report estimates the potential energy usage
and greenhouse gas emissions for the proposed project and evaluates project emissions against
applicable South Coast Air Quality Management District (SCAQMD)-recommended California
Environmental Quality Act (CEQA) significance thresholds for construction and operation.
a) Less Than Significant Impact. The proposed project consists of the demolition of an existing church
and parking lot and construction of a 33-unit townhouse project. Construction activities associated with
the proposed project would require the use of heavy -duty, off-road equipment and construction-related
vehicle trips that would combust fuel, primarily diesel and gasoline. Heavy -duty construction equipment
would be required to comply with CARB’s airborne toxic control measures, which restrict heavy -duty
diesel vehicle idling to five minutes. It is estimated that construction activities would consume
approximately 19,871 gallons of diesel fuel to power on-site, off-road heavy-duty construction
equipment. Worker, vendor, and haul truck trips during construction activities are anticipated to
consume 3,802 gallons of gasoline, 1.137 gallons of diesel, and 894 kilo-Watt hours (kWh) of electricity.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
54 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Once operational, the proposed project would consume energy for vehicle trips, electricity, and water
and wastewater conveyance. As estimated using CalEEMod, the proposed building s would consume
approximately 396 megawatt-hours (mWh) of electricity per year. Operational vehicle trips are
anticipated to consume approximately 3,804 gallons of diesel and 23,191 gallons of gasoline from
operational mobile sources on an annual basis.
The proposed project would not consume natural gas as the project is planned to be all electric.
Electricity and gasoline fuel consumption are energy sources necessary to operate and maintain the
proposed project in a safe manner. Lighting is essential for safety and security and, due to the all -
electric design of the building s, electricity is also needed for heating, cooking, and other temperature -
controlled activities. Due to energy efficiency standards being improved over time, the new structures
would be more efficient in its energy consumption than the existing structures. In addition, the proposed
project includes the use of solar photovoltaic (PV) panels to be provided on all townhomes.
Electricity, and gasoline fuel consumption are energy sources necessary to operate and maintain the
proposed residential project in a safe manner. Lighting is essential for safety and security as well as
heating and other temperature -controlled activities since it will be an all-electric project. Due to energy
efficiency standards being improved over time, the new structures would be more efficient in its energy
consumption than the existing structures. In addition, the proposed project includes elements th at
support modes of transportation that would result in less gasoline consumption than transportation by
single-occupancy gasoline-powered cars. For example, the CalGreen Code requires new residential
units to be wired so that electric vehicle charging equipment be installed by new homeowners if so
desired.
The proposed project would be built to the latest CalGreen Code and State Title 24 energy conservation
standards and would be more energy efficient than the existing structures at the site and would not
conflict with or obstruct a state or local plan for renewable energy. For example, the development will
have photovoltaic solar panels on the roofs of the units to replace electricity from other sources. In
addition, the project will be all electric so there will be no consumption of natural gas, and each unit will
be wired to support electric vehicle charging equipment.
In these ways, the proposed project would not conflict with or obstruct a state or local plan adopted for
the purposes of increasing the amount of renewable energy or energy efficiency because no such plan
is in place in the project area. In these ways energy consumption impacts of the project will be reduced
to the level equal or greater than that required by the CalGreen Code.
For these reasons, the proposed project would not result in the wasteful, inefficient, or unnecessary
use of energy resources. This impact would thus be less than significant and no mitigation is required.
b) Less Than Significant Impact. As previously discussed, the project would be constructed and
operated consistent with the energy conservation requirements of the CalGreen Code and State Title
24 energy conservation standards. In addition, the City of Downey does not have its own Climate Action
Plan (CAP) or other plan that directly addresses energy conservation. Therefore, the proposed project
would not conflict with or obstruct a state or local plan adopted for the purposes of increasing the amount
of renewable energy or energy efficiency because no such plan is in place in the project area. This
impact would be less than significant and no mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 55
City of Downey
4.7 – Geology, Soils, and Paleontological Resources
Would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential
substantial adverse effects, including
the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map issued by the State
Geologist for the area or based on
other substantial evidence of a
known fault? Refer to Division of
Mines and Geology Special
Publication 42.
□ □ □
ii) Strong seismic ground shaking? □ □ □
iii) Seismic-related ground failure,
including liquefaction? □ □ □
iv) Landslides? □ □ □
b) Result in substantial soil erosion or
the loss of topsoil? □ □ □
c) Be located on a geologic unit or soil
that is unstable, or that would
become unstable as a result of the
Project, and potentially result in on -
or off-site landslide, lateral
spreading, subsidence, liquefaction
or collapse?
□ □ □
d) Be located on expansive soil, as
defined in Table 18-1-B of the
Uniform Building Code (1997),
creating substantial direct or indirect
risks to life or property?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
56 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal
systems where sewers are not
available for the disposal of waste
water?
□ □ □
f) Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature? □ □ □
A Geotechnical Investigation 14 was prepared by Albus & Associates, dated February 6, 2023
(Geotechnical Report, Appendix D) and a Paleontological Resources Assessment Report 13 was
prepared by CRM TECH dated October 13, 2023 (Appendix C). The information in this section is largely
taken from those reports unless otherwise noted.
a.i) Less Than Significant Impact. No active faults have been identified at the ground surface within
the City of Downey as identified in the General Plan Safety Element, nor have any Alquist -Priolo
Earthquake Fault zones been designated.15 The project Geotechichnical Report indicates “no active
faults are known to project through or immediately adjacent the subject site and the site do es not lie
within an "Earthquake Fault Zone" as defined by the State of California in Earthquake Fault Zoning Act
(page 6, Albus 2023). Table 3.1 in the Geotechnical Report indicates the following faults are the closest
to the project site: Puente Hills (0.1 mile); Elsinore (5.4 miles); Elysian Park (6.6 miles); and Newport
Inglewood (9 miles). Although there are several faults in the immediate surrounding region, t he
Geotechnical Report found the risk from onsite fault rupture to be negligible. Therefore, impacts related
to earthquake faults and ground rupture would be less than significant.
a.ii) Less Than Significant Impact. Potential impacts from strong seismic ground shaking include
injury or loss of life and property damage. The Geotechnical Report found the peak ground acceleration i
at the site is 0.834g ii which is considered strong. The City lies within the Los Angeles Basin and
underlying geologic formations consist largely of ancient marine and river deposits which are typically
sandy and silty-sandy soils. The proposed project lies in the far northwest corner of the City on relatively
flat terrain next to the Rio Hondo Channel.
The Geotechnical Report indicates there is two to six feet of unconsolidated artificial fill beneath the
project site from deposition of excavated soils when the Rio Hondo Channel was realigned. In its current
condition, the site may be susceptible to ground failure during strong seismic events. However, The
Geotechnical Report also indicate s that standard excavation and compaction of the soil to applicable
engineering standards in the CBC will eliminate this potential for ground failure on the site. Compliance
with these regulatory standards is not considered unique mitigation.
The project site is subject to strong seismic ground shaking, as are virtually all properties in Southern
California. The 2022 California Building Code (California Building Code [CBC], California Code of
Regulations, Title 24, Volume 2, as adopted by the City of Downey Municipal Code (CDMC), Chapter
16.05, contains seismic safety provisions with the aim of preventing building collapse during a design
earthquake, so that occupants would be able to evacuate after the earthquake. The proposed
townhomes would be subject to the seismic design criteria of the 2022 CBC. Adherence to these
regulatory requirements would reduce the potential for building collapse during an earthquake, thereby
i The mapped Maximum Considered Earthquake Geometric Mean (MCEG)
ii The term “g” means onsite groundshaking could reach about 83% of the force of gravity exerted horizontally on project buildings.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 57
City of Downey
minimizing injury and loss of life. Although structures may be damaged during earthquakes, adherence
to seismic design requirements would minimize damage to property within the structure because the
structure is designed not to collapse. The CBC is intende d to provide minimum requirements to prevent
major structural failure and loss of life. Adherence to existing regulations would reduce the risk of loss,
injury, and death. Therefore, impacts due to strong ground shaking would be less than significant and
no mitigation is required.
a.iii) Less Than Significant Impact. The Geotechnical Report indicates there is two to six feet of
unconsolidated fill beneath the project site from deposition of excavated soils when the Rio Hondo
Channel was realigned. The grading plan indicates there will be 7,000 cubic yards (cy) of over -
excavation due to the presence of unconsolidated fill. Other earthwork will involve 2,500 cy of cut/fill
and approximately 4,500 cy will need to be imported after removal and compaction of the
unconsolidated fill materials.
Liquefaction is a phenomenon that occurs when soil undergoes transformation from a solid state to a
liquefied condition due to the effects of increased pore -water pressure. This typically occurs where
susceptible soils (particularly the medium sand to silt range) are located over a high groundwater table
(less than 50 feet in depth), and in an area subject to strong groun dshaking. Affected soils lose their
strength during liquefaction and foundation failure can occur.
The City’s General Plan Safety Element indicates the project area is considered to be in a liquefaction
zone. The Geotechnical Report found no groundwater beneath the project area to the subsurface
exploration depth of 51.5 feet. However, CDMG 16 Special Report 034 suggests that historic high
groundwater in the immediate area could be as shallow as 9 feet below the ground surface. After
additional research by Arbus using online groundwater well data from the Los Angeles County Public
Works Department, two wells were found in proximity to the project site. Data from these wells was from
1950 to 2011 and the recorded depths to groundwater in both wells indicate that groundwater has
remained below a depth of 50 feet in this area since 1950 (i.e., 70-80 feet). Therefore, the Geotechnical
Report concluded that groundwater beneath the site w as expected to be at least 50 feet or more in
depth.
The Geotechnical Report indicates the site and surrounding area have not been subject to historic
occurrence of liquefaction, or local geological, geotechnical, and groundwater conditions . Therefore,
there is no potential for permanent ground displacement that would trigger the need for mitigation as
defined in Public Resources Code Section 2693(c). The site exhibits a very low seismic settlement
potential and liquefaction would not be significant to the proposed development. Therefore, impacts due
to seismically induced ground failure or liquefaction would be less than significant.
a.iv) No Impact. The Geotechnical Report indicates the project site is located in a suburbanized area
that is relatively flat and there is no potential for landslides . Therefore, there will be no impacts to the
proposed project site and no mitigation is required.
b) Less Than Significant Impact. The project site currently supports a church and parking lot and
underlying soils are completely covered by development. However, the project has the potential to
expose surficial soils to wind and water erosion during construction activities. Wind erosion would be
minimized through soil stabilization measures required by South Coast Air Quality Management District
(SCAQMD) Rule 403 (Fugitive Du st), such as daily watering which will minimize the potential for wind
erosion. For more information on dust control, see Threshold 4.3, Air Quality. With regulatory
compliance, project construction will not have significant impacts relative to wind erosion.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
58 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Water erosion would be prevented through the City’s standard erosion control practices required
pursuant to the California Building Code and the National Pollution Discharge Elimination System
(NPDES), such as silt fencing or sandbags. Following project co nstruction, the site would be covered
completely by paving, structures, and landscaping. Therefore, impacts related to soil erosion would be
less than significant with implementation of existing regulations once construction is complete.
c) Less Than Significant with Mitigation Incorporated. Impacts related to liquefaction and
landslides are discussed in Sections 4.7.a and 4.7.b. above and both were determined to be less than
significant.
Lateral spreading is the downslope movement of surface sediment due to liquefaction in a subsurface
layer. The downslope movement is due to gravity and earthquake shaking combined. Such movement
can occur on slope gradients of as little as one degree. Late ral spreading typically damages pipelines,
utilities, bridges, and structures. Lateral spreading of the ground surface during a seismic activity usually
occurs along the weak shear zones within a liquefiable soil layer and has been observed to generally
take place toward a free face (e.g., retaining wall, slope, or channel) and to lesser extent on ground
surfaces with a very gentle slope. Due to the absence of any channel within or near the project site, and
the subsurface soil conditions that are not conducive to liquefaction, the potential for lateral spread
occurring on the project site is considered to be less than significant (page 7, Geotechnical Report).
The project engineer indicates earthwork on the site will be generally balanced with little onsite cut and
fill anticipated. However, there may be a small amount of import or export of soil because the exact
amount is not yet known. This is because the site is underlain by an unknown amount of unconsolidated
fill.
The City requires a comprehensive geotechnical investigation of a development site prior to issuing
grading permits. In addition, the project is required to be constructed in accordance with the
requirements of the 2022 CBC. The CBC includes a requirement that any City -approved
recommendations contained in the soils report be made conditions of the building permit.
The project Geotechnical Report indicated it was prepared for only feasibility purposes and
recommended a supplemental Geotech nical report be prepared to determine site specific project
grading, design, permitting, and construction parameters. Preparation of that supplemental report is
addressed in Mitigation Measure GEO-1. Compliance with site specific geotechnical recommendations
of the original and supplemental Geotech nical Reports (see Mitigation Measure GEO-1) and current
CBC regulations would limit hazard impacts arising from potentially unstable soils to less than significant
levels.
d) Less than Significant Impact. According to the project Geotechnical Report, near surface soils
have a “very low” medium expansion potential. The project would comply with all recommendations
provided in the project Geotechnical Report upon application for grading and building permits. Less
than significant impacts would occur.
e) No Impact. The project proposes to connect the existing municipal wastewater system to an eight-
inch sewer main line in Suva Street along the southern boundary of the site. The project would connect
to this system and would not require use of septic tanks; therefore, no impact would occur .
f) Less than Significant with Mitigation Incorporated. Given the urbanized nature of the project site
and vicinity, previously recorded paleontological resources are not anticipated to be uncovered during
project construction activities. However, in the event that previously undiscovered paleontological
resources are discovered during ground -disturbing activities, Mitigation Measures GEO-2 through GEO-
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 59
City of Downey
5 have been recommended to ensure that paleontological resources are properly treated. With
implementation of the recommended mitigation, impacts to paleontological resources would be reduced
to be less than significant levels.
Mitigation Measures
GEO-1 Supplemental Geotechnical Report. Prior to issuance of a grading permit, the project
proponent shall retain a qualified geotechnical consultant to prepare a supplemental
geotechnical investigation as recommended by the “Geotechnical Due-Diligence
Investigation” prepared by Albus & Associates, Inc. dated February 6, 2023. The
supplemental report shall be certified by the City Engineer as adequate for the purposes of
design, permitting, and construction.
GEO-2 Conduct Paleontological Sensitivity Training for Construction Personnel. If excavation
below 6’ is required, the project proponent must retain a professional paleontologist, who
meets the qualifications set forth by the Society of Vertebrate Paleontology, to conduct a
Paleontological Sensitivity Training for construction personnel before commencement of
excavation activities. The training would include a handout and would focus on how to
identify paleontological resources that may be encountered durin g earthmoving activities,
and the procedures to be followed in such an event; the duties of paleontological monitors;
notification and other procedures to follow upon discovery of resources , and the general
steps a qualified professional paleontologist would follow in conducting a salvage
investigation if one is necessary.
GEO-3 Conduct Periodic Paleontological Spot Checks During Grading and Earth -Moving
Activities. If excavation below 6’ is required, the project proponent must retain a
professional paleontologist, who meets the qualifications set forth by the Society of
Vertebrate Paleontology, to conduct periodic Paleontological Spot Checks beginning at
depths below six feet from the surface to determine if construction e xcavations extend into
older Quaternary deposits. After the initial Paleontological Spot Check, further periodic
checks would be conducted at the discretion of the qualified paleontologist. If the qualified
paleontologist determines that construction excavations have extended into the older
Quaternary deposits, construction monitoring for Paleontological Resources are required.
The project proponent must retain a qualified paleontological monitor, who would work under
the guidance and direction of a professional paleontologist, who meets the qualifications set
forth by the Society of Vertebrate Paleontology. The paleontological monitor must be present
during all construction excavations (e.g., grading, trenching, or clearing/grubbing) into the
older Pleistocene alluvial deposits. Multiple earth -moving construction activities may require
multiple paleontological monitors. The frequency of monitoring is based on the rate of
excavation and grading activities, proximity to known paleontological resources and/or
unique geological features, the materials being excavated (native versus artificial fill soils),
and the depth of excavation, and if found, the abundance and type of paleontological
resources and/or unique geological features encountered. Full -time monitoring can be
reduced to part-time inspections if determined adequate by the qualified professional
paleontologist. Monitoring shall terminate when grading and trenching activities on the site
have been completed.
GEO-4 Cease Ground-Disturbing Activities and Implement Treatment Plan if Paleontological
Resources Are Encountered. In the event that paleontological resources and or unique
geological features are unearthed during ground-disturbing activities, the paleontological
monitor may halt or divert work away from the vicinity of the find so that the find can be
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
60 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
evaluated. A buffer area of at least 50 feet must be established around the find where
construction activities are not allowed to continue until an appropriate paleontological
treatment plan is approved by the project proponent and the City. Work is allowed to continue
outside of the buffer area. The project proponent and City would coordinate with a
professional paleontologist, who meets the qualifications set forth by the Society of
Vertebrate Paleontology, to develop an appropriate treatment plan for the resources.
Treatment may include implementation of paleontological salvage excavations to remove
the resource along with subsequent laboratory processing and analysis or preservation in
place. At the paleontologist’s discretion and to reduce construction delay, the grading and
excavation contractor would assist in removing rock samples for initial processing.
GEO-5 Prepare Report Upon Completion of Monitoring Services. If paleontological resources
are found, upon completion of the activities identified under Mitigation Measure GEO-4, the
professional paleontologist would prepare a report summarizing the results of the monitoring
and salvaging efforts, the methodology used in these efforts, and a description of the fossils
collected and their significance. The report would be submitted to the project proponent, the
City, the Natural History Museums of Los Angeles County, and representatives of other
appropriate or concerned agencies to signify the satisfactory completion of the project and
required mitigation measures.
4.8 – Greenhouse Gas Emissions
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a significant
impact on the environment?
□ □ □
b) Conflict with an applicable plan,
policy or regulation adopted for the
purpose of reducing the emissions of
greenhouse gases?
□ □ □
An Air Quality, Greenhouse Gas, and Energy Impact Analysis was prepared for the proposed project
by MIG, dated September 20, 2023 (Appendix A). The report estimates the potential energy usage and
greenhouse gas emissions for the proposed project and evaluates project emissions against applicable
South Coast Air Quality Management District (SCAQMD)-recommended California Environmental
Quality Act (CEQA) significance thresholds for construction and operation.
a) Less than Significant Impact.
Background Information
Gases that trap heat in the atmosphere and affect regulation of the Earth’s temperature are known as
GHGs. GHG that contribute to climate change are a different type of pollutant than criteria or hazardous
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 61
City of Downey
air pollutants because climate change is global in scale, both in terms of causes and effects.17 Some
GHG are emitted to the atmosphere naturally by biological and geological processes such as
evaporation (water vapor), aerobic respiration (carbon dioxide), and off -gassing from low oxygen
environments such as swamps or exposed permafrost (methane); h owever, GHG emissions from
human activities such as fuel combustion (e.g., carbon dioxide) and refrigerants use (e.g.,
hydrofluorocarbons) significantly contribute to overall GHG concentrations in the atmosphere, climate
regulation, and global climate change. The 1997 United Nations’ Kyoto Protocol international treaty set
targets for reductions in emissions of four specific GHGs – carbon dioxide, methane, nitrous oxide, and
sulfur hexafluoride – and two groups of gases – hydrofluorocarbons and perfluorocarbons. These GHG
are the primary GHG emitted into the atmosphere by human activities. The six most common GHG’s
are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6),
hydrofluorocarbons (HFCs), and perfluorocarbons (PFCs).
GHG emissions from human activities contribute to overall GHG concentrations in the atmosphere and
the corresponding effects of global climate change (e.g., rising temperatures, increased severe weather
events such as drought and flooding). GHGs can remain in the atmosphere long after they are emitted.
The potential for a GHG to absorb and trap heat in the atmosphere is considered its global warming
potential (GWP). The reference gas for measuring GWP is CO 2, which has a GWP of one. By
comparison, CH4 has a GWP of 25, which means that one molecule of CH 4 has 25 times the effect on
global warming as one molecule of CO 2. Multiplying the estimated emissions for non-CO2 GHGs by
their GWP determines their carbon dioxide equivalent (CO 2e), which enables a project’s combined
global warming potential to be expressed in terms of mass CO2 emissions (referred to as CO2
equivalents, or CO2e).
GHG Significance Thresholds
The proposed project is located within the South Coast Air Basin, under the jurisdiction of the SCAQMD.
In order to provide guidance to local lead agencies on determining the significance of GHG emissions
in their CEQA documents, the SCAQMD convened the first GHG Significance Threshold Working Group
(Working Group) meeting on April 30, 2008. To date, the Working Group has convened a total of 15
times, with the last meeting taking place on September 28, 2010. Based on the last Working Group
meeting, the SCAQMD identified an interim, tiered approach for evaluating GHG emissions intent on
capturing 90 percent of development projects where the SCAQMD is not the lead agency. The following
describes the basic structure of the SCAQMD’s tiered, interim GHG significance thresholds:
• Tier 1 consists of evaluating whether or not the project qualifies for applicable CEQA
exemptions.
• Tier 2 consists of determining whether or not a project is consistent with a greenhouse gas
reduction plan. If a project is consistent with a greenhouse gas reduction plan, it would not
have a significant impact.
• Tier 3 consists of using screening values at the discretion of the Lead Agency; however, the
Lead Agency should be consistent for all projects within its jurisdiction. The following
thresholds were proposed for consideration:
o 3,000 MTCO2e per year for all land use types; or
o 3,500 MTCO2e per year for residential; 1,400 MTCO2e per year for commercial;
3,000 MTCO2e per year for mixed use projects.
• Tier 4 has three options for projects that exceed the screening values identified in Tier 3:
o Option 1: Reduce emissions from business-as-usual by a certain percentage
(currently undefined); or
o Option 2: Early implementation of applicable AB 32 Scoping Measures; or
o Option 3: For plan-level analyses, analyze a project’s emissions against an efficiency
value of 6.6 MTCO2e/year/service population by 2020 and 4.1 MTCO2e/year/service
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
62 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
population by 2035. For project-level analyses, analyze a project’s emissions against
an efficiency value of 4.8 and 3.0 MTCO 2e/year/service population for the 2020 and
2035 calendar years, respectively.
This analysis uses the SCAQMD’s interim Tier 3 GHG threshold to evaluate the proposed project’s
GHG emissions levels. The proposed project would generate GHG emissions from both short -term
construction and long-term operational activities.
Construction Emissions
Construction activities would generate GHG emissions primarily from equipment fuel combustion as
well as worker, vendor, and haul trips to and from the project site during demolition, site preparation,
grading, building construction, paving, and architectu ral coating activities. Construction activities would
cease to emit GHG upon completion, unlike operational emissions that would be continuous year after
year over the life of the project. The SCAQMD recommends amortizing construction GHG emissions
over a 30-year period and including them with operational emissions estimates. This normalizes
construction emissions so that they can be grouped with operational emissions and compared to
appropriate thresholds, plans, etc.
Operational Emissions
Once operational, the proposed project would generate GHG emissions from area, stationary, mobile,
water/wastewater, and solid waste sources. The proposed project’s potential GHG emissions were
estimated using CalEEMod, V.2022.1.1 using project information if available or CalEEMod default
assumptions when project-specific data was not available. The proposed project’s unmitigated GHG
emissions for construction and operation are shown in Table 4.8-1 (Project Greenhouse Gas
Emissions).
Table 4.8-1
Project Greenhouse Gas Emissions
GHG Emissions Source
GHG Emissions
(MTCO2e Per Year)
Operations
Area 3
Energy 93
Mobile 232
Refrigerants <1
Solid Waste 8
Water/Wastewater 4
Subtotal(A)
Construction
Total Construction Emissions 240
Average Annual Emissions (30-Year Lifetime)(B) 8
Total Project Emissions(A) 348
SCAQMD Tier 3 Screening Threshold 3,000
SCAQMD Tier 3 Threshold Exceeded? No
Project-Specific GHG Threshold(C) 1,800
Project-Specific Threshold Exceeded? No
Source: MIG 2023a (Appendix B) and SCAQMD, 2010.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 63
City of Downey
(A) Construction emissions value has been averaged over a 30-year assumed project lifetime
(B) Totals may not equal due to rounding.
