HomeMy WebLinkAbout2. PLN-19-00132 12021 Woodruff Ave.STAFF REPORT
PLANNING DIVISION
DATE: FEBRUARY 17, 2021
TO: PLANNING COMMISSION
SUBMITTED BY: ALDO E. SCHINDLER, DIRECTOR OF COMMUNITY DEVELOPMENT
REVIEWED BY:CRYSTAL LANDAVAZO, CITY PLANNER
PREPARED BY: ALFONSO HERNANDEZ, SENIOR PLANNER
SUBJECT: PLN-19-00132 (SITE PLAN REVIEW, CONDITIONAL USE PERMIT,
ZONE CHANGE) – A REQUEST TO CONSTRUCT A 44,162 SQUARE
FOOT INDUSTRIAL TILT-UP BUILDING TO BE USED AS A FREIGHT
TERMINAL, AND APPROVE A ZONE CHANGE FROM P-B (PARKING
BUFFER) TO M-2 (GENERAL MANUFACTURING).
LOCATION: 12021 WOODRUFF AVENUE
ZONING: M-2 (GENERAL MANUFACTURING)
REPORT SUMMARY
This application includes three separate entitlement requests: Site Plan Review, Conditional
Use Permit, and Zone Change. A Site Plan Review (SPR) is required to allow for the
construction of a 44,162 square foot industrial tilt-up building. The project is subject to a
Conditional Use Permit (CUP) due to the proposed use as a Freight Terminal. In addition to the
storage component for the freight terminal, 8,020 square feet will be used as a complementary
accessory office use. Lastly, a Zone Change (ZC) is requested to remove the zoning
designation of P-B (Parking Buffer) from the property so the entire lot has one zoning
designation M-2 (General Manufacturing).
The project underwent an Initial Study, pursuant to the California Environmental Quality Act.
The results of the Initial Study found that identified impacts would be “less than significant with
mitigation incorporated.” Therefore, a Mitigated Negative Declaration was produced for the
project.
Based on the analysis contained in this report, staff is recommending the Planning Commission
adopt the following titled resolution:
1.A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
DOWNEY APPROVING A SITE PLAN REVIEW AND CONDITIONAL USE
PERMIT (PLN-19-00132) AND MITIGATED NEGATIVE DECLARATION
WITH MITIGATION MONITORING AND REPORTING PROGRAM,
THEREBY ALLOWING THE CONSTRUCTION OF A 44,162 SQUARE
FOOT INDUSTRIAL TILT-UP BUILDING TO BE USED AS A FREIGHT
TERMINAL LOCATED AT 12021 WOODRUFF AVENUE.
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2.A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF DOWNEY
RECOMMENDING THAT THE CITY COUNCIL APPROVE A ZONING MAP
AMENDMENT (PLN-19-00132), THEREBY CHANGING THE ZONING
DESIGNATION OF THE EAST PORTION OF THE PROPERTY FROM P-B
(PARKING BUFFER) TO M-2 (GENERAL MANUFACTURING) LOCATED AT
12021 WOODRUFF AVENUE.
BACKGROUND
The site is currently developed with a 193,451 square foot industrial building. The existing use
on the property is heavy manufacturing and rubber processing. The company, Kirkhill
Manufacturing Inc., has been a rubber manufacturer in the City of Downey since 1951. The
company served as a complimentary component of the city’s, previously established, aerospace
industry. The site was first developed in 1951starting with 74,662 square, and later expanding to
the existing 193,451 square feet with additions in 1959, 1962, and 1971. No other major
renovations have occurred since that time.
Existing Front Elevation
Overall, the site is 6.31 acres in size with one street frontage. The property is located on the
west side of Woodruff Avenue between the intersections of Stewart and Gray Road and
Washburn Road. The subject site is located within the city’s M-2 zone, and has a General Plan
land use designation of General Manufacturing. Directly to the rear, abutting the subject
property, are three M-2 zoned properties all occupied with industrial uses. Adjacent to the north
and east are M-2 zoned properties developed primarily with industrial uses. The parcels directly
to the south are also zoned M-2, but are occupied by commercial uses, such as an adult school,
banquet hall, church, medical office, and office.
On August 22, 2019 the applicant filed a request for a SPR, CUP, and Zone Chage.
Subsequently, the applicant was issued an incomplete letter on September 25, 2019. After
submitting all required documents, on January 28, 2021, the application was deemed complete
on February 1, 2021. On February 4, 2021, notice of the pending public hearing was published
in the Downey Patriot and mailed to all property owners within 500 feet of the subject property.
DISCUSSION
Site Plan Review
The SPR includes evaluations of the proposed site changes, landscaping, circulation, and
compliance with the Downey Municipal Code. The changes to the existing site include the
demolition of all buildings totaling 193,451 square feet and complete grading of the entire site.
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The proposed project will consist of a new 44,162 square foot 36 foot tall concrete tilt-up
building. The majority of the building (36,142 square feet) will be used as a warehouse, and the
remaining portion (8,020 square feet) will be used as office. New landscaping, parking, and
pedestrian access is harmoniously designed at the front of the property.
Major development standards for this project are as follows:
Standard Minimum/
Maximums
Proposed
Floor Area Ratio Not Required 0.16
Lot Coverage Not Required 16%
Building Height 45 ft. / 3 stories 35 ft./ 1 story
Minimum Required
Landscaping for Parking Area
27,472 sq. ft.
(10% of site)
27,511 sq. ft.
(10% of site)
Setbacks:
Front
Rear
Side
10 ft.
20 ft.
Not Required
71 ft.
40 ft.
174 ft.
Parking 56 Stalls 56 Stalls
(including 4 ADA
accessible space)
76 Freight Truck Stalls
All elements of the proposed SPR are consistent with the Downey Municipal Code, and no
deviations or special privileges are requested as a part of this proposal.
Architecture
The proposed design for the building is most closely associated with contemporary style
architecture. The construction method will include large concrete tilt-up panels comprising the
vast majority of the sides and rear elevations with nominal glazing. The front elevation will also
include concrete panels, however with heavy glazing. The side and rear elevations will have
minimal visibility from the public right-of-way due to the proposed landscaping and building
placement. As such, the concrete panels at the sides and rear will be flat with minimal texture
and the majority will be painted “Pure White” in color. Other portions of these panels,
surrounding the windows and above the loading bays, will be painted two different shades of
grey (“Sable” and “First Star”) to provide variety and contrast. Various score lines are
incorporated into the building for aesthetic purposes.
The front elevation provides the most design integration and major points of interest as this
façade will have the greatest impact on the streetscape. This elevation is comprised of concrete
panels as well, but heavy glazing and modulation is also provided. The front elevation also
incorporates modulation with seven different setback measurements ranging from 71’ to 82’
from the front property line. In addition to the modulation there are also two canopies provided
above the main entrance. These canopies are painted with an accent color of “New Dark
Green”, and are treated with a composite wood plank underneath which provides visual interest
above when standing beneath these elements. The color of all the concrete panels in the front
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will be “Pure White”. Although the color will be the same throughout, there are two different
types of treatments applied to the concrete panels; flat with minimal texture, and panels with
closely spaced scoring. Composite wood planking will be located vertically at five different areas
of the building intended to provide contrast and dimension. A primary element of the font façade
is the significant amount of window placement located throughout the front elevation with a total
of thirty-eight percent (38%) of the front elevation dedicated to glazing. Dense landscaping,
including trees, and lighting fixtures are used to further accent the building and subject site.
Front View of Proposed Building
Front Side View of Proposed Building
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Conditional Use Permit
Per the Downey Municipal Code a CUP is required for the operation of a “Freight Terminal”
business. As previously stated, the majority of the building (36,142 square feet) will be used as
a warehouse, and the remaining portion (8,020 square feet) will be used as office. Items stored
on site will be transported by freights on and off the site continuously and frequently to
commercial and other industrial locations. Presumably, as the applicant has indicated, the
destination for the majority of the products coming to and from the facility will be the Ports of Los
Angeles and Long Beach. The office component will be used to support the primary freight
terminal use.
The facility will have a total of 70 loading docks and 76 freight truck parking stalls, with a capacity
for 100 employees at any given time. The property owner and developer is Prologis Inc., an
industrial real estate company; there is currently no proposed tenant. Vehicles and freight trucks
are allowed to access the site at two separate entrances via two 40’ wide driveways allowing a
disbursement of traffic North towards Firestone Boulevard and South towards Imperial Highway.
Woodruff Avenue and adjoining corridors that will be used by the freight trucks are all Arterial
streets which are designed to accommodate the type of traffic that will be generated by the
proposed development. During the CEQA review, there were multiple intersections and corridors
evaluated for “Level of Service” (LOS). These intersections include Woodruff/Washburn,
Woodruff/Stewart & Gray, Firestone/Stewart & Gray, and I-605 ramps/Firestone. The analysis
determined that the overall LOS standard for these intersections, as established by the City’s
General Plan, will remain consistent. The acceptable routes in the City’s Truck Route Map show
very minimal interaction near residential corridors when attempting to access the I-605 or I-105, at
no time shall freight trucks access residential corridors.
Lastly, the proposed hours of operation for the business will be twenty-four (24) hours a day
seven (7) days a week. Research conducted of other freight terminal facilities in nearby cities
found that these hours of operation are a common practice. In addition, the one other freight
terminal operation found in the City is allowed to operate twenty-four (24) hours a day Monday
through Friday, five (5) hours on Saturday, and four (4) hours on Sunday. The applicant has
requested that they be allowed to operate twenty-four (24) hours a day every day for this site. The
other freight terminal business was approved in 2003, and the reports specify that the hours of
operation for that project were made at the request of the applicant and not an effort to mitigate
potential impacts. Noise was analyzed as part of a CEQA initial study and Mitigated Negative
Declaration prepared for this project. The studies concluded that impacts related to the operation
of the facility would be less than significant or would not create an impact in comparison to the
current use on site and nearby uses. Specifically, noise levels from the activity on the site will
produce a maximum measurement of 42 dBA Leq, day or night, when measured from the closest
nearby residential property. These levels are well below what is required in an industrial zone
which is 70 dBA, day or night. The noise levels that will reach the nearby residential properties are
comparable to that of the City’s residential zone requirements which are to be no more than 55
dBA in the daytime and 45 dBA at night. Noise levels will be at the specified measurement of 42
dBA Leq due to the proximity of the nearest residential property, which is 200’ from the subject
property and 300’ from loading activity, and buffering created by the surrounding industrial
buildings.
Zone Change
The site currently consists of two zoning designations, M-2 and P-B. The P-B zoning is located
along the eastern portion of the property line throughout the entire width of the parcel. The zone
change is requested to eliminate the P-B zone and designate the entire lot as an M-2 zone. The
M-2 designation is consistent with the adjacent lots along Woodruff Avenue. The proposed
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zoning is also consistent with the General Plan land use designation (General Manufacturing)
for the site.
The P-B zone is identified as obsolete within the City’s Zoning Code and holds no applicable
provisions upon the subject property. Standards previously applicable to the P-B zone were
eliminated as part of a previous comprehensive update to the Zoning Ordinance, on October 14,
2008. Although the zone was eliminated from the code, modifications were not made to the
zoning map and the map still contains the P-B zones. This application is an effort to amend the
City’s Zoning Map to achieve consistency with the Downey Municipal Code and General Plan.
DEVELOPMENT REVIEW COMMITTEE
The Development Review Committee (DRC) discussed and evaluated the project as it pertains
to Planning, Police, Fire, Public Works, and Building and Safety matters. The Public Works
Department expressed interest related to traffic impacts the project may produce. The Mitigated
Negative Declaration found that transportation impacts would increase, but to less-than-
significant levels. The overall Level of Service standard required in the City’s General Plan will
remain consistent. No other departments expressed concerns or opposition over the project,
and issued standard conditions. Recommended conditions of approval have been included in
the attached Resolution to address potential impacts.
ENVIRONMENTAL ANALYSIS
In accordance with the provisions of the California Environmental Quality Act (CEQA), an Initial
Study for Environmental Impacts was prepared for the proposed project. To complete the
environmental analysis, the City of Downey contracted with Dudek, an environmental and
engineering firm. Dudek was selected because of their experience with similar types of projects.
During this analysis, potential impacts from air quality, traffic, noise, and geology, among others,
were reviewed. Upon completion of the initial study, it was found that the project could have
less than significant impacts with mitigations incorporated on biological resources, cultural
resources, geology and soils, hazards and hazardous materials, noise, and tribal cultural
resources.
A copy of the Mitigation Monitoring and Reporting Program, response to comments and errata,
and the Initial Study/Mitigated Negative Declaration (IS/MND) is attached to this report for
reference. A 30-day public comment period on the proposed IS/MND was provided starting
December 15, 2020 and ended on January 14, 2021. Below is a brief summary of the
comments received along with an explanation of the proposed mitigations.
Staff received comments on the IS/MND from the following:
Miya Edmonson – IGR/CEQA Branch Chief, California Department of Transportation
The letter can be found in Exhibit E “Initial Study/Mitigated Negative Declaration, Responses to
Comments, and Errata for the 12021 Woodruff Avenue Industrial Building Project (PLN-19-
00132).” In summary, the correspondence does not state a specific concern or question
regarding the environment impact analysis. The comments, instead, concur that it can be
presumed that traffic impacts and greenhouse gas emissions will be less than significant.
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Biological Resources
Potential impacts to biological resources is limited to the nesting habits of local birds. Although
no native habitat is located on the project site or in the immediate surrounding area, wildlife
species that could occur on the site include common species typically found in urbanized
settings, such as house sparrow (Passer domesticus), mourning dove (Zenaida macroura), and
western fence lizard (Sceloporus occidentalis). These species would not be considered
candidate, sensitive, or special-status wildlife species. Nonetheless, due to the landscaping
currently found on site it is possible these bird species may choose to nest on the site.
Therefore, if construction activities were to occur during nesting season (typically between
February 1 and September 1), the project applicant would be required to conduct pre-
construction nesting bird surveys to ensure that no nests are located within the ornamental trees
adjacent to the project site as outlined in the following mitigation measure.
MM-BIO-1: Prior to the issuance of a demolition, grading, and/or building permit for
activities during the avian nesting season (i.e., February 1 and September 1), the project
applicant shall submit a survey for active nests to the City of Downey Building & Safety
Division conducted by a qualified biologist a maximum of 1 week prior to the activities to
determine the presence/absence, location, and status of any active nests on or adjacent
to the project site. The nesting bird survey shall consist of full coverage of the project
footprint and an appropriate buffer, as determined by the biologist. If no active nests are
discovered or identified, no further mitigation is required. In the event that active nests
are discovered on site, a suitable buffer determined by the biologist shall be established
around any active nest. No ground-disturbing activities shall occur within this buffer until
the biologist has confirmed that breeding/nesting is completed and the young have
fledged the nest. Limits of construction to avoid a nest shall be established in the field by
the biologist with flagging and stakes or construction fencing. Construction personnel
shall be instructed regarding the ecological sensitivity of the fenced area. The results of
the survey shall be documented and filed with the City of Downey within 5 days after the
survey.
Cultural Resources
The mitigation measure for cultural resources is included in an effort to reduce potential impacts
to unanticipated archaeological resources during construction. While past ground disturbance
on the subject site has significantly modified most areas with the potential to support
archaeological deposits within the project site, there remains some potential to encounter
unknown archaeological resources during construction in less developed areas during the
course of project construction. The following mitigation measure provides management
recommendations in the event that resources are discovered.
MM-CUL-1: In the event that archaeological resources (sites, features, or artifacts) are
exposed during construction activities for 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.
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Geology and Soils
Similar to cultural resources, impacts to geology and soil are limited to the potential discovery of
paleontological resources. Therefore, the following mitigation measure is provided and would be
implemented to ensure potential impacts during construction activities to paleontological
resources or unique geologic features are reduced to a less-than-significant level.
MM-GEO-1: In the event that paleontological resources (fossil remains) are exposed
during construction activities for the proposed project, all construction work occurring
within 50 feet of the find shall immediately stop until a qualified paleontologist, as defined
by the Society of Vertebrate Paleontology’s 2010 guidelines, can assess the nature and
importance of the find. Depending on the significance of the find, the paleontologist may
record the find and allow work to continue or recommend salvage and recovery of the
resource. All recommendations will be made in accordance with the Society of
Vertebrate Paleontology’s 2010 guidelines and shall be subject to review and approval
by the City of Downey. Work in the area of the find may only resume upon approval of a
qualified paleontologist.
Hazards and Hazardous Materials
The impacts related to hazards and hazardous materials consists of historical recognized
environmental conditions. A Phase I Environmental Site Assessment found that the site
previously had underground storage tanks for diesel fuel and naphthene cutting oil. Three tanks
were removed in 1989 and one is abandoned in place. Samples taken during the removal of the
three tanks detected evidence of a leak. After remediation of the site under permits from the Los
Angeles County Department of Public Works, further tests indicated that “No Further Action”
was required. The mitigation measure calls for further testing and added remediation to the site
if needed, a Soil Management Plan to handle the known releases, corrections to discrepancies
in the permits issued by the Los Angeles County Department of Public Works, and lastly an
asbestos survey.
MM-HAZ-1: Based on the recommendations made in the Phase I ESA prepared by
Partner Engineering, the following shall occur prior to the issuance of building permits for
the proposed on-site buildings and structures:
1. A limited subsurface investigation shall be conducted in order to determine the
presence or absence of soil and/or soil vapor contamination due to the current
and historical use of the project site.
2. A Soil Management Plan should be prepared to appropriately handle the known
oil releases at the project site and any unknown releases associated with the
current and former industrial use.
3. The No Further Action letter dated August 6, 1992, pertaining to the historical
underground storage tanks (USTs) at the project site should be revised to clearly
include Closure Permit Number 6000B for the abandoned-in-place UST to avoid
confusion in the future as to whether it was officially closed.
4. An asbestos survey conducted in 1990 identified asbestos in the existing building
on the project site. It is not known if the survey was conducted for all equipment
and building materials at the time; therefore, an asbestos survey should be
performed and known asbestos-containing materials (ACMs) should be abated or
removed for safety purposes (or an operations and maintenance program should
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be implemented in order to safely manage the known and suspect ACMs located
at the project site).
Noise
Impacts related to noise are limited to potential nuisances that may occur during the constrction
phase of the project. Noise levels at any other time are considered to be less than significant.
The following mitigation measures are best management practices for reducing noises related
to the construction.
MM-NOI-1: The following measures shall be implemented to reduce construction noise
and vibration emanating from construction of the project:
1. At least 30 days prior to commencement of construction, the project applicant’s
contractor shall provide written notice to all residential property owners and
tenants within 300 feet of the project site that proposed construction activities
could affect outdoor or indoor living areas. The notice shall contain a description
of the project, a construction schedule including days and hours of construction,
and a description of noise-reduction measures.
2. Noise-generating construction activities (which may include preparation for
construction work) shall be permitted weekdays between 7:00 a.m. and 6:00
p.m., excluding federal holidays. When a holiday falls on a Saturday or Sunday,
the preceding Friday or following Monday, respectively, shall be observed as a
legal holiday.
3. Prior to commencement of demolition work, and throughout major construction
work up to but not including architectural coating, a temporary construction noise
barrier (8 feet in height) shall be erected along the southern project site
boundary, from the southwestern corner extending a distance of 75 feet to the
east. This barrier would completely interrupt the line-of-sight of the project site
from residences to the southwest.
4. All construction equipment powered by internal combustion engines shall be
properly muffled and maintained. No internal combustion engine shall be
operated on the site without a muffler. All diesel equipment shall be operated with
closed engine doors and shall be equipped with factory recommended mufflers.
Unnecessary idling of internal combustion engines shall be prohibited.
5. Air compressors and generators used for construction shall be surrounded by
temporary acoustical shelters. Whenever feasible, electrical power shall be used
to run air compressors and similar power tools.
6. The distance between construction equipment staging areas and adjacent
residences shall be maximized where feasible.
7. During construction, stationary construction equipment shall be placed such that
emitted noise is directed away from or shielded from sensitive receptors.
8. Stationary construction equipment that generates noise that exceeds 85 A-
weighted decibels at the property boundaries shall be shielded with a barrier that
meets a Sound Transmission Class rating of 25.
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Tribal Cultural Resources
Similar to cultural resources and geology and soils elements, mitigations to impacts that may
effect tribal and cultural resources is made in an effort to appropriately identify and preserve
resources in the event of a discovery.
MM-TCR-1: Prior to the commencement of any ground disturbing activity at the project
site, the project applicant shall retain a Native American Monitor approved by the
Gabrieleno Band of Mission Indians-Kizh Nation – the tribe that consulted on this project
pursuant to Assembly Bill (AB) 52 (the “Tribe” or the “Consulting Tribe”). A copy of the
executed contract shall be submitted to the City of Downey Community Development
Department, Planning Division prior to the issuance of any permit necessary to
commence a ground-disturbing activity.
The Tribal monitor will only be present on-site during the construction phases that
involve ground-disturbing activities. Ground disturbing activities are defined by the Tribe
as activities that may include, but are not limited to, pavement removal, potholing or
auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching,
within the project site. The Tribal Monitor shall complete daily monitoring logs that will
provide descriptions of the day’s activities, including construction activities, locations,
soil, and any cultural materials identified. The on-site monitoring shall end when all
ground-disturbing activities on the Project Site are completed, or when the Tribal
Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing
activities at the project site have little to no potential for impacting Tribal Cultural
Resources.
Should Tribal Cultural Resources be discovered, construction activities shall cease in the
immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be
assessed. All Tribal Cultural Resources unearthed by project activities shall be
evaluated by the qualified archaeologist and Tribal Monitor approved by the Consulting
Tribe. If the resources are Native American in origin, the Consulting Tribe will retain the
resources in the form and manner the Tribe deems appropriate, for educational, cultural
or historic purposes. If human remains or grave goods are discovered or recognized at
the project site, all ground disturbance shall immediately cease at a minimum of 150 feet
around the discovery, and the Los Angeles County Coroner shall be notified per Public
Resources Code Section 5097.98, and Health & Safety Code Section 7050.5. Human
remains and grave/burial goods shall be treated alike per California Public Resources
Code section 5097.98(d)(1) and (2). Work may continue on other parts of the Project
Site while evaluation and, if necessary, mitigation takes place (CEQA Guidelines Section
15064.5[f]). If a non-Native American resource is determined by the qualified
archaeologist to constitute a “historical resource” or “unique archaeological resource,”
time allotment and funding sufficient to allow for implementation of avoidance measures,
or appropriate mitigation, must be available.