(C) Calculated based on State post-2020 GHG emission targets since it is now 2023
As shown in Table 4.8-1, the proposed project’s potential increase in GHG emissions would be well
below the SCAQMD’s recommended GHG emissions threshold. Furthermore, the proposed project’s
GHG emissions would also be below an adjusted project-specific GHG emissions goal of 1,800
MTCO2e per year, which takes into account post 2020 GHG emissions targets towards which the state
is currently working. The 1,800 MTCO2e per year goal was developed by taking the SCAQMD’s Tier 3
threshold of 3,000 MTCO2e per year, which was the threshold to reduce emissions back to 1990 levels
and reducing it by 40 percent (3,000 MTCO 2e/yr. * (1 - 0.6) = 1,800 MTCO2e/yr.). This reduction is
consistent with the GHG reductions required by the year 2025 to meet GHG reductions required under
Senate Bill 32 (to reduce GHG emissions to levels 40% below 1990 levels by 2030). This linear
reduction approach oversimplifies the threshold development process. The City of Downey is not
adopting nor proposing to use 1,800 MTCO 2e as a CEQA GHG threshold for general use; rather, it is
only intended to provide additional context and information on the magnitude of the proposed project’s
GHG emissions.
Finally, the proposed project’s estimated emissions are presented as gross emissions with no credit
applied rather than the net change. For these reasons, the proposed project would therefore not
generate GHG emissions that exceed SCAQMD CEQA thresholds. Impacts would be less than
significant and no mitigation is required.
b) No Impact. The proposed project would not conflict with or otherwise obstruct implementation of a
plan, policy, or regulation adopted for the purposes of reducing GHG emissions, including the California
Air Resources Board (CARB) 2022 Climate Change Scoping Plan (2022 Scoping Plan ), the Southern
California Association of Governments (SCAG) 2020 Regional Transportation Plan/Sustainable
Communities Strategy (2020 RTP/SCS). Appendix D to CARB’s 2022 Scoping Plan Update identifies
potential actions that could be undertaken at a local level to support the State’s climate goals. In addition
to providing guidance to local lead agencies on long -term climate planning (e.g., developing a qualified
climate action plan), this appendix also provides a list of key GHG reducing attributes for residential and
mixed-use developments - projects that exhibit these attributes represent growth that is consistent with
State’s GHG reduction goals. Table 4.8-2 (Project Consistency with Key GHG Reducing Attributes -
2022 Scoping Plan), evaluates project consistency with these attributes.
Table 4.8-2
Project Consistency with Key GHG Reducing Attributes (2022 Scoping Plan)
Priority Area Key Project Attribute Project Consistency
Transportation
Electrification
Provides electric vehicle (EV) charging
infrastructure that, at a minimum, meets
the most ambitious voluntary standard
in the California Green Building
Standards Code (CalGreen Code) at
the time of project approval.
Consistent. The proposed project would meet
the minimum code compliance specified in the
2022 CalGreen Code.
VMT Reduction
Is located on infill sites that are
surrounded by existing urban uses and
reuses or redevelops previously
undeveloped or underutilized land that
is presently served by existing utilities
and essential public services (e.g.,
transit, streets, water, sewer).
Consistent. The proposed project would add
approximately 33 units on an infill site that is
served by existing utilities.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
64 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Priority Area Key Project Attribute Project Consistency
Does not result in the loss or conversion
of natural and working lands.
Consistent. The proposed project site is already
developed; it would not result in the loss or
conversion of natural or working lands.
Consists of transit-supportive densities
(minimum of 20 residential dwelling
units per acre), or
Is in proximity to existing transit stops
(within a half mile), or
Satisfies more detailed and stringent
criteria specified in the region’s SCS.
Consistent. The proposed project would result
in a development intensity of approximately
25.4 dwelling units per acre, which meets the
criteria.
Reduces parking requirements by:
• Eliminating parking requirements
or including maximum allowable
parking ratios (i.e., the ratio of
parking spaces to residential units
or square feet), or
• Providing residential parking
supply at a ratio of less than one
parking space per dwelling unit, or
• For multifamily residential
development, requiring parking
costs to be unbundled from costs
to rent or own a residential unit.
Inconsistent. The proposed project would not
incorporate parking reduction.
At least 20 percent of units included are
affordable to lower-income residents.
Inconsistent. The proposed project would only
designate up to 3 units as affordable to lower-
income residents.
Results in no net loss of existing
affordable units.
Consistent. The proposed project would not
result in the net loss of existing affordable units.
Building
Decarbonization
Uses all-electric appliances without any
natural gas connections and does not
use propane or other fossil fuels for
space heating, water heating, or indoor
cooking.
Consistent. The proposed project would be an
all-electric design. The project would not include
natural gas plumbing nor use fossil fuels for
space heating, water heating, or indoor cooking.
Source: Table 8, MIG 2023a, CARB 2022, Appendix D, Table 3; and TAG 2023
As shown in Table 4.8-2, the proposed project would be consistent with most of the Key GHG Reducing
Attributes identified in the 2022 Scoping Plan, except for electric vehicle infrastructure, parking
reductions, and low-income housing provisions. This inconsistency does not necessarily imply that the
project would result in a potentially significant impact, because consistency with the project attributes is
simply a qualitative means by which to assess whether or not a project would clearly be consistent with
the State’s climate goals (CARB 2022, pg. 23). In fact, Appendix D to the 2022 Scoping Plan provides
that, “Lead agencies may determine, with adequate additional supporting evidence, that projects that
incorporate some, but not all, of the key project attributes are consistent with the State’s climate goals”
(CARB 2022, pgs. 23 and 24). The proposed project would provide some VMT reductions because it
would be located on an infill site, not result in the loss of natural or working lands, and have transit -
supportive densities (i.e., greater than 20 dwelling units per acre), and would not install, nor us e, natural
gas or fossil fuels for space heating, water heating, or indoor c ooking. Therefore, based on these
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 65
City of Downey
qualitative criteria and the magnitude of the project’s overall GHG emissions levels (less than 350 metric
tons of CO2e per year) the growth proposed by the project would be consistent with the State’s long -
term GHG emission reduction goals.
As described above, the proposed project would not result in significant GHG emissions nor conflict
with an applicable plan, policy, or regulation adopted for the purposes of reducing GHG emissions.
There will be no impact and no mitigation required.
4.9 – Hazards and Hazardous Materials
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the
public or the environment through the
routine transport, use, or disposal of
hazardous materials?
□ □ □
b) Create a significant hazard to the
public or the environment through
reasonably foreseeable upset and
accident conditions involving the
release of hazardous materials into
the environment?
□ □ □
c) Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste
within one-quarter mile of an existing
or proposed school?
□ □ □
d) Be located on a site which is
included on a list of hazardous
materials sites compiled pursuant to
Government Code Section 65962.5
and, as a result, would it create a
significant hazard to the public or the
environment?
□ □ □
e) For a project located within an airport
land use plan or, where such a plan
has not been adopted, within two
miles of a public airport or public use
airport, would the Project result in a
safety hazard or excessive noise for
people residing or working in the
Project area?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
66 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
f) Impair implementation of or
physically interfere with an adopted
emergency response plan or
emergency evacuation plan?
□ □ □
g) Expose people or structures, either
directly or indirectly, to a significant
risk of loss, injury or death involving
wildland fires?
□ □ □
A Phase I Environmental Site Assessment (ESA)18 was performed by SCS Engineers, dated January
31, 2023 (Appendix E). The information on hazardous materials in this section is largely taken from the
ESA.
a) Less than Significant Impact. The project could result in a significant hazard to the public if it
includes the routine transport, use, or disposal of hazardous materials or places housing near a facility,
which routinely transports, uses, or disposes of hazardous materials. The project is located within an
area dominated by residential uses and surface streets. The project would not place housing near any
hazardous materials facilities. The routine use, transport, or disposal of hazardous materials is primarily
associated with industrial uses, which require such materials for manufacturing operations or produce
hazardous wastes as by-products of production applications. The project, which is a residential use,
does not propose or facilitate any activity involving significant use, routine transport, or disposal of
hazardous substances.
Construction of the project would require the use and transport of hazardous materials such as asphalt,
paints, and other solvents. Construction activities could also produce hazardous wastes associated with
the use of such products. Construction would require ordinary construction activities and would not
require a substantial or uncommon ly high amount of hazardous materials to complete. All hazardous
materials are required to be utilized and transported in accordance with their labeling pursuant to federal
and state law. Routine construction practices include good housekeeping measures to
prevent/contain/clean-up spills and contamination from fuels, solvents, concrete wastes, and other
waste materials. Impacts related to construction would be less than significant.
With regard to project operation, widely used hazardous materials common at residential uses include
paints and other solvents, cleaners, and pesticides. Operation of the proposed project would also
involve the use of cleaning solutions for daily operation and paints for routine maintenance and re -
coating of structures. The remnants of these and other products are disposed of as household
hazardous waste (HHW) that includes used dead batte ries, electronic wastes, and other wastes that
are prohibited or discouraged from being disposed of at local landfills. Through compliance with existing
regulations, use of common household hazardous materials and their disposal does not present a
substantial health risk to the community. Therefore, impacts associated with the routine transport, use,
or disposal of hazardous materials or wastes would be less than significant.
b) Less than Significant with Mitigation Incorporated. The project is a residential development
proposed within an existing residential-zoned area of the City of Downey. The proposed project would
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 67
City of Downey
have limited use of hazardous materials , mainly HHW as part of the operations of the proposed
residential use. The Phase I Environmental Site Assessment (ESA) completed by SCS Engineers
(SCS) in 2023 concluded that no known hazards we re present on the project site. Regarding the history
of the site, the ESA indicated excess soil from realignment of the nearby Rio Hondo Channel was
deposited on the site which raised its elevation by several feet. as described below:
The property was undeveloped or agricultural land between 1896 and 1902. Between the 1920s and
the mid-1950s, it was developed with agricultural orchards and a rural farmhouse. The church was
developed in stages, beginning in the late -1950s, expanded to its current configuration with a paved
asphalt parking lot around it by 1989. The construction of the church coincides with the time when
the Rio Hondo was channelized to the southeast, rerouting it from its original course to the west of
the Property. Today, the church parking lot sits approximately 4 -6 feet higher in elevation than the
adjoining residence to the north. It is likely that virgin fill material originating from the river
channelization process was placed on the Property at that time, raising its elevation. In SCS’ opinion,
given the likely origin of this fill material, it does not represent an environmental concern. It is also
SCS’ opinion that, without specific evidence of pesticide storage or mismanagement on the Property,
past use for agricultural purposes does not represent a significant environmental concern and
collection and analysis of soil samples for pesticides is unwarranted. Our opinion is further supported
by the fact that fill material, likely placed on the Property during the river channelization, and former
agricultural orchard soil is now 4 -6 feet below current grade.
The ESA found no indications of aboveground or underground storage tanks or other potential
contamination on the site. However, due to past activities on the site and in the surrounding area, it is
possible that unanticipated hazardous materials may be found during demolition or grading of the site.
Therefore, Mitigation Measure HAZ-1 is recommended to monitor grading by qualified personnel to
assure there will be no release of or health risks from the unanticipated release of subsurface hazardous
materials during grading.
According to the SCAQMD, demolition of older buildings and structures may pose a hazard regarding
asbestos containing materials and lead -based paint. It should be noted that Asbestos Containing
Materials and lead based paint do not represent a significant public health hazard when they are left
undisturbed, however, site development requires demolition of the existing church building prior to
grading.
Asbestos-Containing Materials (ACMs). ACMs were used on a widespread basis in building
construction prior to and into the 1980s. The ESA indicated that construction on the existing church
building began in the late 1950’s and continued through 1989. Typical sources of ACMs include
transite (water) pipes, roofing materials and roof penetrating mastic, and vinyl floor tiles. If ACMs are
present, site demolition could result in airborne emissions of asbestos resulting in exposure of
workers or the environment to a hazardous material. In accordance with Section 112 of the Federal
Clean Air Act, the U.S. EPA establishes National Emission Standards for Hazardous Air Pollutants
(NESHAP). If necessary, the project would comply with SCAQMD Rule 1403, which is the enforcing
rule of the Asbestos NESHAP, and sets forth requirement s for asbestos surveying, notification,
removal procedures, and storage, and disposal requirements for ACMs. Regulatory compliance with
SCAQMD Rule 1403 would ensure the proposed project does not expose sensitive receptors to
ACMs. If present, ACMs would need to be removed by a licensed contractor prior to general onsite
demolition and the start of grading.
Lead Based Paint (LBP). According to the California Department of Toxic Substances, exposure of
construction workers to LBP during demolition of older structures is of concern, similar to that of
exposure to asbestos. Exposure of surrounding land uses to lead from demolition acti vities is
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
68 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
generally not a concern because such activities do not result in appreciable emissions of lead. The
primary emitters of lead are industrial processes. Improper disposal of lead -based paint could
contaminate soil and subsurface groundwater in and under landfills not properly equipped to handle
hazardous levels of this material.
Due to the age of the existing onsite building, a survey needs to be conducted prior to any demolition
on the site to determine whether or not the church building contains ACMs and/or LBP. In this regard,
Mitigation Measure HAZ-2 is recommended to be implemented prior to any demolition activities.
Mitigation Measures
HAZ-1 Inadvertent Hazmat Discovery. Prior to issuance of a grading permit, the project proponent
shall retain a qualified environmental professional (QEP) experienced with remediating
hazardous materials from infill urban construction sites. The QEP must be on -call and
summoned to the site immediately if any potentially hazardous materials are found during
grading. Grading must be halted within 100 feet of an area that appears to contain hazardous
materials. The QEP will ha lt grading as necessary to effectively identify the potential
contaminated materials, including directing any sampling and laboratory testing that may be
required.
If soils are found to be contaminated at levels that are only slightly in excess of applicable
residential standards, the QEP shall exercise professional discretion and have the option to
coordinate with the grading contractor and developer to either remove contaminated soil
and/or mix the contaminated soil with clean soil from either onsite or offsite to dilute any
contaminants to below applicable exposure standards for residential development.
Remediated areas must be retested to assure potential contaminant levels are below
applicable residential standards. The results of any testing shall be provided to the C ity or
other agencies as appropriate . Any contaminated soil that must be removed from the site
shall be done by a licensed contractor and hauled to a landfill approved for such materials.
This measure shall be implemented to the satisfaction of the City Community Development
Department.
HAZ-2 ACMs and LBP Survey. Prior to demolition of any structures on the project site, the
developer shall retain qualified licensed environmental contractor(s) to survey the existing
onsite church building and any related structures for asbestos-containing materials (ACMs)
and Lead-Based Paints (LBPs). If the survey finds the presence of any ACMs or LBPs on
the site, the contractor(s) shall follow all relevant guidance from affected regulatory agencies
(e.g., CalEPA, SCAQMD, DTSC, County Health Department, etc.) in terms of safe removal
and disposal of the contaminated materials as appropriate. The contractor(s) shall prepare
and submit a final report to the City Community Development Department within 30 days
after completion of demolition/removal for ACMs and LBPs on the project site.
With implementation of Mitigation Measures HAZ-1 and HAZ-2, the proposed project would not create
a significant hazard to the public or the environment through reasonably foreseeable upset and accident
conditions involving the release of hazardous materials into the environment . With mitigation, project
impacts would be reduced to less than significant levels.
c) Less than Significant Impact. One school, Suva Elementary School, is located approximately
1,000 feet west of the project site. The project is residential in nature and would not emit hazardous
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 69
City of Downey
emissions or handle hazardous or acutely hazardous materials, substances, or waste . Therefore,
impacts are considered to be less than significant and no mitigation is required.
d) No Impact. The project is not located on a site listed on the state Cortese List, a compilation of
various sites throughout the state that have been compromised due to soil or groundwater
contamination from past uses.19 Based upon review of the Cortese List, the project site is not:
▪ listed as a hazardous waste and substance site by the Department of Toxic Substances Control
(DTSC),20
▪ listed as a leaking underground storage tank (LUFT) site by the State Water Resources Control
Board (SWRCB),21
▪ listed as a hazardous solid waste disposal site by the SWRCB,22
▪ currently subject to a Cease and Desist Order (CDO) or a Cleanup and Abatement Order (CAO)
as issued by the SWRCB,23 or
▪ developed with a hazardous waste facility subject to corrective action by the DTSC.24
Based on available evidence, n o impacts would occur in relation to hazardous material sites.
e) No Impact. The proposed project is not located within two miles of any public or private airport.25
The closest public or private airport facility to the project is the San Gabriel Valley Airport located
approximately 10 miles to the northeast of the site in the City of El Monte. No impact would occur with
regard to safety hazards or excessive airport noise.
f) Less Than Significant Impact. The City of Downey provides an emergency response plan and
emergency preplacement plan for residents and businesses in the City. The project site has direct
access to two local streets, Foster Bridge Road and Suva Street, although Suva Street provides east -
west connection through the northern part of the City and Bell Gardens to the west. The I -5 Freeway
(0.8-mile to the east) and the I-710 Freeway (1.8 miles to the west) provide regional access for the
project area. The proposed project does not propose or result in any permanent lane closures or
reconfiguration of existing streets. Therefore, the proposed project would not impair implementation of
or physically interfere with an adopted emergency response plan or emergency evacuation plan. As
such, a less than significant impact would occur.
g) No Impact. The proposed project is located in a completely urbanized area. The project site is not
located within a fire hazard zone, as identified on the latest Fire Hazard Severity Zone (FHSZ) maps
prepared by the California Department of Forestry and Fire Protection (CALFIRE).26 In addition, the
project is located in a Local Responsibility Area (LRA) and would be served by the City of Downey Fire
Department, and further supported by the Los Angeles County Fire Department s hould wildfires occur.
Therefore, the proposed project would not result in an increased fire threat to the community. The
project would not expose people or structures to a significant risk of loss, injury or death involving
wildland fires. Therefore, no impact would occur.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
70 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.10 Hydrology and Water Quality
Would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards
or waste discharge requirements or
otherwise substantially degrade
surface or ground water quality?
□ □ □
b) Substantially decrease groundwater
supplies or interfere substantially
with groundwater recharge such that
the project may impede sustainable
groundwater management of the
basin?
□ □ □
c) Substantially alter the existing
drainage pattern of the site or area,
including through the alteration of the
course of a stream or river or through
the addition of impervious surfaces,
in a manner which would:
i) result in substantial erosion or
siltation on- or off-site; □ □ □
ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on - or
off-site;
□ □ □
iii) create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or
□ □ □
iv) impede or redirect flood flows? □ □ □
d) In flood hazard, tsunami, or seiche
zones, risk release of pollutants due
to project inundation? □ □ □
e) Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 71
City of Downey
A Preliminary Low Impact Development (LID) Plan27 was prepared by Advanced Civil Group, Inc. dated
June 6, 2023 (Appendix F). The information in this section is largely taken from the LID Plan.
a) Less than Significant Impact. A project normally would have an impact on surface water quality if
discharges associated with the project would create pollution, contamination, or nuisance as defined in
Water Code Section 13050, or that cause regulatory standards to be violated as defined in the
applicable National Pollutant Discharge Elimination System (NPDES) stormwater permit or Water
Quality Control Plan for the receiving water body. A significant impact could occur if the p roposed project
would discharge water that does not meet th e quality standards of the agencies that regulate surface
water quality and water discharge into stormwater drainage systems. Significant impacts could also
occur if the project does not comply with all applicable regulations with regard to surface water q uality
as governed by the State Water Resources Control Board (SWRCB). These regulations include
preparation of a Stormwater Pollution Prevention Plan (SWPPP) to reduce potential water quality
impacts during construction activity (Downey Municipal Code Section 6.30.050) and the implementation
of post-construction best management practices (BMPs) such as detention basins, infiltration ponds,
porous pavement, sand and organic filters, etc. Long-term impacts are addressed by preparation of a
Low Impact Development (LID) Plan per the requirements of the County of Los Angeles National
Pollution Discharge Elimination Permit (Order No. R4 -2012-0175-A01) issued by the Los Angeles
Regional Water Quality Control Board (LARWQCB) under the NPDES.
Construction Impacts
Three general sources of potential short -term, construction-related stormwater pollution associated with
the project include: 1) the handling, storage, and disposal of construction materials containing
pollutants; 2) the maintenance and operation of constr uction equipment; and 3) earth-moving activities
which, when not controlled, may generate soil erosion via storm runoff or mechanical equipment. All
new development projects equal to one acre or more are subject to Los Angeles County NPDES Permit
No. CAS004001. The proposed project would disturb approximately 1.3 gross acres of land and
therefore would be subject to NPDES permit requirements during construction activities. In addition,
pursuant to Municipal Code Section 6.30.050, a Storm Water Pollution Prevention Plan (SWPPP) would
be prepared and submitted for the proposed project. All construction projects must apply Best
Management Practices (BMPs) that include drainage controls such as detention ponds, dikes, filter
berms, and down drains to prevent offsite runoff, and utilizing plastic covering to prevent erosion.
Compliance with City discharge requirements would ensure that construction of the project would not
violate any water quality standards or discharge requirements, or otherwise substantially degrade water
quality. The SWPPP and implementation of BMPs is considered regulatory compliance and not
mitigation under CEQA. With regulatory compliance, construction -related water quality impacts of the
project would be less than significant.
Operational Impacts
In addition, the proposed project would not generate hazardous wastewater that would require any
special waste discharge permits. All wastewater associated with the proposed interior plumbing
systems of the proposed townhomes would be discharged into the local sewer system for treatment at
the regional wastewater treatment plant.28 Impacts associated with operation of the proposed project
would be less than significant with implementation of existing regulations.
The LARWQCB has jurisdiction over this project site which is located in the Los Angeles River
watershed and the Rio Hondo sub -watershed (Rio Hondo Reaches 2 and 1) which flow into Los Angeles
River Reaches 2 and 1 before draining into the Pacific Ocean. Rio Hondo Reach 2 and Reach 1 are
not susceptible to hydromodification or any sediment related issues per latest State 303d list. Therefore,
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
72 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
the project is exempt from hydromodification requirements for any sediment related issues per latest
State 303d list.
A LID Plan was prepared for the project site using the County of Los Angeles Department of Public
Works Low Impact Development Standards Manual dated February 2014 . The LID Manual complies
with the requirements of the NPDES Municipal Separate Storm Sewer System (MS4) Permit for
stormwater and non-stormwater discharges from the MS4 within the coastal watersheds of Los Angeles
County (CAS004001, Order No. R4 - 2012-0175).
Construction of the proposed project would increase impervious areas on the project site from 78% to
87%. The approximately 1.22-net acre site would be redeveloped with 33 condominiums and associated
pavement, parking, and landscaping. Runoff from the developed site would result in increased potential
water contamination from urban pollutants that are commonly found in surface parking lots, ornamental
landscape planters and from atmospheric buildup on rooftops.
According to the LID Plan, the site drains to the southwest into existing storm down drains along Suva
Street which then drain southeasterly 0.1 mile into the City MS4 storm drainage system via the MTD
956 storm drain line into the Rio Hondo Channel. The Rio Hondo Channel then flows southwest to the
confluence with the Los Angeles River about 3 miles downstream. The Los Angeles River then flows
southerly 13 miles to the Pacific Ocean.
The proposed project will generally be drained via area drains as well as curb and gutter flows along
the drive isle and alleys of the property to drop inlet catch basins located in the southwest and northeast.
Storm water runoff flows will generally drain in a southwesterly direction towards Suva Street . The LID
Plan determined that post-development peak stormwater runoff discharge rates would be slightly higher
than the existing rate for the site. This slight increase in flow rate is attributed to the proposed increase
in impervious surfaces on the site that would occur as a result of the project.
The LID Plan indicates the developed condition of the site would have a Storm Water Quality Design
Volume (SWQDv) of 3,213 cubic feet (cf) which would need to be accommodated by BMPs designed
into the project plan. BMPs for the project were evaluated according to the hierarchy recommended in
the County LID Manual: from Infiltration; Bioretention; Rainfall Storage and Reuse; then finally to
Biofiltration. An infiltration BMP is feasible for the project so the other BMPs were not required. The LID
Plan treated runoff from the site as one Drainage Area.
Onsite runoff would be collected by an onsite storm drain system which would direct low flows to a deep
infiltration drywell (30 feet or greater in depth) and an underground storage system (USS, either pipes
or a chamber) located near the center of the property. The drywell and USS are designed to mitigate
discharge of untreated low flow runoff and the USS will help temporarily detain runoff so it can infiltrate
over time. According to the LIP Plan, the drywell and USS have been designed to detain and infiltrate
the SWQDv (3,213 cf) in accordance with County LID Design Manual requirements. Flows greater than
the SWQDv will bypass this system and will discharge directly to Suva Street via an under sidewalk
drain. All of the proposed drainage improvements will be installed and managed by the developer until
a homeowners association (HOA) can be formed for the condominiums that can take over the
maintenance responsibilities.
The project would be able to maintain runoff equal or less than the Los Angeles County allowable flow
rates so no adverse effects would occur to the downstream storm drain system. In addition, the
proposed BMP’s would satisfy the City’s water quality requirements which would reduce the post -
developed flow rates further as well as significantly reduce the pollutants generated from the project.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 73
City of Downey
With this project design and compliance with existing water quality regulations, impacts would be less
than significant and no mitigation is required.
b) Less than Significant Impact. If the project removes an existing groundwater recharge area or
substantially reduces runoff that results in groundwater recharge such that existing wells would no
longer be able to operate, a potentially significant impact could occur.
Project-related grading would not reach the depth of the groundwater table (estimated in the
Geotechnical Report as at least 50 feet and more likely 70 -80 feet below the ground surface). Therefore,
no direct disturbance of groundwater is anticipated.
The proposed building footprints and pavement areas would increase impervious surface coverage on
the site from 78% to 87%, thereby incrementally reducing the total amount of potential infiltration onsite.
However, infiltration of irrigation water through soil would ensure continued groundwater recharge in
Downey as impervious surfaces slowly increase over time. The project site is not utilized for
groundwater recharge and would consist of approximately 13% of landscaped areas or soft-bottom
surfaces that would allow for infiltration. Because this site is not managed for groundwater supplies and
would provide landscaped areas for continued infiltration, this change in infiltration would not have a
significant effect on groundwater table level. Groundwater impacts related to development of the
proposed project would therefore be less than significant and no mitigation is required.
c.i) Less than Significant Impact. Potentially significant impacts to the existing drainage pattern of
the site or area could occur if development of the project results in substantial on - or off-site erosion or
siltation. The site drains into a storm drain system that drains into the Rio Hondo Channel, then to Rio
Hondo that connects into the Los Angeles River Reach 2 and then Reach 1 and then to Pacific Ocean.
Rio Hondo Reach 2 and Reach 1 are currently listed in the federal Clean Water Act 303(d) list due to
impairment of cyanide, copper, lead, pH, toxicity, trash, zinc, and coliform bacteria.
The site is already developed with a church, parking lot, and landscaping. Construction of the proposed
project would slightly increase impervious areas on the project site (currently 78% to 87% for the project)
The approximately 1.3-acre site would be redeveloped with 33-unit townhouses and associated
pavement, parking, and landscaping. Runoff from the redeveloped site would result in increased
potential water contamination from urban pollutants that are commonly found in surface parking lots,
ornamental landscape planters and from atmospheric buildup on rooftops. Section 4.10.a above
describes the onsite drainage and water quality system planned for the center of the site. Runoff would
then drain into existing storm drains along Suva Street and Foster Bridge Boulevard.
The post-developed drainage pattern of the project site would generally maintain the existing drainage
patterns, with runoff ultimately discharging to the Rio Hondo Channel, the Los Angeles River, then finally
to the Pacific Ocean. Therefore, the drainage pattern would not be substantially altered in a manner
that could cause increases in erosion on - or off-site. Erosion and siltation reduction measures would be
implemented during construction through implementation of a SWPPP (see Section 4.10.a above).
At the completion of construction, the site would consist of impervious surfaces or improved landscaped
areas so it would therefore not be prone to substantial erosion. No streams cross the project site so the
project would not alter any stream course. Impacts would be less than significant and no mitigation is
required.
c.ii) Less than Significant Impact. As discussed in Section 4.10.c.i above, a river or stream does not
lie within the proposed project site. Additionally, the project would not lead to a substantial alteration of
existing drainage patterns in the area. The project site is located in Flood Zone X which is “an area
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
74 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
determined to be outside the 100 -year flood hazard area” according to the Federal Emergency
Management Agency (FEMA) Flood Insurance Rate Map (FIRM) Map Number 06037C1810F dated
September 26, 2008. Therefore, the project site has less than significant impacts related to flooding and
no mitigation is required.
c.iii) Less than Significant Impact. Construction of the proposed project would increase the net area
of impervious surfaces on the site so incremental increased discharges to the City’s existing storm drain
system would likely occur. However, an onsite storm drain catch basin system would direct runoff to a
drywell and underground storage system in the center of the site (see Section 4.10.a above). Storm
water from the site that is not captured would then drain south and east into storm drains along Suva
Street and Foster Bridge Boulevard, respectively.
The post-developed drainage pattern of the project site would generally maintain the existing drainage
patterns, with runoff ultimately discharging to the Pacific Ocean. Permits to connect to the existing storm
drainage system would be obtained prior to co nstruction. All drainage plans are subject to City review
and approval, and these requirements would apply to the proposed project. Therefore, project runoff is
not expected to impact local storm drain capacity. The proposed residential use does not have t he
potential to generate significant amounts of polluted runoff and therefore would not result in substantial
pollutant loading such that treatment control BMPs would be required to protect downstream water
quality. Post-construction Infiltration BMP’s would also ensure the project would not result in substantial
pollutant loading. Therefore, impacts related to the proposed project would be less than significant and
no mitigation is required.
c.iv) No Impact. As discussed in Section 4.10.c.i above, the flood maps prepared by the Federal
Emergency Management Agency show the project site is located in Zone X, which is an area
determined to be outside the 100 -year flood hazard area.29 Therefore, the project is not located within
a 100-year flood floodplain and would not impede or redirect flood flows. Impacts would be less than
significant.
d) Less than Significant Impact. As discussed in Section 4.10.c.iv above, the project site is not
located within a 100-year flood floodplain so no direct flooding impacts would occur. The project site is
also not subject to tsunami due to its elevation (minimum 133 feet above mean sea level) and distance
from the ocean (17.1 miles to the southwest and 14.5 miles to the south).
As noted in Section 4.7.iv, the project site has not been identified in an area susceptible to landslides,
thus the potential for mudflow is relatively low because the project does not lie in a landslide hazard
zone.
The Safety Element of the City’s 2005 General Plan (“Downey Vision 2025”) does not identify any
specific upstream reservoirs or water impoundments whose failure could result in inundation of the site.
GP Goal 5.6 is to “minimize potential adverse impacts from flooding” and GP Policy is to “protect life
and property from flooding hazards”. To that end, GP Program 5.6.1.3 encourages the City to “Mitigate
hazards from possible dam or levee failure, including the raising of bridges and levees along rivers,
including in areas outside the City”.
A major earthquake could create a seiche, or a standing seismic wave, in bodies of water, and the
violent movement of water could cause a dam or levee to fail catastrophically. The only large upstream
body of water is the Santa Fe Dam basin in the City of Montebello. The project is located approximately
14 miles southwest and downstream of the Santa Fe Dam along the Rio Hondo Channel.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 75
City of Downey
According to the California Dam Breach Inundation Map website30, even if the Santa Fe basin were full
at the time of a large earthquake or other event that caused a dam failure, flood waters down the Rio
Hondo Channel would not be expected to reach the City of Downey or the project site.
The Los Angeles County Public Works Department operates and maintains a state -of-the-art ALERT
computer system to monitor meteorological conditions in the County and Southern California in real
time, i.e., as they occur. The system includes a network of fi eld sensors that monitor and receive
precipitation amounts including rainfall data from the Corps of Engineers' Los Angeles Telemetry
System. These systems allow for system level real time checks that provide for emergency
management planning. The City of Downey likewise operates an Emergency Management system in
the event of dam failures. The proposed project does not include modifications to a dam system or
levees that would alter the hazard planning completed by the City of Downey. With adherence to existing
policies, regulations, and ord inances, the proposed project would have a less than significant impact
related to dam or levee failures and no mitigation is required.
e) Less than Significant Impact. The LARWQCB’s Basin Plan is designed to preserve and enhance
surface and groundwater quality and protect the beneficial uses of all regional waters. Specifically, the
Basin Plan: (i) designates beneficial uses for surface and ground waters, (ii) sets narrative and
numerical objectives that must be attained or maintained to protect the designated beneficial uses and
conform to the state's anti-degradation policy, and (iii) describe s implementation programs to protect all
waters in the region. Development of the project would be required to adhere to requirements of the
water quality control plan, including all existing regulation and permitting requirements. This would
include the incorporation of best management practices (BMPs) to protect water quality during
construction and operational periods. Development of the project would also be subject to all existing
water quality regulations and programs, including all applicable construction permits. Existing General
Plan policies related to water quality would also be applicable to the project. Impleme ntation of these
policies, in conjunction with compliance with existing regulatory programs, would ensure that surface
and groundwater quality impacts related to the project would be less than significant.
The City’s water supply is primarily extracted from the Central (groundwater) Basin which is a sub -basin
of the Coastal Plain of Los Angeles pursuant to DWR Bulletin 118, Basin Number 4 -11.04. Pursuant to
the Sustainable Groundwater Management Act of 2014 (SGMA), the Central Basin was named as an
adjudicated groundwater basin and is exempt from the requirements of developing a Groundwater
Sustainability Plan and subsequently was designated a very -low-priority basin in DWR’s 2019 SGMA
Basin Prioritization report. In compliance with SGMA, the Central Basin Watermaster (which is the
Water Replenishment District of Southern California and the Central Basin Water Rights Panel) submits
its Annual Report to DWR. Therefore, the project would not affect the quality o r quantity of groundwater
or its management. Impact would be less than significant and no mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
76 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.11 – Land Use and Planning
a) No Impact. The project site is currently developed with a church and its parking lot. There are single
family residences to the north (adjacent) and east (across Foster Bridge Boulevard), a self-storage
facility adjacent to the west, and apartments to the southwest across Suva Street. The project will be a
gated townhouse community so surrounding residents would not be able to walk through the property
as they can at present. However, there are sidewalks on both sides of Foster Bridge Boulevard and
Suva Street so local residents will still have access to the surrounding neighborhoods if needed or
desired. Therefore, the new land use would not physically divide the existing commun ity. In addition,
the project does not involve construction of any roadway, flood control channel, or other structure that
would physically divide any portion of the community. Therefore, no impact would occur.
b) Less than Significant Impact. The two primary land use plans that apply to the project site, and
that can avoid environmental effects of land development, are the City General Plan and zoning code.
The Land Use Element of the City’s General Plan indicates the project site currently has a land use
designation of Low Density Residential (LDR) which allows up to 8.9 units/acre. The project is
requesting a General Plan Amendment to change the site’s land use designation to Medium Density
Residential (MDR) which allows up to 24 units/acre. The density of the proposed project is 20.6 units
per gross acre. Similarly, the City of Downey Municipal Code (CDMC) zoning regulations designate the
project site as R-1 6,000 which is a single-family detached residential designation. The project proposes
to change the site’s zoning designation to Multi -Family Residential Ownership Zone (R-3-0). It should
be noted the site is currently developed with a church and its parking lot which are allowed uses within
the residential land use categories of the General Plan and residential zoning districts.
The density of the project as proposed is 20.6 units per gross acre while the R -3-O zone allows up to
approximately 22 units/acre. According to the City Zoning Code, the R -3-O zone is intended to provide
“for the development of multiple -family ownership type housing in selected areas compatible with the
neighborhood environment. The Zoning Code states…”such areas are intended to be complementary
with adjacent uses and provide sufficient opportunities for ownership in multiple -family housing”. The
project is also consistent with the development standards of the adjacent residential categories/zones
(e.g., height, setbacks, etc.). The project also does not include any features that would circumvent any
mitigating policies in the Downey General Plan , as outlined in other sections of this IS/MND. Since the
proposed use is considered to be compatible with surrounding uses under the General Plan and zoning,
Would the project:
Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Physically divide an established
community? □ □ □
b) Cause a significant environmental
impact due to a conflict with any
applicable land use plan, policy, or
regulation adopted for the purpose of
avoiding or mitigating an
environmental effect?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 77
City of Downey
the proposed project is not expected to result in any significant land use impacts and no mitigation is
required.
4.12 – Mineral Resources
Would the project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Result in the loss of availability of a
known mineral resource that would
be of value to the region and the
residents of the state?
□ □ □
b) Result in the loss of availability of a
locally-important mineral resource
recovery site delineated on a local
general plan, specific plan or other
land use plan?
□ □ □
a) No Impact. The project site is in a completely urbanized area within the City of Downey. According
to the California Department of Conservation, Division of Mines and Geology Resources, no known
mineral resources exist in the City of Downey.31 No loss of availability of a known mineral resource
would occur. Therefore, no impact would occur.
b) No Impact. The project site is located in a completely urbanized area within the City of Downey.
There are no mineral extraction or process facilities on or near the site.32 No mineral resources are
known to exist within the vicinity of the project site. No known mineral resources have been identified
by the Downey General Plan EIR or in any other plan. Therefore, no impact would occur.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
78 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.13 – Noise
Would the Project result in:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generation of a substantial
temporary or permanent in ambient
noise levels in the vicinity of the
project in excess of standards
established in the local general plan
or noise ordinance, or applicable
standards of other agencies?
□ □ □
b) Generation of excessive
groundborne vibration or
groundborne noise levels? □ □ □
c) For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where such
a plan has not been adopted, within
two miles of a public airport or public
use airport, would the Project expose
people residing or working in the
Project area to excessive noise
levels?
□ □ □
A Noise and Vibration Analysis33 was prepared for the proposed project by MIG, dated September 22,
2023 (Appendix D). The information in this section is based on that Noise Study (MIG 2023b).
Existing Noise Environment
The proposed project is located in northern Downey, in an area classified and designated as Residential
(R-1) by the City’s Zoning Code and Low Density Residential by the Land Use Chapter of the City’s
General Plan. The City’s General Plan identifies vehicular traffic, aircraft overflights, and trains as the
dominant noise sources in the City. The existing noise environment in the project vicinity consists
primarily of vehicles along Foster Bridge Boulevard and Suva Street, overhead air traffic, construction
power tools, and residential noises such as stereos and pedestrians.
Ambient noise monitoring was conducted on the project site including one long-term and two short-term
measurement locations. The long-term monitoring was conducted near the center of the site while the
short-term monitoring was conducted along the northern boundary and the northeast boundary of the
site to effectively characterize ambient noise levels near the closest existing residential uses (i.e., to the
north and northeast). Typical ambient noise levels at the project site ranged from approximately 55 to
60 dBA during the daytime and 47 to 57 dBA during the evening and nighttime. It should be noted the
project site is not located within any airport planning boundaries or proximate to any private airport
facilities.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 79
City of Downey
Sensitive Receptors
Some people are especially sensitive to noise and are given special consideration when evaluating
noise impacts from projects. These groups of people include children, the elderly, and individuals with
hearing impairments or unusual sensitivity to noise . Structures that house these persons or places
where they gather are defined as “sensitive receptors”. Noise sensitive receptors are buildings or areas
where unwanted sound or increases in sound may have an adverse effect on people or land uses.
Residential areas, hospitals, schools, and parks are examples of noise receptors that could be sensitive
to changes in existing environmental noise levels. Sensitive single-family residential receptors could be
within 25 feet of work areas for short periods of time (e.g., site grading along the north property
boundary), at which distance construction equipment may reach 89 dBA Leq. Project construction in
the middle of the site would be at least 100 feet from sensitive single-family residential receptors to the
north (adjacent to the site) and east (across Foster Bridge Boulevard) as well as the multi-family
residential complex to the south (across Suva Street).
Regulatory Setting
The City’s Municipal Code and General Plan Safety Element establish the following standards
applicable to construction noise, operational noise, and noise/land use compatibility.
▪ Construction Noise: Municipal Code Section 4606.5 exempts construction, repair or
remodeling equipment and devices and other related construction noise sources shall be
exempted from the provisions of this chapter provided a valid permit for such construction,
repair, or remodeling shall have been obtained from the City. In any circumstance other than
emergency work, no repair or remodeling shall take place between the hours of 9:00 p.m. of
one day and 7:00 a.m. of the following day, and no repair or remode ling shall exceed eighty-
five (85) db(A) across any property boundary at any time during the course of a twenty -four
(24) hour day.
▪ Operational Noise: Municipal Code Section 4606.3 Subsection (b) states that if the alleged
noise source is of a continuous nature and cannot reasonably be discontinued for a time
period wherein the ambient noise level can be determined, the maximum permissible steady
noise level by sound sources across the property boundary of any land use cited below may
be less, but not greater than (for residential land use):
o Daytime (7:00 AM – 10:00 PM): 55 dBA Leq
o Nighttime (10:00 PM – 7:00 AM): 45 dBA Leq
Municipal Code Section 4606.3 adjusts these standards in the hours between 7:00 a.m. to 10:00 p.m.,
the noise levels permitted in Subsection (b) of this section may be adjusted by the inclusion of the
following factors when applicable:
o Noise source operated 12 minutes per hour or less + 5 db(A)
o Noise source operated 3 minutes per hour or less + 10 db(A)
o Noise source operated 1 minute per hour or less + 15 db(A)
▪ Noise/Land Use Compatibility: The City’s General Plan Noise Chapter establishes a noise
land use compatibility goal for residential uses of 60 CNEL.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
80 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
a) Less Than Significant with Mitigation Incorporated. The proposed project would generate noise
during construction and operation of the proposed facilities. The following analysis evaluates if the
project would:
▪ Generate a substantial temporary or permanent increase in ambient noise levels in the
vicinity of the project in excess of the standards established in:
o City of Downey Municipal Code Section 4606.3 (Maximum Permissible Noise Levels by
Sound Sources Across Property Boundaries) or Section 4606.5 (Construction Projects); or
o The City of Downey General Plan; or
▪ Generate excessive groundborne vibration or groundborne noise levels; or
▪ Expose people residing or working in the project area to excessive airport-related noise
levels.
An analysis of these potential project noise impacts is provided below.
Short-Term Construction Noise
The proposed project involves construction activities including demolition, site preparation, grading,
building construction, paving and architectural coating in an existing residential area of the City.
Construction activities are anticipated to begin early -2024 and may last approximately 12 months in
total. In general, construction activities would involve the use of worker vehicles, delivery trucks, dump
trucks, and heavy-duty construction equipment such as (but not limited to) backhoes, tractors, loaders,
graders, excavators, rollers, cranes, material lifts, generators, and air compressors. These types of
construction activities would generate noise and vibration from the following sources:
▪ Heavy equipment operations at different work areas. Some heavy equipment would consist
of mobile equipment such as a loader and excavator that would move around work areas;
other equipment would consist of stationary equipment (e.g., cranes or material hoi sts/lifts)
that would generally operate in a fixed location until work activities are complete. Heavy
equipment generates noise from engine operation, mechanical systems, and components
(e.g., fans, gears, propulsion of wheels or tracks), and other sources such as back-up
alarms. Mobile equipment generally operates at different loads, or power outputs, and
produces higher or lower noise levels depending on the operating load. Stationary
equipment generally operates at a steady power output that produces a constant noise level.
▪ Vehicle trips, including worker, vendor, and haul truck trips. These trips would occur on Suva
Street and Foster Bridge Boulevard and other local roads used to access the site.
Typical construction equipment noise levels at different distances are shown in Table 4 .13-1 (Potential
Project Construction Equipment Noise Levels ). With regard to construction noise, demolition, site
preparation, and grading phases typically result in the highest temporary noise levels due to the use of
heavy-duty equipment such as dozers, excavators, graders, loaders, and trucks. Construction noise
impacts generally occur when construction activities occur in areas immediately adjoining noise
sensitive land uses, during noise sensitive times of the day, or when construction durations last over
extended periods of time.
Construction activities associated with the proposed project would last approximately 12 months.
Construction activities would occur in close proximity to the adjacent residential property north of the
project site and to the residential properties east of the site across Foster Bridge Boulevard. As shown
in Table 4.13-1, worst case hourly construction equipment noise levels are predicted to be
approximately 83 dBA Leq and 90 dBA Lmax, respectively, at 50 feet; however, the magnitude of the
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 81
City of Downey
project’s temporary and periodic increase in ambient noise levels would depend on the nature of the
construction activity (i.e., demolition, building construction, grading) and the distance between the
construction activity and sensitive receptors/outdoor use areas.
Sensitive residential receptors could be within 25 feet of work areas for short periods of time (e.g., site
grading along the property boundary), at which distance construction equipment may reach 89 dBA
Leq. Project construction in the middle of the site would be at least 100 feet from sensitive receptors to
the north and east. At this distance (100 feet), equipment could reach 77 dBA Leq. The concurrent
operation of a dozer, backhoe, and delivery truck at the same time and in the same general area could
produce a combined noise level of approximately 80 dBA Leq on a short -term basis (less than an hour)
at 100 feet.
Table 4.13-1
Potential Project Construction Equipment Noise Levels
Typical
Equipment
Noise
Level at
50 feet
(Lmax)(A)
Percent
Usage
Factor(B)
Predicted Equipment Noise Levels (Leq)(C)
25
Feet
50
Feet
75
Feet
100
Feet
150
Feet
200
Feet
250
Feet
Bulldozer 85 40 87 81 77 75 71 69 67
Backhoe 80 40 82 76 72 70 66 64 62
Compact Roller 80 20 79 73 69 67 63 61 59
Concrete Mixer 85 40 87 81 77 75 71 69 67
Concrete Saw 90 20 89 83 79 77 73 71 69
Crane 85 16 83 77 74 71 67 65 63
Delivery Truck 84 40 86 80 76 74 70 68 66
Generator 82 50 85 79 75 73 69 67 65
Grader 85 40 87 81 77 75 71 69 67
Paver 85 50 88 82 78 76 72 70 68
Sources: Table 4, MIG 2023b, Caltrans, 2013 and FHWA, 2010.
(A) Lmax noise levels based on manufacturer’s specifications.
(B) Usage factor refers to the amount (percent) of time the equipment produces noise over the time period
(C) Estimate does not account for any atmospheric or ground attenuation factors. Calculated noise levels based
on Caltrans, 2013: Leq (hourly) = Lmax at 50 feet – 20log (D/50) + 10log (UF), where: Lmax = reference Lmax from
manufacturer or other source; D = distance of interest; UF = usage fraction or fraction of time period of interest
equipment is in use.
Although project construction may temporarily increase noise levels near the site, it is not anticipated
to result in physical harm (e.g., temporary or permanent hearing loss or damage) to any sensitive noise
receptor because receptors would not be continuously expo sed to elevated construction noise levels
(i.e., noise levels would return to ambient conditions when construction ceases for the day) and the
construction noise levels presented above are exterior noise levels, whereas receptors would be likely
to be inside buildings. Residential construction in California typically provides at least 12 dBA of exterior
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
82 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
to interior noise attenuation with windows open and 20 dBA of exterior to interior noise attenuation with
windows closediii.
Physiological effects occur when the human ear is subjected to prolonged exposure to high noise
environments. For example, to protect workers from noise -induced hearing loss, the U.S. Occupational
Safety and Health Administration (OSHA) limits worker noise exposure to 90 dBA as averaged over an
8-hour time period (29 CFR 1910.95). Similarly, the National Institute for Occupational Safety and
Health (NIOSH) recommends workers limit noise exposure to no more than 85 dBA over an 8 -hour
period to protect against noise-induced hearing loss (NIOSH, 1998).
As shown in Table 4.13-1, potential worst-case hourly noise level estimates for any single piece of
equipment would be approximately 89 dBA L eq at 25 feet and 77 dBA Leq at 100 feet. Although hourly
construction noise levels may approach 89 dBA Leq for one or two hours, such noise levels would not
be sustained over an 8 -hour period (due to movement of equipment and changes in operations that
occur during daily construction activities). Therefore, at worst -case, noise from construction activities
may pose a temporary interference or annoyance effect on nearby sensitive receptors but would not
result in adverse physiological effects on human receptors in the surrounding area.