The treatment plan established for the resources shall be in accordance with CEQA
Guidelines Section 15064.5(f) for historical resources and PRC Sections 21083.2(b) for
unique archaeological resources. Preservation in place (i.e., avoidance) is the preferred
manner of treatment. If preservation in place is not feasible, treatment may include
implementation of archaeological data recovery excavations to remove the resource
along with subsequent laboratory processing and analysis. Any historic archaeological
material that is not Native American in origin shall be curated at a public, non-profit
institution with a research interest in the materials, such as the Natural History Museum
of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the
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material. If no institution accepts the archaeological material, it shall be offered to a local
school or historical society in the area for educational purposes.
FINDINGS
Pursuant to Municipal Code Section 9820.08, there are seven (7) findings that must be adopted
prior to approving the Site Plan Review. The findings are as follows:
A. The site plan is consistent with the goals and polices embodied in the General
Plan and other applicable plans and policies adopted by the Council;
The project is consistent with all applicable goals and policies specified in the City’s
General Plan and policies adopted by the City Council. In addition, the project’s objective
to revitalize the site helps achieve various long-term goals. Specifically, the following
policies are promoted by the proposed development:
Policy 8.1.1 – Promote architectural design of the highest quality.
Policy 8.2.2 – Promote the upgrading of properties.
The proposed architecture is a significant upgrade to the existing facilities on site, and is
compatible with surrounding properties although it will be newer than most
developments within its proximity. The redevelopment of this site can serve as an
example of higher quality architecture for future developments within the city.
Program 9.1.1.5 – Continue the revitalization of commercial and industrial corridors.
The site has remained relatively the same since 1971 (with the exception of multiple
minor interior tenant improvements), and is surrounded by older developed industrial
properties. The quality of design, site layout, and landscaping not only upgrade the
subject property but the surrounding area as well.
Program 1.1.4 – Provide an appropriate amount of land use for people to acquire goods
and services.
The use of Freight Terminal is only practiced by one other business within the City.
Therefore, the CUP promotes the above policy by introducing a land use that aims to
further diversify the vast variety of land uses found in the city. This will not only continue
to provide, but will also expand, the type and amount of goods and services available to
the nearby business community.
B. The proposed development is in accordance with the purposes and objectives of
this article and the zone in which the site is located;
The purpose of the M-2 (General Manufacturing) zone, as stated in the Downey
Municipal Code, “is intended to provide for the orderly development of general
manufacturing, research and development, wholesale and distribution, warehousing,
biomedical uses that facilitate the growth of businesses during all stages of the business
cycle, and other compatible uses within the community.” The proposed application is in
full conformance with the objectives stated above. Furthermore, a freight terminal use is
appropriate for the General Manufacturing zone and is consistent with other uses found
along Woodruff Avenue.
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C. The proposed development’s site plan and its design features, including
architecture and landscaping, will integrate harmoniously and enhance the
character and design of the site, the immediate neighborhood, and the
surrounding areas of the City;
The proposed design of the project will integrate harmoniously with the surrounding area
by providing aesthetically pleasing architecture and landscaping. The proposed 44,162
square foot building will serve as a significant upgrade from the existing facility on the
site and nearby lots. In addition, the streetscape will be enhanced as well as the
transition from the street onto the site through the proposed landscaping and upgraded
vehicle approaches.
D. The site plan and location of the buildings, parking areas, signs, landscaping,
luminaries, and other site features indicate that proper consideration has been
given to both the functional aspects of the site development, such as automobile
and pedestrian circulation, and the visual effects of the development from the
view of the public streets;
The site layout has one frontage, 432.15 feet, and will be developed with two driveway
approaches, sufficient parking for employees, visitors, freight trucks, and loading.
Employee and visitor parking is orientated towards the front of the property heavily
surrounded by landscape buffers of over 22 feet from the front property line and 35 feet
from the side property lines. The project provides ADA compliant pedestrian access onto
the site. The proposed landscaping surrounding the property is intended to compliment
the aesthetics of the building proposed on the site. The landscaping will provide a
mixture of trees, shrubs and ground cover at various heights and maturity. In addition,
the species of trees located most adjacent to the freight trucks should provide screening
of these trucks from the public right-of-way. Lastly, the photometric plan proposed for
this project shows that all parts of the site will be well illuminated while simultaneously
not causing any nuisance to the neighboring properties or public right-of-way. Therefore,
it is determined that proper consideration has been given to the functional aspects and
visual effects of the development.
E. The proposed development will improve the community appearance by preventing
extremes of dissimilarity or monotony in new construction or in alterations of
facilities;
The proposed project reflects true contemporary style architecture and keeps with a
scale consistent of industrial developments. It is staff’s opinion that the proposed
architectural style is neither dissimilar nor monotonous from other buildings in the area
and this project will upgrade the overall appearance of the site and, in turn, improve the
community appearance. This proposed development elevates the quality of design of all
industrial properties within the City.
F. The site plan and design considerations shall tend to upgrade property in the
immediate neighborhood and surrounding areas with an accompanying
betterment of conditions affecting the public health, safety, comfort, and welfare;
The proposed architecture is a significant upgrade to the existing facilities on site, and is
compatible with surrounding properties although it will be newer than most
developments within its proximity. In addition, the redevelopment of this site has the
potential to serve as an example of higher quality architecture for future industrial
developments within the City of Downey. Lastly, the operational procedures of the
PC Agenda Page 12
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 13
proposed development are also conditioned in an effort to ensure that any potential
effects in public health, safety, comfort and general welfare are mitigated as much as
possible.
G. The proposed development’s site plan and its design features will include graffiti-
resistant features and materials in accordance with the requirements of Section
4960 of Chapter 10 of Article IV of this Code;
The project has been conditioned to meet the requirements specified in Section 4960 of
the Downey Municipal Code. Section 4960 discusses the installation of anti-graffiti
materials and the appropriate allotted time limit for the removal of graffiti.
Pursuant to Municipal Code Section 9824.06, there are four (4) findings that must be adopted
prior to approving the Conditional Use Permit. The findings are as follows:
A. The requested Conditional Use Permit will not adversely affect the intent and
purpose of this article or the City’s General Plan or the public convenience or
general welfare of persons residing or working in the neighborhood thereof;
The project is consistent with all applicable goals and policies specified in the City’s
General Plan and policies adopted by the City Council. In addition, the project’s objective
to revitalize the site helps achieve various long-term goals. Specifically, the following
policies are promoted by the proposed project:
Policy 8.1.1 – Promote architectural design of the highest quality.
Policy 8.2.2 – Promote the upgrading of properties.
The proposed architecture is a significant upgrade to the existing facilities on site, and is
compatible with surrounding properties although it will be newer than most
developments within its proximity. The redevelopment of this site has the potential of
serving as an example of higher quality architecture for future developments within the
city.
Program 9.1.1.5 – Continue the revitalization of commercial and industrial corridors.
The site has remained relatively the same since 1971 (with the exception of multiple
minor interior tenant improvements), and is surrounded by older developed industrial
properties. The quality of design, site layout, and landscaping not only upgrade the
subject property but the surrounding area as well.
Program 1.1.4 – Provide an appropriate amount of land use for people to acquire goods
and services.
The use of Freight Terminal is only practiced by one other business within the City.
Therefore, the CUP promotes the above policy by introducing a land use that aims to
further diversify the vast variety of land uses found in the city. This will not only continue
to provide, but will also expand, the type and amount of goods and services available to
the nearby business community.
PC Agenda Page 13
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 14
B. The requested use will not adversely affect the adjoining land uses and the growth
and development of the area in which it is proposed to be located;
The use is common and appropriate within industrial areas and in urbanized areas
occasionally found within proximity to residential zones. The site and location are ideal
due to direct and short access to the City’s major transportation corridors and highways.
Acceptable truck routes implemented by the City show very minimal interaction near
residential corridors when accessing the I-605 or I-105, and transportation through the
City’s primary corridors when attempting to access the 1-5 and I-710 if not accessed via
freeway. At no time shall freight trucks access residential corridors. In relation to the
activities that will be conduct on site, the proposed use is less intensive. The building will
primarily function as a storage facility, as opposed to the existing use that currently
conducts heavy manufacturing and processing of rubber. During the CEQA analysis it
was found that impacts related to aesthetics, air quality, energy, greenhouse gases,
water quality, transportation, among others, were either less than significant or no impact
would occur. Therefore adverse impacts are not anticipated as a result of approval.
Lastly, the proposed conditions of approval are intended to mitigate any potential
impacts.
C. The size and shape of the site proposed for the use is adequate to allow the full
development of the proposed use in a manner not detrimental to the particular
area;
The site is approximately 6.31 acres, and the proposed building will occupy a total of
44,162 square feet, resulting in a floor-area ratio of .16. The project exceeds the
minimum development standards for industrial developments per D.M.C. Section
9318.06, and is found to be satisfactory per the analysis contained in the environmental
impact analysis for this application. In addition, the proposed development does not
create alterations that would restrict future permitted industrial uses from occupying the
site or an existing use located within the nearby area from altering their operations.
Therefore, the size and shape of the site proposed for the use is adequate to allow the
full development of the proposed use in a manner not detrimental to the particular area.
D. The traffic generated by the proposed use will not impose an undue burden upon
the streets and highways in the area;
Woodruff Avenue and adjoining corridors that will be used by the freight trucks visiting
the facility are all Arterial streets which are designed to accommodate the type of traffic
that will be generated by this application request. During the CEQA review, there were
multiple intersections and corridors evaluated for “Level of Service” (LOS). These
intersections include Woodruff/Washburn, Woodruff/Stewart & Gray, Firestone/Stewart &
Gray, and I-605 ramps/Firestone. The analysis determined that the overall LOS standard
for these intersections required in the City’s General Plan will remain consistent. On site
there will be two separate driveways allowing different opportunities for ingress and
egress from the site, and distribution of traffic in multiple directions. Therefore, traffic
generated by the proposed use will not impose an undue burden upon the streets and
highways in the area.
PC Agenda Page 14
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 15
Pursuant to Municipal Code Section 9824.06, there are five (5) findings that must be adopted
prior to approving the Zone Change. The findings are as follows:
A. The zone change is necessary and desirable for the development of the
community in harmony with the objectives of the General Plan and this chapter
and is in the interests or furtherance of the public health, safety, and general
welfare.
The City Council adopted a comprehensive update to the Zoning Ordinance, on October
14, 2008, which eliminated the P-B (Parking Buffer) zoning category. The change of
zone from P-B to M-2 (General Manufacturing) will make the zoning of the site not only
consistent with the current Zoning Code but also with the General Plan, as the General
Plan Land Use designation of the site is General Manufacturing. Furthermore, the
change in zoning for this property does not grant the subject property any added liberties
it did not previously already have. Therefore, with this action there is no opportunity to
negatively affect the public health, safety, or general welfare of the community.
B. The zone change will be compatible and complementary to existing conditions
and adjoining property in the surrounding area.
The site is currently comprised of two separate zones, M-2 and P-B. The intent of the
zone change is to remove the P-B and provide one consistent zoning designation of M-2
for the entire site. This is ultimately compatible with the existing and proposed use on the
subject property. It is also compatible with the surrounding area, as nearby properties
located to the north, south, east and West are also zoned M-2 and developed with
industrial uses.
C. The site is adequate in size to accommodate the uses permitted in the zone
requested and that all applicable property development standards can be
complied with.
The 6.31 acre site is substantially greater than the minimum required lot size of 40,000
square feet for the M-2 zone. The minimum lot size is established in part to ensure sites
can appropriately meet development standards and accommodate allowed uses.
Furthermore, this proposed development will comply with all applicable development
standards.
D. The site properly relates to streets and highways designed and fully improved to
carry the type and quantity of traffic that is expected to be generated in the area
and that utilities exist or are planned which will adequately serve the property as
rezoned.
The zone change does not alter the existing development potential of the site because
the M-2 zone already exists for the vast majority of the lot. The M-2 zone is also present
among adjacent properties facing Woodruff Avenue. Therefore, the existing streets are
already designed to accommodate the traffic generated by industrial developments. The
same is true of existing utilities and other infrastructure.
PC Agenda Page 15
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 16
E. The proposed zone change is in general conformance with the General Plan and
General Plan land use designation for the parcel.
The zone change will eliminate the current inconstancy between the zoning code and
the zoning map and General Plan. The entire property will now be zoned M-2 as it is
intended per the General Plan.
CORRESPONDENCE
During the public noticing period for this application as required by the Downey Municipal Code,
as of the date that this report was printed, staff has not received any correspondence regarding
this application.
CONCLUSION
Based on the analysis contained within this report, staff is concluding that the proposed Site
Plan Review, Conditional Use Permit, and Zone Change (PLN-19-00132) aim to enhance the
site and surrounding area, and in addition will not create significant adverse effects to adjoining
properties. Furthermore, staff is concluding that all findings required for approval can be made
in a positive manner. As such, staff is recommending that the Planning Commission approve
the application (PLN-19-00132), thereby approving the construction of a new 44,162 square foot
industrial tilt-up building to be used as a freight terminal, a Mitigated Negative Declaration with
Mitigation Monitor and Reporting Program and recommend the City Council approve a zone
change to eliminate the P-B zone from the property.
EXHIBITS
A. Maps
B. Draft Resolution Approving – Site Plan Review and Conditional Use Permit
C. Draft Resolution Recommending Approval to City Council – Zone Change
D. CEQA Mitigation Monitoring and Reporting Program
E. CEQA Response to Comments and Errata
F. Mitigated Negative Declaration
G. Project Plans
PC Agenda Page 16
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 17
Location
PC Agenda Page 17
Site Plan Review, Conditional Use Permit, & Zone Change - PLN-19-00132
February 17, 2021 - Page 18
Aerial Photograph
Zoning
PC Agenda Page 18
RESOLUTION NO. 21-
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
DOWNEY APPROVING A SITE PLAN REVIEW AND CONDITIONAL USE
PERMIT (PLN-19-00132) AND MITIGATED NEGATIVE DECLARATION
WITH MITIGATED MONITORING AND REPORTING PROGRAM,
THEREBY ALLOWING THE CONSTRUCTION OF A 44,162 SQUARE
FOOT INDUSTRIAL TILT-UP BUILDING TO BE USED AS A FREIGHT
TERMINAL LOCATED AT 12021 WOODRUFF AVENUE
THE PLANNING COMMISSION OF THE CITY OF DOWNEY DOES RESOLVE AS FOLLOWS:
SECTION 1. The Planning Commission of the City of Downey does hereby find,
determine and declare that:
A. On August 22, 2019, the applicant filed a request for a Conditional Use Permit,
Site Plan Review and Zone Change (PLN-19-00132) to construct a 44,162
square foot industrial tilt-up building to be used as a freight terminal and change
the zone from P-B (Parking Buffer) to M-2 (General Manufacturing); and,
B. On September 25, 2019, the applicant was issued a letter deeming the
application incomplete; and,
C. On December 15, 2020, in accordance with the requirement of CEQA, a Notice
of Intent to adopt a Mitigated Negative Declaration was submitted to the Los
Angeles County Recorder’s Office.
D. On February 1, 2021, the application was deemed complete after all required
documents were submitted and reviewed; and,
E. On February 4, 2021, a notice of the public hearing was sent to all property
owners within 500’ of the subject site and the notice was published in Downey
Patriot; and,
F. The Planning Commission held a duly noticed public hearing on February 17,
2021, and after fully considering all oral and written testimony, facts, and
opinions offered at the aforesaid public hearing adopted this resolution.
SECTION 2. The Planning Commission further finds, determines, and declares that
after preparing an Initial Study was prepared in compliance with the requirements of the
California Environmental Quality Act, which found that unless mitigated the project could have a
significant environmental impact. As such a Mitigated Negative Declaration was circulated for
public review from December 15, 2020 to January 14, 2021. Based on its own independent
judgment, the Planning Commission finds that the facts stated in the Initial Study/Mitigated
Negative Declaration are true and adopt the Initial Study/Mitigated Negative Declaration along
with the corresponding Mitigation Monitoring and Reporting Program.
SECTION 3. Having considered all of the oral and written evidence presented to it at
said public hearings regarding the Site Plan Review, the Planning Commission further finds,
determines and declares that:
A. The site plan is consistent with the goals and polices embodied in the General
Plan and other applicable plans and policies adopted by the Council. The project
is consistent with all applicable goals and policies specified in the City’s General
PC Agenda Page 19
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 2
Plan and policies adopted by the City Council. In addition, the project’s objective
to revitalize the site helps achieve various long-term goals. Specifically, the
following policies are promoted by the proposed development:
Policy 8.1.1 – Promote architectural design of the highest quality.
Policy 8.2.2 – Promote the upgrading of properties.
The proposed architecture is a significant upgrade to the existing facilities on site,
and is compatible with surrounding properties although it will be newer than most
developments within its proximity. The redevelopment of this site can serve as an
example of higher quality architecture for future developments within the city.
Program 9.1.1.5 – Continue the revitalization of commercial and industrial
corridors.
The site has remained relatively the same since 1971 (with the exception of
multiple minor interior tenant improvements), and is surrounded by older
developed industrial properties. The quality of design, site layout, and
landscaping not only upgrade the subject property but the surrounding area as
well.
Program 1.1.4 – Provide an appropriate amount of land use for people to acquire
goods and services.
The use of Freight Terminal is only practiced by one other business within the
City. Therefore, the CUP promotes the above policy by introducing a land use
that aims to further diversify the vast variety of land uses found in the city. This
will not only continue to provide, but will also expand, the type and amount of
goods and services available to the nearby business community.
B. The proposed development is in accordance with the purposes and objectives of
this article and the zone in which the site is located. The purpose of the M-2
(General Manufacturing) zone, as stated in the Downey Municipal Code, “is
intended to provide for the orderly development of general manufacturing,
research and development, wholesale and distribution, warehousing, biomedical
uses that facilitate the growth of businesses during all stages of the business
cycle, and other compatible uses within the community.” The proposed
application is in full conformance with the objectives stated above. Furthermore,
a freight terminal use is appropriate for the General Manufacturing zone and is
consistent with other uses found along Woodruff Avenue.
C. The proposed development’s site plan and its design features, including
architecture and landscaping, will integrate harmoniously and enhance the
character and design of the site, the immediate neighborhood, and the
surrounding areas of the City. The proposed design of the project will integrate
harmoniously with the surrounding area by providing aesthetically pleasing
architecture and landscaping. The proposed 44,162 square foot building will
serve as a significant upgrade from the existing facility on the site and nearby
lots. In addition, the streetscape will be enhanced as well as the transition from
the street onto the site through the proposed landscaping and upgraded vehicle
approaches.
PC Agenda Page 20
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 3
D. The site plan and location of the buildings, parking areas, signs, landscaping,
luminaries, and other site features indicate that proper consideration has been
given to both the functional aspects of the site development, such as automobile
and pedestrian circulation, and the visual effects of the development from the
view of the public streets. The site layout has one frontage, 432.15 feet, and will
be developed with two driveway approaches, sufficient parking for employees,
visitors, freight trucks, and loading. Employee and visitor parking is orientated
towards the front of the property heavily surrounded by landscape buffers of over
22 feet from the front property line and 35 feet from the side property lines. The
project provides ADA compliant pedestrian access onto the site. The proposed
landscaping surrounding the property is intended to compliment the aesthetics of
the building proposed on the site. The landscaping will provide a mixture of trees,
shrubs and ground cover at various heights and maturity. In addition, the species
of trees located most adjacent to the freight trucks should provide screening of
these trucks from the public right-of-way. Lastly, the photometric plan proposed
for this project shows that all parts of the site will be well illuminated while
simultaneously not causing any nuisance to the neighboring properties or public
right-of-way. Therefore, it is determined that proper consideration has been given
to the functional aspects and visual effects of the development.
E. The proposed development will improve the community appearance by
preventing extremes of dissimilarity or monotony in new construction or in
alterations of facilities. The proposed project reflects true contemporary style
architecture and keeps with a scale consistent of industrial developments. It is
staff’s opinion that the proposed architectural style is neither dissimilar nor
monotonous from other buildings in the area and this project will upgrade the
overall appearance of the site and, in turn, improve the community appearance.
This proposed development elevates the quality of design of all industrial
properties within the City.
F. The site plan and design considerations shall tend to upgrade property in the
immediate neighborhood and surrounding areas with an accompanying
betterment of conditions affecting the public health, safety, comfort, and welfare.
The proposed architecture is a significant upgrade to the existing facilities on site,
and is compatible with surrounding properties although it will be newer than most
developments within its proximity. In addition, the redevelopment of this site has
the potential to serve as an example of higher quality architecture for future
industrial developments within the City of Downey. Lastly, the operational
procedures of the proposed development are also conditioned in an effort to
ensure that any potential effects in public health, safety, comfort and general
welfare are mitigated as much as possible.
G. The proposed development’s site plan and its design features will include graffiti-
resistant features and materials in accordance with the requirements of Section
4960 of Chapter 10 of Article IV of this Code. The project has been conditioned
to meet the requirements specified in Section 4960 of the Downey Municipal
Code. Section 4960 discusses the installation of anti-graffiti materials and the
appropriate allotted time limit for the removal of graffiti.
PC Agenda Page 21
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 4
SECTION 4. Having considered all of the oral and written evidence presented to it at
said public hearings regarding the Conditional Use Permit, the Planning Commission further
finds, determines and declares that:
A. The requested Conditional Use Permit will not adversely affect the intent and
purpose of this article or the City’s General Plan or the public convenience or
general welfare of persons residing or working in the neighborhood thereof. The
project is consistent with all applicable goals and policies specified in the City’s
General Plan and policies adopted by the City Council. In addition, the project’s
objective to revitalize the site helps achieve various long-term goals. Specifically,
the following policies are promoted by the proposed project:
Policy 8.1.1 – Promote architectural design of the highest quality.
Policy 8.2.2 – Promote the upgrading of properties.
The proposed architecture is a significant upgrade to the existing facilities on site,
and is compatible with surrounding properties although it will be newer than most
developments within its proximity. The redevelopment of this site has the
potential of serving as an example of higher quality architecture for future
developments within the city.
Program 9.1.1.5 – Continue the revitalization of commercial and industrial
corridors.
The site has remained relatively the same since 1971 (with the exception of
multiple minor interior tenant improvements), and is surrounded by older
developed industrial properties. The quality of design, site layout, and
landscaping not only upgrade the subject property but the surrounding area as
well.
Program 1.1.4 – Provide an appropriate amount of land use for people to acquire
goods and services.
The use of Freight Terminal is only practiced by one other business within the
City. Therefore, the CUP promotes the above policy by introducing a land use
that aims to further diversify the vast variety of land uses found in the city. This
will not only continue to provide, but will also expand, the type and amount of
goods and services available to the nearby business community.
B. The requested use will not adversely affect the adjoining land uses and the
growth and development of the area in which it is proposed to be located. The
use is common and appropriate within industrial areas and in urbanized areas
occasionally found within proximity to residential zones. The site and location are
ideal due to direct and short access to the City’s major transportation corridors
and highways. Acceptable truck routes implemented by the City show very
minimal interaction near residential corridors when accessing the I-605 or I-105,
and transportation through the City’s primary corridors when attempting to
access the 1-5 and I-710 if not accessed via freeway. At no time shall freight
trucks access residential corridors. In relation to the activities that will be conduct
on site, the proposed use is less intensive. The building will primarily function as
a storage facility, as opposed to the existing use that currently conducts heavy
PC Agenda Page 22
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 5
manufacturing and processing of rubber. During the CEQA analysis it was found
that impacts related to aesthetics, air quality, energy, greenhouse gases, water
quality, transportation, among others, were either less than significant or no
impact would occur. Therefore adverse impacts are not anticipated as a result of
approval. Lastly, the proposed conditions of approval are intended to mitigate
any potential impacts.
C. The size and shape of the site proposed for the use is adequate to allow the full
development of the proposed use in a manner not detrimental to the particular
area. The site is approximately 6.31 acres, and the proposed building will occupy
a total of 44,162 square feet, resulting in a floor-area ratio of .16. The project
exceeds the minimum development standards for industrial developments per
D.M.C. Section 9318.06, and is found to be satisfactory per the analysis
contained in the environmental impact analysis for this application. In addition,
the proposed development does not create alterations that would restrict future
permitted industrial uses from occupying the site or an existing use located within
the nearby area from altering their operations. Therefore, the size and shape of
the site proposed for the use is adequate to allow the full development of the
proposed use in a manner not detrimental to the particular area.
D. The traffic generated by the proposed use will not impose an undue burden upon
the streets and highways in the area. Woodruff Avenue and adjoining corridors
that will be used by the freight trucks visiting the facility are all Arterial streets
which are designed to accommodate the type of traffic that will be generated by
this application request. During the CEQA review, there were multiple
intersections and corridors evaluated for “Level of Service” (LOS). These
intersections include Woodruff/Washburn, Woodruff/Stewart & Gray,
Firestone/Stewart & Gray, and I-605 ramps/Firestone. The analysis determined
that the overall LOS standard for these intersections required in the City’s
General Plan will remain consistent. On site there will be two separate driveways
allowing different opportunities for ingress and egress from the site, and
distribution of traffic in multiple directions. Therefore, traffic generated by the
proposed use will not impose an undue burden upon the streets and highways in
the area.
SECTION 5. Based upon the findings set forth in Sections 1 through 4 of this
Resolution, the Planning Commission of the City of Downey hereby approves the Site Plan
Review and Conditional Use Permit (PLN-19-00132), subject to conditions of approval attached
hereto as Exhibit ‘A’, which are necessary to preserve the health, safety and general welfare of
the community and enable the Planning Commission to make the findings set forth in the
previous sections. The conditions are fair and reasonable for the accomplishment of these
purposes.
PC Agenda Page 23
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 6
SECTION 6. The Secretary shall certify the adoption of this Resolution.
PASSED, APPROVED AND ADOPTED this 17th day of February 2021.
Miguel Duarte, Chairman
City Planning Commission
I HEREBY CERTIFY that the foregoing is a true copy of a Resolution adopted by the
Planning Commission of the City of Downey at a regular meeting thereof, held on the 17th day of
February 2021, by the following vote, to wit:
AYES: COMMISSIONERS:
NOES: COMMISSIONERS:
ABSENT: COMMISSIONERS:
Mary Cavanagh, Secretary
City Planning Commission
PC Agenda Page 24
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 7
PLN-19-00132
(SITE PLAN REVIEW & CONDITIONAL USE PERMIT)
EXHIBIT A – CONDITIONS
PLANNING
1) The approval of this Site Plan Review and Conditional Use Permit (PLN-19-00132)
allows for the construction of a one-story 44,162 square-foot industrial tilt-up building to
be used as freight terminal located at 12021 Woodruff Avenue with 56 parking stalls, 76
freight truck stalls, and landscaping as reflected on plans date stamped February 1,
2021.
2) This approval shall not be construed to mean any waiver of applicable and appropriate
zoning regulations, or any Federal, State, County, and City laws and regulations. Unless
otherwise expressly specified, all other requirements of the City of Downey Municipal
Code shall apply.
3) The site shall remain in substantial conformance with this request and the approved set
of plans.
4) The Owner/Applicant agrees, as a condition of approval of this resolution, to indemnify,
defend and hold harmless, at Applicant's expense, City and City's agents, officers and
employees from and against any claim, action or proceeding commenced within the time
period provided in Government Code Section 66499.37 to attack, review, set aside, void
or annul the approval of this resolution, to challenge the determination made by City
under the California Environmental Quality Act or to challenge the reasonableness,
legality or validity of any condition attached hereto. City shall promptly notify Applicant of
any such claim, action or proceeding to which City receives notice, and City will
cooperate fully with Applicant in the defense thereof. Applicant shall reimburse the City
for any court costs and attorney's fees that the City may be required to pay as a result of
any such claim, action or proceeding. City may, in its sole discretion, participate in the
defense of any such claim, action or proceeding, but such participation shall not relieve
Applicant of the obligations of this condition.
5) The City Planner is authorized to make minor modifications to the approved preliminary
plans or any of the conditions if such modifications shall achieve substantially the same
results as would strict compliance with said plans and conditions.
6) Prior to the submittal of plans into Building and Safety Plan Check or commencement of
business, whichever occurs first, the applicant and the property owner shall sign an
affidavit of Acceptance of Conditions, as provided by the City of Downey.
7) The applicant must comply with the art in public places requirements set forth in Downey
Municipal Code 8950 et seq. This shall include payment of all required fees prior to the
issuance of building permits. Should the applicant exercise their right to install public art
on site, the public art application (including payment of all deposits) shall be submitted
prior to the issuance of building permits.
8) The business owner shall consent to and provide access to all areas of the subject
premises without charge during normal business hours to any City Official for purposes
of verifying compliance with any of the Conditions of Approval of this application, as well
PC Agenda Page 25
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 8
as with any Police Permit and approved Security Plan.
9) The approved architectural style shall be Contemporary, as noted in the approved plans.
Changes to the facades and/or colors shall be subject to the review and approval of the
City Planner.
10) All finished materials must be to the satisfaction of the City Planner. Final approval of all
building materials (including but not limited to glass type, wall texture, canopies and
awnings, and wood planking) must be granted by the City Planner prior to the issuance
of Building Permits.
11) All landscaping must comply with the Downey Municipal Code, be composed of drought
tolerant plants, and requires final approval from the City Planner prior to the issuance of
Building Permits.
12) The permitted hours of operation are twenty-four hours seven (7) days a week.
13) All freight trucks visiting the facility must strictly adhere to the City of Downey’s Truck
Route Map provided by the Public Works Department.
14) At no time shall the site store inoperable freight trucks or vehicles in its parking areas,
either within the vehicles spaces or the freight truck spaces.
15) No repair of vehicles or freight truck shall occur at any time.
16) All exterior lights on the property must be LED and must be directed, positioned, and/or
shielded such that they do not illuminate surrounding properties and the public right-of-
way.
17) For security purposes, lighting must be placed in such a way as to illuminate the area
surrounding the trash enclosure, transformer, and all vehicle parking spaces. This
lighting shall be un-switched and photo-sensor controlled.
18) All interior and exterior mechanical, plumbing, and unfinished electrical equipment and
materials (including but not limited to wiring and pipes) must be screened from the
public’s view. All screening materials must be approved by the City Planner.
19) Any bollards on the site must be decorative in nature and shall be approved by the City
Planner.
20) All buildings and walls must be finished with graffiti resistant materials. Prior to the
issuance of building permits, the applicant shall demonstrate to the satisfaction of the
City Planner, that the finished materials will comply with this requirement.
21) Any graffiti applied to the site shall be removed within 48 hours.
22) The applicant must provide stamped color concrete or pavers across the driveways.
The stamped color concrete or pavers shall be as approved by the City Planner.
23) Roof-mounted equipment shall be screened at all times by a material to be approved by
the City Planner.
PC Agenda Page 26
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 9
24) All above grade back-flow preventers and check valves shall be painted green and
screened from view from the public right-of-way with decorative metal cut-out panels as
approved by the City Planner.
25) Noise generated from the site shall comply with Municipal Code Section 4600 et. seq. In
any case, noise shall not exceed 70 dBA as measured at the property line.
26) The Applicant must incorporate a copy of this Exhibit A, Conditions of Approval, into the
approved set of building plans.
27) The applicant shall comply with all mitigation measures, as established by the Mitigated
Negative Declaration, at all times. This shall include:
MM-BIO-1: Prior to the issuance of a demolition, grading, and/or building permit for
activities during the avian nesting season (i.e., February 1 and September 1), the project
applicant shall submit a survey for active nests to the City of Downey Building & Safety
Division conducted by a qualified biologist a maximum of 1 week prior to the activities to
determine the presence/absence, location, and status of any active nests on or adjacent
to the project site. The nesting bird survey shall consist of full coverage of the project
footprint and an appropriate buffer, as determined by the biologist. If no active nests are
discovered or identified, no further mitigation is required. In the event that active nests
are discovered on site, a suitable buffer determined by the biologist shall be established
around any active nest. No ground-disturbing activities shall occur within this buffer until
the biologist has confirmed that breeding/nesting is completed and the young have
fledged the nest. Limits of construction to avoid a nest shall be established in the field by
the biologist with flagging and stakes or construction fencing. Construction personnel
shall be instructed regarding the ecological sensitivity of the fenced area. The results of
the survey shall be documented and filed with the City of Downey within 5 days after the
survey.
MM-CUL-1: In the event that archaeological resources (sites, features, or artifacts) are
exposed during construction activities for 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.
MM-GEO-1: In the event that paleontological resources (fossil remains) are exposed
during construction activities for the proposed project, all construction work occurring
within 50 feet of the find shall immediately stop until a qualified paleontologist, as defined
by the Society of Vertebrate Paleontology’s 2010 guidelines, can assess the nature and
importance of the find. Depending on the significance of the find, the paleontologist may
record the find and allow work to continue or recommend salvage and recovery of the
resource. All recommendations will be made in accordance with the Society of
Vertebrate Paleontology’s 2010 guidelines and shall be subject to review and approval
by the City of Downey. Work in the area of the find may only resume upon approval of a
qualified paleontologist.
PC Agenda Page 27
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 10
MM-HAZ-1: Based on the recommendations made in the Phase I ESA prepared by
Partner Engineering, the following shall occur prior to the issuance of building permits for
the proposed on-site buildings and structures:
1. A limited subsurface investigation shall be conducted in order to determine the
presence or absence of soil and/or soil vapor contamination due to the current
and historical use of the project site.
2. A Soil Management Plan should be prepared to appropriately handle the known
oil releases at the project site and any unknown releases associated with the
current and former industrial use.
3. The No Further Action letter dated August 6, 1992, pertaining to the historical
underground storage tanks (USTs) at the project site should be revised to clearly
include Closure Permit Number 6000B for the abandoned-in-place UST to avoid
confusion in the future as to whether it was officially closed.
4. An asbestos survey conducted in 1990 identified asbestos in the existing building
on the project site. It is not known if the survey was conducted for all equipment
and building materials at the time; therefore, an asbestos survey should be
performed and known asbestos-containing materials (ACMs) should be abated or
removed for safety purposes (or an operations and maintenance program should
be implemented in order to safely manage the known and suspect ACMs located
at the project site).
MM-NOI-1: The following measures shall be implemented to reduce construction noise
and vibration emanating from construction of the project:
1. At least 30 days prior to commencement of construction, the project applicant’s
contractor shall provide written notice to all residential property owners and
tenants within 300 feet of the project site that proposed construction activities
could affect outdoor or indoor living areas. The notice shall contain a description
of the project, a construction schedule including days and hours of construction,
and a description of noise-reduction measures.
2. Noise-generating construction activities (which may include preparation for
construction work) shall be permitted weekdays between 7:00 a.m. and 6:00
p.m., excluding federal holidays. When a holiday falls on a Saturday or Sunday,
the preceding Friday or following Monday, respectively, shall be observed as a
legal holiday.
3. Prior to commencement of demolition work, and throughout major construction
work up to but not including architectural coating, a temporary construction noise
barrier (8 feet in height) shall be erected along the southern project site
boundary, from the southwestern corner extending a distance of 75 feet to the
east. This barrier would completely interrupt the line-of-sight of the project site
from residences to the southwest.
4. All construction equipment powered by internal combustion engines shall be
properly muffled and maintained. No internal combustion engine shall be
PC Agenda Page 28
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 11
operated on the site without a muffler. All diesel equipment shall be operated with
closed engine doors and shall be equipped with factory recommended mufflers.
Unnecessary idling of internal combustion engines shall be prohibited.
5. Air compressors and generators used for construction shall be surrounded by
temporary acoustical shelters. Whenever feasible, electrical power shall be used
to run air compressors and similar power tools.
6. The distance between construction equipment staging areas and adjacent
residences shall be maximized where feasible.
7. During construction, stationary construction equipment shall be placed such that
emitted noise is directed away from or shielded from sensitive receptors.
8. Stationary construction equipment that generates noise that exceeds 85 A-
weighted decibels at the property boundaries shall be shielded with a barrier that
meets a Sound Transmission Class rating of 25.
MM-TCR-1: Prior to the commencement of any ground disturbing activity at the project
site, the project applicant shall retain a Native American Monitor approved by the
Gabrieleno Band of Mission Indians-Kizh Nation – the tribe that consulted on this project
pursuant to Assembly Bill (AB) 52 (the “Tribe” or the “Consulting Tribe”). A copy of the
executed contract shall be submitted to the City of Downey Community Development
Department, Planning Division prior to the issuance of any permit necessary to
commence a ground-disturbing activity.
The Tribal monitor will only be present on-site during the construction phases that
involve ground-disturbing activities. Ground disturbing activities are defined by the Tribe
as activities that may include, but are not limited to, pavement removal, potholing or
auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching,
within the project site. The Tribal Monitor shall complete daily monitoring logs that will
provide descriptions of the day’s activities, including construction activities, locations,
soil, and any cultural materials identified. The on-site monitoring shall end when all
ground-disturbing activities on the Project Site are completed, or when the Tribal
Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing
activities at the project site have little to no potential for impacting Tribal Cultural
Resources.
Should Tribal Cultural Resources be discovered, construction activities shall cease in the
immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be
assessed. All Tribal Cultural Resources unearthed by project activities shall be
evaluated by the qualified archaeologist and Tribal Monitor approved by the Consulting
Tribe. If the resources are Native American in origin, the Consulting Tribe will retain the
resources in the form and manner the Tribe deems appropriate, for educational, cultural
or historic purposes.If human remains or grave goods are discovered or recognized at
the project site, all ground disturbance shall immediately cease at a minimum of 150 feet
around the discovery, and the Los Angeles County Coroner shall be notified per Public
Resources Code Section 5097.98, and Health & Safety Code Section 7050.5. Human
remains and grave/burial goods shall be treated alike per California Public Resources
Code section 5097.98(d)(1) and (2). Work may continue on other parts of the Project
Site while evaluation and, if necessary, mitigation takes place (CEQA Guidelines Section
PC Agenda Page 29
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 12
15064.5[f]). If a non-Native American resource is determined by the qualified
archaeologist to constitute a “historical resource” or “unique archaeological resource,”
time allotment and funding sufficient to allow for implementation of avoidance measures,
or appropriate mitigation, must be available.
The treatment plan established for the resources shall be in accordance with CEQA
Guidelines Section 15064.5(f) for historical resources and PRC Sections 21083.2(b) for
unique archaeological resources. Preservation in place (i.e., avoidance) is the preferred
manner of treatment. If preservation in place is not feasible, treatment may include
implementation of archaeological data recovery excavations to remove the resource
along with subsequent laboratory processing and analysis. Any historic archaeological
material that is not Native American in origin shall be curated at a public, non-profit
institution with a research interest in the materials, such as the Natural History Museum
of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the
material. If no institution accepts the archaeological material, it shall be offered to a local
school or historical society in the area for educational purposes.
BUILDING
28) All construction must comply with the most recent adopted City and State building
codes:
a) 2019 California Building Code.
b) 2019 California Electrical Code.
c) 2019 California Mechanical Code.
d) 2019 California Plumbing Code.
e) 2019 California Fire Code.
f) 2019 California Green Code.
29) Special Inspections – As indicated by California Building Code Section 1704, the owner
shall employ one or more special inspectors who shall provide special inspections when
required by CBC section 1704. Please contact the Building Division at time of plan
submittal to obtain application for special inspections.
30) The Title Sheet of the plans shall include:
a) Occupancy Group.
b) Occupant Load.
c) Description of use.
d) Type of Construction.
e) Height of Building.
f) Floor area of building(s) and/or occupancy group(s).
31) Dimensioned building setbacks and property lines, street centerlines and between
buildings or other structures shall be designed on plot plan.
32) All property lines and easements must be shown on plot plan. A statement that such
lines and easements are shown is required.
33) The project design will conform with energy conservation measures articulated in Title
24 of the California Code of Regulations and address measures to reduce energy
PC Agenda Page 30
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 13
consumption such as flow restrictors for toilets, low consumptions light fixtures, and
insulation and shall use to the extent feasible draught landscaping.
34) A design professional will be required at time of construction drawings, to prepare plans
for proposed improvements per the Business and Professions’ Code.
35) Public and private site improvements shall be designed in accordance with the
Americans with Disabilities Act and Chapter 11 of the California Building Code. Site plan
shall include a site accessibility plan identifying exterior routes of travel and detailing
running slope, cross slope, width, pedestrian ramp, curb ramps, handrails, signage and
truncated domes. Path of travel shall be provided from the public right of way and
accessible parking to building. The design professional shall ensure that the site
accessibility plan is compliance with the latest Federal and State regulations.
36) Construction hours shall be limited to 7:00 a.m. to 7:00 p.m., Monday through Friday and
8:00 a.m. to 5:00 p.m., Saturdays. There shall be no construction on the site outside of
these hours.
FIRE
37) The following comments pertain to a fire review of a submitted design review plan(s).
The comments contained herein shall not be construed as complete or encompassing all
fire-life safety code requirements as set forth in local, State, and/or National codes.
38) Provide additional information/detail as to Occupancy Type and Occupant Load as to
determine what level of fire protection shall be required [CA Fire Code §1004].
39) Install approved key boxes (e.g. Knox Boxes) to occupancy [CA Fire Code §506.1].
Motorized gate shall also be equipped with Knox key (override) switch.
40) Premises shall be appropriately addressed. Approved address identification shall be
provided that is legible and placed in a position that is visible from the street/road. Sizing
shall be approved and at a minimum meet requirement of CA Fire Code [CA Fire Code
§505.1]
41) The security gate shall not be erected across any fire apparatus road without prior
approval from the fire chief and the gate shall be provided with an approved
unobstructed width as determined by Fire Chief [CA Fire Code §503.2.1; 503.6].
42) Building egress shall be designed to meet requirements of the CA Building Code and
Chapter 10 of the CA Fire Code for occupant load, number of egresses, egress sizing,
door swing direction, exit sign illumination, etc.
43) Provide commodity classification for high-pile storage [CA Fire Code §3203.1].
44) High-pile storage shall require a deferred plan submittal. High-pile combustible storage
requires a submittal of construction documents (plans) which provide detail on the
elements contained in Section 3201.3 of the CA Fire Code.
45) If hazardous materials operations (i.e. LP-gas forklift operations, mechanical
refrigeration, etc.) shall occur at occupancy, business shall be required to establish,
PC Agenda Page 31
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 14
implement, and submit a Hazardous Materials Business Plan (HMBP) to Statewide
Environmental Reporting System (CERS) where required for handling reportable
thresholds of hazardous materials [HSC 25507; 25508].
46) Provide visible NFPA 704 hazard warning placard to address side of building. NFPA 704
placard shall be required where hazardous substances equal to or above permitted
quantities are handled, stored, or used [CA Fire Code §5003.5].
47) The DCDA for the fire sprinkler system shall be of an approved type and model (type
and model as approved by the City of Downey Public Works Department).
48) Provide an approved Class I Standpipe System (2 ½ inch hose connections) at interior
of warehouse for firefighting operations. Hose connections shall be installed in
accordance with CA Fire Code and NFPA 14.
49) A deferred automatic fire sprinkler plan submittal shall be required [CA Fire Code
§903.2]. The automatic fire sprinkler system design, installation, and testing shall be in
accordance with NFPA 13.
50) A deferred fire alarm and detection system plan submittal shall be required [CA Fire
Code §907.2]. The fire alarm and detection system shall be designed, installed, and
tested in accordance with NFPA 72.
51) Emergency Responder Radio Coverage shall be provided to the building in accordance
with CA Fire Code 510, NFPA 72 and NFPA 1221.
52) Provide approved fire lane markings [CA Fire Code §503.3]
53) Provide fire hydrants (yard hydrants) on property. Fire hydrants shall have required clear
space of 3 feet, protected from vehicle impact with approved crash protection, and to be
located on portion of fire apparatus road sized to 26 ft. in width [CA Fire Code §507.5.1;
507.5.5; 507.5.6]
54) Parking stalls, including wheel stops, shall be of sufficient size as to accommodate
vehicles. Parked vehicles shall not encroach into the fire lane/access road.