The City’s Municipal Code (Section 4606.5) limits construction activities to the hours of 7 AM to 9 PM
and establishes that construction noise shall not exceed 85 dBA across any property boundary at any
time of day. As discussed above, the project’s potential construction noise levels would range from
approximately 77 dBA L eq to 89 dBA Leq depending on the specific equipment in use and the distance
between the equipment and adjacent residential properties. Since the proposed project has the potential
to exceed the City’s construction noise limit established in the CDMC, Mitigation Measures NOI-1
through NOI-5 are required to reduce construction noise to less than significant levels.
These five mitigation measures would provide advanced notice of construction activities to surrounding
residential properties, limit construction hours per City Municipal Code requirements, limit noise from
stationary and other construction equipment, and reduce temporary construction no ise impacts by a
minimum of 5 to 10 dBs, which would lower the project’s potential construction noise levels at nearby
residential property lines to less than 85 dBA L eq as required by the City’s Municipal Code. The proposed
project would comply with the City’s applicable construction noise control provisions and implement
other mitigation measures to reduce the potential for project construction activities to result in a
substantial temporary increase in ambient noise levels. With implementation of these measures,
potential construction-related noise impacts on nearby sensitive receptors will be reduced to less than
significant levels.
Long-term Operational Noise
Project Operation (Onsite Noise Sources)
The project site and surrounding properties are all designated Residential (R-1, 6,000 square feet
minimum lot size) by the City’s zoning code. Municipal Code Section 4606.3 establishes the maximum
permissible noise level that may intrude into adjacent property lines. The code establishes maximum
permissible noise levels for residential land uses of 55 dBA L eq for daytime hours (7:00 AM to 10:00
PM) and 45 dBA Leq for nighttime hours (10:00 PM – 7:00 AM). The existing daytime ambient noise
iii The U.S. Department of Housing and Urban Development (HUD) Noise Guidebook and supplement (2009a, 2009b) includes information
on noise attenuation provided by building materials and different construction techniques. As a reference, a standard exterio r wall
consisting of 5/8-inch siding, wall sheathing, fiberglass insulation, two by four wall studs on 16 -inch centers, and 1/2-inch gypsum wall
board with single strength windows provides approximately 35 dBs of attenuation between exterior and interior noise l evels, provided
windows do not occupy more than 30% of the exterior wall space.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 83
City of Downey
levels at the project site ranged from 55.8 to 58.9 dBA L eq, which is above the City’s permissible daytime
noise levels (55 dBA L eq). Nighttime (10 PM to 7 AM) ambient noise levels ranged from 47.2 to 57.2
dBA, which are all above the City’s permissible nighttime noise level (45 dBA L eq).
The existing residential land uses at and near the site generate noise from vehicle parking activities,
waste collection activities, landscaping activities, stationary heating, ventilation, and air conditioning
(HVAC) equipment, and, for the existing use of the project site, religious service and education activities
(e.g., community masses, after-school gatherings, etc.). The proposed project would involve similar
noise generating sources and activities as the existing land uses; however, the amount of mechanical
equipment and the intensity of parking would be greater than existing land uses on the site.
Although the proposed project could increase the amount of noise sources and noise -generating
activities compared to existing conditions, the project would have a limited potential to generate
significant on-site noise levels. In general, residential land uses (including the proposed multi -family
townhome land uses) are not a substantial noise-generating land use because they do not involve
substantial noise-generating activities during the nighttime, mechanical equipment associated with
garage door openers, residential amenities, and other building systems are typically enclos ed within
closets, sheds, and/or equipment rooms, and HVAC equipment is typically screened from public view
by landscaping, fences, or walls and, therefore, shielded from adjacent propert ies.
Once constructed, the proposed project’s primary on-site noise generating activities will be parking,
human activity, and HVAC equipment. The site design indicates each unit would have two garage
parking spaces. Circulation onsite would provide access to Foster Bridge Boulevard on the no rtheastern
part of the site and Suva Street on the south part of the site. Onsite vehicle travel would occur at very
ow speeds and thus would not produce significantly high noise levels.
The project’s small ground level HVAC units would be rated to condition individual townhome spaces
that would be approximately 1,100 to 1,800 square feet in size. Small, individual residential HVAC units
can produce a noise level up to 75 dBA at a distance of 3 feet. At their closest, these HVAC units would
be approximately 6 feet from the eastern and western property lines. The project would also include a
six-foot-tall concrete masonry unit wall along the western and northern perimeter. Based on distance
and the six-foot barrier, uncontrolled HVAC noise levels would be approximately 11 dBA lower due to
attenuation at the adjacent commercial property line on the western part of the site, which would reduce
HVAC noise to levels be below the City’s noise limit of 65 dBA for commercial land uses. The project
would not include any HVAC units facing the northern property line. Nonetheless , the six-foot barrier
would provide approximately 5 dBA of noise attenuation for this receptor. Residential land uses to the
east of the project site are at least 50 feet from any HVAC units facing the eastern side of the site and
also contain a six-foot-tall perimeter wall that would limit HVAC noise transmission into these properties.
In addition, HVAC equipment does not operate continuously and would not affect ambient noise levels
when the equipment is not in use. For these reasons, potential HVAC equipment would not generate
noise levels in excess of the City’s 45 dBA L eq nighttime noise standard at any shared residential
property line, or otherwise result in a substantial permanent increase in ambient noise levels in the
vicinity of the project.
The proposed project would also include an approximately 192 square foot pet station open area in the
northwestern portion of the site. This area would be shielded by the six -foot barrier along the western
and northern sections of the site perimeter, providing approxima tely 5 dBA of noise attenuation for the
adjacent residential receptor to the north of the site. This area would generate similar noise levels to
other nearby existing residential land uses, and thus would not substantially increase ambient noise
levels in the vicinity of the project.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
84 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
For the reasons outlined above, the proposed project would not generate onsite noise levels that exceed
City standards or otherwise result in a substantial permanent increase in ambient noise levels in the
vicinity of the project. This impact would be less than significant and no mitigation is required.
Project Operation (Off-Site Vehicle Trip Noise)
The Project Traffic and Circulation Analysis Scoping Agreement indicates the proposed project will
result in a net increase of 158 daily vehicle trips (Ganddini Group, 2023). In general, it takes a doubling
of traffic to increase traffic noise volumes by 3 dBA (Caltrans, 2013). Although the current average daily
traffic volume on Foster Bridge Boulevard is not known, the area surrounding the project site is
developed with residential land uses and traffic volumes on Foster Bridge Boulevard and other
roadways used to access the project site are assumed to be at least 1,000 vehicle trips per day. The
addition of 158 passenger cars to the roadway system would not result in a doubling of traffic on any
roadway segment at or in the vicinity of the project site and, therefore, would result in a less than 3 dBA
increase in noise levels on local roads used to access the project site. The proposed project would
therefore not result in a substantial, permanent increase in noise levels along the roadways used to
access the proposed project as compared to existing or future conditions. This impact would be less
than significant and no mitigation is required.
Other Planning Considerations (Noise / Land Use Compatibility)
In 2015, the California Supreme Court in California Building Industry Association v. Bay Area Air Quality
Management District, 62 Cal.4th 369 ruled that CEQA review is focused on a project’s impact on the
environment “and not the environment’s impact on the project.” Per this ruling, a Lead Agency is not
required to analyze how existing conditions might impact a project’s existing or future population except
where specifically required by CEQA . However, a Lead Agency may elect to disclose information
relevant to a project even if it not is considered an impact under CEQA. Furthermore, the City’s General
Plan sets noise standards for receiving land uses which require evaluation for consistency and
compliance even if such evaluation is not required by CEQA to be identified as a physical impact of a
project.
The City’s General Plan Noise Chapter establishes a noise and land use compatibility goal for
residential uses of 60 dBA CNEL. Noise monitoring conducted at the project site indicates daytime
hourly ambient noise levels at the site ranged from approximately 55 to 60 dBA L eq. The long-term
ambient noise data indicated a CNEL of 60.9 dBA, which would exceed the City’s General Plan
acceptable noise levels for residential land use. However, the proposed project would have noise levels
less than 70 dBA, which is within the “conditionally acceptable” range for a residential land use.
The City’s General Plan Noise Chapter states that in order for new construction or development to be
conditionally acceptable, noise insulation features such as conventional construction with closed
windows and fresh air supply systems or air conditioning need to be included in the design. As
mentioned previously, the proposed project would include HVAC units for each individual townhome
unit. Typical building construction provides an exterior-to-interior noise reduction of approximately 12
dBA with windows open and approximately 20 dBA with windows closed. iv With windows closed, interior
noise levels would be approximately 40.9 dBA, which is less than the interior acceptable noise level (45
dBA) for residential land use. Daily noise exposure at the project is, therefore, considered to be within
the City’s noise and land use compatibility conditionally acceptable level of 70 CNEL. In addition, interior
iv The U.S. Department of Housing and Urban Development (HUD) Noise Guidebook and supplement (2009a, 2009b) includes information
on noise attenuation provided by building materials and different construction techniques. As a reference, a standard exterio r wall consisting
of 5/8-inch siding, wall sheathing, fiberglass insulation, two by four wall studs on 16 -inch centers, and 1/2-inch gypsum wall board with single
strength windows provides approximately 35 dBs of attenuation between exterior and interior noise levels. Increasing window space may also
decrease attenuation, with a reduction of 10 dBs possible if windows occupy 30% of the exterior wall façade.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 85
City of Downey
noise exposure would be less than 45 CNEL with windows closed and use of the project’s HVAC
system. Therefore, the proposed project is considered compatible with the exterior ambient noise
environment in the project area and no exterior or interior noise design features are required to protect
project residents from significant noise impacts.
Cumulative Impacts
The Noise Study determined that project noise impacts during construction (with mitigation) and
operation (without mitigation) would be less than significant (i.e., within City standards). Surrounding
cities and the County have similar types of noise stand ards, and new development projects are required
to document their potential offsite noise impacts and, if they are significant, to mitigate those impacts to
less than significant levels (i.e., to within the locally established standards). Like the City of Downey,
the surrounding communities have similar requirements to review impacts and mitigate when necessary
under CEQA. It should also be noted that the ambient noise levels in many of these communities already
exceed their established noise standards. As long as the City continues to require an evaluation of
impacts and mitigation when necessary under CEQA, it is not expected that this project will make a
significant contribution to cumulatively considerable noise impacts in the surrounding region, and no
mitigation other than the recommended project level mitigation is required.
Conclusion
As detailed above, the proposed project would not generate temporary or permanent noise levels that
would exceed the City’s standards or otherwise result in a substantial increase in ambient noise levels
with the incorporation of mitigation measures. The refore, the proposed project would not result in a
substantial, adverse noise -related effect on the environment, including cumulative impacts. With
implementation of the recommended mitigation for construction activities, noise -related impacts of the
project will be less than significant.
b) Less Than Significant Impact. Vibration is the movement of particles within a medium or object
such as the ground or a building. Vibration sources are usually characterized as continuous, such as
factory machinery, or transient, such as explosions. As is the case with airborne sound, g roundborne
vibrations may be described by amplitude and frequency; however, unlike airborne sound, there is no
standard way of measuring and reporting amplitude. Vibration amplitudes can be expressed in terms of
velocity (inches per second) or discussed in dB units in order to compress the range of numbers
required to describe vibration. Vibration impacts to buildings are usually discussed in terms of peak
particle velocity (PPV) in inches per second (in/sec). PPV represents the maximum instantaneous
positive or negative peak of a vibration signal and is most appropriate for evaluating the potential for
building damage. Vibration can impact people, structures, and sensitive equipment. The primary
concern related to vibration and people is the potential to an noy those working and residing in the area.
Vibration with high enough amplitudes can damage structures (such as crack plaster or destroy
windows). Groundborne vibration can also disrupt the use of sensitive medical and scientific
instruments, such as electron microscopes. Groundborne noise is noise generated by vibrating building
surfaces such as floors, walls, and ceilings that radiate noise inside buildings subjected to an external
source of vibration. The vibration level, the acoustic radiation of the v ibrating element, and the acoustical
absorption of the room are all factors that affect potential groundborne noise generation.
Caltrans’ Transportation and Construction Vibration Guidance Manual provides a summary of vibration
human responses and structural damage criteria that have been reported by researchers,
organizations, and governmental agencies. These thresholds are summar ized in Table 4.13-2
(Caltrans’ Vibration Threshold Criteria for Building Damage ), and Table 4.13-3 (Caltrans’ Vibration
Threshold Criteria for Human Response ).
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
86 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Table 4.13-2
Caltrans’ Vibration Criteria for Building Damage
Structural Integrity
Maximum PPV (in/sec)
Transient Continuous
Historic and some older buildings 0.50 0.12 to 0.2
Older residential structures 0.50 0.30
New residential structures 1.00 0.50
Modern industrial and commercial structures 2.00 0.50
Source: Table 5, MIG 2023b, Caltrans, 2020
Table 4.13-3
Vibration Criteria for Human Response
Human Response
Maximum PPV (in/sec)
Transient Continuous
Slightly perceptible 0.035 0.012
Distinctly perceptible 0.24 0.035
Strongly perceptible 0.90 0.10
Severe/Disturbing 2.0 0.7 (at 2 Hz) to 0.17 (at 20 Hz)
Very disturbing -- 3.6 (at 2 Hz) to 0.4 (at 20 Hz)
Source: Table 6, MIG 2023b, Caltrans, 2020
Construction activities have the potential to result in varying degrees of ground vibration, depending on
the specific construction equipment used and activities involved. Vibration generated by construction
equipment spreads through the ground and diminishes with increases in distance. The effects of ground
vibration may be imperceptible at low levels, result in low rumbling sounds and detectable vibrations at
moderate levels and can disturb human activities such as sleep and vibration sensitive equipment at
high levels.
Ground vibration can also potentially damage the foundations and exteriors of existing structures even
if it does not result in a negative human response. Pile drivers and other pieces of high impact
construction equipment are generally the primary cause o f construction-related vibration impacts. The
use of such equipment is generally limited to sites where there are extensive layers of very hard
materials (e.g., compacted soils, bedrock) that must be loosened and/or penetrated to achieve grading
and foundation design requirements. The need for such methods is usually determined through site -
specific geotechnical investigations that identify the subsurface materials within the grading envelope,
along with foundation design recommendations and the constructio n methods needed to safely permit
development of a site. Pile driving equipment is not anticipated to be required at the proposed project
site.
Construction vibration impacts generally occur when construction activities occur in close proximity to
buildings and vibration -sensitive areas, during evening or nighttime hours, or when construction
activities last extended periods of time. Although pote ntial heavy equipment operations at the site for
all demolition, site preparation, grading, and paving activities would not last more than approximately
45 days, construction activities would occur in close proximity to an adjacent residential property to the
north. The ground-borne vibration levels generated by the type of equipment that would be used to
construct the proposed project are shown in Table 4.13-4 (Potential Project Construction Vibration
Levels).
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 87
City of Downey
Table 4.13-4
Potential Project Construction Vibration Levels
Equipment
Peak Particle Velocity (in/sec) (A)
25 feet 50 feet 100 feet 200 feet
Small bulldozer 0.003 0.001 0.001 0.000
Jackhammer 0.035 0.016 0.008 0.004
Loaded truck 0.076 0.035 0.017 0.008
Large bulldozer 0.089 0.042 0.019 0.009
Vibratory Roller 0.21 0.098 0.046 0.021
Sources: Table 7, MIG 2023b, Caltrans, 2020 and FTA, 2018
(A) Estimated PPV calculated as: PPV(D)=PPV(ref)*(25/D)^1.1 where PPV(D)= Estimated PPV at distance;
PPVref= Reference PPV at 25 ft; D= Distance from equipment to receiver; and n= ground attenuation
rate (1.1 for dense compacted hard soils).
As shown in Table 4.13-4, the vibration levels associated with typical construction equipment are
dependent on the type of equipment used. For structural damage, the use of typical equipment during
construction activities (e.g., bulldozer, jack hammer, trucks etc.) would produce PPV levels up to 0.098
in/sec at 50 feet. These PPV values are well below Caltrans’ guidelines standards for potential structural
damage for the types of buildings in and adjacent to the Plan Area, which consist of modern residential
structures (0.5 PPV for continuous vibration sources , see Table 4.13-2). For human annoyance and
interference responses, the use of typical equipment (e.g., bulldozer, jack hammer, trucks, etc.) during
construction could produce vibration levels near the project site (within 50 feet) that exceed Caltrans’
perceptible vibration detection threshold (0.012 PPV, see Table 4.13-3). Specific vibration-generating
equipment, such as vibratory rollers which may be used during paving activities, could produce vibration
levels at 50 feet that would be more pronounced and perceptible but still below Caltrans’ guidelines for
structural damage to modern residential structures (0.50 PPV for continuous vibra tion sources).
The above vibration estimates represent potential vibration levels based on typical equipment
operations and assume there is no change in elevation between work areas and receptor locations and
no change in subsurface conditions that may affect vibration t ransmission through soil media and
structures. As discussed above, the proposed project does not have the potential to result in structural
damage to buildings near work areas; however, construction -related groundborne vibrations have the
potential to be perceptible at buildings within approximately 200 feet of typical construction work areas
and 400 feet of construction work areas involving a vibratory roller . Although some vibration associated
with construction activities may be felt by nearby residential properties that surround the site, this
potential vibration effect would not be excessive because it would occur during daytime hours only
(when residential properties would be less sensitive to perceived vibrations, be infrequent (occurring
only when equipment is in full operation, not idling or in low power modes), be intermittent (equipment
would not operate in the same location every day and would move around the site so that properties
are not exposed to continuous peak vibration levels), and would no t damage buildings or structures at
any point. For these reasons, project construction activities would not generate excessive groundborne
vibration or noise levels. This impact would be less than significant.
Once operational, the proposed project would not have any large equipment that would generate
vibration. This impact would be less than significant and no mitigation required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
88 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
c) Less Than Significant Impact. The proposed project is not located within two miles of any public
or private airport or within an airport land use plan. The closest public or private airport facility to the
project is the San Gabriel Valley Airport located approximately 10 miles to the northeast of the site in
the City of El Monte. No impact would occur with regard to excessive airport noise. Impacts would be
less than significant and no mitigation is required.
Mitigation Measuresv
To reduce potential noise levels from project construction activities, the project proponent shall:
NOI-1 Notify Residential Land Uses of Planned Construction Activities. This notice shall be
provided at least two (2) weeks prior to the start of any construction activities, describe the
noise control measures to be implemented by the project, and include the name and phone
number of the designated contact for the project proponent and the City of Downey
responsible for handling construction -related noise complaints (per MM NOI-5). This notice
shall be provided to the owner/occupants of residential dwelling units within 500 feet of
construction work areas.
NOI-2 Restrict Work Hours. All construction-related work activities, including material deliveries,
shall be subject to the requirements of City Municipal Code Section 4.50.100. Construction
activities, including deliveries, shall occur only during the hours of 7 AM to 7 PM Monday to
Friday and 9 AM to 6 PM on Saturday. No construction is to occur on Sunday and holidays.
The project proponent representative and/or its contractor shall post a sign at all entrances
to the construction site informing contractors, subcontractors, other workers, etc. of this
requirement.
NOI-3 Construction Equipment Selection, Use, and Noise Control Measures . The following
measures shall apply to construction equipment used at the project site:
a. Contractors shall use the smallest size equipment capable of safely completing work
activities.
b. Construction staging shall occur as far away from residential land uses as possible
given site and active work constraints.
c. Electric hook-ups shall be provided for stationary equipment (e.g., pumps,
compressors, welding sets). If it is not feasible to provide an electric hook -up, the
project proponent shall ensure mitigation measures 3a and 3d are implemented.
d. All stationary noise generating equipment shall be shielded and located as far as
possible from residential land uses given site and active work constraints. Shielding
may consist of existing vacant structures or a three -or four-sided enclosure provided
the structure/enclosure breaks the line of sight between the equipment and the
receptor and provides for proper ventilation and equipment operation.
e. Heavy equipment engines shall be equipped with standard noise suppression devices
such as mufflers, engine covers, and engine/mechanical isolators, mounts, and be
maintained in accordance with manufacturer’s recommendations during active
construction activities.
f. Pneumatic tools shall include a suppression device on the compressed air exhaust.
v The project Noise Study recommended one mitigation measure (NOI-1) with five related actions. However, this document separates that
one measure into five (NOI-1 through NOI-5) so the City will be better able to monitor implementation of the various required actions
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 89
City of Downey
g. No radios or other amplified sound devices shall be audible beyond the property line
of the construction site.
NOI-4 Implement Construction Activity Noise Control Measures . The following measures shall
apply to project construction activities:
a. Demolition: Activities shall be sequenced to take advantage of existing
shielding/noise reduction provided by existing buildings or parts of buildings , and
methods that minimize noise and vibration, such as sawing concrete blocks,
prohibiting on-site hydraulic breakers, crushing or other pulverization activities, shall
be employed during project construction.
b. Demolition, Site Preparation, Grading, and Foundation Work: During all demolition,
site preparation, grading, and structure foundation work activities, a physical noise
barrier shall be installed and maintained around the site perimeter to the maximum
extent feasible given site constraints and access requirements. The noise barrier
shall extend to a height of eight (8) feet above grade. Potential barrier options
capable of reducing construction noise levels could include, but are not limited to:
i. A concrete, wood, or other barrier installed at -grade (or mounted to structures
located at-grade, such as a K-Rail), and consisting of a solid material (i.e.,
free of openings or gaps other than weep holes) that has a minimum rated
transmission loss value of 20 dB.
ii. Commercially available acoustic panels or other products such as acoustic
barrier blankets that have a minimum sound transmission class (STC) or
transmission loss value of 20 dB.
iii. Any combination of noise barriers and commercial products capable of
achieving the required construction noise reductions of 20 dB during
demolition, site preparation, grading, and structure foundation work activities.
The noise barrier may be removed following the completion of building foundation work
(i.e., it is not necessary once framing and typical vertical building construction begins
provided no other grading, foundation, etc. work is still occurring on -site).
NOI-5 Prepare a Construction Noise Complaint Plan. The project proponent shall prepare a
Construction Noise Complaint Plan that shall:
a. Identify the name and/or title and contact information (including phone number and
email) for a designated project and City representative responsible for addressing
construction-related noise issues.
b. Includes procedures describing how the designated project representative will
receive, respond, and resolve construction noise complaints.
c. At a minimum, upon receipt of a noise complaint, the project representative shall
notify the City contact, identify the noise source generating the complaint, determine
the cause of the complaint, and take steps to resolve the complaint.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
90 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.14 Population and Housing
Would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Induce substantial unplanned
population growth in an area, either
directly (for example, by proposing
new homes and businesses) or
indirectly (for example, through
extension of roads or other
infrastructure)?
□ □ □
b) Displace substantial numbers of
existing people or housing,
necessitating the construction of
replacement housing elsewhere?
□ □ □
a) Less than Significant Impact. The project site currently contains a church and parking lot but has
no residential units or residents. The project proposes 33 multi-family residential townhouse units within
a gated community. According to the California Department of Finance, the City of Downey has 3.02
persons per household.34 Therefore, the project could generate approximately 100 additional residents
in the City. According to the Southern California Association of Governments’ (SCAG) 2024 Regional
Transportation Plan/Sustainable Communities Strategy (RTP/SCS), the number of households in the
City is expected to increase by 1,500 units between 2016 and 2045 (from 32,600 to 324,100 units) or
+4.6% as shown in Table 4.14-1 (SCAG Growth Projections for Downey). Similarly, the City’s population
is expected to increase by 5,900 persons between 2016 and 2045 (113,300 to 119,200 persons) or
+5.2%. The project represents approximately 2.2% of the total anticipated housing growth and 1.7% of
the total anticipated population growth for the City over that time period. The new housing added by the
project is well within the anticipated SCAG overall and annual growth projections for the City. Therefore,
the project would not induce substantial unplanned population growth in the area. The project is not
proposing any new expanded infrastructure that could accommodate additional growth in the area that
is not already possible with existing infrastructure or beyond that anticipated by SCAG and the City.
Impacts would be less than significant and no mitigation is required.