PUBLIC WORKS
55) All public utilities shall be installed underground.
56) Proposed public improvements shall comply with the latest edition of Standard Plans
and Specifications for Public Works Construction, City of Downey standards and the
Americans with Disabilities Act (ADA).
57) Obtain permits from the Public Works Department for all improvements within the public
right of way at least two weeks prior to commencing work. Contact Brian Aleman,
Assistant Civil Engineer, at (562) 904-7110 for information.
58) Remove and replace damaged, uneven or sub-standard curb, gutter, sidewalk, driveway
approaches, and pavement to the satisfaction of the Public Works Department. Contact
the Public Works Inspector at (562) 904-7110 to identify the limits of the areas to be
PC Agenda Page 32
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 15
removed and replaced at least 48 hours prior to commencing work.
59) Owner/Applicant shall reconstruct the two existing driveway approaches per Standard
Plans of Public Works Construction (SPPWC) No. 110-2 Type C. Driveway width bottom
of X to bottom of X shall be a minimum of 26 feet in order accommodate for large
vehicles. The new widen driveways shall be at least five (5) feet away from any above-
ground obstructions (including storm drains) in the public right-of-way to the top of the
driveway “X.” Otherwise, the obstruction shall be relocated at the applicant’s expense.
Ensure that each driveway provides proper pedestrian access across, in compliance
with ADA standards. The final layout and site driveway approach design shall be subject
to the review and approval by the Public Works Department.
60) All unused driveway approaches shall be removed and constructed with full-height curb
gutter, and sidewalk to match existing improvements.
61) Submit public improvement plan for review and approval by Public Works Department
prior to the start of construction and the issuance of any encroachment permit for
improvements within the public right of way.
62) Remove all Underground Service Alert (USA) temporary pavement markings
immediately following the completion of the work / Final permit inspection.
63) Paint property address numbers (4” height) on the curb face in front of the proposed
development to the City’s satisfaction.
64) Any utilities that are in conflict with the development shall be relocated at the
owner/applicant's expense.
65) Complete a construction & demolition (C&D) waste management plan per Article V,
Chapter 8 of the Downey Municipal Code.
66) Construct onsite pavement, consisting of a minimum section of 4” thick aggregate base,
and a minimum 2-1/2” thick asphalt concrete pavement. Construct Pavement on-site
parking and circulation areas as required by a pavement engineering or geotechnical
report prepared by a Registered Civil Engineer, subject to the review and approval of the
Public Works and Community Development Departments.
67) The owner/applicant must comply with all applicable Federal, State and local rules and
regulations, American Disabilities Act (ADA), including compliance with South Coast Air
Quality Management District (SCAQMD) regulations.
68) The owner/applicant must coordinate with the County Sanitation District of Los Angeles
to assure that the current Industrial Waste Discharge permit is closed and an exempt
letter is used by the county notifying that an Industrial Waste Discharge permit is not
need anymore. Please provide copies to the City of Downey’s Public Works Department.
69) Connection of any new water service lines must be to the existing 8-inch main located
on Woodruff Avenue.
70) The owner/applicant shall furnish and install public potable water improvements
including installation of a new main on Woodruff Avenue if it is determined that proposed
PC Agenda Page 33
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 16
fire service(s) require a larger than the current 8 inch main located on Woodruff Avenue.
71) The owner/applicant shall retrofit any existing fire hydrant(s) within the property frontage
in accordance to latest Fire Department and Department of Public Works standards
including but not limited to furnishing and installation of a new riser, fire hydrant head,
and associated fittings.
72) The owner/applicant shall provide a fire sprinkler system(s) in accordance with Fire
Department and Building and Safety standards. Should such fire sprinkler system(s)
require the installation of dedicated fire service lateral(s), such lateral(s) shall be
constructed in accordance with the latest Department of Public Works and Fire
Department standards including backflow devices, fire department connections and
other appurtenances as required. New fire service lateral(s) shall be connected to
existing 8-inch main located on Woodruff Avenue and shall be dedicated for fire service
only.
73) The owner/applicant shall furnish and install irrigation, domestic, and fire water backflow
devices in accordance with City of Downey standards and as required by State and LA
County Department of Public Health. Backflow devices shall be located on private
property, readily accessible for emergency and inspection purposes, and screened from
view by providing sufficient landscaping.
74) Backflow devices shall be certified in the field by a licensed LA County Department of
Public Health certified tester prior to placing into service and such certification provided
to City.
75) Existing potable, irrigation and fire water service lines and associated appurtenances
must be removed and abandoned from existing water main.
76) Owner or tenant must establish accounts with the City Cashier prior to the City activating
and the tenant using any fire, potable, or recycled water service and meter.
77) The owner/applicant shall provide separate water improvement plan sets for review and
approval consisting of the following:
a) Potable Water Improvement Plans (all City-owned potable water and fire service
lateral improvements)
b) Recycled Water Irrigation Plans
78) Final City approved potable water and recycled water main improvement plans shall be
submitted on mylars and shall be signed and stamped by a State of California licensed
civil engineer.
79) Improvement plans for either potable main improvements shall be both plan and profile.
80) Upon completion of water improvements, owner/applicant shall submit red-lined
construction plans to City noting all changes to the plan and profile of all water
improvements installed. Such changes shall be incorporated into a final record drawing
mylar which shall be signed and stamped by the original engineer and/or architect of
record and submitted to the City along with digital files (AutoCAD – latest edition).
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Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 17
81) The owner/applicant shall provide and record utility easement(s) for access to, and
inspection and maintenance of, public water lines, meters, and appurtenances.
82) The owner/applicant shall consult the Department of Public Works to determine the
sewer location and design requirements.
83) Site shall be served by adequately sized water supply facilities, which shall include fire
hydrants of the size, type and location approved by the Fire Chief.
84) The water mains shall be of sufficient size to accommodate the total domestic and fire
flow required for the subdivision. The domestic/fire water flows required are to be
checked and approved by the Dept. of Public Works or the water provider for size and
velocity. Fire flows required are to be determined by the Fire Chief.
85) Any deviation from the city standards in constructing the water and sewer lines shall be
approved by the Los Angeles County Health Department.
86) Submit an engineered grading plan and/or hydraulic calculations and site drainage plan
for the site (prepared and sealed by a registered civil engineer in the State of California)
accompanied by a soil and geology report for approval by the Engineering Division and
Building and Safety Division. Lot(s) shall not have less than one (1%) percent gradient
on any asphalt or non-paved surface, or less than one quarter (1/4%) percent gradient
on any concrete surface. Provide the following information on plans: topographic site
information, including all building pad and other elevations, dimensions/location of
existing/proposed public improvements adjacent to project (i.e. street, sidewalk, parkway
and driveway widths, catch basins, pedestrian ramps); the width and location of all
existing and proposed easements, the dimensions and location of proposed dedications;
(for alley dedications, show elevations of the four corners of the dedication and
centerline of alley, existing and proposed underground utility connections); the location,
depth and dimensions of potable water, reclaimed water and sanitary sewer lines;
chemical and hazardous material storage, if any, including containment provisions; and
the type of existing use, including the gross square footage of the building and its
disposition; construction details of drainage devices and details of Low Impact
Development (LID) plan.
87) Include any other applicable site-specific conditions.
88) The drainage plan must provide for the site having an independent drainage system to
the public street, to a public drainage facility, or by means of an approved drainage
easement.
89) Surface water generated from the site shall not drain over the sidewalk or driveway into
the gutter on Woodruff Avenue. A parkway drain(s) is required for sites.
90) The owner/applicant shall comply with the National Pollutant Discharge Elimination
System (NPDES); Ordinance 1142 of the Downey Municipal Code (DMC); and the Low
Impact Development (LID) Plan. Furthermore, the applicant shall be required to Certify
and append Public Works standard “Attachment A” to all construction and grading plans
as required by the LACoDPW Stormwater Quality Management Plan (SQMP).
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Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 18
91) If any hazardous material is encountered on the site that has the potential to reach the
ground water supply, the owner/applicant shall secure a permit for the State Regional
Water Quality Control Board.
92) If any hazardous material is encountered on the site, the owner/applicant shall secure an
ID number from the EPA.
93) The owner/applicant shall deploy Best Management Practices during and after
construction.
94) The owner/applicant hereby consents to the annexation of the property into the Downey
City Lighting Maintenance District in accordance with Division 15 of the Streets and
Highways Code, and to incorporation or annexation into a new or existing Benefit
Assessment or Municipal Improvement District in accordance with Division 10 and
Division 12 of the Streets and Highways Code and/or Division 2 of the Government
Code of the State of California.
[End of Conditions]
PC Agenda Page 36
RESOLUTION NO. 21-____
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
DOWNEY RECOMMENDING THAT THE CITY COUNCIL APPROVE A
ZONING MAP AMENDMENT (PLN-19-00132), THEREBY CHANGING THE
ZONING DESIGNATION OF THE EAST PORTION OF THE PROPERTY
FROM P-B (PARKING BUFFER) TO M-2 (GENERAL MANUFACTURING)
LOCATED AT 12021 WOODRUFF AVENUE
THE PLANNING COMMISSION OF THE CITY OF DOWNEY DOES RESOLVE AS FOLLOWS:
SECTION 1. The Planning Commission of the City of Downey does hereby find,
determine and declare that:
A. On August 22, 2019, the applicant filed a request for a Conditional Use Permit,
Site Plan Review and Zone Change (PLN-19-00132) to construct a 44,162
square foot industrial tilt-up building to be used as a freight terminal and change
the zone from P-B (Parking Buffer) to M-2 (General Manufacturing); and,
B. On September 25, 2019, the applicant was issued a letter deeming the
application incomplete; and,
C. On December 15, 2020, in accordance with the requirement of CEQA, a Notice
of Intent to adopt a Mitigated Negative Declaration was submitted to the Los
Angeles County Recorder’s Office.
D. On February 1, 2021, the application was deemed complete after all required
documents were submitted and reviewed; and,
E. On February 4, 2021, a notice of the public hearing was sent to all property
owners within 500’ of the subject site and the notice was published in Downey
Patriot; and,
F. The Planning Commission held a duly noticed public hearing on February 17,
2021, and after fully considering all oral and written testimony, facts, and
opinions offered at the aforesaid public hearing adopted this resolution.
SECTION 2. The Planning Commission further finds, determines, and declares that
after preparing an Initial Study in compliance with the requirements of the California
Environmental Quality Act, which found that unless mitigated the project could have a significant
environmental impact. As such the Initial Study/Mitigated Negative Declaration was circulated
for public review from December 15, 2020 to January 14, 2021. Based on its own independent
judgment that the facts stated in the initial study are true, the Planning Commission hereby
recommends that the City Council of the City of Downey adopt a Mitigated Negative Declaration
of Environmental Impacts.
PC Agenda Page 37
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 2
SECTION 3. Having considered all of the oral and written evidence presented to it at
said public hearings regarding the Zone Change, the Planning Commission further finds,
determines and declares that:
A. The zone change is necessary and desirable for the development of the
community in harmony with the objectives of the General Plan and this chapter
and is in the interests or furtherance of the public health, safety, and general
welfare. The City Council adopted a comprehensive update to the Zoning
Ordinance, on October 14, 2008, which eliminated the P-B (Parking Buffer)
zoning category. The change of zone from P-B to M-2 (General Manufacturing)
will make the zoning of the site not only consistent with the current Zoning Code
but also with the General Plan, as the General Plan Land Use designation of the
site is General Manufacturing. Furthermore, the change in zoning for this
property does not grant the subject property any added liberties it did not
previously already have. Therefore, with this action there is no opportunity to
negatively affect the public health, safety, or general welfare of the community.
B. The zone change will be compatible and complementary to existing conditions
and adjoining property in the surrounding area. The site is currently comprised of
two separate zones, M-2 and P-B. The intent of the zone change is to remove
the P-B and provide one consistent zoning designation of M-2 for the entire site.
This is ultimately compatible with the existing and proposed use on the subject
property. It is also compatible with the surrounding area, as nearby properties
located to the north, south, east and West are also zoned M-2 and developed
with industrial uses.
C. The site is adequate in size to accommodate the uses permitted in the zone
requested and complies with all applicable property development standards. The
6.31 acre site is substantially greater than the minimum required lot size of
40,000 square feet for the M-2 zone. The minimum lot size is established in part
to ensure sites can appropriately meet development standards and
accommodate allowed uses. Furthermore, this proposed development will
comply with all applicable development standards.
D. The site properly relates to streets and highways designed and fully improved to
carry the type and quantity of traffic that is expected to be generated in the area
and that utilities exist or are planned which will adequately serve the property as
rezoned. The zone change does not alter the existing development potential of
the site because the M-2 zone already exists for the vast majority of the lot. The
M-2 zone is also present among adjacent properties facing Woodruff Avenue.
Therefore, the existing streets are already designed to accommodate the traffic
generated by industrial developments. The same is true of existing utilities and
other infrastructure.
E. The proposed zone change is in general conformance with the General Plan and
General Plan land use designation for the parcel. The zone change will eliminate
the current inconstancy between the zoning code and the zoning map and
General Plan. The entire property will now be zoned M-2 as it is intended per the
General Plan.
PC Agenda Page 38
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 3
SECTION 4. Based upon the findings set forth in Sections 1 through 3 of this resolution,
the Planning Commission of the City of Downey hereby recommends that the City Council
approve a zone change (PLN-19-00132) and update the Comprehensive Zoning Map to rezone
the subject property to M-2 (General Manufacturing), as outlined in Exhibit A of this resolution.
SECTION 5. The Secretary shall certify the adoption of this Resolution.
PASSED, APPROVED AND ADOPTED this 17th day of February, 2021.
Miguel Duarte, Chairman
City Planning Commission
I HEREBY CERTIFY that the foregoing is a true copy of a Resolution adopted by the Planning
Commission of the City of Downey at a regular meeting thereof, held on the 17th day of
February, 2021, by the following vote, to wit:
AYES: COMMISSIONERS:
NOES: COMMISSIONERS:
ABSENT: COMMISSIONERS:
ABSTAIN: COMMISSIONERS:
Mary Cavanagh, Secretary
City Planning Commission
PC Agenda Page 39
Resolution No. 21-
Downey Planning Commission
PLN-19-00132 – 12021 Woodruff Ave.
February 17, 2021 - Page 4
EXHIBIT A
Existing Zoning
Proposed Zoning
PC Agenda Page 40
Mitigation Monitoring and Reporting Program
Initial Study/Mitigated Negative Declaration
12021 Woodruff Avenue Industrial Building Project
Prepared for:
City of Downey
11111 Brookshire Avenue
Downey, California 90241
Contact: Alfonso S. Hernandez
Prepared by:
27372 Calle Arroyo
San Juan Capistrano, California 92675
Contact: Collin Ramsey
JANUARY 2021
Exhibit D PC Agenda Page 41
Exhibit D PC Agenda Page 42
Table of Contents
SECTION PAGE NO.
1 INTRODUCTION ............................................................................................................................................ 1
2 MITIGATION MONITORING AND REPORTING PROGRAM TABLE .................................................................... 2
TABLES
Table 1 Mitigation Monitoring and Reporting Program .................................................................................................... 2
Exhibit D PC Agenda Page 43
INTENTIONALLY LEFT BLANK
Exhibit D PC Agenda Page 44
1 Introduction
The California Environmental Quality Act (CEQA) requires that a public agency adopting a Mitigated Negative
Declaration (MND) take affirmative steps to determine that approved mitigation measures are implemented after
project approval. The lead or responsible agency must adopt a reporting and monitoring program for the mitigation
measures incorporated into a project or included as conditions of approval. The program must be designed to
ensure compliance with the MND during project implementation (California Public Resources Code, Section
21081.6(a)(1)).
This Mitigation Monitoring and Reporting Program (MMRP) will be used by the City of Downey (City) to ensure
compliance with adopted mitigation measures identified in the MND for the proposed 12021 Woodruff Avenue
Industrial Building Project (project) when construction begins. The City, as the lead agency, will be responsible for
ensuring that all mitigation measures are carried out. Implementation of the mitigation measures would reduce
impacts to below a level of significance for biological resources, cultural resources, geology and soils
(paleontological resources, noise, and tribal cultural resources.
The remainder of this MMRP consists of a table that identifies the mitigation measures by resource for each project
component. Table 1 identifies the mitigation monitoring and reporting requirements, list of mitigation measures,
party responsible for implementing mitigation measures, timing for implementation of mitigation measures, agency
responsible for monitoring of implementation, and date of completion. With the MND and related documents, this
MMRP will be kept on file at the following location:
City of Downey
Community Development Department
11111 Brookshire Avenue
Downey, California 90241
Exhibit D PC Agenda Page 45
2 Mitigation Monitoring and Reporting Program Table
Table 1 Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
Biological Resources
MM-BIO-1: Prior to the issuance of a demolition, grading,
and/or building permit for activities during the avian
nesting season (i.e., February 1 and September 1), the
project applicant shall submit a survey for active nests to
the City of Downey Building & Safety Division conducted by
a qualified biologist a maximum of 1 week prior to the
activities to determine the presence/absence, location,
and status of any active nests on or adjacent to the project
site. The nesting bird survey shall consist of full coverage of
the project footprint and an appropriate buffer, as
determined by the biologist. If no active nests are
discovered or identified, no further mitigation is required. In
the event that active nests are discovered on site, a
suitable buffer determined by the biologist shall be
established around any active nest. No ground-disturbing
activities shall occur within this buffer until the biologist
has confirmed that breeding/nesting is completed and the
young have fledged the nest. Limits of construction to
avoid a nest shall be established in the field by the
biologist with flagging and stakes or construction fencing.
Construction personnel shall be instructed regarding the
ecological sensitivity of the fenced area. The results of the
survey shall be documented and filed with the City of
Downey within 5 days after the survey.
Prior to
construction;
during
construction (if
active nests are
identified)
Project applicant and their
construction contractor
City of Downey
Cultural Resources
MM-CUL-1: In the event that archaeological resources
(sites, features, or artifacts) are exposed during
construction activities for the project, all construction work
occurring within 100 feet of the find shall immediately stop
until a qualified archaeologist, meeting the Secretary of the
During
construction
Project applicant and their
construction contractor
City of Downey
Exhibit D PC Agenda Page 46
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
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.
Geology and Soils
MM-GEO-1: In the event that paleontological resources
(fossil remains) are exposed during construction activities
for the proposed project, all construction work occurring
within 50 feet of the find shall immediately stop until a
qualified paleontologist, as defined by the Society of
Vertebrate Paleontology’s 2010 guidelines, can assess the
nature and importance of the find. Depending on the
significance of the find, the paleontologist may record the
find and allow work to continue or recommend salvage and
recovery of the resource. All recommendations will be
made in accordance with the Society of Vertebrate
Paleontology’s 2010 guidelines and shall be subject to
review and approval by the City of Downey. Work in the
area of the find may only resume upon approval of a
qualified paleontologist.
During
construction
Project applicant and their
construction contractor
City of Downey
Hazards and Hazardous Materials
MM-HAZ-1: Based on the recommendations made in the
Phase I ESA prepared by Partner Engineering, the following
shall occur prior to the issuance of building permits for the
proposed on-site buildings and structures:
1. A limited subsurface investigation shall be conducted
in order to determine the presence or absence of soil
and/or soil vapor contamination due to the current and
historical use of the project site.
Prior to issuance
of building
permits
Project applicant City of Downey
Exhibit D PC Agenda Page 47
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
2. A Soil Management Plan should be prepared to
appropriately handle the known oil releases at the
project site and any unknown releases associated with
the current and former industrial use.
3. The No Further Action letter dated August 6, 1992,
pertaining to the historical underground storage tanks
(USTs) at the project site should be revised to clearly
include Closure Permit Number 6000B for the
abandoned-in-place UST to avoid confusion in the
future as to whether it was officially closed.
4. An asbestos survey conducted in 1990 identified
asbestos in the existing building on the project site. It is
not known if the survey was conducted for all
equipment and building materials at the time;
therefore, an asbestos survey should be performed
and known asbestos-containing materials (ACMs)
should be abated or removed for safety purposes (or
an operations and maintenance program should be
implemented in order to safely manage the known and
suspect ACMs located at the project site).
Noise
MM-NOI-1: The following measures shall be implemented
to reduce construction noise and vibration emanating from
construction of the project:
1. At least 30 days prior to commencement of
construction, the project applicant’s contractor shall
provide written notice to all residential property owners
and tenants within 300 feet of the project site that
proposed construction activities could affect outdoor or
indoor living areas. The notice shall contain a
description of the project, a construction schedule
including days and hours of construction, and a
description of noise-reduction measures.
2. Noise-generating construction activities (which may
include preparation for construction work) shall be
Prior to
construction
Project applicant and their
construction contractor
City of Downey
Exhibit D PC Agenda Page 48
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
permitted weekdays between 7:00 a.m. and 6:00 p.m.,
excluding federal holidays. When a holiday falls on a
Saturday or Sunday, the preceding Friday or following
Monday, respectively, shall be observed as a legal
holiday.
3. Prior to commencement of demolition work, and
throughout major construction work up to but not
including architectural coating, a temporary
construction noise barrier (8 feet in height) shall be
erected along the southern project site boundary, from
the southwestern corner extending a distance of 75
feet to the east. This barrier would completely interrupt
the line-of-sight of the project site from residences to
the southwest.
4. All construction equipment powered by internal
combustion engines shall be properly muffled and
maintained. No internal combustion engine shall be
operated on the site without a muffler. All diesel
equipment shall be operated with closed engine doors
and shall be equipped with factory recommended
mufflers. Unnecessary idling of internal combustion
engines shall be prohibited.
5. Air compressors and generators used for construction
shall be surrounded by temporary acoustical shelters.
Whenever feasible, electrical power shall be used to
run air compressors and similar power tools.
6. The distance between construction equipment staging
areas and adjacent residences shall be maximized
where feasible.
7. During construction, stationary construction equipment
shall be placed such that emitted noise is directed
away from or shielded from sensitive receptors.
8. Stationary construction equipment that generates
noise that exceeds 85 A-weighted decibels at the
property boundaries shall be shielded with a barrier
that meets a Sound Transmission Class rating of 25.