Table 4.14-1
SCAG Growth Projections for Downey
Demographic 2016 2045 Total Growth1 Annual Growth2
Population 113,300 119,200 +5,900 persons
+5.2%
+204 persons
+0.18%/year
Housing 32,600 34,100 1,500 units
+4.6%
+255 units
+0.78%/year
Source: 2024 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS),
1 difference between 2016 and 2045 figures divided by 2016 (beginning year) figure
2 total growth divided by number of years evaluated (2016 to 2045 or 29 years)
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 91
City of Downey
b) No Impact. The project site is located in a largely residential area of the City. The project site
currently contains a church and no residential structures or residents. The proposed project would
demolish the church and add 33 multi -family townhouse units with an estimated occupancy of 100
persons. As demonstrated in Threshold 4.13.a above, the project would not add unplanned population
or housing to the City and no existing residential units will be lost by project development. Therefore,
the project will have no impacts regarding the loss of existi ng residences.
4.15 Public Services
Would the project result in substantial adverse physical impacts associated with the provision
of new or physically altered governmental facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environ mental impacts,
in order to maintain acceptable service ratios, response times or other performance objectives
for any of the public services:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Fire protection? □ □ □
b) Police protection? □ □ □
c) Schools? □ □ □
d) Parks? □ □ □
e) Other public facilities? □ □ □
a) Less Than Significant Impact. Fire services in the City are provided by the Downey Fire
Department (DFD). DFD has four fire districts each served by its own station. The project site is located
in Fire District 3 and would be served by Fire Station #3 (9900 Paramount Boulevard), located
approximately 1.1 miles south of the project site. The estimated response time from Station #3 to the
project site is estimated to be approximately two minutes assuming an average speed of 35 miles per
hour. Additionally, DFD has automatic aid agreements with the Cities of Santa Fe Springs and
Montebello and the County of Los Angeles. The agreement provides coverage at fires by the closest
unit regardless of the jurisdictional boundary.
The project site has an existing church that is within and served by the DFD. Once the project is
occupied, the new townhouse neighborhood would continue to be served by DFD. As previously
discussed in Section 3.14, Population and Housing, the project would result in a population of 100
residents but is not expected to induce substantial or unanticipated unplanned population growth in the
City. The project site currently supports an existing church and it is likely calls for fire or emergency
medical service to the townhouse project would incrementally increase compared to the existing church.
Due to its small size, it is anticipated that the project would be adequately served by existing DFD
facilities, equipment, and personnel, and not result in a significant increase in the demand for DFD
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
92 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
services. The DFD will derive a portion of property tax revenues from increased property taxes on the
project site that will offset incremental demand for DFD services.
In addition, technical fire prevention activities such as building plan checks to make sure fire code
requirements are met, proposed fire sprinkler systems, fire alarm systems, and compliance with
emergency access and evacuation requirements would reduce the impacts associated with the
proposed project. All site plans for the proposed project would, as part of the City of Downey’s standard
review process, be subject to approval and site -specific conditions of approval to ensure compliance
with all applicable fire code standards . No new or expanded fire protection facilities would be required
as a result of this project because it will not induce a substantial population increase that was not
anticipated under the City’s General Plan. Furthermore, the proposed project does not propose to use
hazardous materials or engage in hazardous activities that would require new or modified fire protection
equipment to meet potential emergency demand. Review of project plans and implementation of
standard conditions of approval for fire protection are considered regulatory compliance and not unique
mitigation under CEQA.
Therefore, project impacts associated with the construction or expansion of fire protection facilities
would be less than significant and no mitigation is required.
b) Less Than Significant Impact. Police services in the City are provided by the Downey Police
Department (DPD), except for properties owned by the County of Los Angeles in the southwest part of
the City, which are patrolled by the Los Angeles County Sheriff’s Department. The DPD station at 10911
Brookshire Avenue would service the project site and is located approximately 1 mile to the northwest.
The estimated response times to service calls for DPD are 1 to 2 minutes for emergency calls and 5 to
8 minutes for nonemergency calls. DPD has 138 sworn officers and responds to an average of 1,000
service calls per month. Additionally, DPD has mutual ai d agreements with all cities in Los Angeles
County, with the exception of the City of Los Angeles. The agreement establishes a reciprocal law
enforcement status between other cities and the City of Downey (City of Downey 2005).
The project site is already within the DPD service area, and once operational, the project would continue
to be served by DPD. As previously discussed in Section 3.14, Population and Housing, the project
would result in 100 new City residents but would not induce substantial unplanned population growth in
the City. The project site currently supports an existing church so calls for DPD services to the project
site would likely increase in comparison to the existing condition. The proposed residential development
would not result in any unique or more extensive crime problems that cannot be handled with the
existing level of police resources. Overall, it is anticipated that the project wo uld be adequately served
by existing DPD facilities, equipment, and personnel. The DPD will derive a portion of property tax
revenues from increased property taxes on the project site that will help pay for D PD services.
Therefore, project impacts associated with the construction or expansion of police protection facilities
would be less than significant and no mitigation is required.
c) Less than Significant Impact. The project site is served by the Downey Unified School District
(DUSD). The project site is within the attendance areas of the three schools35 shown in Table 4.15-1
(Local School Enrollments), along with their enrollments over the past three school years36. Table 43.15-
1 indicates that State enrollment figures for DUSD have been declining for the past three years at the
elementary level but have remained relatively constant over the past three years at the middle and high
school levels. In addition, a comparison of the capacities of the schools serving the project area and
their projected enrollments is shown in Table 4.15 -2 (School Capacities vs. Projected Enrollment). Table
4.15-2 indicates that the highest projected enrollment for the three project -area schools, as shown in
the District’s 2022 Facility Master Plan37, is within each school’s estimated student capacity for at least
the immediate future.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 93
City of Downey
Table 4.15-1
Local School Enrollments
School/Address Grades School Year Student Enrollment
2020-2021 2021-2022 2022-2023
Price Elementary School
9525 Tweedy Lane, Downey K-5 844 734 779
Griffiths Middle School
9633 Tweedy Lane, Downey 6-8 1,298 1,301 1,296
Warren High School
8141 De Palma Street, Downey 9-12 3,469 3,451 3,437
Total
Project Area
District-Wide
K-12
K-12
5,611
22,216
5,486
22,261
5,512
22,359
Source: DUSD website 2023, California Dept. of Education DataQuest database 2023
Table 4.15-2
School Capacities vs. Projected Enrollment
School/Address Grades
Estimated Number of Students
Estimated
Capacity
Lowest
Projected
Enrollment
Highest
Projected
Enrollment
Price Elementary School
9525 Tweedy Lane, Downey K-5 821 742 801
Griffiths Middle School
9633 Tweedy Lane, Downey 6-8 1,500 1,264 1,295
Warren High School
8141 De Palma Street, Downey 9-12 4,014 3,527 3,782
Total
Project Area
District-Wide
K-12
K-12
6,335
25,466
5,533
22,512
5,878
21,492
Source: DUSD website 2023, Table 17, DUSD Facility Master Plan 2022.
Development impact fees may be levied for residential construction, pursuant to Education Code
Section 17620 and California Government Code Section 65995 and DUSD has currently established
impact fees of $4.79 per square foot for residential development as of 2022. As stated in California
Government Code Section 65996, payment of school impact fees in accordance with California
Government Code Section 65995 and/or Education Code Section 17620 is deemed to constitute full
and complete mitigation for potential impact s to schools caused by development. Payment of
established development impact fees is considered full mitigation under CEQA. Since the proposed
project involves a General Plan Amendment and Zone Change, the developer may also choose to enter
into a voluntary negotiated fee agreement (called a “mutual benefit agreement”) in lieu of statutory
developer fees. The impact fee process is considered regulatory compliance and not project mitigation
under CEQA.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
94 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
The City of Downey requires school impact fees to be paid to DUSD by the developer prior to issuance
of building permits. These fees would help to fund future needs in the district with relation to the
provision of new or physically altered District facilities. For these reasons, impacts related to the need
for new school facilities as a result of implementing the proposed project would be less than significant
with regulatory compliance.
d) Less Than Significant Impact. Demand for park and recreational facilities is generally the direct
result of residential development. The City has approximately 117 acres of parkland in 12 park sites.
The closest City park to the project site is Treasure Island Park. This park has approximately 4.7 linear
acres along the west side of the Rio Hondo Channel with turf, walking path, and a playground. This park
is 800 feet east of the project site at the eastern end of South Bluff Road. Based on a 2020 population
of 114,360 residents, the City provides its residents and workers with approximately 1.02 acres per
thousand residents. In addition, there are County parks in the surrounding area that also provide
recreational facilities and open spaces for the region.
The State Quimby Act recommends a ratio of 3.0 acres of parkland per thousand residents as a
minimum standard for new development. As previously discussed in Section 3.14(a), Population and
Housing, the project is expected to generate approximately 100 new City residents. Therefore, the
proposed project should provide 0.3 acres of public parkland or pay the equivalent in in-lieu park DIF
fees to the City to meet the Quimby Act standardvi. According to the project plans, the project proposes
to provide a total of 6,958 square feet (0.16-acre) of private recreation/open space for its residents. This
figure includes 2,569 square feet of “public” spaces (but only for project residents) and 4,389 square
feet of private spaces such as uncovered private patio/yard spaces, covered private front porch space,
and covered and uncovered decks. Since all of this recreational space is private, the project proponent
would be responsible for paying the City’s established in-lieu park fee. The provision of adequate
recreation and open space for project residents is considered regulatory compliance and not unique
mitigation under CEQA.
The City’s Parks and Open Space Master Plan38 (2016) indicates that its park in-lieu fees have been
minimal for several years which generally reflects largely built -out housing conditions in the City. With
the project design and payment of the City’s in -lieu park fee, the project’s impacts regarding recreational
facilities would be less than significant and no mitigation is required.
e) Less Than Significant Impact.
As previously mentioned in Section 3.14(a), Population and Housing, the project would add an
estimated 100 residents to the City but would not induce substantial or unanticipated population growth
in the City. Population growth as a result of the project is well within SCAG’s overall growth projections
for the City and would not result in a substantial increase in population. As such, the project would result
in an incremental but not substantial increase in patronage at libraries, community centers, and other
public facilities. Therefore, impacts associated with other public facilities would be less than significant
and no mitigation is required.
vi 33 townhomes X 3.01 persons/household or unit = 100 residents divided by 3 acres/1000 residents = 0.3 acre for the proposed p roject
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 95
City of Downey
4.16 Recreation
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of
existing neighborhood and regional
parks or other recreational facilities
such that substantial physical
deterioration of the facility would
occur or be accelerated?
□ □ □
b) Does the project include recreational
facilities or require the construction
or expansion of recreational facilities
which might have an adverse
physical effect on the environment?
□ □ □
a) Less than Significant Impact. See discussion in Threshold 4.15(d). The City has 117 acres of
parkland in 12 parks. The closest park to the project site is Treasure Island Park with 4.7 linear acres
along the west side of the Rio Hondo Channel . The project is expected to generate approximately 100
new City residents, so the proposed project should provide 0.3 acres or 13,068 square feet to meet the
Quimby Act standard (3 acres per thousand residents). The project proposes a total of 6,958 square
feet (0.16-acre) of private recreation/open space for its residents and the Quimby Act requirement would
be 0.3 acre of public recreation/open space. The project proponent would thus be responsible for paying
the City’s in-lieu park fee. The provision of adequate recreation and open space for project residents is
considered regulatory compliance and not unique mitigation under CEQA.
Since the project has only a small amount of internal recreational area, it is likely project residents will
use Treasure Island Park as well as other City parks for recreational activities. The City of Downey
maintains and operates the existing neighborhood parks and the County maintains and operates
regional parks and other recreational facilities in the surrounding region. The small number of new
residents would only represent an incremental increase in local and regional park use. The project will
pay the City’s in-lieu park fee for the difference of onsite vs. required park and open space land as noted
above. It is not likely such incremental use would result in the need to reconstruct or upgrade existing
park facilities. Therefore, impacts would be less than significant with payment of the City’s in -lieu park
fee.
b) Less than Significant Impact. As discussed in Section 4.16(a) above, the project is expected to
generate approximately 100 new City residents . The proposed project should provide 0.3 acres or
13,068 square feet to meet the Quimby Act standard. The project proposes a total of 6,958 square feet
(0.16-acre) of recreation/open space for its residents and the Quimby Act requirement would be 0.3
acre of recreation/open space. The applicant would thus be responsible for paying the City’s in -lieu park
fees to cover the difference. The provision of adequate recreation and open space for project residents
is considered regulatory compliance and not unique mitigation under CEQA. The project does not
include removal of any existing City of Downey recreational facility or require the construction or
expansion of recreational facilities which might have an adverse physical effect on the environment.
Therefore, impacts would be less than significant and no mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
96 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.17 Transportation and Traffic
Would the Project:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with program plan, ordinance
or policy addressing the circulation
system, including transit, roadway,
bicycle and pedestrian facilities?
□ □ □
b) Would the project conflict or be
inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)? □ □ □
c) Substantially increase hazards due
to a geometric design feature (e.g.,
sharp curves or dangerous
intersections) or incompatible uses
(e.g., farm equipment)?
□ □ □
d) Result in inadequate emergency
access? □ □ □
A Vehicle Miles Traveled (VMT) Screening Assessment39 was prepared for the proposed project by
the Ganddini Group dated November 15, 2023 (Appendix G). The information in this section is
largely taken from that assessment.
a) Less than Significant Impact. Prior to the passage of California Senate Bill 743 (SB 743) in
2013, the analysis of transportation impacts in CEQA documents was Level of Service (LOS) or
congestion on public streets and intersections. This type of analysis was to assure the local street grid
network functioned well and allowed for efficient movement of vehicles. The current focus of traffic
analyses for CEQA is to encourage active transportation (e.g., pedestrians, bicyclists, etc.) and transit,
and to limit increases in Vehicle Miles Traveled (VMT) to better balance traffic on a regional basis. An
important part of this analysis is to determine if a proposed action is consistent with both the vehicular
and non-vehicular aspects of the Circulation Element of the General Plan.
Pedestrian Access
The streets adjacent to the project site, Suva Street, Foster Bridge Boulevard, and South Bluff
Road, all have sidewalks on both sides of the street. Project construction will include constructing
new sidewalks along the project frontage of these adjacent streets. Therefore, project impacts on
pedestrian access will be less than significant and no mitigation is required.
Bicycle Access
According to Exhibit 2.6-1 in the City’s Master Plan of Parks and Open Space 38, the City has a
network of Class II and Class III bike lanes within the City, and there are also regional Class I bike
paths along the San Gabriel River and Rio Hondo channels bordering the City to the southeast
and northwest, respectively. There is currently a Class III bike lane along Suva Street (adjacent to
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 97
City of Downey
the project site) that runs from the City limit just west of the site east to Paramount Boulevard. This
bike lane then connects to another Class III bike lane along Tweedy Lane/Rivers Avenue to the
southwest. These two bike lanes then connect to other bike lanes throughout the City. The project
will not remove or have any impacts on existing bicycle lanes. Therefore, impacts will be less than
significant and no mitigation is required.
Transit Services
Transit services are provided within the City of Downey and to the Los Angeles region by the Los
Angeles County Metropolitan Transportation Authority40 (MTA or Metro). The following Metro bus
lines are located within a mile of the project site:
• Route 110 operates along Garfield Avenue in the vicinity of the project site. At its closest
this line is 0.75 mile northwest of the site;
• Route 111 operates along Florence Boulevard in the vicinity of the project site. At its closest
this line is 0.6 mile southwest of the site; and
• Line 265 along Paramount Boulevard in the vicinity of the project site. At its closest this line
is 0.7 mile southeast of the site.
The closest bus stops are located on Garfield Avenue near Loveland Street serving Line 110, on
Florence Avenue near Scout Avenue serving Route 111, and on Paramount Boulevard at Suva
Street serving Line 265. Development of the project would not conflict with the existing bus routes
or bus stops. Impacts to transit would be less-than-significant.
In addition, Metrolink41 commuter rail service to the City is available via the C Line (formerly the
“Green Line”) at the Lakewood Boulevard Station located approximately 3.6 miles south of the
project site, as well as the Norwalk Station located approximately 4 miles southeast of the project
site.
Therefore, the project will not conflict with the program plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities. Impacts will be less
than significant and no mitigation is required.
b) Less than Significant Impact. Following the passage of California Senate Bill 743 (SB 743) in
2013, the State of California’s Governor’s Office of Planning and Research (OPR) was tasked with
developing new guidelines for evaluating transportation impacts under CEQA. These guidelines were
intended to shift the performance metric from automobile d elay and level of service (LOS) to one that
would promote the reduction of greenhouse gas emissions and the development of multimodal and
diverse transportation networks. As a result, OPR determined that the CEQA guidelines would use
vehicle miles traveled (VMT) as the primary metric for evaluating environmental and transportation
impacts. In December 2018, OPR published the revised CEQA Guidelines incorporating the transition
to VMT, along with the Technical Advisory on Evaluating Transportation Impacts in CEQA (December
2018) to assist with the implementation of the revised CEQA Guidelines.
In 2020, the County of Los Angeles adopted the Los Angeles County Transportation Impact Analysis
Guidelines 42 based on OPR’s Technical Advisory. The City of Downey has not established VMT
analysis guidelines at this time; therefore, the project VMT impact has been assessed based on
available guidance from the County of Los Angeles, OPR Technical Advisory, and consideration of
implementation policies established by other jurisdictions in the Southern California region.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
98 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Trip Generation
The VMT Assessment estimated trip generation for the existing church and proposed residential uses
based upon trip generation rates obtained from the Institute of Transportation Engineers (ITE) Trip
Generation Manual43 Based on review of the ITE land use descriptions, trip generation rates for Church
(ITE Land Use Code 560) and Multi-Family Housing (Low-Rise) (ITE Land Use Code 220) were
determined to best represent the existing land use and proposed project uses in terms of trip generation
forecasts. The VMT Assessment determined the existing land use generates approximately 64 daily
trips, including 3 trips during the AM peak hour and 4 trips during the PM peak hour. In addition, the
proposed project will generate approximately 222 daily trips, including 13 trips during the AM peak hour
and 17 trips during the PM peak hour. When combined, the proposed project will result in a “net”
increase of approximately 158 additional daily trips compared to the existing use, including 10 additional
trips during the AM peak hour and 13 additional trips during the PM peak hour - see Table 4.17-1
(Project Trip Generation). As shown in Table 4.17-1, the proposed project will result in a “net” generation
of 10 AM Peak Hour trips, 13 PM Peak Hour trips, and 158 total daily trips.
Table 4.17-1
Project Trip Generation
Land Use1
Trips Generated
AM Peak Hour PM Peak Hour Daily In Out Total In Out Total
Existing 2 1 3 2 2 4 64
Proposed 3 10 13 11 6 17 222
Net New Trips +1 +9 +10 +9 +4 +13 +158
Source: Table 3, Ganddini Group, 2023
1 Existing land use is church (ITE 560) while proposed use is 33 townhomes (ITE 220)
VMT Screening Assessment
According to the LA County TIA Guidelines, certain types of projects, because of their size, nature, or
location, are exempt from the requirement of preparing a traffic impact analysis. The County Guidelines
establish screening thresholds for certain types of projects that may be presumed to cause a less than
significant VMT impact based on substantial evidence provided in OPR’s 2018 Technical Advisory. The
County TIA Guidelines specify the following four screening steps: 1) Non -Retail Project Trip Generation
Screening; 2) Retail Project Site Plan Screening; 3) Proximity to Transit Based Screening; and 4)
Residential Land Use Based Screening. The VMT Screening Assessment evaluated the proposed
project and found that, for various reasons, it did not meet any of the four screening criteria.
Daily Trip Thresholds
During the project evaluation of LA County VMT Screening Thresholds, the VMT Assessment noted
that the County’s non-retail trip generation threshold was based on extrapolation of categorical
exemption criteria rather than consideration of the actual potential for VMT impacts and is very low
compared to historical screening thresholds for determining the need to prepare a traffic impact
analysis. Historically, the County of Los Angeles, and subsequently the City of Downey, used a trip
generation threshold of peak hour trips for determining the need to prepare a traffic impact analysis.
For residential uses, 50 peak hour trips would roughly equate to 500 daily trips. Accordingly, several
jurisdictions in the region have developed higher daily trip thresholds for small projects based on the
intent and stated goals of SB 743 to reduce greenhouse gas (GHG) emissions.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 99
City of Downey
The VMT Assessment found a number of other jurisdictions in the region that have established their
own daily trip thresholds for screening small residential projects. The daily trip thresholds of these
sample jurisdictions generally range from 250 to 500 daily trips, as shown in Table 4.17-2 (Daily
Screening Thresholds Established by Other Jurisdictions in the Region). It must be noted that the OPR
Technical Advisory recommended thresholds are based on the Categorical Exemption for 10,000
square foot additions to existing structures; from this, the OPR Technical Advisory calculated a 110
daily trip threshold based on 10,000 square feet of office use. There are many uses, however, that
would result in substantially higher trips than the 110 daily trip threshold recommended by the OPR
Technical Advisory.
Based on the intent and stated goals of SB 743 to reduce greenhouse gas (GHG) emissions, some
jurisdictions have adopted daily trip thresholds based on GHG emissions rather than extrapolation of
categorical exemption criteria. For example , the City of Redlands CEQA Assessment VMT Analysis
Guidelines and County of Riverside Transportation Analysis Guidelines for Level of Service [and]
Vehicle Miles Traveled (December 2020) include the documentation used to establish substantial
evidence for GHG emissions-based trip thresholds for screening small projects (see Attachment A in
Appendix A).
In addition, the South Coast Air Quality Management District (SCAQMD) threshold of 3,000 metric tons
of carbon dioxide emissions (MTCO2e) per year is the most stringent GHG threshold in the region, the
City of Redlands and County of Riverside have established small project thresholds by evaluating the
significance of mobile source emissions associated with VMT generated by various land uses using the
California Emissions Estimate Model (CalEEMod). Table 4.17-2 (Range of Local Daily Trip Screening
Thresholds in the Region), shows a number of jurisdictions in the region have thresholds for small multi -
family residential projects that range from 250 -500 average daily trips or 147-299 units. In either case,
the proposed project is below any of these locally established standards.
In addition, the VMT Assessment presented the results of a similar GHG-based emissions analysis for
a multi-family housing (low-rise) project in the City of Downey (similar to the proposed project) using the
updated ITE Trip Generation Manual trip generation rates and CalEEMod defaults (see Air Quality,
Greenhouse Gas, and Energy Analysis5- Appendix A). Table 4.17-3 (Daily Trip Threshold that Exceed
the GHG Emissions Threshold) estimates it would take approximately 321 dwelling units of low-rise
multi-family housing to generate 2,164 daily trips that would exceed the GHG emissions threshold
established by the SCAQMD. Therefore, multi-family housing (low-rise) projects with 320 dwelling units
or less, like the proposed project, would not exceed the SCAQMD threshold for GHG emissions and
could be presumed to result in a less than significant VMT impact using the GHG emissions approach
for establishing daily trip thresholds for small projects.
It is noted that the analysis and thresholds shown in Tables 4.17 -2 and 4.17-3 are not intended to
establish policy or precedent for the City of Downey, but rather to demonstrate potential screening
criteria in light of those established by other jurisdictions in the region. For purposes of this analysis,
the proposed project would result in a less than significant VMT impact using a daily trip threshold of
250 daily trips which is at the low end of the thresholds adopted by the other jurisdictions reviewed as
shown in Table 4.17-2.