Exhibit D PC Agenda Page 49
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
Tribal Cultural Resources
MM-TCR-1: Prior to the commencement of any ground
disturbing activity at the project site, the project applicant
shall retain a Native American Monitor approved by the
Gabrieleno Band of Mission Indians-Kizh Nation – the tribe
that consulted on this project pursuant to Assembly Bill
(AB) 52 (the “Tribe” or the “Consulting Tribe”). A copy of the
executed contract shall be submitted to the City of Downey
Community Development Department, Planning Division
prior to the issuance of any permit necessary to commence
a ground-disturbing activity.
The Tribal monitor will only be present on-site during the
construction phases that involve ground-disturbing
activities. Ground disturbing activities are defined by the
Tribe as activities that may include, but are not limited to,
pavement removal, potholing or auguring, grubbing, tree
removals, boring, grading, excavation, drilling, and
trenching, within the project site. The Tribal Monitor shall
complete daily monitoring logs that will provide
descriptions of the day’s activities, including construction
activities, locations, soil, and any cultural materials
identified. The on-site monitoring shall end when all
ground-disturbing activities on the Project Site are
completed, or when the Tribal Representatives and Tribal
Monitor have indicated that all upcoming ground-disturbing
activities at the project site have little to no potential for
impacting Tribal Cultural Resources.
Should Tribal Cultural Resources be discovered,
construction activities shall cease in the immediate vicinity
of the find (not less than the surrounding 100 feet) until
the find can be assessed. All Tribal Cultural Resources
unearthed by project activities shall be evaluated by the
qualified archaeologist and Tribal Monitor approved by the
Consulting Tribe. If the resources are Native American in
origin, the Consulting Tribe will retain the resources in the
During
construction
Project applicant and their
construction contractor
City of Downey
Exhibit D PC Agenda Page 50
Mitigation Measure
Implementation
Timing
Party Responsible for
Implementation
Party Responsible For
Monitoring
Date of
Completion/Notes
form and manner the Tribe deems appropriate, for
educational, cultural or historic purposes.
If human remains or grave goods are discovered or
recognized at the project site, all ground disturbance shall
immediately cease at a minimum of 150 feet around the
discovery, and the Los Angeles County Coroner shall be
notified per Public Resources Code Section 5097.98, and
Health & Safety Code Section 7050.5. Human remains and
grave/burial goods shall be treated alike per California
Public Resources Code section 5097.98(d)(1) and (2).
Work may continue on other parts of the Project Site while
evaluation and, if necessary, mitigation takes place (CEQA
Guidelines Section 15064.5[f]). If a non-Native American
resource is determined by the qualified archaeologist to
constitute a “historical resource” or “unique archaeological
resource,” time allotment and funding sufficient to allow for
implementation of avoidance measures, or appropriate
mitigation, must be available.
The treatment plan established for the resources shall be
in accordance with CEQA Guidelines Section 15064.5(f) for
historical resources and PRC Sections 21083.2(b) for
unique archaeological resources. Preservation in place
(i.e., avoidance) is the preferred manner of treatment. If
preservation in place is not feasible, treatment may include
implementation of archaeological data recovery
excavations to remove the resource along with subsequent
laboratory processing and analysis. Any historic
archaeological material that is not Native American in
origin shall be curated at a public, non-profit institution with
a research interest in the materials, such as the Natural
History Museum of Los Angeles County or the Fowler
Museum, if such an institution agrees to accept the
material. If no institution accepts the archaeological
material, it shall be offered to a local school or historical
society in the area for educational purposes.
Exhibit D PC Agenda Page 51
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Exhibit D PC Agenda Page 52
FINAL
Initial Study/Mitigated Negative Declaration, Responses to
Comments, and Errata for the
12021 Woodruff Avenue Industrial Building Project
(PLN-19-00132)
Prepared for:
City of Downey
11111 Brookshire Avenue
Downey, California 90241
Contact: Alfonso S. Hernandez
Prepared by:
27372 Calle Arroyo
San Juan Capistrano, California 92675
Contact: Collin Ramsey
FEBRUARY 2021
Exhibit E PC Aegenda Page 53
Exhibit E PC Aegenda Page 54
Table of Contents
SECTION PAGE NO.
1 INTRODUCTION ............................................................................................................................................. 1
2 RESPONSES TO COMMENTS ........................................................................................................................ 2
3 ERRATA ......................................................................................................................................................... 3
4 REFERENCES ................................................................................................................................................ 9
TABLES
1 Comment Letter Summary .................................................................................................................................. 1
Exhibit E PC Aegenda Page 55
INTENTIONALLY LEFT BLANK
Exhibit E PC Aegenda Page 56
1 Introduction
An Initial Study/Mitigated Negative Declaration (IS/MND) was prepared for the proposed 12021 Woodruff Avenue
Industrial Building Project (project) and made available for public comment for a 30-day public review period from
December 15, 2020, through January 14, 2021. In accordance with the California Environmental Quality Act (CEQA)
Guidelines, Section 15074(b) (14 CCR 15074(b)), before approving the proposed project, the City of Downey (City),
as the lead agency under CEQA, will consider the IS/MND with any comments received during this public review
period. Specifically, Section 15074(b) of the CEQA Guidelines (14 CCR 15074(b)) states the following:
Prior to approving a project, the decision-making body of the lead agency shall consider the proposed negative
declaration or mitigated negative declaration together with any comments received during the public review
process. The decision-making body shall adopt the proposed negative declaration or mitigated negative declaration
only if it finds on the basis of the whole record before it (including the initial study and any comments received),
that there is no substantial evidence that the project will have a significant effect on the environment and that the
negative declaration or mitigated negative declaration reflects the lead agency’s independent judgment and
analysis.
The agencies and individuals who provided substantive written comments on the environmental issues addressed
in the Draft IS/MND are listed in Table 1. Although CEQA (California Public Resources Code, Section 21000 et seq.)
and the CEQA Guidelines (14 CCR 15000 et seq.) do not explicitly require a lead agency to provide written responses
to comments received on an IS/MND, the lead agency may do so voluntarily. Individual comments within each
communication are numbered so comments can be cross-referenced with responses. The comment letter received
during the public review period is included in Appendix A.
Table 1 Comment Letter Summary
Letter Number Commenter Date
1 California Department of Transportation
Signed: Miya Edmonson, IGR/CEQA Branch
Chief
January 14, 2021
Responses to comments are made in the following text to supplement, clarify, or expand on information already
presented in the Draft IS/MND. These responses do not change the significance of determinations made or the
severity of potential environmental impacts evaluated in the Draft IS/MND. Section 15073.5(c)(4) of the CEQA
Guidelines (14 CCR 15073.5(c)(4)) permits the inclusion of new information within an IS/MND if the additional
information “merely clarifies, amplifies, or makes insignificant modifications to the negative declaration.”
Exhibit E PC Aegenda Page 57
2 Responses to Comments
Response to Comment Letter 1
Miya Edmonson, IGR/CEQA Branch Chief
California Department of Transportation
January 14, 2021
1-1 This comment serves as an introduction to comments that follow. The City appreciates the California
Department of Transportation’s (Caltrans) review of the Draft Initial Study and Mitigated Negative
Declaration. This comment provides a synopsis of the project from the Draft IS/MND and does not state
a specific concern or question regarding the adequacy of the environmental impact analysis in the Draft
IS/MND.
1-2 This comment summarizes Senate Bill 743 requirements and states that both a level of service (LOS)
and vehicle miles travelled (VMT) analysis were provided for the IS/MND. The commenter concurs that
the since the project is located near a High-Quality Transit Corridor, and meets criteria outlined in the
Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018), the office component of
the project can be presumed to have a less than significant Vehicle Miles Traveled (VMT) impact.
Additionally, links to the Caltrans’ updated VMT-Focused Transportation Impact Study Guide (TISG),
dated May 2020, and interim safety analysis guidance, dated July 2020, are provided for informational
purposes. The commenter does not identify a specific concern with the adequacy of the Draft IS/MND
or raise an issue or comment specifically related to the Draft IS/MND’s environmental analysis.
Notwithstanding, the project’s transportation impacts, including impacts with respect to VMT and
transportation safety, were addressed in Section 3.17 of the Draft IS/MND. No further response is
required.
1-3 The commenter provides transportation demand management (TDM) strategy recommendations for
incorporation into the project in order to further reduce impacts to VMT and greenhouse gas emissions.
This comment does not identify a specific concern with the adequacy of the Draft IS/MND or raise an
issue or comment specifically related to the Draft IS/MND’s environmental analysis. As discussed in
Sections 3.9 and 3.17 of the Draft IS/MND, the project would result in less-than-significant greenhouse
gas emissions and VMT impacts and no additional mitigation measures, including TDM measures, are
required. No further response is required.
1-4 This comment states that a Caltrans transportation permit will be required for any oversized-transport
vehicles on State highways being used to transport heavy construction equipment and/or materials.
Should a Caltrans transportation permit be required for the project, the City will ensure that the project
applicant complies with all laws and regulations, including those implemented by Caltrans. This
comment does not identify a specific concern with the adequacy of the Draft IS/MND or raise an issue
or comment specifically related to the Draft IS/MND’s environmental analysis. No further response is
required.
Exhibit E PC Aegenda Page 58
3 Errata
The following provides minor revisions, corrections, and additions to the Draft IS/MND. The corrections and
additions are organized by section and page number of the Draft IS/MND. New text additions are shown in underline
format, and deletions are shown in strikeout format.
Section 1.1, Project Overview
The size of the existing on-site building is 193,451 square feet; however, the size was incorrectly listed as 74,662
square feet in the Draft IS/MND. The text of the Draft IS/MND has been revised to reflect the correct existing square
footage, as listed below. (Note that although the modeling for air quality, greenhouse gas em issions, and
transportation impacts took into account baseline conditions, this modeling was based on empirical data provided
by the existing property owner/operator, so the existing on-site square footage did not factor into the modeling or
impact conclusions; thus, the increase of the size of the existing on-site building from 74,662 square feet to
193,451 square feet does not have an effect on the methodology, analysis, or conclusions presented in the Draft
IS/MND).
Page 1
The project would include the demolition of the existing, 74,662 193,451-square-foot industrial building
and construction of an approximately 44,162-square-foot industrial tilt-up building for truck terminal use.
Section 2.3, Project Characteristics
Page 4
Proposed Project
The project includes the demolition of an existing, 74,662 193,451 -square-foot industrial building and
construction of an approximately 44,162-square -foot tilt-up industrial building for truck terminal use.
Section 3, Initial Study Checklist
Page 10
Description of Project:
The project includes the demolition of an existing, 74,662 193,451-square-foot industrial building and
construction of an approximately 44,162-square-foot tilt-up industrial building for truck terminal use.
Section 3.5, Cultural Resources
Page 41
The proposed project includes demolition of an existing, 74,662 193,451-square-foot industrial building
located at 12021-12023 Woodruff Avenue, Downey, California 90241 (subject property) on a 6.31-acre
parcel (AIN 6284-025-018) originally developed in 1951 for Kirkhill Manufacturing Inc.
Exhibit E PC Aegenda Page 59
Section 3.7, Geology and Soils
Page 53
The project would include the demolition of an existing, 74,662 193,451 -square-foot industrial
building and construction of an approximately 44,162 -square-foot industrial building for truck terminal
use.
Section 3.9, Hazards and Hazardous Materials
Page 70
The project would include the demolition of an existing, 74,662 193,451 -square-foot industrial
building and constru ction of an approximately 44,162 -square -foot industrial building.
Section 3.14, Population and Housing
Page 98
The project would include the demolition of an existing, 74,662 193,451 -square-foot industrial
building and construction of an approximately 44,162-square-foot industrial tilt-up building (industrial
building) for truck terminal use.
Section 3.18, Tribal Cultural Resources
As discussed within Section 3.18 of the Draft IS/MND, under CEQA, an effect to a TCR is considered a “substantial
adverse change,” if it is shown that the change would materially impair the significance of the historical resource.
That is, a project that demolishes or materially alters in an adverse manner those physical characteristics of a
historical resource conveying its historic significance would materially impair the significance of a historical
resource. Therefore, such a change would constitute a “substantial adverse change” under CEQA.
In order to assess the potential to encounter TCR and other archaeological resources on the project site, Dudek
prepared a Cultural and Historical Resources Technical Report, which was included as Appendix A to the Draft
IS/MND. As part of the Cultural and Historical Resources Technical Report, Dudek con ducted a review of records
of archaeological resources with the California Historical Resources Information System and the Native American
Heritage Commission Sacred Lands File. No archaeological resources were identified during these records
searches. Additionally, in compliance with AB 52, the City contacted all NAHC-listed traditionally geographically
affiliated tribal representatives on August 31, 2020 in an effort to identify resources that could potentially be
located on the project site.
As a result of these efforts, one tribe requested consulting party status under AB 52: the Gabrieleno Band of Mission
Indians – Kizh Nation. The response from representative Andrew Salas of the Gabrieleno Band of Mission Indians
– Kizh Nation was received on September 8, 2020. However, after making several attempts to contact the
Gabrieleno Band of Mission Indians – Kizh Nation to schedule a consultation meeting, no response was ever
received, and consultation between the City and the Gabrieleno Band of Mission Indians – Kizh Nation was
considered completed. Formal notice of the process’s completion was provided to Andrew Salas of the Gabrieleno
Band of Mission Indians – Kizh Nation on December 9, 2020.
Exhibit E PC Aegenda Page 60
Upon completion of the AB 52 process, the Draft IS/MND concluded that there are no TCRs within the immediate
vicinity of the project site that have been determined by the City to be significant pursuant to the criteria set forth
in Public Resources Code Section 5024.1. Nonetheless, given the Gabrieleno Band of Mission Indians – Kizh
Nation’s initial interest in consulting on this project, a mitigation measure, MM-TCR-1, was included in the Draft
IS/MND. MM-TCR-1 would set forth steps to ensure that if potential TCRs are unearthed, they would be appropriately
treated and preserved. With implementation of MM-TCR-1, it was concluded that the project would have a less-
than-significant impact on potential TCRs. Following these efforts, the Draft IS/MND was circulated for public review
on December 15, 2020, with a notice of the document’s availability being sent to the Gabrieleno Band of Mission
Indians – Kizh Nation.
On December 16, 2020, following the City’s proposed conclusion of the AB 52 consultation process, the Gabrieleno
Band of Mission Indians – Kizh Nation provided a new letter recommending a new mitigation measure be required
of the project applicant in order to comply with CEQA. However, no additional information was provided in this letter
that would indicate that there are TCRs on the project site or that the project could have an adverse effect TCRs.
Nonetheless, in in an abundance of caution and in an effort to maintain a good faith relationship with the Gabrieleno
Band of Mission Indians – Kizh Nation, the City will refine MM-TCR-1 to include the mitigation measures included
within the Tribe’s comment letter, with a minor change to specify the minimum radius for which work shall
temporarily stop if a resource is encountered. This change to MM-TCR-1 has been made below.
This modification does not change the significance determination made regarding TCRs, but rather merely
strengthens and clarifies manner in which MM-TCR-1 would be implemented. As such, this modification is
consistent with Section 15073.5(c)(4) of the CEQA Guidelines (14 CCR 15073.5(c)(4)), and no f urther action is
necessary.
Page 115-116
MM-TCR-1 While no tribal cultural resources (TCRs) have been identified that may be affected by the
project, the following approach for the unanticipated discovery of TCRs has been prepared to
reduce potential impacts to unanticipated resources. Should a potential TCR be encountered,
construction activities near the potential TCR shall be temporarily halted within 50 feet of the
potential TCR and the City of Downey (City) shall be notified. The City will notify Native American
tribes that have been identified by the Native American Heritage Commission (NAHC) to be
traditionally and culturally affiliated with the geographic area of the project. If the unanticipated
resource is archaeological in nature, appropriate management requirements shall be
implemented as outlined in mitigation measure MM-CUL-1. If the City determines that the
potential resource is a TCR (as defined by Public Resources Code, Section 21074), tribes
consulting under AB 52 would be provided a reasonable period of time, typically five days from
the date a new discovery is made, to conduct a site visit and make recommendations regarding
future ground disturbance activities as well as the treatment and disposition of any discovered
TCRs. A qualified archaeologist shall implement a plan for the treatment and disposition of any
discovered TCRs based on the nature of the resource and considering the recommendations of
the tribe(s). All activities shall be conducted in accordance with regulatory requirements.
Prior to the commencement of any ground disturbing activity at the project site, the project
applicant shall retain a Native American Monitor approved by the Gabrieleno Band of Mission
Indians-Kizh Nation – the tribe that consulted on this project pursuant to Assembly Bill (AB) 52
(the “Tribe” or the “Consulting Tribe”). A copy of the executed contract shall be submitted to the
Exhibit E PC Aegenda Page 61
City of Downey Community Development Department, Planning Division prior to the issuance of
any permit necessary to commence a ground-disturbing activity.
The Tribal monitor will only be present on-site during the construction phases that involve ground-
disturbing activities. Ground disturbing activities are defined by the Tribe as activities that may
include, but are not limited to, pavement removal, potholing or auguring, grubbing, tree removals,
boring, grading, excavation, drilling, and trenching, within the project site. The Tribal Monitor shall
complete daily monitoring logs that will provide descriptions of the day’s activities, including
construction activities, locations, soil, and any cultural materials identified. The on-site monitoring
shall end when all ground-disturbing activities on the Project Site are completed, or when the
Tribal Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing
activities at the project site have little to no potential for impacting Tribal Cultural Resources.
Should Tribal Cultural Resources be discovered, construction activities shall cease in the
immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be
assessed. All Tribal Cultural Resources unearthed by project activities shall be evaluated by the
qualified archaeologist and Tribal Monitor approved by the Consulting Tribe. If the resources are
Native American in origin, the Consulting Tribe will retain the resources in the form and manner
the Tribe deems appropriate, for educational, cultural or historic purposes.
If human remains or grave goods are discovered or recognized at the project site, all ground
disturbance shall immediately cease at a minimum of 150 feet around the discovery, and the Los
Angeles County Coroner shall be notified per Public Resources Code Section 5097.98, and Health
& Safety Code Section 7050.5. Human remains and grave/burial goods shall be treated alike per
California Public Resources Code section 5097.98(d)(1) and (2). Work may continue on other
parts of the Project Site while evaluation and, if necessary, mitigation takes place (CEQA
Guidelines Section 15064.5[f]). If a non-Native American resource is determined by the qualified
archaeologist to constitute a “historical resource” or “unique archaeological resource,” time
allotment and funding sufficient to allow for implementation of avoidance measures, or
appropriate mitigation, must be available.
The treatment plan established for the resources shall be in accordance with CEQA Guidelines
Section 15064.5(f) for historical resources and PRC Sections 21083.2(b) for unique
archaeological resources. Preservation in place (i.e., avoidance) is the preferred manner of
treatment. If preservation in place is not feasible, treatment may include implementation of
archaeological data recovery excavations to remove the resource along with subsequent
laboratory processing and analysis. Any historic archaeological material that is not Native
American in origin shall be curated at a public, non-profit institution with a research interest in the
materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if
such an institution agrees to accept the material. If no institution accepts the archaeological
material, it shall be offered to a local school or historical society in the area for educational
purposes.
Exhibit E PC Aegenda Page 62
Section 3.19, Utilities and Services
As discussed above, the square footage of the existing building on the project site has been updated to reflect the
correct square footage:
Page 117
Water Facilities
The project would include the demolition of an existing, 74,662 193,451-square-foot industrial building
and construction of an approximately 44,162-square-foot industrial building for truck terminal use.
Page 121
The project involves the demolition of an existing, 74,662 193,451 -square-foot industrial building and
construction of an approximately 44,162-square -foot industrial building for truck terminal use.
Exhibit E PC Aegenda Page 63
INTENTIONALLY LEFT BLANK
Exhibit E PC Aegenda Page 64
4 References
OPR (Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA.
December 2018. https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf.
Exhibit E PC Aegenda Page 65
INTENTIONALLY LEFT BLANK
Exhibit E PC Aegenda Page 66
Appendix A
Comment Letter
Exhibit E PC Aegenda Page 67
“Provide a safe, sustainable, integrated and efficient transportation system
to enhance California’s economy and livability”
STATE OF CALIFORNIA------- CALIFORNIA STATE TRANSPORTATION AGENCY Gavin Newsom, Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 7 – Office of Regional Planning
100 S. MAIN STREET, MS 16
LOS ANGELES, CA 90012
PHONE (213) 897-0475
FAX (213) 897-1337
TTY 711
www.dot.ca.gov
Making Conservation
a California Way of Life.
January 14, 2021
Alfonso S. Hernandez
City of Downey
11111 Brookshire Avenue
Downey, CA 90241
RE: 12021 Woodruff Avenue Industrial Building
Project – Mitigated Negative Declaration
(MND)
SCH # 2020120264
GTS # 07-LA-2020-03451
Vic. LA-105/PM: R17.101
Dear Alfonso S. Hernandez:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review
process for the above referenced MND. The project includes the demolition of an existing, 74,662-square-
foot industrial building and construction of an approximately 44,162-square-foot tilt-up industrial building
that would serve as a trucking terminal for distribution and logistics purposes. The industrial building would
include approximately 36,142 square feet of warehouse space and 8,020 square feet of office space. On-
site activities will include storage of and/or consolidation of manufactured goods before their distribution
to commercial establishments or other warehouses. The City of Downey is the Lead Agency under the
California Environmental Quality Act (CEQA).
The project is located near the following state facilities:
• Interstate 5 (I-5): approximately 1.5 miles away from the I-5 and Interstate 605 interchange.
• Interstate 105 (I-105): approximately 1 mile from the I-105 and Bellflower Boulevard ramps.
• Interstate 605 (I-605): approximately 4,000 feet away from the I-605 and Firestone
Boulevard ramps.
• State Route 19 (SR-19): approximately 1.6 miles from the I-105 and SR-19 interchange.
From reviewing the MND, Caltrans has the following comments:
• We concur that since the project is located near a High-Quality Transit Corridor, and meets the
four criteria below, the office component of the project can be presumed to have a less than
significant Vehicle Miles Traveled (VMT) impact. This conclusion is based on the Technical
Advisory on Evaluating Transportation Impacts in CEQA by the California Governor’s Office of
Planning and Research (OPR), dated December 2018.
o Has a Floor Area Ratio (FAR) of more than 0.75.
o Does not include more parking for use by residents, customers, or employees of the project
than required by the jurisdiction.
o Is consistent with the applicable Sustainable Communities Strategy.
o Does not replace affordable residential units with a smaller number of moderate- or high-
Comment Letter 1
1-1
1-2
Cont.