The VMT Assessment concluded the proposed project will generate fewer than 250 new daily trips
(gross or net). Based on review of the daily trip screening thresholds for small projects established by
other jurisdictions in the region and taking into account the evaluation of GHG emissions thresholds
established by SCAQMD, the proposed project will have a less than significant VMT impact and no
mitigation is required.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
100 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Table 4.17-2
Range of Local Daily Trip Screening Thresholds in the Region
Jurisdiction Local Daily Trip Screening Threshold
Average Daily Traffic Dwelling Units
City of Los Angeles 250 --
City of Irvine 250 --
City of Newport Beach 300 --
City of Long Beach 500 --
City of Perris 500 ---
City of Redlands1
Multi-Family (low rise)
Multi-Family (mid-rise)
370 – 4,243
--
--
232
299
County of Riverside1
Multi-Family (low rise)
Multi-Family (mid-rise)
--
--
147
194
Proposed Project (Downey)2 158 33
Source: Table 4, Ganddini 2023
1 Emissions would not exceed SCAQMD threshold of 3,000 MTCO2e emissions per year based on CalEEMod analysis
2 Net trips based on analysis in Table 4.7-1
Table 4.17-3
Daily Trip Threshold that Exceeds the GHG Emissions Threshold
Land Use Quantity1
Total
CO2e
(MT/yr)2
CO2e
Threshold
(MT/yr)
Daily
Trip
Rate3
Size that
Triggers
Threshold
Daily Trips
that
Trigger
Threshold
Condo/Townhouse 100 DU 955 3,000 6.74 321 DU 2,164
Source: Table 5, Ganddini Group, 2023
c) No Impact. A significant impact would occur if the project substantially increased an existing
hazardous design feature or introduced incompatible uses to the existing traffic pattern. It should first be
noted the street layout around the project site is somewhat unusual in that two adjacent collector streets
(Suva Street and Foster Bridge Boulevard) are separated at the southern end of the site by a small
segment of a third street (South Bluff Road). This alignment results in a skewed intersection with 5
approaches instead of the typical 4 approaches. In addition, instead of all the approaches being at 90o
to each other, 3 approaches are at approximately 60o and two approaches are at 120o. However, the
intersection does have 4-way stop control which allows this intersection to operate in an acceptable
manner even with the additional skewed approach (see Exhibit 2 to see the skewed nature of this
intersection).
The project proposes a gated entry with a 26 -foot driveway at the north end of the site from Foster Bridge
Boulevard, and an “emergency vehicle access” (EVA) with a gate and Knox box for emergency
responder access if needed at the south end of the project at Suva Street. These two access points will
be connected by a slightly curved 26-foot wide drive aisle.
The design of the project access points and onsite road comply with all applicable City regulations.
Furthermore, the project does not involve changes in the alignments of Suva Street, Foster Bridge
Boulevard, or South Bluff Road, nor does it create hazardous geometric design features.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 101
City of Downey
The project would not construct any new roadways, modify any existing roadway or intersection
geometries (i.e., the skewed intersection was a pre-existing condition), or result in temporary road
closures during construction or any permanent road closures. Any and all site adjacent road or
intersection improvements required are within the public right-of-way and would be required to comply
with standards set forth by the City to ensure that the project does not introduce an incompatible design
feature that would impede operations on project-adjacent roadways or intersection(s). Therefore, no
impact would occur and no mitigation is required.
d) Less than Significant Impact. A significant impact would occur if the design of the project would
not satisfy emergency access requirements of the Downey Fire Department or Police Department, or in
any other way threaten the ability of emergency vehicles to access and serve the project site or adjacent
uses. As discussed above, access to the project site is proposed via two 26-foot wide driveways - one a
public gated access to Foster Bridge Boulevard and one for emergency vehicles only to Suva Street.
The driveway widths are sufficient to provide access to fire and emergency vehicles are consistent with
the California Fire Code requiring a minimum of 18 feet. All access features are subject to and must
satisfy the City of Downey design requirements, including the Fire Department’s requirements.
Therefore, the project would result in less than significant impacts with regard to emergency access and
no mitigation is required.
4.18 – Tribal Cultural Resources
Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in Public Resources Code section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a Cultural Native American tribe, and that is:
Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Listed or eligible for listing in the
California Register of Historical
resources, or in a local register of
historical resources as defined in
Public Resources Code Section
5020.1(k), or
□ □ □
b) A resource determined by the lead
agency, in its discretion and
supported by substantial evidence,
to be significant pursuant to criteria
set forth in subdivision (c) of Public
Resources Code Section 5024.1. In
applying the criteria set forth in
subdivision (c) of Public Resource
Code Section 5024.1, the lead
agency shall consider the
significance of the resource to a
California Native American tribe.
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
102 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
a) Less than Significant Impact with Mitigation Incorporated. A significant impact would occur if the
proposed project would cause a substantial adverse change in the significance of a tribal cultural
resource (TCR) listed or eligible for listing in the California Resources of Historical Resources, or in a
local register of historical resources as defined in Public Resources Code Section 5020.1(k). When
available, results of the cultural resources records research conducted at the South -Central Coastal
Information Center (SCCIC), a part of the California Historical Resources Information System (CHRIS),
are expected to confirm that there are no known tribal cultural or historic resources within the project
boundaries, and possibly even up to a one-half mile radius from the project site.
A Cultural Resources Assessment (CRA) was prepared for the project site by CRM TECH dated
October 13, 2023 that included archival archaeological research (Appendix C). In addition, the
Gabrieleno Band of Mission Indians - Kizh Nation has indicted the project area has a definite potential
to contain tribal cultural resources (TCRs) as stated in their consultation correspondence (Appendix I):
“Due to the project site being located within and around a perennial Community (Suvangna
,Nakaungna), adjacent to sacred water courses and major traditional trade routes, there is a high
potential to impact Tribal Cultural Resources still present within th e soil from the thousands of
years of prehistoric activities that occurred within and around these Tribal Cultural landscapes.
Therefore, to avoid impacting or destroying Tribal Cultural Resources that may be inadvertently
unearthed during the project's ground disturbing activities and pursuant to our consultation, we
have provided to the Lead Agency substantial evidence that the proposed project may have a
significant impact on our TCRs.”
As discussed in Section 4.5, Cultural Resources, Mitigation Measure CUL-1 was recommended to
address potential impacts to archaeological resources but Mitigation Measures TCR -1 through TCR-3
were specifically recommended by the Gabrieleno Band of Mission Indians - Kizh Nation to help prevent
any adverse changes in the significance of a tribal cultural or historical resource as defined in CEQA
§15064.5. With the recommended mitigation measures (i.e., CUL-1 and TCR-1 through TCR-3),
potential impacts to TCRs are reduced to less than significant levels.
b) Less than Significant Impact with Mitigation Incorporated. Government Code §§ 65352.3 and
65562.5 (SB 18); and Public Resources Code §§ 21073, 21074, 21080.3.1, 21080.3.2, 21082.3,
21083.09, 21084.2, and 21084.3 (AB 52) provide that a project that may cause a substantial adverse
change to a defined Tribal Cultural Resource (TCR) can result in a significant effect on the environment.
AB 52 requires tribes interested in development projects within a traditionally and culturally aff iliated
geographic area to notify a lead agency of such interest and to request notification of future projects
subject to CEQA prior to determining if a negative declaration, mitigated negative declaration, or
environmental impact report is required for a project. The Lead Agency is required to notify tribes within
14 days of deeming a development application complete subject to CEQA to notify the requesting tribe
as an invitation to consult on the project. AB 52 identifies examples of mitigation measures that would
avoid or minimize impacts to TCR. The bill makes the above provisions applicable to projects that have
a notice of preparation or a notice of intent to adopt a negative declaration/mitigated negative
declaration circulated on or after July 1, 2015.
Section 4.5(b), Cultural Resources, indicates that according to the General Plan1 and the CRA13, the
project area has no facilities that satisfy any of the criteria for a historic resource defined in CEQA
Guidelines Section 15064.5. However, the onsite church building was constructed from the late 1950’s
to 1989, so CRM TECH considered it possible that structure may have historical value. Therefore, CRM
TECH undertook a preliminary evaluation of the church building and determined it did not meet any
established criteria for historical resources under CEQA. As previously stated, CRM TECH concluded
the site did not have any structures or resources eligible for listing in the National or California Registers
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 103
City of Downey
under any of the significance criteria. Therefore, the project would not result in an adverse change in
the significance of a historical resource as defined in CEQA Section15064.5.
Although there is no indication of TCRs on or in the immediate vicinity of the project site, AB 52 is clear
in stating that it is the responsibility of the Public Agency (i.e., Lead Agency) to consult with Native
American tribes early in the CEQA process to allow tribal governments, lead agencies, and project
proponents to discuss the appropriate level of environment review, identify and address potential
adverse impacts to TCRs, and reduce the potential for delay and conflict in the environmental review
process (see Public Resources Code Section 2108.3.2). Specifically, governmen t-to-government
consultation may provide “tribal knowledge” of the project area that can be used in identifying TCRs
that cannot be obtained through other investigative means.
In addition, projects that involve a General Plan Amendment (such as the proposed project) also require
separate or combined notification in compliance with SB 18. Th at law requires a 90-day review period
in which the local tribal group representatives have to indicate if they want to consult on a particular
development project.
The City of Downey submitted AB 52 notifications on May 1, 2023 and SB 18 notifications on August 7,
2023 to the following tribal governments that have traditional/cultural habitation or resources in the
project area:
• Gabrieleno Band of Mission Indians - Kizh Nation (Andrew Salas, Chairperson)
• Gabrieleno/Tongva San Gabriel Band of Mission Indians (Anthony Morales, Chairperson)
• Gabrielino Tongva Indians of California Tribal Council (Robert Dorame, Chairperson)
• Gabrielino /Tongva Nation (Sandonne Goad, Chairperson )
• Gabrielino-Tongva Tribe (Charles Alvarez)
The AB 52 and SB 18 notices were submitted to tribal cultural representatives via emailed letters instead
of certified mail as recently agreed to by the local tribal representatives (Appendix I). The City received
one response letter from the Gabrieleno Band of Mission Indians - Kizh Nation (GBMI-KN) which
recommended mitigation language but did not identify any tribal cultural resources actually on the
project site. At the time this IS/MND was circulated for public review, the tribal notification periods for
both AB 52 and SB 18 had closed (September 6, 2023 and July 30, 2023, respectively). The City has
received no other responses from the Native American community concerning the proposed project.
However, despite the heavy disturbances of the project area that may have displaced or destroyed
archaeological resources relating to TCRs on the surface, local tribal groups including GBMI-KN
consider it still possible that intact tribal cultural resources exist at depth. Therefore, Mitigation Measure
CUL-1 outlined in Section 4.5, Cultural Resources, and Mitigation Measures TCR-1 through TCR-3
outlined in this section, are recommended to address the potential for any previously undiscovered
archaeological and tribal cultural resources encountered during project grading. Incorporation of these
mitigation measures will ensure that potential impacts to buried TCRs are less than significant through
requirements for halting work (if necessary), allowing for monitoring of grading by an archaeologist and
tribal monitors, evaluation, salvage, curation, and reporting . It should be noted the following mitigation
measures were recommended in correspondence received from the GBMI-KN during the project’s
Native American consultation period.
Mitigation Measures
TCR-1 Tribal Monitor. The project applicant/lead agency shall retain a Native American Monitor
from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The monitor
shall be retained prior to the commencement of any “ground -disturbing activity” for the
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
104 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
subject project at all project locations (i.e., both on -site and any off-site locations that are
included in the project description/definition and/or required in connection with the project,
such as public improvement work). “Ground -disturbing activity” shall include, but is not
limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and trenching.
A copy of the executed monitoring agreement shall be submitted to the lead agency prior to
the commencement of any ground -disturbing activity, or the issuance of any permit
necessary to commence a ground-disturbing activity.
The monitor will complete daily monitoring logs that will provide descriptions of the relevant
ground-disturbing activities, the type of construction activities performed, locations of
ground-disturbing activities, soil types, cultural-related materials, and any other facts,
conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and
describe any discovered TCRs, including but not limited to, Native American cultural and
historical artifacts, remains, places of significance, etc., (collectively, tribal cultural
resources, or “TCR”), as well as any discovered Native American (ancestral) human remains
and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency
upon written request to the Tribe.
On-site tribal monitoring shall conclude upon the latter of the following (1) written
confirmation to the Kizh from a designated point of contact for the project applicant/lead
agency that all ground-disturbing activities and phases that may involve ground -disturbing
activities on the project site or in connection with the project are complete; or (2) a
determination and written notification by the Kizh to the project applicant/lead agency that
no future, planned construction activity and/or development/con struction phase at the project
site possesses the potential to impact Kizh TCRs.
TCR-2 Unanticipated Discoveries. Upon discovery of any Tribal Cultural Resources (TCRs), all
construction activities in the immediate vicinity of the discovery shall cease (i.e., not less
than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully
assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all
discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole
discretion, and for any purpose the Tribe deems appropriate, including for educational,
cultural and/or historic purposes.
TCR-3 Human Remains. Native American human remains are defined in PRC 5097.98 (d)(1) as
an inhumation or cremation, and in any state of decomposition or skeletal completeness.
Funerary objects, called associated grave goods in Public Resources Code Section
5097.98, are also to be treated according to this statute. If Native American human remains
and/or grave goods are discovered or recognized on the project site, then Public Resource
Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. Human
remains and grave/burial goods shall be treated alike per California Public Resources Code
section 5097.98(d)(1) and (2). Preservation in place (i.e., avoidance) is the preferred manner
of treatment for discovered human remains and/or burial goods. A ny discovery of human
remains/burial goods shall be kept confidential to prevent further disturbance.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 105
City of Downey
4.19 – Utilities and Service Systems
Would the Project:
Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Require or result in the relocation or
construction of new or expanded
water, wastewater treatment or storm
water drainage, electric power,
natural gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effects?
□ □ □
b) Have sufficient water supplies
available to serve the Project an d
reasonably foreseeable future
development during normal, dry and
multiple dry years?
□ □ □
c) Result in a determination by the
wastewater treatment provider which
serves or may serve the Project that
it has adequate capacity to serve the
Project’s Projected demand in
addition to the provider’s existing
commitments?
□ □ □
d) Generate solid waste in excess of
State or local standards, or in excess
of the capacity of local infrastructure,
or otherwise impair the attainment of
solid waste reduction goals?
□ □ □
e) Comply with federal, state, and local
management and reduction statutes
and regulations related to solid
waste?
□ □ □
a) Less than Significant Impact. The project would require water, wastewater collection and
treatment, storm water drainage, electrical power, natural gas, and telecommunication services. An
analysis of impacts related to these services is provided below.
Water
A Water Demand Study44 was prepared for the project by Alan Short, PE dated May 8, 2023. The project
site currently contains a church, parking lot, and landscaping. The proposed project would include the
development of 33 condominium units and would increase the intensity of uses on the project site,
resulting in increased water use. For this analysis, all of the project water use was considered new and
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
106 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
no deduction or reduction was calculated for existing water use by the church. Therefore, the following
are conservative estimates for project water use. As discussed in Section 3.10(b), the project would
increase the amount of impervious surfaces on the project site from 78 to 87 percent. Pursuant to the
City’s Municipal Code Section 5707, the project has prepared a Low Impact Development (LID) plan to
comply with City efforts to retain stormwater runoff generated from new construction projects.
The project Water Demand Study assumed 33 multi-family residential units with 3-bedrooms each and
with a maximum occupancy of 6 persons per unit. Expected water demand could either be 200 gallons
per day (gpd) per bedroom or 48 gpd per person. Therefore, the Water Study used the higher daily rate
(per bedroom) which indicated the project would consume 19,800 gpd of water per day which is
equivalent to 196 gpd per person per day. The Water Study estimated the project would consume 7.2
million gallons per year or 22.2 acre-feet/year (AFY)vii.
The project site is within the water service boundaries of the City which is responsible for the production
and distribution of the City's water supply and the maintenance of all water system facilities. The City
had 23,631 connections in 2020 and supplied 14,449 acre-feet (AF) of water that year. According to the
City’s 2020 Urban Water Management Plan (UWMP), the reliable quantities of projected water supply
and demand for Year 2025 through Year 2045 are shown in Table 4.19-1 (Projected City Water Demand
and Supply), from the UWMP. Table 4.19-1 indicates that water demand is projected to increase by
3.6% over the next 20 years, while water supplies are projected to increase by 4.1% over the same
period. The projection of supplies assumes no imported water from CBMWD is purchased but use of
recycled water from CBMWD is expected to increase by 16.4% over that time period. The proposed
project’s annual water consumption of 1,349,303 gallons per year equals 4.1 acre -feet/year which
represents 0.025% of the projected water supply in the City by 2025 and 0.024% by 2045. According
to the UWMP supply/demand data in Table 4.19 -1, the estimated water consumption of the proposed
project is well within the Utility Division’s projected water supply for 2025 and 2045 and would not,
therefore, significantly impact existing water service.
Table 4.19-1
Projected City Water Demand and Supply (acre-feet/year)
Water Users1/Supplies 2025 2030 2035 2040 20451 2020-2045
Demand2
Single Family 7,573 7,637 7,704 7,774 7,842 +3.5%
Multi-Family 3,204 3,233 3,261 3,290 3,319 +3.6%
Commercial 2,701 2,725 2,749 2,773 2,797 +3.6%
Industrial 759 766 773 779 786 +3.6%
Government 429 433 437 440 444 +3.5%
Landscape 143 145 146 147 148 +3.5%
Losses 892 900 908 916 924 +3.6%
Other 128 130 131 132 133 +3.9%
Sub-Total 15,828 15,969 16,109 16,251 16,393 +3.6%
Supplies3
Groundwater-Central Basin 15,829 15,969 16,109 16,251 16,393 +3.6%
Imported Water-CBMWD 0 0 0 0 0 0
Recycled Water-CBMWD 730 770 815 850 850 +16.4%
Sub-Total 16,559 16,739 16,924 17,101 17,243 +4.1%
Difference (supply/demand) +731
+4.6%
+770
+4.8%
+815
+5.1%
+850
+5.2%
+850
+5.2%
--
+0.5%
Source: Tables 4-2 and 6-9, UWMP 2022
1 UWMP lists 2045 as an “optional” calculation
vii One AF = approx. 326,000 gallons
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 107
City of Downey
2 Retail use for potable and non-potable water not including recycled water demand
3 Represents the “reasonably available volume” for each supply category
The Water Study and project plans indicate the project will connect to an 8 -inch water line in Suva Street
and a 10-inch water line in Foster Bridge Boulevard.
The project site would be developed in compliance with the California Green Building Code which
implements water efficiency standards for appliances and fixtures that further reduce project water
usage. For these reasons, the proposed project would not require or result in the construction of new
water facilities. Impacts would be less than significant and no mitigation is required.
Wastewater
The proposed project would generate sewage which would be collected by the City’s local sewer pipe
system45 and transferred to the Sanitation Districts of Los Angeles County (SDLAC) for treatment and
disposal. The City’s Public Works Department, through its Utilities Division, manages the City’s local
sewer collection system which delivers local sewage to larger sewer trunk lines managed by the
SDLAC. The wastewater is then treated and discharged by SDLAC facilities.
The City is located within the jurisdictional boundaries of SDLAC District No. 2. The County operates
11 wastewater treatment facilities, 10 of which are classified as water reclamation plants. Wastewater
generated by the City is treated at the Joint Water Pollution Control Plant (JWPCP) in Carson. Serving
over 4.8 million residents, businesses and industries, the JWPCP currently provides primary and
secondary treatment with a design capacity of 400 million gallons per day (MGD) of wastewater and
currently treats an average of 260 MGD. All solids from the Joint Outfall System are processed at this
plant and anaerobically digested to produce methane gas. The methane gas is then burned in the Total
Energy Facility to produce enough electrical power to run the entire plant. After treatment, the effluent
is chlorinated and discharged offshore through two ocean outfalls46.
A Sewer Study prepared for the project indicated it would generate a sewage flow of 0.02 cubic feet per
second (cfs) (Appendix J). These wastes can be accommodated by the existing 10-inch line in Suva
Street just south of the site. In addition, the CalEEMod air quality computer model estimate d the project
would generate approximately 5,371 gallons of wastewater per day or 0.005 MGD (see Attachment A
in Appendix J). This amount of wastewater represents much less than 0.0017% of the 260 MGD daily
treatment volume of the JWPCP.
Although the proposed project would include construction of onsite water and wastewater distribution
and collection facilities necessary to serve the development (i.e., pipes, valves, meters, etc.), Los
Angeles Regional Water Quality Control Board wastewater treatment requirements , as well as State
Water Resources Control Board Division of Drinking Water potable water treatment requirements , are
more applicable to the service providers rather than the proposed project itself.
The City Public Works Department, through its Utilities Division, and the SCLAC are required to treat
wastewater in accordance with federal, state and local regulations. For example, sewage generated by
the proposed project would be treated in accordance with applicable waste discharge requirements
prior to being discharged. Both the City of Downey and the County of Los Angeles are subject to
compliance with State Water Resources Control Board Order No. 2006 -0003-DWQ, Statewide General
Waste Discharge Requirements for Sanitary Sewer Systems, as amended. State Water Resources
Control Board Order No. 2006-0003-DWQ establishes performance criteria and effluent limitations to
ensure that treated effluent discharges do not violate basin plan objectives for receiving waters. The
order ensures that the City and the SDLAC properly maintain and manage sewer systems and reduce
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
108 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
frequency and severity of sanitary sewer overflows and their potential impacts on public health, safety,
and the environment. The water and sewer fees paid by the project proponent would be used by the
utility providers, at least in part, to fund projects and programs necessary to meet their regulatory
obligation with respect to treatment requirements, treatment capacity, and supply reliability.
Based on the above, the potential impact with respect to wastewater treatment requirements would be
less than significant and no mitigation is required.
Stormwater
Construction of the proposed project would increase the net area of impervious surfaces on the site;
therefore, increased discharges to the City’s existing storm drain system would likely occur. As
described under Sections 4.10(a) and 4.10(c), the drainage patterns of the site would not subs tantially
change relative to existing conditions. The existing church on the project site would be replaced with 33
condominium units and associated pavement, parking, and landscaping. If not controlled, runoff from
the developed site would result in increased potential water contamination from urban pollutants that
are commonly found in surface parking lots, ornamental landscape planters , and from atmospheric
buildup on rooftops.
After onsite water treatment, the proposed project would drain toward Suva Street and Foster Bridge
Boulevard to the City’s existing storm drain system.
In accordance with the current Los Angeles Municipal NPDES permit, the project proponent would be
required to prepare and comply with a Low Impact Development (LID) Plan (Appendix F) which would
reduce the peak volume of stormwater runoff discharged into the City’s storm drain system and would
ensure that stormwater is retained onsite to the extent feasible. As such, the proposed project would
not require the construction or expansion of off -site storm water drainage facilities, as the project would
not contribute a substantial amount of new stormwater runoff relative to existing conditions. Impacts
would be less than significant and no mitigation is required.
Electric Power
The project site would be serviced by Southern California Edison (SCE). The project site would connect
to the existing power grid via existing underground lines within the Suva Street and Foster Bridge
Boulevard rights-of-way. New electrical connections to the project site would be installed via
underground lines. Although the project would require new electrical line tie-ins for service, it would not
result in the need for new electrical substations or electrical generating facilities. SCE conditions of
service would apply to the proposed project which is considered regulatory compliance and not
mitigation under CEQA. Therefore, the project would have a less than significant impact on electric
systems and no mitigation is required .
Natural Gas
The Southern California Gas Company (Gas Company) provide s natural gas services to the project
area. However, the project is proposed to be all-electric so it will have no impacts on natural gas supplies
or service.
Telecommunication Facilities
The project site is supported by telecommunication services for a variety of providers. Cable and
wireless telephone services are provided to the City by Verizon. Fiber optic cables and high-speed
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 109
City of Downey
connections for television and internet services are provided to the City by Time Warner. The project
site would be required to comply with all Federal, State , and local regulations for installation and wiring
of telecommunications to the project. With adherence to existing City and state Electrical, Building and
Safety code requirements, the project would have a less than significant impact on telecommunications
facilities and no mitigation is required .
b) Less than Significant Impact. As discussed in Section 4.18(a), the proposed project operation is
anticipated to require approximately 7,164 gallons of water per day, or 8.0 AFY. The proposed project
would connect to municipal water service provided by the City ’s Public Works Department through its
Utilities Division. Water Code Section 10910-10915 requires the preparation of a water supply
assessment (WSA) demonstrating sufficient water supplies for any subdivision that involves the
construction of more than 500 dwelling units, or the equivalent thereof. As the project includes 33
townhouse units it is below the established thresholds, and no WSA is required. However, to better
characterize the potential water use of the project, a Water Demand Study was prepared and its results
are described below.