Exhibit E PC Aegenda Page 68
Alfonso S. Hernandez
January 14, 2021
Page 2 of 2
“Provide a safe, sustainable, integrated and efficient transportation system
to enhance California’s economy and livability”
income residential units.
•The above conclusion is also based on Caltrans’ updated Vehicle Miles Traveled-Focused
Transportation Impact Study Guide (TISG), dated May 2020 and released on Caltrans’ website in
July 2020: https://dot.ca.gov/-/media/dot-media/programs/transportation-planning/documents/sb-
743/2020-05-20-approved-vmt-focused-tisg-a11y.pdf. Caltrans’ new TISG is largely based on the
2018 OPR Technical Advisory.
•The updated TISG states, “Additional future guidance will include the basis for requesting
transportation impact analysis that is not based on VMT. This guidance will include a simplified
safety analysis approach that reduces risks to all road users and that focuses on multi-modal
conflict analysis as well as access management issues.” Since releasing the TISG, Caltrans has
released interim safety analysis guidance, dated December 2020 and found here, for the City’s
reference: https://dot.ca.gov/-/media/dot-media/programs/transportation-planning/documents/sb-
743/2020-12-22-updated-interim-ldigr-safety-review-guidance-a11y.pdf.
The following information is included for your consideration.
The mission of Caltrans is to provide a safe, sustainable, integrated and efficient transportation system
to enhance California’s economy and livability. Furthermore, Caltrans encourages Lead Agencies to
implement Transportation Demand Management (TDM)strategies that reduce VMT and Greenhouse
Gas (GHG) emissions. Thus, Caltrans supports the TDM strategies this project has incorporated, such
as implementing a TDM plan.For more TDM options to integrate into this project to further reduce VMT,
please refer to:
•The 2010 Quantifying Greenhouse Gas Mitigation Measures report by the California Air
Pollution Control Officers Association (CAPCOA), available at http://www.capcoa.org/wp-
content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf, or
•Integrating Demand Management into the Transportation Planning Process: A Desk Reference
(Chapter 8) by the Federal Highway Administration (FHWA), available at
https://ops.fhwa.dot.gov/publications/fhwahop12035/index.htm.
Also, any transportation of heavy construction equipment and/or materials which requires use of
oversized-transport vehicles on State highways will need a Caltrans transportation permit. Caltrans
recommends that the project limit construction traffic to off-peak periods to minimize the potential impact
on State facilities. If construction traffic is expected to cause delays on any State facilities, please submit
a construction traffic control plan detailing these delays for Caltrans’ review.
If you have any questions about these comments, please contact Emily Gibson and Mayra Jimon, the
project coordinators, at Emily.Gibson@dot.ca.gov and Mayra.Jimon@dot.ca.gov, and refer to GTS #07-
LA-2020-03451.
Sincerely,
MIYA EDMONSON
IGR/CEQA Branch Chief
cc: Scott Morgan, State Clearinghouse
1-2
Cont.
1-3
1-4
Exhibit E PC Aegenda Page 69
December 14, 2020
To: Interested Parties
Subject: NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION FOR THE
PLANNING DIVISION APPLICATION (PLN-19-00132)
The City of Downey is the California Environmental Quality Act (CEQA) lead agency responsible for the review
and approval of the proposed Planning Division Application PLN-19-00132 for a Zone Change, Site Plan Review,
and Conditional Use Permit for 12021–12023 Woodruff Avenue (project site). As such, the City of Downey (City)
has prepared an Initial Study/Draft Mitigated Negative Declaration (IS/MND), which evaluates the potential
environmental impacts of the project.
Project Location: The project site consists of a single parcel (Assessor’s Identification Number 6284-025-018). The
addresses associated with the project site are 12021–12023 Woodruff Avenue, Downey, California 90241 (Figure 1,
Project Location).
The majority of the project site is zoned M-2 (Manufacturing); however, a portion of the project site to the west is
zoned as P-B (Parking Buffer). The project site has a General Plan Land Use Designation of GM (General
Manufacturing).
Project Description: The project includes the demolition of an existing, 74,662-square-foot industrial building
and construction of an approximately 44,162-square-foot tilt-up industrial building for truck terminal use. The
proposed industrial building would include approximately 36,142 square feet of warehouse space and 8,020
square feet of office space (Figure 2, Site Plan).
The new industrial building is intended to be used as a trucking terminal for distribution and logistics purposes.
On-site activities will include storage of and/or consolidation of manufactured goods before the distribution to
commercial establishments or other warehouses. Other than truck parking and storage, all activities will occur
within the industrial building. The office space is intended to be used for office uses ancillary to the warehouse
operation.
Exhibit F PC Agenda Page 70
Zone Change: The project site currently maintains two zoning classifications: General Manufacturing (M-2) and
Parking Buffer (P-B). Incidentally, the Downey Zoning Code (Article IX, Land Use, of the Downey Municipal
Code [2020]) no longer references the P-B zone. All mention of it was removed from the Zoning Code in 2008
when the code was updated. The Downey City Council removed the P-B zone because it was considered
redundant since the development standards of the City’s residential and non-residential zones provide the same
safeguards as the former P-B zone. The only trace of the P-B zone is the City’s Zoning Map and properties on the
map that still maintain that classification.
The Zone Change application is a request to rezone the P -B portion of the project site to M-2 so that the entire
property maintains the M-2 zoning classification. The M-2 zone is the classification that corresponds with General
Manufacturing General Plan category.
Public Review Period: The IS/MND is being made available for public review for a period of 30 days beginning
December 15, 2020, and concluding January 14, 2021. Following the close of the public review period, the City
will consider this IS/MND and comments thereto in determining whether to approve the project.
The electronic version of the IS/MND may be viewed at the following website address:
https://www.downeyca.org/our-city/departments/community-development/planning/environmental-documents
Printed copies of the IS/MND are also available for review at the City of Downey Planning Counter, located at
11111 Brookshire Avenue, California 90241.
Comments on the IS/MND must be received in writing no later than January 14, 2021, and sent to, or
delivered in person to:
Mr. Alfonso Hernandez, Senior Planner
City of Downey
11111 Brookshire Avenue,
Downey, California 90241
Public Hearing: A Planning Commission hearing where the project, the IS/MND, and requested project
entitlements will be considered for potential recommendation to the City Council has yet to be scheduled. Once
the Planning Commission hearing has been scheduled, the City will notice the hearing consistent with all
applicable City public noticing requirements.
Exhibit F PC Agenda Page 71
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SOURCE: USDA NAIP 2016; Open Street Map 2019; USGS NHD 2020
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Exhibit F PC Agenda Page 72
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SOURCE: Bing Maps 2020; Open Street Map 2019; HPA Architecture 2020
001050Feet
FIGURE 2
Full Access P = Full Access Passenger Cars
INBD-T = Inbound Trucks (No Truck Exit)
OTBD-T = Outbound Trucks (No Truck Entry)
Driveway 1
(FA-P, INBD-T)
Driveway 2
(FA-P, OTBD-T)
Exhibit F PC Agenda Page 73
DRAF T
Initial Study/Mitigated Negative Declaration
12021 Woodruff Avenue Industrial Building Project
(PLN-19-00132)
Prepared for:
City of Downey
11111 Brookshire Avenue
Downey, California 90241
Contact: Alfonso S. Hernandez
Prepared by:
27372 Calle Arroyo
San Juan Capistrano, California 92675
Contact: Collin Ramsey
DECEMBER 2020
Exhibit F PC Agenda Page 74
Printed on 30% post-consumer recycled material. Exhibit F PC Agenda Page 75
12818
i December 2020
Table of Contents
SECTION PAGE NO.
ACRONYMS AND ABBREVIATIONS .............................................................................................................................. V
1 INTRODUCTION ............................................................................................................................................. 1
1.1 Project Overview ..................................................................................................................................... 1
1.2 California Environmental Quality Act Compliance ................................................................................ 1
1.3 Public Review Process ........................................................................................................................... 2
2 PROJECT DESCRIPTION ................................................................................................................................ 3
2.1 Project Location ...................................................................................................................................... 3
2.2 Environmental Setting ............................................................................................................................ 3
2.3 Project Characteristics ........................................................................................................................... 4
2.4 Project Approvals .................................................................................................................................... 7
3 INITIAL STUDY CHECKLIST ............................................................................................................................ 9
3.1 Aesthetics ............................................................................................................................................ 14
3.2 Agriculture and Forestry Resources ................................................................................................... 16
3.3 Air Quality ............................................................................................................................................. 18
3.4 Biological Resources ........................................................................................................................... 37
3.5 Cultural Resources .............................................................................................................................. 40
3.6 Energy .................................................................................................................................................. 46
3.7 Geology and Soils ................................................................................................................................ 51
3.8 Greenhouse Gas Emissions ................................................................................................................ 56
3.9 Hazards and Hazardous Materials ..................................................................................................... 69
3.10 Hydrology and Water Quality ............................................................................................................... 76
3.11 Land Use and Planning ....................................................................................................................... 82
3.12 Mineral Resources .............................................................................................................................. 87
3.13 Noise .................................................................................................................................................... 88
3.14 Population and Housing ...................................................................................................................... 98
3.15 Public Services .................................................................................................................................. 100
3.16 Recreation .......................................................................................................................................... 102
3.17 Transportation ................................................................................................................................... 103
3.18 Tribal Cultural Resources .................................................................................................................. 113
3.19 Utilities and Service Systems ............................................................................................................ 116
3.20 Wildfire ............................................................................................................................................... 122
3.21 Mandatory Findings of Significance ................................................................................................. 124
4 REFERENCES AND PREPARERS................................................................................................................ 127
4.1 References Cited ............................................................................................................................... 127
4.2 List of Preparers ................................................................................................................................ 134
Exhibit F PC Agenda Page 76
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
ii December 2020
APPENDICES
A Historic and Cultural Resources Report
B Air Quality, Greenhouse Gas Emission, and Energy Modeling Inputs and Outputs
C Transportation Impact Analysis
D Geotechnical Study
E Phase I Environmental Site Assessment
F1 Preliminary Low-Impact Development Plan
F2 Preliminary Hydraulics Study
G Noise Modeling Inputs and Outputs
FIGURES
1 Project Location .............................................................................................................................................. 135
2 Vicinity Map ..................................................................................................................................................... 137
3 Project Aerial ................................................................................................................................................... 139
4 Existing Site Photographs ............................................................................................................................... 141
5 Existing Zoning ................................................................................................................................................ 143
6 General Plan Land Use Designation .............................................................................................................. 145
7 Surrounding Land Uses and General Plan Land Use Designations ............................................................. 147
8 Site Plan ........................................................................................................................................................... 149
9 Proposed Zoning ............................................................................................................................................. 151
10A Architectural Elevations (North and South) ................................................................................................... 153
10B Architectural Elevations (East) ....................................................................................................................... 155
11 Landscape Plans ............................................................................................................................................. 157
12 Existing Utilities ............................................................................................................................................... 159
13 Proposed Storm Drain System ....................................................................................................................... 161
14 Proposed Wet Utilities ..................................................................................................................................... 163
15 Expansion of the Kirkhill Manufacturing Inc. Building .................................................................................. 165
16 Noise Measurement and Modeling Locations .............................................................................................. 167
17 City of Downey Truck Route Map ................................................................................................................... 169
18 Transit and Bicycle Facilities .......................................................................................................................... 171
TABLES
1 Surrounding Land Uses ....................................................................................................................................... 4
2 Anticipated Project Construction Schedule ........................................................................................................ 7
3 South Coast Air Quality Management District Air Quality Significance Thresholds ...................................... 21
4 Construction Scenario Assumptions ................................................................................................................ 22
Exhibit F PC Agenda Page 77
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
iii December 2020
5 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ..................................................... 23
6 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions ....................................................... 27
7 Construction Localized Significance Thresholds Analysis .............................................................................. 29
8 Operational Health Risk Assessment American Meteorological Society/EPA Regulatory Model
Operational Principal Parameters .................................................................................................................... 32
9 Operational Health Risk Assessment Results ................................................................................................. 32
10 Estimated Annual Operational Energy Demand .............................................................................................. 47
11 Annual Operational Natural Gas Demand ....................................................................................................... 48
12 Annual Operational Petroleum Demand .......................................................................................................... 49
13 Estimated Annual Construction Greenhouse Gas Emissions ......................................................................... 59
14 Estimated Annual Operational Greenhouse Gas Emissions .......................................................................... 61
15 Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies ........................... 62
16 Project Consistency with the SCAG Connect SoCal RTP/SCS ........................................................................ 67
17 Supply and Demand Comparison – Multiple-Dry-Year Events ....................................................................... 79
18 Policy Consistency Analysis .............................................................................................................................. 82
19 Exterior Noise Limits ......................................................................................................................................... 89
20 Ambient Measured Noise Levels...................................................................................................................... 90
21 Construction Equipment by Phase ................................................................................................................... 91
22 Construction Noise Model Results Summary .................................................................................................. 92
23 Summary of Off-Site Existing and Future (Year 2022) Unmitigated Traffic Noise Levels (dBA CNEL) ........ 94
24 Mechanical Equipment (HVAC) Noise .............................................................................................................. 96
25 Employment Growth for the City of Downey .................................................................................................... 99
26 Project Trip Generation for 12021 Woodruff Avenue Industrial Building Project ....................................... 106
27 Existing plus Ambient Growth plus Cumulative Projects plus Project Driveway and Project
Access Queuing Summary .............................................................................................................................. 111
28 Existing plus Ambient Growth plus Cumulative Projects plus Project Caltrans Off-Ramp
Queuing Summary ........................................................................................................................................... 112
29 Supply and Demand Comparison – Normal Year ......................................................................................... 119
30 Supply and Demand Comparison – Single-Dry Year ..................................................................................... 120
31 Supply and Demand Comparison – Multiple-Dry-Year Events ..................................................................... 120
Exhibit F PC Agenda Page 78
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
iv December 2020
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Exhibit F PC Agenda Page 79
12818
v December 2020
Acronyms and Abbreviations
Acronym/Abbreviation Definition
AB Assembly Bill
ACM asbestos-containing materials
AERMOD American Meteorological Society/EPA Regulatory Model
AFY acre-feet per year
AIN Assessor’s Identification Number
APA Allowed Pumping Allocation
AQMP air quality management plan
AST aboveground storage tank
BenMAP Benefits Mapping and Analysis Program
BenMAP-CE Benefits Mapping and Analysis Program—Community Edition
BMP best management practices
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CAL FIRE California Department of Forestry and Fire Protection
CALGreen California Green Building Standards
Cal/OSHA California Occupation Health and Safety Administration
Caltrans California Department of Transportation
CARB California Air Resources Board
CASGEM California Statewide Groundwater Elevation Monitoring
CEQA California Environmental Quality Act
CH4 methane
City City of Downey
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
County County of Los Angeles
CRHR California Register of Historical Resources
dB decibel
dBA A-weighted decibel
DFD Downey Fire Department
DPD Downey Police Department
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
DWR Department of Water Resources
EAC Existing plus Ambient Growth plus Cumulative Project
EIR environmental impact report
EMFAC Mobile Source Emissions Inventory Model
EO Executive Order
EPA U.S. Environmental Protection Agency
ESA Environmental Site Assessment
FEMA Federal Emergency Management Agency
FHSZ fire hazard severity zone
GHG greenhouse gas
GWP global warming potential
Exhibit F PC Agenda Page 80
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
vi December 2020
Acronym/Abbreviation Definition
HARP2 Hot Spots Analysis and Reporting Program
HHDT heavy heavy-duty truck
HIA health impact assessment
HIC Chronic Hazard Index
HRA Health Risk Assessment
HREC historical recognized environmental condition
HVAC heating, ventilation, and air conditioning
I- Interstate
IS Initial Study
ITE Institute of Transportation Engineers
JWPCP Joint Water Pollution Control Plant
kBTU thousand British thermal units
KMC Kirkhill Manufacturing Company
kWh kilowatt-hour
LDA light-duty automobile
LDT light-duty truck
Leq measured energy-averaged noise level
LHDT light heavy-duty truck
LID low-impact development
Lmax maximum noise level
LOS level of service
LST localized significance threshold
mgd million gallons per day
MICR maximum individual cancer risk
MM mitigation measure
MND Mitigated Negative Declaration
MT metric ton
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NFA No Further Action
NO nitric oxide
NO2 nitrogen dioxide
NOx oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
O3 ozone
OEHHA Office of Environmental Health Hazard Assessment
PCE passenger car equivalent
PGM photochemical grid model
PM2.5 particulate matter with an aerodynamic diameter less than or equal to 2.5 microns
PM10 particulate matter with an aerodynamic diameter less than or equal to 10 microns
project 12021 Woodruff Avenue Industrial Building Project
RCNM Roadway Construction Noise Model
RTP Regional Transportation Plan
SB Senate Bill
SCAB South Coast Air Basin
Exhibit F PC Agenda Page 81
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
vii December 2020
Acronym/Abbreviation Definition
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCS Sustainable Communities Strategy
SJVAPCD San Joaquin Valley Air Pollution Control District
SO2 sulfur dioxide
SOx sulfur oxides
SoCalGas Southern California Gas Company
SR State Route
ST short-term noise measurement location
TAC toxic air contaminant
TCR tribal cultural resource
UST underground storage tank
VMT vehicle miles traveled
VOC volatile organic compound
WRP water reclamation plant
Exhibit F PC Agenda Page 82
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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Exhibit F PC Agenda Page 83
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1 December 2020
1 Introduction
1.1 Project Overview
The City of Downey (City) received a Planning Division Application PLN-19--00132 from 12021 Woodruff, LLC
(applicant) requesting the approval of the following discretionary actions for the proposed 12021 Woodruff Avenue
Industrial Building Project (project):
• Zone Change to change the zoning designation of the portions of the site currently zoned P-B Parking Buffer
to M-2 General Manufacturing.
• Conditional Use Permit to permit the proposed “truck terminal” use in the M-2 General Manufacturing Zone.
• Site Plan Review to consider the project’s architecture and on-site improvements.
The 6.31-acre site currently consists of an industrial building located directly west of Woodruff Avenue. The project
would include the demolition of the existing, 74,662-square-foot industrial building and construction of an
approximately 44,162-square-foot industrial tilt-up building for truck terminal use. The project would be used to
mobilize both imported and exported goods that pass through the Ports of Los Angeles and Long Beach. The project
would include 56 parking spaces for passenger vehicles, 76 spaces for cargo containers, and 70 loading docks.
The project is subject to analysis pursuant to the California Environmental Quality Act (CEQA). In accordance with
CEQA Guidelines Section 15367, the City is the lead agency with principal responsibility for considering the project
for approval (14 CCR 15000 et seq.).
1.2 California Environmental Quality Act Compliance
CEQA, a statewide environmental law contained in California Public Resources Code, Sections 21000 –21177,
applies to most public agency decisions to carry out, authorize, or approve actions that have the potential to
adversely affect the environment. The overarching goal of CEQA is to analyze the environmental impacts of
development projects with an aim of protecting the environment. To achieve that goal, CEQA requires that public
agencies identify the environmental consequences of their discretionary actions and consider alternatives and
mitigation measures that could avoid or reduce significant adverse impacts when avoidance or reduction is
feasible. It also gives other p ublic agencies and the public an opportunity to comment on the project. If significant
adverse impacts cannot be avoided, reduced, or mitigated to below a level of significance, the public agency is
required to prepare an environmental impact report (EIR) and balance the project’s environmental concerns with
other goals and benefits in a statement of overriding considerations.
In accordance with the CEQA Guidelines, the City, as the lead agency, has prepared an initial study (IS) to evaluate
potential environmental effects and to determine whether an EIR, a negative declaration, or a mitigated negative
declaration (MND) should be prepared for the project. CEQA Guidelines Section 15070(b) provides that an MND
should be prepared for a project when the IS has identified potentially significant environmental impacts associated
with the project, but (1) revisions to the project’s plans or proposals made or agreed to by the applicant before release
of an MND for public review would avoid or mitigate environmental effects to a point where no significant effect on
the environment would occur, and (2) there is no substantial evidence in the record before the public agency that the
project, as revised, may have a significant effect on the environment. The IS determined that implementation of the
Exhibit F PC Agenda Page 84
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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2 December 2020
project would result in no impacts or less-than-significant impacts with incorporation of mitigation. Therefore, the
City has prepared an MND for the project.
1.3 Public Review Process
As specified by the CEQA Guidelines, the project’s Notice of Intent was circulated for a 30 -day public review period
(14 CCR 15082[b]) to a variety of public agencies, including agencies with jurisdiction over resources affected by
the project. The Notice of Intent has been provided to the State Clearinghouse, Clerk of the County of Los Angeles,
responsible agencies, and interested organizations and individuals.
Reviewers of the IS/MND are given a 30-day public review period, beginning on December 15, 2020 and ending on
January 14, 2021, to prepare written comments on the IS/MND. During the public review period, the IS/MND,
including the technical appendices, is available online for review at the City’s website:
https://www.downeyca.org/our-city/departments/community-development/planning/environmental-documents
A hard copy of the IS/MND is available for review at Downey City Hall by appointment on Monday through Thursday
from 7:30 a.m. to 5:30 p.m. (except during office closures):
City of Downey
Community Development Department, Planning Division
11111 Brookshire Avenue
Downey, California 90241
To schedule an appointment to review the IS/MND at Downey City Hall, please contact Alfonso Hernandez at
562.904.7154 or ashernandez@downeyca.org.
In reviewing the IS/MND, affected public agencies and interested members of the public should focus on the
adequacy of the document in identifying and analyzing the potential environmental impacts. Comments on the
IS/MND and the analysis contained herein may be sent to the following recipient and address:
Alfonso S. Hernandez
City of Downey
Community Development Department
11111 Brookshire Avenue
Downey, California 90241
ashernandez@downeyca.org
Exhibit F PC Agenda Page 85
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3 December 2020
2 Project Description
2.1 Project Location
The project site is located in the southern portion of the City, which is located in the County of Los Angeles (County).
Regionally, the City is bordered by the cities of Pico Rivera, Santa Fe Springs, Norwalk, Bellflower, Paramount, South
Gate, and Commerce (Figure 1, Project Location). Locally, the project site is immediately bounded by Woodruff Avenue
to the east, and existing industrial/manufacturing uses to the north, west, and south (Figure 2, Vicinity Map).
The project site consists of a single parcel (Assessor’s Identification Number [AIN] 6284-025-018). The addresses
associated with the project site are 12021–12023 Woodruff Avenue, Downey, California 90241 (Figure 3, Project Aerial).
2.2 Environmental Setting
City of Downey
The City is approximately 12.8 square miles in area and is located in the southeastern part of the 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 14 miles and 12 miles northeast of the Ports of Los Angeles and Long
Beach, respectively. 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, although it does not cross the City, 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 bound 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; however, they are
predominantly located to the north, east, and west. Commercial uses are scattered throughout the north, east,
south, and west. Manufacturing uses are primari ly concentrated in the southeastern portion of the City.
Existing Project Site Conditions and Environmental Baseline
The 6.31-acre site currently contains an existing industrial building and related improvements associated with the
Kirkhill Manufacturing Company, Inc. (KMC), a manufacturer of rubber products. The existing KMC building was
initially constructed in 1951 and consisted of one large single-story structure. Over the years, additional structures
were added in piecemeal fashion. The existing on-site structures are a mix of older and relatively newer buildings
(Figure 4, Existing Site Photographs). The project site currently has two gated entrances along Woodruff Avenue
that lead to private internal roads, which connect together around the building. These internal roads provide parking
for employees and storage for heavy operation equipment.
Exhibit F PC Agenda Page 86
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4 December 2020
KMC has operated at varying capacities since its operations began in 1951. These fluctuations in capacity are
largely due to permitted expansions in useable building area that primarily occurred during the 1970s (Appendix
A). Over the past few years, baseline operational conditions included approximately 200 full-time employees
working on site, with the site receiving approximately 20 truck trips per day. Work shifts have been maintained over
the past years from 5:00 a.m. to 10:00 p.m., Monday through Friday, with occasional Saturday shifts. KMC has
recently decided to relocate their operations and plans on scaling down their on-site operations until the full
transition is complete.
The majority of the project site is zoned M-2 (Manufacturing); however, a portion of the project site to the west is
zoned as P-B (Parking Buffer) (Figure 5, Existing Zoning). The project site has a General Plan Land Use Designation
of GM (General Manufacturing) (Figure 6, General Plan Land Use Designation) (City of Downey 2012a, 2012b).
Surrounding Land Uses
The project site is located in a predominantly industrial part of the City, although some commercial and residential
uses are located in the general project vicinity. Table 1, Surrounding Land Uses, and Figure 7, Surrounding Land
Uses and General Plan Land Use Designations, depict the land uses surrounding the project site.
Table 1. Surrounding Land Uses
Direction General Plan Land Use Designation Existing Use(s)
North GM (General Manufacturing) Industrial uses
East GM (General Manufacturing) Industrial uses
NC (Neighborhood Commercial) Restaurant
South GM (General Manufacturing) Adult Development Center/Trade School and
Event Center/Banquet Hall
NC (Neighborhood Commercial) Church use, medical uses, and office uses
Southeast NC (Neighborhood Commercial) Church use
GM (General Manufacturing) Industrial uses
West GM (General Manufacturing); followed by MDR
(Medium Density Residential)
Industrial uses, followed by multi-family
residential uses
Southwest LDR (Low Density Residential) Single-family residential uses
Source: City of Downey 2012a.
Note: See Figure 7, Surrounding Land Uses and General Plan Designations.
2.3 Project Characteristics
Proposed Project
The project include s the demolition of an existing, 74,662 -square-foot industrial building and construction of
an approximately 44,162-square-foot tilt-up industrial building for truck terminal use. The proposed industrial
building would include approximately 36,142 square feet of warehouse space and 8,020 square feet of office
space (Figure 8, Site Plan).
The new industrial building is intended to be used as a trucking terminal for distribution and logistics purposes.
On-site activities will include storage of and/or consoli dation of manufactured goods before the distribution to
Exhibit F PC Agenda Page 87
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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5 December 2020
retail locations or other warehouses. Other than truck parking and storage, all activities will occur within the
industrial building . The office space is intended to be used for office uses ancillary to the warehouse operation.
Zone Change
The project site currently maintains two zoning classifications: General Manufacturing (M -2) and Parking Buffer
(P-B). Incidentally, the Downey Zoning Code (Article IX, Land Use, of the Downey Municipal Code [20 20]) no
longer references the P-B zone. All mention of it was removed from the Zoning Code in 2008 when the code
was updated. The Downey City Council removed the P -B zone because it was considered redundant since the
development standards of the City’s residen tial and non-residential zones provide the same safeguards as the
former P-B zone. The only trace of the P -B zone is the City’s Zoning Map and properties on the map that still
maintain that classification.
The Zone Change applica tion is a request to rezone the P-B portion of the project site to M-2 so that the entire
property maintains the M-2 zoning classification (Figure 9, Proposed Zoning). The M-2 zone is the classification
that corresponds with General Manufacturing General Plan category.
Architecture
The proposed industrial building would reach a maximum height of 36 feet above grade. The building would
include concrete tilt -up panels on all sides of the building. The east side of the building would be the entrance
of the office component and would include glazed windows and metal siding panels. All exterior and interior
glazing would be tempered with insulated vision glass and spandrel glass around. The building would be
painted with a color palette approved by the City, architect, and building owner (Figures 10A and 10B,
Architectural Elevations).
The east side of the proposed building would include concrete stairs with an attached ramp. The ramp would
consist of a 3.5-foot-high concrete tilt-up guard wall on both sides of the ramp. The building would include
additional concrete staircases with guardrails and cable rail s along the north and south sides.
Site Access, Circulation, and Parking
Site access would be provided via two 40-foot-wide driveways located along Woodruff Avenue:
• Driveway 1 (North) via Woodruff Avenue: Full access for passenger cars and inbound only (right-in/left-in)
for trucks (no truck exit)
• Driveway 2 (South) via Woodruff Avenue: Full access for passenger cars and outbound only (right-out/left-
out) for trucks (no truck entry)
Both driveways would lead to passenger vehicle parking lots on the northeast and southeast corners of the project
site. The parking lots would be connected by a north–south through-lane, which provides additional passenger
vehicle parking spaces along the eastern boundary of the site. On the west side of both parking lots would be a
gated driveway leading to truck courts, trailer parking stalls, and loading docks. The project would include 56
parking spaces for passenger vehicles (52 standard, 2 accessible parking, and 2 van-accessible parking), 76
spaces for cargo containers and/or trailers, and 70 loading docks (refer to Figure 8, Site Plan).
Exhibit F PC Agenda Page 88
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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6 December 2020
Frontage Improvements
The project would include a new concrete walkway to provide pedestrian access from Woodruff Avenue to the office
component of the project. The area of the walkway traversing the parking lot would consist of decorative pavers.
Consistent with a plant palette approved by the City, a variety of trees, shrubs, and vegetated groundcovers would
be planted throughout all required setbacks, including the eastern portion of the project site fronting Woodruff
Avenue. The total landscape area would be 27,511 square feet. The project would include an irrigation system
that would comply with applicable local water efficiency standards (Figure 11, Landscape Plan).
Stormwater and Other Utility Improvements
Since the project site is currently developed with an industrial land use, the site is served by existing domestic
water, sanitary sewer, stormwater, electrical, and natural gas utilities (Figure 12, Existing Utilities Locations). The
project would connect to these utilities from their current locations within the project vicinity.
Stormwater Drainage
Currently, the project site is developed and is composed entirely of impervious surfaces. Stormwater is presently
collected from the existing building’s roof drains, conveyed towards the southwest portion of the project site, and
discharged off-site via a parkway culvert into an existing storm drain within Washburn Road. Runoff from the vehicle
parking lot and the landscaped area fronting Woodruff Avenue sheet flows toward the street, where it then drains
via a parkway culvert located at the southeast portion of the site into an existing 36-inch public storm drain within
Woodruff Avenue.
As part of the project, the project site would be graded so that stormwater collected via the building’s roof and parking
areas would be collected by concrete catchbasins and conveyed via underground pipes to an underground stormwater
detention chamber and proprietary biofiltration system (Figure 13, Proposed Storm Drain System). The biofiltration
system would use plants and soil media to treat stormwater before ultimately being discharged into the adjacent existing
36-inch public storm drain system within Washburn Road via an underdrain system and sump pump.
Domestic Water and Sanity Sewer
The City’s Water Department would provide domestic water to the project site. The project would connect to an existing
12-inch-diameter water line in Woodruff Avenue for domestic and irrigation purposes. The City is located within the
jurisdictional boundaries of the Sanitation Districts of Los Angeles County, District No. 2. Wastewater generated by the
City is treated at the Joint Water Pollution Control Plant (JWPCP) located in the City of Carson and the Los Coyotes Water
Reclamation Plant (WRP) in the City of Cerritos. The project site would connect to an existing 21-inch-diameter sewer line
in Woodruff Avenue for sewage conveyance purposes (Figure 14, Proposed Wet Utilities).
Natural Gas and Electric Service
Southern California Gas Company would provide natural gas service to the project site. The project would connect
to an existing 4-inch-diameter underground gas line within Woodruff Avenue.
Southern California Edison would provide electric service. The project would connect to existing overhead electrical
lines on the west side of project site by undergrounded electric lines.
Exhibit F PC Agenda Page 89
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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7 December 2020
Construction and Scheduling
The project applicant intends to commence construction on or around March 2021. It is anticipated that
construction would take approximately 10 months. Table 2 provides a tentative project construction schedule, as
used in the air quality, greenhouse gas (GHG) emissions, and health risk assessment impact analysis (refer to
Section 3.3, Air Quality, and Section 3.8, Greenhouse Gas Emissions, of this IS/MND; also see Appendix B, Air
Quality, Greenhouse Gas Emission, and Energy Modeling Inputs and Outputs).
Table 2. Anticipated Project Construction Schedule
Construction Phase Duration Phase Start Date Phase End Date
Demolition 2 months March 2021 April 2021
Site Preparation 1 month May 2021 May 2021
Grading 1 month June 2021 June 2021
Building Construction 6 months July 2021 December 2021
Paving 1 month January 2022 January 2022
Architectural Coating 1 month January 2022 January 2022
Operation
Upon completion of construction, the project would operate as a truck terminal for distribution and logistics purposes.
On-site activities will include storage of and/or consolidation of manufactured goods before the distribution to retail
locations or other warehouses. Other than truck parking and storage, all activities will occur within the industrial
building. The office space is intended to be used for office uses ancillary to the warehouse operation.
The project will employ approximately 50 to 100 non-construction employees. The proposed project would operate
24 hours a day, 7 days a week.
2.4 Project Approvals
The actions and/or approvals that the City needs to consider for the project include, but are not limited to, the
following. This list is preliminary, and may not be comprehensive:
• Zone Change to change the zoning designation of the westernmost portion of the project site from the P-B
zone to G-2 zone.
• Conditional Use Permit to permit the proposed truck terminal use in the M-2 General Manufacturing Zone.
• Site Plan Review to review the project’s architecture and on-site improvements.
Exhibit F PC Agenda Page 90
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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8 December 2020
INTENTIONALLY LEFT BLANK
Exhibit F PC Agenda Page 91
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9 December 2020
3 Initial Study Checklist
1. Project title:
12021 Woodruff Avenue Industrial Building Project (PLN-19—00132)
2. Lead agency name and address:
City of Downey
Community Development Department
11111 Brookshire Avenue
Downey, California 90241
3. Contact person and phone number:
Alfonso S. Hernandez, Senior Planner
ashernandez@downeyca.org
562.904.7154
4. Project location:
12021–12023 Woodruff Avenue
Downey, California 90241
5. Project sponsor’s name and address:
12021 Woodruff, LLC
2141 Rosecrans Avenue, Suite 1151
El Segundo, California 90245
6. General plan designation:
GM (General Manufacturing)
7. Zoning:
Existing:
M-2 (Manufacturing) and P-B (Parking Buffer)
Proposed:
M-2 (Manufacturing)
Exhibit F PC Agenda Page 92
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10 December 2020
8. Description of project:
The project includes the demolition of an existing, 74,662-square-foot industrial building and construction
of an approximately 44,162-square-foot tilt-up industrial building for truck terminal use. The proposed
industrial building would include approximately 36,142 square feet of warehouse space and 8,020 square
feet of office space.
9. Surrounding land uses and setting:
The project site is located in a predominantly industrial part of the City, although some commercial and
residential uses are located in the general project vicinity. The project site is presently occupied by KMC, a
manufacturer of rubber products.
10. Other public agencies whose approval is required:
No other public agency approval is required.
11. Have California Native American tribes traditionally and culturally affiliated with the project area
requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan
for consultation that includes, for example, the determination of significance of impacts to tribal
cultural resources, procedures regarding confidentiality, etc.?
Yes, please refer to Section 3.18, Tribal Cultural Resources, for additional detail.
Exhibit F PC Agenda Page 93
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11 December 2020
Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact
that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.
Aesthetics Agriculture and
Forestry Resources
Air Quality
Biological Resources Cultural Resources Energy
Geology and Soils Greenhouse Gas
Emissions
Hazards and Hazardous
Materials
Hydrology and Water Quality Land Use and
Planning
Mineral Resources
Noise Population and
Housing
Public Services
Recreation Transportation Tribal Cultural Resources
Utilities and Service Systems Wildfire Mandatory Findings of
Significance
Exhibit F PC Agenda Page 94
Exhibit F PC Agenda Page 95
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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13 December 2020
Evaluation of Environmental Impacts
1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by
the information sources a lead agency cites in the parentheses following each question. A “No Impact”
answer is adequately supported if the referenced information sources show that the impact simply does not
apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact”
answer should be explained where it is based on project-specific factors as well as general standards (e.g.,
the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative
as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3. Once the lead agency has determined that a particular physical impact may occur, then the checklist
answers must indicate whether the impact is potentially significant, less than significant with mitigation,
or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that
an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the
determination is made, an Environmental Impact Report (EIR) is required.
4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the
incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a
“Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly
explain how they reduce the effect to a less than significant level (mitigation measures from “Earlier
Analyses,” as described in (5) below, may be cross-referenced).
5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an
effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In
this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review.
b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope
of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state
whether such effects were addressed by mitigation measures based on the earlier analysis.
c. Mitigation Measures. For effects that are “Less Than Significant With Mitigation Measures
Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier
document and the extent to which they address site-specific conditions for the project.
6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential
impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document
should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7. Supporting Information Sources: A source list should be attached, and other sources used or individuals
contacted should be cited in the discussion.
8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies
should normally address the questions from this checklist that are relevant to a project’s environmental
effects in whatever format is selected.
9. The explanation of each issue should identify:
a. The significance criteria or threshold, if any, used to evaluate each question; and
b. The mitigation measure identified, if any, to reduce the impact to less than significance.
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14 December 2020
3.1 Aesthetics
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
I. AESTHETICS – Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a
scenic vista?
b) Substantially damage scenic resources
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
c) 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 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) Would the project have a substantial adverse effect on a scenic vista?
No Impact. The Downey Vision 2025 General Plan (City of Downey 2005) does not identify any scenic vistas in
the City, and the project site is located in an urban setting within the primarily industrial Woodruff Avenue
corridor. The project would involve the demolition of an existing industrial building and construction of a
new industrial tilt-up building that would be consistent with the surrounding industrial land uses.
Additionally, the presence of single and multi-story industrial developments adjacent to the project site and
along Woodruff Avenue limits opportunities for long-distance sightlines in the surrounding area which could be
of scenic value. Therefore, no impacts associated with scenic vistas would occur.
b) Would the project substantially damage scenic resources including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
No Impact. None of the highways and freeways passing through the City have been designated state scenic
highways by the California Department of Transportation (Caltrans). Within Los Angeles County, State Route
27 (SR-27; also known as Topanga Canyon Highway) is an officially designated state scenic highway (SR -
27 is approximately 27 miles north of the project site). Additionally, SR-2 (also known as the Angeles Crest
Highway) from La Cañada Flintridge north to the San Bernardino County line is an officially designated state
scenic highway (SR-2 is located approximately 20 miles north of the project site) (Caltrans 2016). South of
SR-2 and through the Seal Beach area, SR-1 is an eligible state scenic highway; however, this segment of
Exhibit F PC Agenda Page 97
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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15 December 2020
the highway is more than 10 miles south of the project site. Due to the presence of intervening development
and landscaping, views to the project site are not available from any of these designated or eligible state
scenic highways. Therefore, no impacts associated with a state scenic highway would occur.
c) In non-urbanized areas, would the project substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are experienced from publicly
accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable
zoning and other regulations governing scenic quality?
Less-than-Significant Impact. Section 15387 of the CEQA Guidelines states that an urbanized area means
a central city or a group of contiguous cities with a population of 50,000 or more, together with adjacent
densely populated areas having a population density of at least 1,000 persons per square mile. In July
2019, the population in the City was estimated to be 111,126 (U.S. Census 2019). Therefore, the project
is located within an urbanized area, and the second question of this threshold applies to the project. The
majority of the project site is zoned M-2 (Manufacturing); however, portions of the project site to the south,
east, and west are zoned as P-B (Parking Buffer) (refer to Figure 5, Existing Zoning). Implementation of the
project would also involve a zone ch ange to change the zoning designation of the portions of the site
currently zoned P-B (Parking Buffer) to M -2 (Manufacturing) (refer to Figure 9, Proposed Zoning). Upon
approval of the proposed zone change, the project site would be uniformly zoned M-2 (Manufacturing).
The City’s Municipal Code includes design standards related to building height, setbacks, landscaping
requirements, and other development considerations that are relevant to scenic quality. Specifically, Title 11,
Zoning and Development, of the City’s Municipal Code includes design standards for each zoning district,
including the M-2 (Manufacturing) zone, which would be the zoning designation for the project site. The M-2
(Manufacturing) zone has specified regulations that are outlined in Section 9318.06 of the City’s Municipal
Code (City of Downey 2020a). The purpose of the design standards are, in part, to regulate the uses of
buildings and structures and to encourage the most appropriate use of land. As a part of the City’s
development and design review process, project plans are reviewed by City staff, to ensure compliance with
applicable provisions of the City’s Municipal Code, including those provisions relating to scenic quality.
Because the project would undergo review by City staff, and no project components that are inconsistent with
provisions of the Municipal Code that relate to scenic quality are being requested, the project would not
conflict with applicable zoning and other regulations governing scenic quality. Therefore, impacts associated
with conflicting with applicable zoning governing scenic quality would be less than significant.
d) Would the project create a new source of substantial light or glare which would adversely affect day or
nighttime views in the area?
No Impact. Under existing conditions, the project site is developed with an existing industrial building with
outdoor safety and security lighting. Similarly, the project would feature interior and exterior lighting for
general illumination, security, and safety purposes. Interior spaces would be illuminated with a variety of
lighting options, which would operate during regular business hours. Due to the existing industrial uses on
site and in the surrounding area, implementation of the project and operation of nighttime lighting would
not substantially increase lighting levels generated on site and projected onto adjacent properties. In
addition, lighting for the project would be required to comply with applicable City regulations, including
standards established for outdoor lighting. More specifically, the project would be required to comply with
the City’s Municipal Code, Section 9520.06, Outdoor Lighting, which requires the installation of low-level
Exhibit F PC Agenda Page 98
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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16 December 2020
parking-lot lighting designed to eliminate spillover to the street and adjacent areas (City of Downey 2020a).
Furthermore, existing City standards require all outdoor lighting to be directed, positioned, and shielded so
as to not direct lighting on any street or abutting property. City standards also state that the type, location,
and intensity of lighting is subject to review and approval by the City Planner (City of Downey 2020a).
Because the project’s lighting would not result in new or more intense levels of light and/or glare beyond
levels already occurring on the project site, and because all project lighting would conform to City lighting
requirements, no impacts with light and glare would occur.
3.2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are
significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and
Site Assessment Model (1997) prepared by the California Department of Conservation as an optional
model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest
resources, including timberland, are significant environmental effects, lead agencies may refer to
information compiled by the California Department of Forestry and Fire Protection regarding the state’s
inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy
Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by
the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on the maps
prepared pursuant to the Farmland
Mapping and Monitoring Program of the
California Resources Agency, to non-
agricultural use?
b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)),
timberland (as defined by Public Resources
Code section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104(g))?
d) Result in the loss of forest land or
conversion of forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
Exhibit F PC Agenda Page 99
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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17 December 2020
a) Would the project 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?
No Impact. The project site and surrounding areas are characterized by features typical of an urban
landscape. As shown on the Los Angeles County Important Farmland map, the project site does not include
any sites mapped by the Farmland Mapping and Monitoring Program as Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance (DOC 2017a). Implementation of the project would not involve
changes that could result in conversion of farmland to non-agricultural use, as no agricultural uses or
farmland exist on the project site or in proximity to the project site. Furthermore, the project site is already
graded and fully developed. Therefore, no impacts associated with the conversion of Farmland to non-
agricultural uses would occur.
b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
No Impact. The project site is located within an industrial area of the City, zoned as M-2 (Manufacturing) and
designated as General Manufacturing (GM), and is fully developed with an existing industrial use. As shown
on the Los Angeles County Williamson Act Fiscal Year 2015/2016 map, no areas that are under a Williamson
Act contract exist on the project site or in the vicinity of the project site (DOC 2017b). For these reasons,
implementation of the project would not conflict with existing zoning for agricultural use, as no agriculturally
zoned sites exist in the area, nor would it conflict with a Williamson Act contract, as none exist in the area.
Therefore, no impact to Williamson Act contract lands or land zoned for agricultural uses would occur.
c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or
timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. According to the City’s Zoning Map, the project site is not located on or adjacent to forestland,
timberland, or timberland zoned timberland production (City of Downey 2012b). Therefore, no impacts
associated with forestland, timberland, or timberland zoned timberland production would occur.
d) Would the project result in the loss of forest land or conversion of forest land to non-forest use?