The City of Downey extracts groundwater from the Central Basin which is located in Los Angeles
County, approximately 20 miles southeasterly of downtown Los Angeles. Groundwater in the Central
Basin provides a substantial portion of the water supply needed by residents and industries in the
overlying area. In the Central Basin Judgment of 1965 (Central Basin Judgment), the Superior Court
fixed allowable withdrawals from the Central Basin at a level that was greater than the amount of water
returned to the Central Basin through natural replenishment. The City was one of the original parties
involved in the Central Basin Judgment and has acquired additional water rights since that time.
Additionally, the 2014 Sustainable Groundwater Management Act directed DWR to establish initial
groundwater basin priorities for the basins identified and defined in DWR’s Bulletin 118. DWR finalized
the basin prioritization in June 2014 through the California Statewide Groundwater Elevation Monitoring
(CASGEM) program. The CASGEM basin prioritization program is being used by DWR to focus
resources towards implementing legislation to require all groundwater basins be monitored for seasonal
and long‐term groundwater elevation trends. DWR plans to evaluate the status of groundwater level
monitoring in “High” or “Medium” priority groundwater basins. If DWR determines that groundwater
levels in all or part of a High or Medium Priority basin are not being monitor ed, DWR will work
cooperatively with local entities to establish a monitoring program. Compliance with DWR requirements
allows the basin monitoring entities to be eligible to receive state water grants or loans.
City 2020 Urban Water Management Plan
The following is summarized from the City’s 2020 UWMP which is also discussed in Section 4.19(a).
The Downey Water Utilities Division of the Public Works Department is a Public Water System and is
regulated by the State Water Resources Control Board. It would provide water to the proposed project.
The City provides water service to an area with a 2020 population of 112,068 and is projected to have
a population of 117,081 by 2045. The City’s main water supply source is treated groundwater pumped
from the Central Basin, and the Central Basin Municipal Water District (CBMWD) is the City’s wholesale
water supplier. Supplemental imported water can also be purchased from the CBMWD for emergencies
in the event that system demands exceed the production capacity of the City’s groundwater wells and
recycled water supplies from CBMWD.
The Central Basin is one of two groundwater sub-basins in the Coastal Plain of the Los Angeles County
Groundwater Basin. It is comprised of Quaternary-age sediments (less than 1.8 million years old) of
gravel, sand, silt, and clay that were deposited from the erosion of nearby hills and mountains, and from
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
110 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
historical beaches and shallow ocean floors that covered the area in the past. Central Basin covers
approximately 270 square miles and its storage capacity is approximately 13.8 million acre-feet (AF)viii.
Drought Resiliency
State law requires UWMPs to address drought conditions based on single -year and multiple years
scenarios. According to the UWMP, the City has already started to reduce its reliance on imported water
supplies from 2015 to 2010. In addition, the City is projected to continue reducing its reliance on
imported water supplies through 2045 (p. 1-7, UWMP 2020). The City maintains connections to
imported water that can be purchased from MWD through CBMWD for emergencies. Water quality from
MWD relating to supply reliability is addressed separately in MWD’s 2020 Regional Urban Water
Management Plan. UWMP states that the City’s water supplies sources have been sufficient in meeting
the City’s historical water demands during an average year, a single dry year, and a five consecutive
year drought (p. 7-7, UWMP 2020). In addition, Table 4.19-2 (Single Dry Year Supply and Demand
Scenario), and Table 4.19-3 (Multiple Dry Year Supply and Demand Scenario ), shows the City’s water
supplies will be resilient through either drought scenarios through 2045.
Table 4.19-2
Single Dry Year Supply and Demand Scenario
Supply and Demand 2025 2030 2035 2040 20451
Total Supply 17,243 17,430 17,623 17,807 17,956
Total Demand 17,243 17,430 17,623 17,807 17,956
Difference 0 0 0 0 0
Source: Table 7-3, UWMP 2022
1 UWMP lists 2045 as an “optional” calculation
Table 4.19-3
Multiple Dry Year Supply and Demand Scenario
Year Supply/
Demand
Acre-Feet/Year
2025 2030 2035 2040 20451
1st Year
Total Supply 18,653 18,854 19,063 19,262 19,423
Todal Demand 18,653 18,854 19,063 19,262 19,423
Difference 0 0 0 0 0
2nd Year
Total Supply 19,015 19,221 19,434 19,637 19,801
Todal Demand 19,015 19,221 19,434 19,637 19,801
Difference 0 0 0 0 0
3rd Year
Total Supply 19,086 19,293 19,506 19,710 19,875
Todal Demand 19,086 19,293 19,506 19,710 19,875
Difference 0 0 0 0 0
4th Year
Total Supply 17,417 17,605 17,800 17,986 18,136
Todal Demand 17,417 17,605 17,800 17,986 18,136
Difference 0 0 0 0 0
5th Year
Total Supply 15,366 15,532 15,704 15,868 16,000
Todal Demand 15,366 15,532 15,704 15,868 16,000
Difference 0 0 0 0 0
Source: Table 7-4, UWMP 2020
viii one AF is equivalent to 326,000 gallons
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 111
City of Downey
In addition to drought resilience, the UWMP explains the City’s Water Shortage Contingency Plan which
is a detailed approach to how the City intends to act, or respond, in the case of an actual water shortage
contingency. The City will still manage water supplies to minimize the adverse impacts of water
shortages. The City’s plan for water usage during periods of shortage is designed to incorporate six
standard water shortage levels corresponding to progressive ranges from up to a 10, 20, 30, 40, and
50 percent shortage, and greater than a 50 percent shortage. For each declared water supply shortage
level, customers will be required to reduce their consumption by the percentage specified in the
corresponding water supply shortage level. To augment future supplies, the City will consider
groundwater storage, leased water, and imported water may be used more extensively as discussed in
the UWMP.
The proposed project would also be required to pay development impact fees to offset any project
impacts to existing infrastructure and fund future expansion. Further, the project site would be
developed in compliance with the California Green Building Code (which implements water efficiency
standards for appliances and fixtures), which would further reduce water usage. For these reasons,
impacts would be considered less than significant.
c) Less than Significant Impact. As previously discussed in Section 4.18(a), the proposed project
would connect to water service provided by the City’s Water Utility Division and would deliver sewage
into the City’s sewer collection system operated and maintained by the City’s Public Works Department
and treated by the LACSD. Wastewater generated from the project would be treated at the Joint Water
Pollution Control Plant (JWPCP). As described in Section 4.18(a) the amount of wastewater generated
by the proposed project would be relatively small compared to current and would not exceed the current
capacity of this wastewater plant. As such, impacts would be less than significant.
d) Less than Significant Impact. Significant impacts could occur if wastes from the proposed project
would exceed the existing permitted landfill capacity or violates federal, state, and local statutes and
regulations. Solid waste disposal services for the project site would be provided by Athens Services
(Athens). Athens offers waste and recycling collection, green waste recycling programs, organic waste
composting, special waste transportation, and transfer and materials recovery services to the City as
well as many other areas in Southern California.
The project proposes 33 townhomes that could generate approximately 100 new residents. Based on
the default CalEEMod solid waste generation rates, the proposed project would generate approximately
48 tons of solid waste per year (see Attachment A in Appendix A). This estimate is equal to 96,000
pounds per year, 263 pounds per day for the project, or 2.63 pounds per day per person. S olid waste
generated by the proposed project would be collected by Athens and transported to a local or regional
landfill operated by Waste Management under contract to Los Angeles County .
The increase in solid waste generation from implementation of the proposed project would be minimal
compared to the remaining capacity of the area landfills . Regional landfills in the Los Angeles area are
anticipated to have sufficient capacity to accommodate the minor increase in solid waste generation
attributable to the proposed project. Locally, the Downey Area Recycling and Transfer (DART) Center,
operated by Athens, is located on 6.2 acres at 9770 Washburn Road in Downey and accepts municipal
waste from the City. This landfill is regulated by the U.S. Environmental Protection Agency and the
applicable state laws. This facility buries trash and garbage below secured and stratified layers of dirt
and isolating material – it accepts tire, solid waste, hazardous waste, and inert material waste.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
112 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
According to the CalRecycle Website, t he DART facility47 currently has a daily permitted capacity of
5,000 tons per day. The project is expected to generate approximately 48 tons per year of waste which
represents one percent or a negligible amount of the landfill’s daily disposal rate.
Additionally, Article V, Chapter 8 (Ordinance No. 09 -1252) of the Downey Municipal Code requires that
100% of inert debris and at least 50% of the remaining construction and demolition debris generated
during a construction or demolition project be diverted from landfil l disposal.
The City of Downey has been required to reclaim or recycle at least 50% of domestic waste since 2000
according to the California Integrated Waste Management Act of 1989. Required compliance with this
regulation would reduce the project’s solid waste generation once occupied.
In addition to the DART facility, the combined remaining capacities at the County’s landfills would be
adequate to accommodate the proposed project. For these reasons, solid waste impacts resulting from
the construction and operation /occupancy of the proposed project would be considered less than
significant and no mitigation is required.
e) Less than Significant Impact. The project proponent is required to comply with all local, state, and
federal requirements for integrated waste management (e.g., recycling, green waste) and solid waste
disposal. The project would be required to comply with the City’s Recycling and Waste Handling
Requirement for construction and demolition debris, which requires at least 75% of all building and
demolition materials to be recycle d.
Athens Services currently transports all of Downey’s recycling to a Material Recovery Facility, where
recyclable materials are sorted and then diverted from local landfills. The proposed residential use
would not generate hazardous waste of any kind. Downey commercial and residential uses that are
serviced by Athens Services are already in compliance with AB 341. Therefore, a less than significant
impact would occur.
4.20 – Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project:
Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Substantially impair an adopted
emergency response plan or
emergency evacuation plan? □ □ □
b) Due to slope, prevailing winds, and
other factors, exacerbate wildfire
risks, and thereby expose project
occupants to pollutant concentrations
from a wildfire or the uncontrolled
spread of a wildfire?
□ □ □
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 113
City of Downey
c) Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result
in temporary or ongoing impacts to
the environment?
□ □ □
d) Expose people or structures to
significant risks, including downslope
or downstream flooding or landslides,
as a result of runoff, post-fire slope
instability, or drainage changes?
□ □ □
a) No Impact. The proposed project is located in an area that is fully developed and not considered a
high fire-threat area. No native vegetation occurs on the project site, and the street trees located along
Foster Bridge Boulevard and Suva Street are maintained by the City of Downey Public Works
Department and therefore would not contribute significantly to fire threat. The proposed project would
be served by the City of Downey Fire Department, and further supported by the Los Angeles County
Fire Department under a “mutual aid” agreement should fires occur. The project site is not located within
a very high or high fire hazard zone, as identified on the latest Fire Hazard Severity Zone (FHSZ) maps
prepared by the California Department of Forestry and Fire Protection (CALFIRE). Further, the project
site and surrounding area is not identified as being within or near any State Responsibility Area (SRA)
on CALFIRE maps.48 Therefore, the project would not substantially impair an adopted emergency
response plan or emergency evacuation plan and no impact would occur.
b) No Impact. As discussed above, the project site is not located within a fire hazard zone, as identified
on the latest FHSZ maps prepared by CALFIRE. There are no wildland conditions in the urbanized area
where the project site is located. Therefore, the project would not exacerbate wildfire risks, thereby
exposing project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a
wildfire. No impact would occur.
c) No Impact. The project site is not located within or near any State Responsibility Areas. As a result,
none of the project improvements would exacerbate fire risk or would result in a temporary or ongoing
impact from wildfires requiring the installation or maintenance of associated infrastructure that may
exacerbate fire risk or that may result in temporary or ongoing impacts to the environment . No impact
would occur.
d) No Impact. The project site is not located within or near any State Responsibility Areas. The project
site is also not located in a FEMA 100 -year flood floodplain. No impact would occur.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
114 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
4.21 – Mandatory Findings of Significance
Potentially
Significant
Impact
Less Than
Significant
with Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Does the project have the potential to
degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species,
cause a fish or wildlife population to
drop below self-sustaining levels,
threaten to eliminate a plant or
animal community, reduce the
number or restrict the range of a rare
or endangered plant or animal or
eliminate important examples of the
major periods of California history or
prehistory?
□ □ □
b) Does the project have impacts that
are individually limited, but
cumulatively considerable? □ □ □
c) Does the project have environmental
effects which will cause substantial
adverse effects on human beings,
either directly or indirectly?
□ □ □
a) Less than Significant with Mitigation Incorporated. The proposed project would not significantly
impact any scenic vistas, scenic resources, or the visual character of the area, as discussed in Section
4.1, Aesthetics, and would not result in excessive light or glare. The project site is located within a
suburbanized area with no significant natural habitat onsite. The project would not significantly impact
any sensitive plants, plant communities, fish, wildlife, or habitat for any sensitive species after
incorporation of Mitigation Measure BIO-1, as discussed in Section 4.4. Adverse impacts to
archeological and historic resources would be less than significant with implementation of Mitigation
Measures CUL-1 and TCR-1 through TCR-3. Adverse impacts to paleontological resources would be
less than significant with implementation of Mitigation Measures GEO-2 through GEO-5. With the
implementation of these mitigation measures, the proposed project would not have a significant adverse
impact with respect to the degradation of the quality of the environment . The proposed project would
not restrict the levels of fish and wildlife below sustaining levels or threaten to eliminate a plant or wildlife
community. No sensitive species are known to occupy the proposed project site. No rare or endangered
plants or animals are known to occur on the project site or would be removed as a result of the proposed
project.
b) Less than Significant with Mitigation Incorporated. Cumulative impacts can result from the
interactions of environmental changes resulting from one proposed project with changes resulting from
other past, present, and future projects that affect the same resources, utilities and infrastructure
systems, public services, transportation network elements, air basin, watershed, or other physical
conditions. Such impacts could be short -term and temporary, usually consisting of overlapping
construction impacts, as well as long term, due to the permanent land use c hanges and operational
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 115
City of Downey
characteristics involved with the project. Cumulative impacts would be less than significant with
mitigation incorporated, as further discussed herein.
Aesthetics
Impacts related to aesthetics at the project -level have no potential for cumulative impacts because
impacts are limited to on -site conditions and include no component that could result in similar impacts
over time or space. Therefore, no cumulative impacts related to this topic would occur.
Agricultural Resources
The analysis provided in Section 4.2 found that no individual impacts would occur; therefore, the project
could not contribute considerably to local agricultural or forestry.
Air Quality
The analysis provided in Section 4.3 related to air quality (criteria pollutants) and sensitive receptors
(local significance thresholds) found that impacts would be less than significant with regulatory
compliance and no mitigation was required. That section also determined the project would not
contribute considerably to cumulative air quality impacts in the region. The project would have no other
air quality impacts.
Biological Resources
The analysis provided in Section 4.4 found that no individual impacts to sensitive species would occur
with implementation of Mitigation Measure BIO-1. With mitigation, the project would not contribute
considerably to regional impacts on migratory birds or any sensitive species. The project would have
no other impacts on biological resources.
Cultural Resources
Loss of on-site archaeological resources could reduce or eliminate important information relevant to the
County of Los Angeles and the City of Downey. In Section 4.5, impacts related to historical and
archaeological resources were found to be potentially significant and require mitigation to reduce to less
than significant levels. Therefore, the project could contribute considerably to significant localized
cumulative impacts in this topic area. Mitigation Measures CUL-1 and TCR-1 through TCR-3 are
incorporated into the project requiring evaluation of any discovered potential cultural or archaeological
resources, the uniqueness of the sample, and appropriate steps to preserve or curate the artifact. This
would eliminate any potential loss of important local cultural or archaeological information that may be
buried under the project site. Therefore, the project would have no contribution to a cumulative loss of
important local or regional archaeological knowledge.
Energy
The analysis provided in Section 4.6 related to energy found that impacts would be less than significant.
Therefore, the project would not contribute to cumulative energy impacts.
Geology and Soils
Impacts related to geology at the project -level will be mitigated by Mitigation Measure GEO-1. Section
4.7 concluded the project impacts have no potential for cumulative impacts because impacts are limited
to on-site conditions and include no component that could result in similar impacts over time or space.
Loss of onsite paleontological resources could reduce or eliminate important information relevant to the
County of Los Angeles and the City of Downey. Impacts related to paleontological resources were found
to be potentially significant and require mitigation to reduce to less than significant levels. Therefore,
the project could contribute considerably to significant localized cumulative impacts in this topic area.
Mitigation Measures GEO-2 through GEO-5 are incorporated into the project requiring evaluation of any
discovered potential paleontological resources, the uniqueness of the sample, and appropriate steps to
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
116 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
preserve or curate the artifact. This would eliminate any potential loss of important local cultural or
paleontological information that may be buried under the project site. Therefore, the project would have
no contribution to a cumulative loss of important local or regional paleontological knowledge. No other
cumulative impacts related to this topic would occur.
Greenhouse Gas Emissions
As discussed in Section 4.8, climate change is the result of numerous, cumulative sources of
greenhouse gas emissions all over the world. The project would not contribute considerably to global
climate change.
Hazardous Materials
The analysis provided in Section 4.9(a-f) related to hazards and hazardous materials found that impacts
would be less than significant with implementation of Mitigation Measure HAZ-1 to address
unanticipated hazardous materials that may be found during grading, and Mitigation Measure HAZ-2 to
determine if the existing church contains asbestos -containing materials or lead-based paint prior to
demolition. Compliance with these measures and all applicable regulations related to the disposal and
storage of household waste would ensure that impacts would be less than significant. Therefore, the
project would not contribute to localized or regional cumulative impacts related to hazardous materials.
Airport Hazards
Section 4.9(g) indicates impacts related to airport hazards at the project -level have no potential for
cumulative impacts because impacts are limited to on -site conditions and include no component that
could result in similar impacts over time or space. Therefore, no cumulative impacts related to this topic
would occur.
Wildfires
The analysis provided in Section 4.9(h) and Section 4.20 found that no individual, local, or regional
impacts would occur; therefore, no cumulative impacts related to this topic would occur.
Groundwater Levels
The analysis provided in Section 4.10 (a) found that less than significant local, or regional impacts would
occur; therefore, while the project would contribute to individual, localized or regional cumulative
impacts, the project contribution would not be considerable.
Drainage/Water Quality
The analysis provided in Section 4.10, found that less than significant individual, local, or regional
impacts would occur; therefore, while the project would contribute to individual, localized or regional
cumulative impacts, the project contribution would not be considerable.
Flooding
The analysis provided in Section 4.10, found that no regional impacts would occur; therefore, no
cumulative impacts related to this topic would occur.
Land Use and Planning
The analysis provided in Section 4.11 related to Land Use and Planning found that impacts would be
less than significant even with implementation of a General Plan Amendment and Zone Change. While
the project would contribute to incremental localized or regional cumulative impacts, the project’s
contribution would not be considerable.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
Foster Bridge and Bluff Residential Project 117
City of Downey
Mineral Resources
The analysis provided in Section 4.1 2 related to mineral resources found that impacts there would be
no impact; therefore, while the project would contribute to localized or regional cumulative impacts, the
project contribution would not be considerable.
Noise
The project is not a substantial source of operational noise, as discussed in Section 4.1 3(a), and
therefore would not contribute considerably to noise levels in the immediate vicinity of the project. The
project would contribute to temporary increases in noise levels in the immediate project vicinity during
construction activities, however, these would be reduced to less than significant through incorporation
of Mitigation Measures NOI-1 through NOI-5. The project would increase traffic in the project area;
however, project traffic-related noise would not be discernible to the public and therefore would have
no considerable contribution to cumulative traffic -related noise. With mitigation incorporated, the project
would not contribute considerably to regional noise impacts. The project would have no other impacts
related to noise.
Population and Housing
The analysis provided in Section 4.1 4 related to Population and Housing found that no impacts would
result; therefore, no cumulative impacts related to this topic would occur.
Public Services
The analysis provided in Section 4.15 related to Public Services found that impacts would be less than
significant; therefore, while the project would contribute to localized cumulative impacts, the project
contribution would not be considerable.
Recreation
The analysis provided in Section 4.1 6 related to Recreation found that impacts would be less than
significant; therefore, while the project would contribute to localized cumulative impacts, the project
contribution would not be considerable.
Traffic and Transportation
The analysis provided in Section 4.17 found impacts related to transportation to be less than significant.
The project’s contribution to cumulative impacts to local and regional transportation facilities would not
be considerable.
Tribal Cultural Resources
Loss of on-site tribal cultural resources could reduce or eliminate important information relevant to the
County of Los Angeles and the City of Downey. Section 4.18 indicates impacts related to tribal cultural
resources were found to be potentially significant and require mitigation to reduce to less than significant
levels. Therefore, the project could contribute considerably to significant localized cumulative impacts
in this topic area. Mitigation Measures CUL-1 and TCR-1 through TCR-3 are incorporated into the
project requiring evaluation of any discovered potential archaeological or tribal cultural resources,
coordinating with local tribal groups for monitoring, determining the uniqueness of any resources
discovered, and appropriate steps to preserve or curate the artifact. This would eliminate any potential
loss of important local archaeological or tribal cultural information that may be buried under the project
site; therefore, the project would have no contribution to a cumulative loss of important local or regional
archaeological or tribal cultural knowledge.
Exhibit E (Attachment C)
4 – Evaluation of Environmental Impacts
118 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Utilities and Service Systems
The analysis provided in Section 4.19 related to Utilities and Service Systems found that impacts would
be less than significant; therefore, while the project would contribute to localized or regional cumulative
impacts, the project contribution would not be considerable.
Wildfire
The analysis provided in Section 4.20 related to wildfire found that impacts would not occur. Therefore,
the project would not contribute to local or regional cumulative impacts.
c) Less than Significant with Mitigation Incorporated. Based on the analysis of the project’s
impacts in the responses to items 4.1 through 4.20, there is no indication that this project would result
in substantial adverse effects on human beings. Section 4.9, Hazards and Hazardous Materials,
recommended Mitigation Measure HAZ-1 to address unanticipated hazardous materials that may be
found during grading, and Mitigation Measure HAZ-2 to determine if the existing church contains
asbestos-containing materials or lead -based paint prior to demolition. In addition, Section 4.13, Noise,
recommended Mitigation Measures NOI-1 through NOI-5 to preclude any significant noise impacts
during project construction . The analysis herein concludes that direct and indirect environmental effects
on humans would be less than significant with implementation of the recommended mitigation measures
and regulatory compliance.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project (17005) 119
City of Downey
5 Mitigation Summary
Aesthetics
AES-1 Enhanced Landscaping. Prior to issuance of the first occupancy permit, the developer
shall install enhanced landscaping along the northern boundary of the site. Its purpose is
to substantially block views and lighting from the project site onto the residence at 7336
Foster Bridge Boulevard just north of the site. The design and location of this enhanced
landscaping, primarily trees, shall be the responsibility of the City Planning Department.
Biological Resources
BIO-1 Nesting Bird Survey. To the extent feasible, construction activities shall be scheduled to
avoid the nesting season. If construction activities are scheduled to take place during the
nesting season, all impacts to nesting birds protected under the MBTA and California Fish
and Game Code must be avoided. The nesting season for most birds in Los Angeles County
extends from February 1 through September 1.
If it is not possible to schedule construction activities between September 1 and January 31,
then a pre-construction survey for nesting birds will be conducted by a qualified biologist to
ensure that no nests would be disturbed during project implementation. Th is survey will be
conducted no more than 5 days prior to the initiation of any site disturbance activities and
equipment mobilization, including tree, shrub, or vegetation removal, fence installation,
grading, etc. If project activities are delayed by more than 5 days, an additional nesting bird
survey will be performed. During this survey, the biologist will inspect all trees and other
potential nesting habitats (e.g., trees and shrubs) in and immediately adjacent to the impact
area for nests. Active nesting is present if a bird is building a nest, sitting in a nest, a nest
has eggs or chicks in it, or adults are observed carrying food to the nest. The results of the
survey(s) will be documented.
If an active nest is found sufficiently close to work areas to be disturbed by these activities,
the qualified biologist will determine the extent of a construction -free buffer zone to be
established around the nest (typically up to 300 feet for raptors an d up to 100 feet for other
species), to ensure that no nests of species protected by the Migratory Bird Treaty Act
(MBTA) and California Fish and Game Code will be disturbed during project implementation.
Within the buffer zone, no site disturbance and mob ilization of heavy equipment, including
but not limited to equipment staging, fence installation, clearing, grubbing, vegetation
removal, demolition, and grading will be permitted until the chicks have fledged.
A qualified biologist is an individual who has a degree in biological sciences or related
resource management with a minimum of two seasonal years post -degree experience
conducting surveys for nesting birds. During or following academic training, the quali fied
biologist will have achieved a high level of professional experience and knowledge in
biological sciences and special-status species identification, ecology, and habitat
requirements.
Exhibit E (Attachment C)
5 – Mitigation Summary
120 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
Cultural Resources
CUL-1 Unanticipated Resources. In the event that archaeological resources (sites, features, or
artifacts) are exposed during construction activities of the project, all construction work
occurring within 100 feet of the find shall immediately stop until a qualified archaeologist,
meeting the Secretary of the Interior’s Professio nal Qualification Standards, can evaluate
the significance of the find and determine whether or not additional study is warranted.
Depending upon the significance of the find under the California Environmental Quality Act
(CEQA: 14 CCR 15064.5(f): PRC Section 21083.2), the archaeologist may simply record
the find and allow work to continue. However, if the discovery proves significant under
CEQA, additional work, such as preparation of an archaeological treatment plan, testing, or
data recovery, may be warranted.
Geology/Soils/Paleontological Resources
GEO-1 Supplemental Geotechnical Report. Prior to issuance of a grading permit, the project
proponent shall retain a qualified geotechnical consultant to prepare a supplemental
geotechnical investigation as recommended by the “Geotechnical Due -Diligence
Investigation” prepared by Albus & Associates, Inc. dated February 6, 2023. The
supplemental report shall be certified by the City Engineer as adequate for the purposes
of design, permitting, and construction.
GEO-2 Conduct Paleontological Sensitivity Training for Construction Personnel. If
excavation below 6’ is required , the project proponent must retain a professional
paleontologist, who meets the qualifications set forth by the Society of Vertebrate
Paleontology, to conduct a Paleontological Sensitivity Training for construction
personnel before commencement of excavation activities. The tra ining would include a
handout and would focus on how to identify paleontological resources that may be
encountered during earthmoving activities, and the procedures to be followed in such an
event; the duties of paleontological monitors; notification and other procedures to follow
upon discovery of resources; and the general steps a qualified professional
paleontologist would follow in conducting a salvage investigation if one is necessary.
GEO-3 Conduct Periodic Paleontological Spot Checks During Grading and Earth-Moving
Activities. If excavation below 6’ is required , the project proponent must retain a
professional paleontologist, who meets the qualifications set forth by the Society of
Vertebrate Paleontology, to conduct periodic Paleontological Spot Checks beginning at
depths below six feet from the surface to determine if construction e xcavations extend
into older Quaternary deposits. After the initial Paleontological Spot Check, further
periodic checks would be conducted at the discretion of the qualified paleontologist. If
the qualified paleontologist determines that construction excavations have extended into
the older Quaternary deposits, construction monitoring for Paleontological Res ources
are required. The project proponent must retain a qualified paleontological monitor, who
would work under the guidance and direction of a professional paleontologist, who meets
the qualifications set forth by the Society of Vertebrate Paleontology. The paleontological
monitor must be present during all construction excavations (e.g., grading, trenching, or
clearing/grubbing) into the older Pleistocene alluvial deposits. Multiple earth -moving
construction activities may require multiple paleontologica l monitors. The frequency of
monitoring is based on the rate of excavation and grading activities, proximity to known
paleontological resources and/or unique geological features, the materials being
excavated (native versus artificial fill soils), and the depth of excavation, and if found, the
Exhibit E (Attachment C)
5 – Mitigation Summary
Foster Bridge and Bluff Residential Project 121
City of Downey
abundance and type of paleontological resources and/or unique geological features
encountered. Full-time monitoring can be reduced to part-time inspections if determined
adequate by the qualified professional paleontologist. Monitoring shall terminate when
grading and trenching activities on the site have been completed.
GEO-4 Cease Ground-Disturbing Activities and Implement Treatment Plan if
Paleontological Resources Are Encountered. In the event that paleontological
resources and or unique geological features are unearthed during ground -disturbing
activities, the paleontological monitor may halt or divert work away from the vicinity of
the find so that the find can be evaluated. A buffer area of at least 50 feet must be
established around the find where construction activities are not allowed to continue until
an appropriate paleontological treatment plan is approved by the project proponent and
the City. Work is allowed to continue outside of the buffer area. The project proponent
and City would coordinate with a professional paleontologist, who meets the
qualifications set forth by the Society of Vertebrate Paleontology, to develop an
appropriate treatment plan for the resources. Treatment may include implementation of
paleontological salvage excavations to remove the resource along with subsequent
laboratory processing and analysis or preservation in place. At the paleontologist’s
discretion and to reduce construction delay, the grading and excavation contractor would
assist in removing rock samples for initial processing.
GEO-5 Prepare Report Upon Completion of Monitoring Services. If paleontological
resources are found, upon completion of the activities identified under Mitigation
Measure GEO-4, the professional paleontologist would prepare a report summarizing
the results of the monitoring and salvaging efforts, the methodology use d in these efforts,
and a description of the fossils collected and their significance. The report would be
submitted to the project proponent, the City, the Natural History Museums of Los Angeles
County, and representatives of other appropriate or concerned agencies to signify the
satisfactory completion of the project and required mitigation measures.
Hazards/Hazardous Materials
HAZ-1 Inadvertent Hazmat Discovery. Prior to issuance of a grading permit, the project
proponent shall retain a qualified environmental professional (QEP) experienced with
remediating hazardous materials from infill urban construction sites. The QEP must be
on-call and summoned to the site immediately if any potentially hazardous materials are
found during grading. Grading must be halted within 100 feet of an area that appears to
contain hazardous materials. The QEP will ha lt grading as necessary to effectively
identify the potential contaminated materials, including directing any sampling and
laboratory testing that may be required.
If soils are found to be contaminated at levels that are only slightly in excess of applicable
residential standards, the QEP shall exercise professional discretion and have the option
to coordinate with the grading contractor and developer to either remove contaminated
soil and/or mix the contaminated soil with clean soil from either onsite or offsite to dilute
any contaminants to below applicable exposure standards for residential development.
Remediated areas must be retested to assure potential contaminant levels are below
applicable residential standards. The results of any testing shall be provided to the C ity
or other agencies as appropriate and no further action is needed. Any contaminated soil
that must be removed from the site shall be done by a licensed contractor and hauled to
Exhibit E (Attachment C)
5 – Mitigation Summary
122 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
a landfill approved for such materials. This measure shall be implemented to the
satisfaction of the City Community Development Department.
HAZ-2 ACMs and LBP Survey. Prior to demolition of any structures on the project site, the
developer shall retain qualified licensed environmental contractor(s) to survey the
existing onsite church building and any related structures for asbestos-containing
materials (ACMs) and Lead-Based Paints (LBPs). If the survey finds the presence of any
ACMs or LBPs on the site, the contractor(s) shall follow all relevant guidance from
affected regulatory agencies (e.g., CalEPA, SCAQMD, DTSC, County Health
Department, etc.) in terms of safe removal and disposal of the contaminated materials
as appropriate. The contractor(s) shall prepare and submit a final report to the City
Community Development Department within 30 days after completion of
demolition/removal for ACMs and LBPs on the project site.
Noise
NOI-1 Notify Residential Land Uses of Planned Construction Activities. This notice shall
be provided at least two (2) weeks prior to the start of any construction activities, describe
the noise control measures to be implemented by the project, and include the name and
phone number of the designated contact for the project proponent and the City of
Downey responsible for handling construction -related noise complaints (per MM NOI-5).
This notice shall be provided to the owner/occupants of residential dwelling units within
500 feet of construction work areas.
NOI-2 Restrict Work Hours. All construction-related work activities, including material
deliveries, shall be subject to the requirements of City Municipal Code Section 4.50.100.
Construction activities, including deliveries, shall occur only during the hours of 7 AM to
7 PM Monday to Friday and 9 AM to 6 PM on Saturday. No construction is to occur on
Sunday and holidays. The project proponent representative and/or its contractor shall
post a sign at all entrances to the construction site informing contractors, subcontractors,
other workers, etc. of this requirement.
NOI-3 Construction Equipment Selection, Use, and Noise Control Measures. The
following measures shall apply to construction equipment used at the project site:
a. Contractors shall use the smallest size equipment capable of safely completing
work activities.
b. Construction staging shall occur as far away from residential land uses as
possible given site and active work constraints.
c. Electric hook-ups shall be provided for stationary equipment (e.g., pumps,
compressors, welding sets). If it is not feasible to provide an electric hook -up, the
project proponent shall ensure mitigation measures 3a and 3d are implemented.
d. All stationary noise generating equipment shall be shielded and located as far as
possible from residential land uses given site and active work constraints.
Shielding may consist of existing vacant structures or a three -or four-sided
enclosure provided the structure/enclosure breaks the line of sight between the
equipment and the receptor and provides for proper ventilation and equipment
operation.
e. Heavy equipment engines shall be equipped with standard noise suppression
devices such as mufflers, engine covers, and engine/mechanical isolators,
Exhibit E (Attachment C)
5 – Mitigation Summary
Foster Bridge and Bluff Residential Project 123
City of Downey
mounts, and be maintained in accordance with manufacturer’s recommendations
during active construction activities.
f. Pneumatic tools shall include a suppression device on the compressed air
exhaust.
g. No radios or other amplified sound devices shall be audible beyond the property
line of the construction site.
NOI-4 Implement Construction Activity Noise Control Measures. The following measures
shall apply to project construction activities:
a. Demolition: Activities shall be sequenced to take advantage of existing
shielding/noise reduction provided by existing buildings or parts of buildings and
methods that minimize noise and vibration, such as sawing concrete blocks,
prohibiting on-site hydraulic breakers, crushing or other pulverization activities,
shall be employed during project construction.
b. Demolition, Site Preparation, Grading, and Foundation Work: During all
demolition, site preparation, grading, and structure foundation work activities, a
physical noise barrier shall be installed and maintained around the site perimeter
to the maximum extent feasible given site constraints and access requirements.
The noise barrier shall extend to a height of eight (8) feet above grade. Potential
barrier options capable of reducing construction noise levels could include, but
are not limited to:
i. A concrete, wood, or other barrier installed at -grade (or mounted to structures
located at-grade, such as a K-Rail), and consisting of a solid material (i.e.,
free of openings or gaps other than weep holes) that has a minimum rated
transmission loss value of 20 dB.
ii. Commercially available acoustic panels or other products such as acoustic
barrier blankets that have a minimum sound transmission class (STC) or
transmission loss value of 20 dB.
iii. Any combination of noise barriers and commercial products capable of
achieving required construction noise reductions during demolition, site
preparation, grading, and structure foundation work activities.
iv. The noise barrier may be removed following the completion of building
foundation work (i.e., it is not necessary once framing and typical vertical
building construction begins provided no other grading, foundation, etc. work
is still occurring on-site).
NOI-5 Prepare a Construction Noise Complaint Plan. The project proponent shall prepare a
Construction Noise Complaint Plan that shall:
a. Identify the name and/or title and contact information (including phone number
and email) for a designated project and City representative responsible for
addressing construction-related noise issues.
b. Includes procedures describing how the designated project representative will
receive, respond, and resolve construction noise complaints.
Exhibit E (Attachment C)
5 – Mitigation Summary
124 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
c. At a minimum, upon receipt of a noise complaint, the project representative shall
notify the City contact, identify the noise source generating the complaint,
determine the cause of the complaint, and take steps to resolve the complaint.
Tribal Cultural Resources
TCR-1 Tribal Monitor. The project applicant/lead agency shall retain a Native American Monitor
from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The monitor
shall be retained prior to the commencement of any “ground -disturbing activity” for the
subject project at all project locations (i.e., both on -site and any off-site locations that are
included in the project description/definition and/or required in connection with the project,
such as public improvement work). “Ground -disturbing activity” shall include, but is not
limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and trenching.
A copy of the executed monitoring agreement shall be submitted to the lead agency prior to
the commencement of any ground -disturbing activity, or the issuance of any permit
necessary to commence a ground-disturbing activity.
The monitor will complete daily monitoring logs that will provide descriptions of the relevant
ground-disturbing activities, the type of construction activities performed, locations of
ground-disturbing activities, soil types, cultural-related materials, and any other facts,
conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and
describe any discovered TCRs, including but not limited to, Native American cultural and
historical artifacts, remains, places of significance, etc., (collectively, tribal cultural
resources, or “TCR”), as well as any discovered Native American (ancestral) human remains
and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency
upon written request to the Tribe.
On-site tribal monitoring shall conclude upon the latter of the following (1) written
confirmation to the Kizh from a designated point of contact for the project applicant/lead
agency that all ground-disturbing activities and phases that may involve ground -disturbing
activities on the project site or in connection with the project are complete; or (2) a
determination and written notification by the Kizh to the project applicant/lead agency that
no future, planned construction activity and/or development/con struction phase at the project
site possesses the potential to impact Kizh TCRs.
TCR-2 Unanticipated Discoveries. Upon discovery of any Tribal Cultural Resources (TCRs), all
construction activities in the immediate vicinity of the discovery shall cease (i.e., not less
than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully
assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all
discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole
discretion, and for any purpose the Tribe deems appropriate, including for educational,
cultural and/or historic purposes.
TCR-3 Human Remains. Native American human remains are defined in PRC 5097.98 (d)(1) as
an inhumation or cremation, and in any state of decomposition or skeletal completeness.
Funerary objects, called associated grave goods in Public Resources Code Section
5097.98, are also to be treated according to this statute. If Native American human remains
and/or grave goods are discovered or recognized on the project site, then Public Resource
Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. Human
Exhibit E (Attachment C)
5 – Mitigation Summary
Foster Bridge and Bluff Residential Project 125
City of Downey
remains and grave/burial goods shall be treated alike per California Public Resources Code
section 5097.98(d)(1) and (2). Preservation in place (i.e., avoidance) is the preferred manner
of treatment for discovered human remains and/or burial goods. Any dis covery of human
remains/burial goods shall be kept confidential to prevent further disturbance.
Exhibit E (Attachment C)
Foster Bridge and Bluff Residential Project (17005) 126
City of Downey
6 References
6.1 List of Preparers
City of Downey (Lead Agency)
Community Development Department
11111 Brookshire Avenue
Downey, California 90241
(562) 904-7154
• Irma Huitron, Community Development Director
• Edwin Norris, Deputy Director of Public Works
• Alfonso Hernandez, Principal Planner
MIG (Environmental Analysis)
1650 Spruce Street, Suite 106
Riverside, California 92507
951-787-9222
▪ Bob Prasse, Director of Environmental Services
▪ Kent Norton, AICP, REPA, Senior Project Manager
▪ Chris Dugan, Director of Air Quality, Greenhouse Gas, and Noise Services
▪ Phillip Gleason, Senior Environmental Analyst
▪ Cameron Hile, Senior Analyst
▪ William Deeman, ACES Technical Analyst
▪ Betty Kempton, Ph.D, Senior Biologist
Ganddini Group (Transportation)
555 Parkcenter Drive, Suite 225
Santa Ana, California 92705
(714) 795-3100
▪ Giancarlo Ganddini, PE, PTP, Principal
▪ Bryan Crawford, Senior Transportation Planner
CRM TECH (Cultural Resources)
1016 East Cooley Drive, Suite A/B
Colton, California 92507
(909) 824-6400
• Michael Hogan, Principal Investigator
• Bai “Tom” Tang, Principal Investigator
6.2 Persons and Organizations Consulted
▪ N/A
Exhibit E (Attachment C)
6 – References
Foster Bridge and Bluff Residential Project (17005) 127
City of Downey
6.3 Bibliography
1 City of Downey. Downey General Plan (Downey Vision 2025). https://www.downeyca.org/our-
city/departments/community-development/planning/general-plan-
map#:~:text=The%20General%20Plan%2C%20Downey%20Vision%202025%2C%20is%20a,add
ress%20further%20changes%20in%20the%20City%20of%20Downey [Accessed July 2023].
2 California Department of Transportation. California State Scenic Highways: State Scenic Highway
Map. https://dot.ca.gov/programs/design/lap -landscape-architecture-and-community-livability/lap-
liv-i-scenic-highways [Accessed July 2023].
3 California Department of Conservation. Farmland Mapping and Monitoring Program.
ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf [Accessed July 2023].
4 California Department of Conservation. Williamson Act Program.
ftp://ftp.consrv.ca.gov/pub/dlrp/wa/ [Accessed July 2023].
5 MIG, Inc. Air Quality, Greenhouse Gas, and Energy Analysis for the Townhome Community
Residential Project at 7360 Foster Bridge Blvd. in Downey, CA. September 20, 2023 (Appendix A).
6 Ganddini Group. 7360 Foster Bridge Residential Project Vehicle Miles Traveled (VMT) Screening
Assessment. November 15, 2023 (Appendix H)
7 South Coast Air Quality Management District (SCAQMD) 1993. Air Quality Analysis Handbook.
Diamond Bar, CA. 1993. http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-
handbook. [Accessed July 2023].
8 California Department of Fish and Wildlife (CDFW), California Natural Diversity Database (CNDDB).
Website accessed August 3, 2023](Appendix B).
9 California Department of Fish and Wildlife. RareFind 5 Database.
http://www.dfg.ca.gov/biogeodata/cnddb/mapsanddata.asp [Accessed July 2023].
10 U.S. Fish and Wildlife Service. FWS Critical Habitat for Threatened & Endangered Species.
http://ecos.fws.gov/ecp/report/table/critical-habitat.html [Accessed July 2023].
11 United States Fish and Wildlife Service. National Wetlands Inventory.
https://www.fws.gov/wetlands/data/mapper.html [Accessed July 2023].
12 California Department of Fish and Wildlife. Natural Community Conservation Planning.
http://www.dfg.ca.gov/habcon/nccp/ [Accessed July 2023].
13 CRM TECH. Preliminary Draft, Cultural Resources Assessment and Paleontological Assessment,
Foster Bridge and Bluff Residential Project, City of Downey, CA. October 13, 2023 (Appendix C)
14 Albus Associates. Geotechnical Due Diligence Investigation, Proposed Multi -Family Residential
Development, 7360 Foster Bridge Boulevard, Downey, California . February 6, 2023 (Appendix D).
15 City of Downey. Downey General Plan Safety Element. Figure SCS-2: Earthquake Faults. 2005.
16 California Division of Mines and Geology (CDMG). Seismic Hazard Zone Report for the South Gate
7.5-Minute Quadrangles, Los Angeles County, California. Seismic Hazard Zone Report 034. 1998.
17 United States Environmental Protection Agency. Frequently Asked Questions About Global
Warming and Climate Change. Back to Basics. April 2009.
Exhibit E (Attachment C)
6 - References
128 Initial Study and Mitigated Negative Declaration
Public Review Draft November 2023
18 SCS Engineers. Phase I Environmental Site Assessment, 7360 Foster Bridge Boulevard, Downey,
California. January 31, 2023 (Appendix E)
19 California Environmental Protection Agency. Cortese List Data Resources.
http://www.calepa.ca.gov/sitecleanup/corteselist/ [Accessed July 2023].
20 California Department of Toxic Substances Control. DTSC’s Hazardous Waste and Substances
Site List – Site Cleanup (Cortese List). http://www.dtsc.ca.gov/SiteCleanup/Cortese_List.cfm
[Accessed July 2023].
21 California State Water Resources Control Board. GeoTracker.
https://geotracker.waterboards.ca.gov/ [Accessed July 2023].
22 California State Water Resources Control Board. Sites Identified with Waste Constituents Above
Hazardous Waste Levels Outside the Waste Management Unit.
http://www.calepa.ca.gov/files/2016/10/SiteCleanup -CorteseList-CurrentList.pdf [Accessed July
2023].
23 California State Water Resources Control Board. List of Active CDO and CAO.
http://www.calepa.ca.gov/sitecleanup/corteselist/ [Accessed July 2023].
24 California Department of Toxic Substances Control. Cortese List: Section 65962.5(a).
https://www.calepa.ca.gov/sitecleanup/corteselist/section -65962-5a/ [Accessed July 2023].
25 AirNav, LLC. Airport Information. http://www.airnav.com [Accessed July 2023].
26 California Department of Forestry and Fire Protection (CalFIRE). Fire Hazard Severity Zones
Maps. https://osfm.fire.ca.gov/divisions/wildfire -planning-engineering/wildland-hazards-building-
codes/fire-hazard-severity-zones-maps/. [Accessed July 2023].
27 Advanced Civil Group, Inc. Preliminary Low Impact Development (LID) Plan. June 6, 2023
(Appendix F)
28 Sanitation Districts of Los Angeles County. Joint Outfall System Water Reclamation Plants.
http://www.lacsd.org/wastewater/wwfacilities/joint_outfall_system_wrp/default.asp [Accessed July
2023].
29 Federal Emergency Management Agency. Flood Insurance Rate Map. Map Number
06037C1810F. September 26, 2008. https://msc.fema.gov/portal/home. [Accessed July 2023].
30 California Department of Water Resources (DWR), Division of Safety of Dams (DSOD), California
Dam Breach Inundation Maps https://fmds.water.ca.gov/maps/damim/ [website accessed 9-22-23]
31 California Department of Conservation Division of Mines: Open Data and Maps CNRA. https://maps-
cnra-cadoc.opendata.arcgis.com/ [Accessed July 2023].
32 California Department of Conservation Division of Mines: Open Data and Maps CNRA. https://maps-
cnra-cadoc.opendata.arcgis.com/ [Accessed July 2023].
33 MIG, Inc. Noise and Vibration Analysis for Townhome Community Residential Project at 7360 Foster
Bridge Boulevard in Downey, CA. September 22, 2023 (Appendix G).
34 California Department of Finance. Population and Housing Estimates.
https://www.dof.ca.gov/Forecasting/Demographics/Estimates/E -5/ [Accessed July 2023].
35 Downey Unified School District Website [accessed 9 -21-23] https://web.dusd.net/
Exhibit E (Attachment C)
6 – References
Foster Bridge and Bluff Residential Project (17005) 129
City of Downey
36 California Department of Education. DataQuest database [Website accessed 9-22-23]
https://dq.cde.ca.gov/dataquest/dqcensus/enrgrdlevels.aspx?cds=1964451&agglevel=District&yea
r=2020-21&ro=y
37 Downey Unified School District. Facility Master Plan. 2022 [Website accessed 9-23-23]
https://web.dusd.net/wp-content/uploads/2023/01/DUSD_FacilitiesMasterPlan.pdf
38 City of Downey. Parks and Open Space Master Plan. 2016.
39 Ganddini Group. 7360 Foster Bridge Residential Project Vehicle Miles Traveled (VMT) Screening
Assessment. November 15, 2023 (Appendix H).
40 Los Angeles County Metropolitan Transportation Authority . Website, maps and schedules
[Website accessed 9-23-23] https://www.metro.net/riding/guide/
41 Metrolink Website [Accessed 9-24-23] https://metrolinktrains.com/rider-info/general-info/maps/
42 Los Angeles County Public Works Department. Transportation Impact Analysis Guidelines. July 23,
2020.
43 Institute of Transportation Engineers (ITE). Trip Generation Manual (11th Edition, 2021).
44 Alan Short, PE. Water Demand Study for City of Downey, Tentative Tract No. 84168, 7360 Foster
Bridge Blvd. May 8, 2023a (Appendix J)
45 Tetra Tech. City of Downey Sewer System Management Plan. May 2023.
46 Sanitation Districts of Los Angeles County [Website accessed 9 -23-23]
https://www.lacsd.org/services/wastewater-sewage/facilities/joint-water-pollution-control-plant
47 CalRecycle Website, Solid Waste Information System (SWIS) database [Accessed 9 -25-23]
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/3649?siteID=1111
48 California Department of Forestry and Fire Protection. California State Responsibility Areas Map.
https://www.arcgis.com/home/item.html?id=5ac1dae3cb2544629a845d9a19e83991 [Accessed
July 2023].
Exhibit E (Attachment C)