No Impact. The project site is not located on or adjacent to forestland. No private timberlands or public
lands with forests are located in the City. Therefore, no impacts associated with the conversion of forest
land to non-forest uses would occur.
e) Would the project involve other changes in the existing environment which, due to their location or
nature, could re sult in conversion of Farmland, to non -agricultural use or conversion of forest land to
non-forest use?
No Impact. The project site is not located on or adjacent to any parcels identified as Important Farmland or
forestland. In addition, the project would not involve changes to the existing environment that would result
in the indirect conversion of Important Farmland or forestland located away from the project site. Therefore,
no impacts would occur.
Exhibit F PC Agenda Page 100
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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18 December 2020
3.3 Air Quality
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality
management district or air pollution control district may be relied upon to make the following
determinations. Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is 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?
a) Would the project conflict with or obstruct implementation of the applicable air quality plan?
Less-than-Significant Impact. The project site is located within the South Coast Air Basin (SCAB), which
includes the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange
County, and is within the jurisdictional boundaries of the South Coast Air Quality Management District
(SCAQMD). The SCAQMD administers the SCAB’s Air Quality Management Plan (AQMP), which is a
comprehensive document outlining an air pollution control program for attaining the California Ambient Air
Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). The most recently adopted
AQMP for the SCAB is the 2016 AQMP (SCAQMD 2017). The 2016 AQMP focuses on available, proven, and
cost-effective alternatives to traditional air quality strategies while seeking to achieve multiple goals in
partnership with other entities seeking to promote reductions in GHGs and toxic risk, as well as efficiencies
in energy use, transportation, and goods movement (SCAQMD 2017).
The purpose of a consistency finding with regard to the AQMP is to determine if a project is consistent with
the assumptions and objectives of the regional air quality plans, and if it would interfere with the region’s
ability to comply with federal and state air quality standards. The SCAQMD has established criteria for
determining consistency with the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3 of the
SCAQMD CEQA Air Quality Handbook. These criteria are as follows (SCAQMD 1993):
Consistency Criterion No. 1: Whether the project would result in an increase in the
frequency or severity of existing air quality violations, cause or contribute to new violations,
or delay timely attainment of the ambient air quality standards or interim emission
reductions in the AQMP.
Exhibit F PC Agenda Page 101
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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19 December 2020
Consistency Criterion No. 2: Whether the project would exceed the assumptions in the
AQMP or increments based on the year of project buildout and phase.
To address the first criterion, project-generated criteria air pollutant emissions have been estimated and
analyzed for significance and are addressed under Section 3.3(b). Detailed results of this analysis are
included in Appendix B of this addendum. As presented in Section 3.3(b), construction and operation of the
project would not generate criteria air pollutant emissions that exceed the SCAQMD’s thresholds, and thus,
the project would be consistent with Criterion No. 1.
The second criterion regarding the potential of the project to exceed the assumptions in the AQMP or
increments based on the year of project buildout and phase is primarily assessed by determining
consistency between the project’s land use designations and its potential to generate population growth.
In general, projects are considered consistent with, and not in conflict with or obstructing implementation
of, the AQMP if the residential and/or employment population growth they produce is consistent with the
underlying regional plans used to develop the AQMP (SCAQMD 1993). The SCAQMD primarily uses
demographic growth forecasts for various socioeconomic categories (e.g., population, housing, and
employment by industry) developed by the Southern California Association of Governments (SCAG) for its
2016–2040 Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS) (SCAG 2016).
SCAQMD uses this document, which is based in large part on general plans for cities and counties in the
SCAB, to develop the AQMP emissions inventory (SCAQMD 2017).1 The SCAG RTP/SCS, and associated
Regional Growth Forecast, is generally consistent with the local plans; therefore, the 2016 AQMP is
generally consistent with the City’s General Plan.
As discussed in Section 2.2, Environmental Setting, the project site is designated in the City’s General Plan
as General Manufacturing (GM) (City of Downey 2012a), and the zoning for the majority of the project site
is M-2 (Manufacturing); however, a portion of the project site to the west is zoned as P-B (Parking Buffer).
Implementation of the project will require approval of a Zone Change requested by the project applicant
to change the zoning designation of the westernmost portion of the project site from the P -B (Parking
Buffer) zone to the G -2 (General Manufacturing) zone . As the proposed uses for the project site are
consistent with the existing land use designation, no amendments to the General Plan would be required.
Accordingly, the project is consistent with the SCAG RTP/SCS forecasts used in the SCAQMD AQMP
development, and thus, the project would be consistent with Criterion No. 2.
In summary, based on the considerations presented for the two criteria, impacts relating to the project’s
potential to conflict with or obstruct implementation of the applicable AQMP would be less than significant.
1 Information necessary to produce the emissions inventory for the SCAB is obtained from the SCAQMD and other governmental
agencies, including the California Air Resources Board, Caltrans, and SCAG. Each of these agencies is responsible for collect ing
data (e.g., industry growth factors, socioeconomic projections, travel activity levels, emission factors, emission speciation profi le,
and emissions) and developing methodologies (e.g., model and demographic forecast improvements) required to generate a
comprehensive emissions inventory. SCAG incorporates these data into its Travel Demand Model for estimating/projecting vehicle
miles traveled and driving speeds. SCAG’s socioeconomic and transportation activities projections in their 2016–2040 Regional
Transportation Plan/Sustainable Communities Strategy are integrated in the 2016 AQMP (SCAQMD 2017).
Exhibit F PC Agenda Page 102
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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20 December 2020
b) Would the project 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?
Less-than-Significant Impact. Air pollution is largely a cumulative impact. The nonattainment status of
regional pollutants is a result of past and present development, and the SCAQMD develops and implements
plans for future attainment of ambient air quality standards. Based on these considerations, project -level
thresholds of significance for criteria pollutants are used in the determination of whether a project’s
individual emissions would have a cumulatively considerable contribution on air quality. If a project’s
emissions would exceed the SCAQMD significance thresholds, it would be considered to have a
cumulatively considerable contribution. Conversely, projects that do not exceed the project-specific
thresholds are generally not considered to be cumulatively significant (SCAQMD 2003a).
A quantitative analysis was conducted to determine whether proposed construction activities would result
in a cumulatively considerable net increase in emissions of criteria air pollutants for which the SCAB is
designated as nonattainment under the NAAQS or CAAQS. Criteria air pollutants include ozone (O3), nitrogen
dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), particulate matter with an aerodynamic diameter
less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter less than or
equal to 2.5 microns (PM2.5), and lead. Pollutants that are evaluated herein include volatile organic
compounds (VOCs) and oxides of nitrogen (NOx), which are important because they are precursors to O3,
as well as CO, sulfur oxides (SOx), PM10, and PM2.5.
Regarding NAAQS and CAAQS attainment status,2 the SCAB is designated as a nonattainment area for
national and California O3 and PM2.5 standards (CARB 2019a; EPA 2019). The SCAB is designated as a
nonattainment area for California PM10 standards; however, it is designated as an attainment area for
national PM10 standards. The SCAB nonattainment status of O3, PM10, and PM2.5 standards is the result of
cumulative emissions from various sources of air pollutants and their precursors within the SCAB, including
motor vehicles, off-road equipment, and commercial and industrial facilities. The SCAB is designated as an
attainment area for national and California NO2, CO, and SO2 standards. Although the SCAB has been
designated as partial nonattainment (Los Angeles County) for the federal ro lling 3-month average lead
standard, it is designated attainment for the state lead standard.3
The project would result in emissions of criteria air pollutants for which the California Air Resources Board
(CARB) and U.S. Environmental Protection Agency (EPA) have adopted ambient air quality standards (i.e.,
the NAAQS and CAAQS). Projects that emit these pollutants have the potential to cause, or contribute to,
violations of these standards. The SCAQMD CEQA Air Quality Significance Thresholds, as revised in April
2019, set forth quantitative emission significance thresholds for criteria air pollutants, which, if exceeded,
would indicate the potential for a project to contribute to violations of the NAAQS or CAAQS. Table 3 lists
the SCAQMD Air Quality Significance Thresholds (SCAQMD 2019).
2 An area is designated as in attainment when it is in compliance with the NAAQS and/or the CAAQS. The NAAQS and CAAQS are set
by the U.S. Environmental Protection Agency and CARB, respectively, for the maximum level of a given air pollutant that can exist in
the outdoor air without unacceptable effects on human health or the public welfare. Attainment = meets the standards;
attainment/maintenance = achieve the standards after a nonattainment designation; nonattainment = does not meet the standards.
3 Re-designation of the lead NAAQS designation to attainment for the Los Angeles County portion of the SCAB is expected based on
current monitoring data. The phase out of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is
not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis.
Exhibit F PC Agenda Page 103
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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21 December 2020
Table 3. South Coast Air Quality Management District Air Quality Significance Thresholds
Criteria Pollutants Mass Daily Thresholds
Pollutant Construction (Pounds per Day) Operation (Pounds per Day)
VOCs 75 55
NOx 100 55
CO 550 550
SOx 150 150
PM10 150 150
PM2.5 55 55
Leada 3 3
TACs and Odor Thresholds
TACsb Maximum incremental cancer risk 10 in 1 million
Cancer Burden >0.5 excess cancer cases (in areas 1 in 1 million)
Chronic and acute hazard index 1.0 (project increment)
Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402
Source: SCAQMD 2019.
Notes: VOC = volatile organic compounds; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter;
PM2.5 = fine particulate matter; TAC = toxic air contaminant; SCAQMD = South Coast Air Quality Management District.
GHG emissions thresholds for industrial projects, as added in the March 2015 revision to the SCAQMD Air Quality Significance Thresholds,
were not include included in this table as they are addressed within the GHG emissions analysis and not the air quality analysis.
a The phase out of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is not anticipated to result
in impacts related to lead; therefore, it is not discussed in this analysis.
b TACs include carcinogens and noncarcinogens.
Short-Term Construction Impacts
Construction of the project would result in the temporary addition of pollutants to the local airshed caused by
on-site sources (e.g., off-road construction equipment, soil disturbance, VOC off-gassing from architectural
coatings and asphalt pavement application) and off-site sources (e.g., vendor trucks, haul trucks, and worker
vehicle trips). Specifically, entrained dust results from the exposure of earth surfaces to wind from the direct
disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. Internal combustion engines used by
construction equipment, haul trucks, vendor trucks (i.e., delivery trucks), and worker vehicles would result in
emissions of VOC, NOx, CO, PM10, and PM2.5. Construction emissions can vary substantially from day to day
depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions.
Application of architectural coatings, such as exterior paint and other finishes, and application of asphalt
pavement would also produce VOC emissions. VOC off-gassing emissions result from evaporation of solvents
contained in surface coatings such as in paints and primers used during construction of the facility. California
Emissions Estimator Model (CalEEMod) calculates the VOC evaporative emissions from application of surface
coatings based on the VOC emissions factor, the building square footage, and the assumed fraction of surface
area. The emissions associated with architectural coatings are estimated based on CalEEMod defaults
values for VOC content.
The project would be required to comply with SCAQMD Rule 403 to control dust emissions generated during any
dust-generating activities. Standard construction practices that would be employed to reduce fugitive dust
emissions include watering of the active dust areas at least two times per day or more depending on weather
conditions, which was assumed in CalEEMod.
Exhibit F PC Agenda Page 104
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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22 December 2020
Emissions from the construction phase of the project were estimated using CalEEMod (version 2016.3.2)
default values. For the purpose of conservatively estimating project emissions, construction was modeled
beginning in March 2021 and concluding in January 2022,4 lasting approximately 11 months. As a result
of demolition, 3,200 tons of debris were estimated to be exported from the site. The analysis contained
herein is based on the following schedule assumptions (duration of phases is approximate):
• Demolition: 2 months (March 2021 – April 2021)
• Site Preparation: 1 month (May 2021)
• Grading: 1 month (June 2021)
• Building construction: 6 months (July 2021 – December 2021)
• Paving: 1 month (January 2022)
• Application of architectural coatings: 1 month (January 2022)
Construction modeling assumptions for equipment and vehicles are provided in Table 4. Equipment mix and
horsepower were based on CalEEMod default values, including equipment load factor. The site will be balanced
without need for import or export of earthwork materials. For the analysis, it was generally assumed that heavy-
duty construction equipment would be operating at the site 5 days per week.
Table 4. Construction Scenario Assumptions
Construction
Phase
One-Way Vehicle Trips Equipment
Average Daily
Worker Trips
Average Daily
Vendor Truck
Trips
Total Haul
Truck Trips Equipment Type Quantity
Usage
Hours
Demolition 18 0 400 Concrete/industrial
saws
1 8
Excavators 3 8
Other construction
equipment
1 8
Rubber-tired dozers 2 8
Site
Preparation
18 0 0 Rubber-tired dozers 3 8
Tractors/loaders/
backhoes
4 8
Grading 16 0 0 Excavators 1 8
Graders 1 8
Rubber-tired dozers 1 8
Tractors/loaders/
backhoes
3 8
4 The analysis assumes a construction start date of March 2021, which represents the earliest date construction would initiate.
Assuming the earliest start date for construction represents the worst-case scenario for criteria air pollutant and GHG emissions,
because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use
off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
Exhibit F PC Agenda Page 105
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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23 December 2020
Table 4. Construction Scenario Assumptions
Construction
Phase
One-Way Vehicle Trips Equipment
Average Daily
Worker Trips
Average Daily
Vendor Truck
Trips
Total Haul
Truck Trips Equipment Type Quantity
Usage
Hours
Building
construction
34 14 0 Cranes 1 7
Forklifts 3 8
Generator sets 1 8
Tractors/loaders/
backhoes
3 7
Welders 1 8
Paving 16 0 0 Pavers 2 8
Paving equipment 2 8
Rollers 2 8
Architectural
coating
8 0 0 Air compressors 1 6
Source: Appendix B.
Table 5 shows the estimated maximum daily construction emissions associated with the construction
phase of the project.
Table 5. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions
Year
VOC NOx CO SOx PM10 PM2.5
Pounds Per Day
2021 3.97 40.55 26.39 0.60 10.38 6.40
2022 25.99 12.60 17.23 0.03 0.92 0.68
Maximum Daily
Emissions
25.99 40.55 26.39 0.60 10.38 6.40
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Source: Appendix B.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter;
PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District.
The values shown are the maximum summer or winter daily emissions results from CalEEMod.
These estimates reflect control of fugitive dust required by SCAQMD Rule 403, specifically, watering of active site areas two times per day.
As shown in Table 5, daily construction emissions would not exceed the SCAQMD significance thresholds
for VOC, NOx, CO, SOx, PM10, or PM2.5 during project construction, and short-term construction impacts
would be less than significant.
Long-Term Operational Impacts
Operation of the project would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile sources,
including vehicle trips; area sources, including the use of consumer products, architectural coatings for
repainting, and landscape maintenance equipment; and energy sources, including combustion of fuels
Exhibit F PC Agenda Page 106
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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24 December 2020
used for space and water heating, which are described further below. Unrefrigerated warehouse was
selected as the representative land use in CalEEMod because the project would not include cold storage.
Baseline Operational Emissions
The existing manufacturing facility also generates criteria air pollutant emissions, which are primarily
associated with vehicular traffic. Emissions generated during operation of the existing facility were
estimated to provide a baseline for comparison to projected operational emissions generated by buildout
of the project. An operational year of 2020 was used to represent existing conditions. For the purposes of
estimating emissions from the existing operations at the site, Manufacturing was selected as the
representative land in CalEEMod and CalEEMod default values were used for area and energy sources. As
discussed under mobile sources, the baseline trip rates and truck fleet mix are based on the Transportation
Impact Analysis (TIA) prepared for the project and included as Appendix C. The TIA used existing employee
information and Institute of Transportation Engineering trip rates to develop trip generation data.
Area Sources
CalEEMod was used to estimate operational emissions from area sources, including emissions from
consumer product use, architectural coatings, and landscape maintenance equipment. Emissions
associated with natural gas usage in space heating and water heating are calculated in the building energy
use module of CalEEMod, as described in the following text.
Consumer products are chemically formulated products used by household and institutional consumers,
including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products;
home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty
products. Other paint products, furniture coatings, or architectural coatings are not considered consumer
products (CAPCOA 2017). Consumer product VOC emissions are estimated in CalEEMod based on the floor
area of nonresidential buildings and on the default factor of pounds of VOC per building square foot per
day. The CalEEMod default values for consumer products were assumed.
VOC off-gassing emissions result from evaporation of solvents contained in surface coatings such as in
paints and primers used during building maintenance. CalEEMod calculates the VOC evaporative emissions
from application of surface coatings based on the VOC emission factor, building square footage, assumed
fraction of surface area, and reapplication rate. The VOC emission factor is based on the VOC content of
the surface coatings, and SCAQMD’s Rule 1113 (Architectural Coatings) governs the VOC content for
interior and exterior coatings. The model default reapplication rate of 10% of area per year is assumed.
Consistent with CalEEMod defaults for non-residential uses, it is assumed that the surface area for painting
equals 2.0 times the floor square footage, with 75% assumed for interior coating and 25% assumed for
exterior surface coating (CAPCOA 2017). The emissions associated with architectural coatings are
estimated based on CalEEMod defaults values for VOC content.
Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers,
rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. The emissions
associated from landscape equipment use are estimated based on CalEEMod default values for emission
factors (grams per square foot of building space per day) and number of summer days (when landscape
maintenance would generally be performed) and winter days.
Exhibit F PC Agenda Page 107
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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25 December 2020
Energy Sources
As represented in CalEEMod, energy sources include emissions associated with building electricity and
natural gas usage (non-hearth). Electricity use would contribute indirectly to criteria air pollutant emissions;
however, the emissions from electricity use are only quantified for GHGs in CalEEMod, since criteria
pollutant emissions occur at the power plant, which is typically off site.
CalEEMod default values for energy consumption for the land use (unrefrigerated warehouse) were applied for
the project analysis because the project would not include cold storage. The energy use from nonresidential land
uses is calculated in CalEEMod based on the California Commercial End-Use Survey database. Energy use in
buildings (both natural gas and electricity) is divided by the program into end-use categories subject to Title 24
requirements (end uses associated with the building envelope, such as the heating, ventilation, and air
conditioning [HVAC] system; water heating system; and integrated lighting) and those not subject to Title 24
requirements (such as appliances, electronics, and miscellaneous “plug-in” uses).
Title 24 of the California Code of Regulations serves to enhance and regulate California’s building
standards. The current Title 24, Part 6 standards, referred to as the 2016 Title 24 Building Energy Efficiency
Standards, became effective on January 1, 2017. The 2019 Title 24 Building Energy Efficiency Standards,
which became effective on January 1, 2020, will further reduce energy use and associated emissions
compared to current standards. Nevertheless, for a conservative estimate, the 2016 Title 24 standards are
assumed within the CalEEMod (CAPCOA 2017) for this analysis.
Mobile Sources
The project would generate criteria pollutant emissions from mobile sources (vehicular traffic) as a result
of the employee passenger vehicles (workers) and truck traffic associated with the operation of the
warehouse. Emissions from the mobile sources during operation of the project were estimated using a
spreadsheet-based model and emissions factors from the CARB Mobile Source Emissions Inventory Model
(EMFAC, version 2017), and EPA AP-42 factors for paved road dust generation. Emission calculation
equations and assumptions were primarily derived from CalEEMod. The key factors in the mobile source
emission calculations include trip rates, trip lengths, fleet mix, and emissions factors for each vehicle, which
are described further below.
The baseline and project trip rates and the truck fleet mix are based on the TIA prepared for the project and
included as Appendix C. As detailed in the TIA, the project is anticipated to generate 238 average daily trips
from passenger vehicles and 279 average daily trips from heavy-duty trucks. Of the 279 average daily truck
trips, 11% (32 truck trips) were assumed to be two-axle trucks; 26% (72 truck trips) would be three-axle trucks;
and 63% (176 truck trips) would be four+-axle trucks. Consistent with CalEEMod default values for Los
Angeles County, the worker trip lengths were assumed to be of 16.6 miles per one-way trip. For the heavy-
duty trucks, an average truck distance of 40 miles was assumed, consistent with general recommendations
from the SCAQMD.
Vehicle emissions occur during startup, operation (running), idling, and from evaporative losses when the
engines are resting. The emissions factors for trucks and passenger vehicles were determined using
EMFAC2017. EMFAC2017 generates emissions factors, expressed in grams per mile, grams per trip, and
grams per vehicle per day for the fleet in a class of motor vehicles within a county for a particular study
Exhibit F PC Agenda Page 108
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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26 December 2020
year. For this analysis, Los Angeles County and calendar year 2022 was selected in EMFAC. For each vehicle
emissions factor, aggregated values for model year and speed were assumed.
Consistent with the TIA, vehicle emission factors were developed for passenger cars and heavy-duty trucks.
A composite, or weighted-average, emissions factor was developed for project vehicle types if more than
one vehicle category in EMFAC is anticipated to be representative of the project vehicle. For passenger
vehicles, the composite emission factor represents the weighted average emission rate by vehicle miles
traveled (VMT) for passenger vehicles (light-duty automobiles [LDA]), light-duty trucks (LDT1, 0–3,750
pounds), light-duty trucks (LDT2, 3,751–5,750 pounds), and a composite mix of gasoline and diesel-fueled
and electric. For the trucks, the percent breakdown by axle was used to developed the composite emission
factor assuming the following vehicle categories in EMFAC2017: two-axle trucks reflect a mix of light heavy-
duty trucks (LHDT1, 8,501 to 10,000 pounds, and LHDT2, 10,001 to 14,000 pounds); three-axle trucks
reflect medium heavy-duty trucks (MHDT); and four+-axle trucks reflect heavy heavy-duty trucks (HHDT).
Running Exhaust, Tire Wear, and Brake Wear (grams per mile). The vehicle exhaust, tire wear, and brake
wear emission factors developed for trucks and passenger vehicles in grams per mile were then multiplied
by the weighted average daily VMT to estimate emissions associated with vehicle travel to and from the
site. As explained previously, it was assumed that each worker trip would be 16.6 miles and each truck trip
would be 40 miles.
Starting Exhaust, Hot Soak, Running Loss Evaporative (grams per trip). The vehicle starting exhaust, hot soak,5
and running loss evaporative6 emissions factors developed for trucks and passenger vehicles were then
multiplied by the average daily vehicle trips to estimate emissions associated with vehicle travel to and from the
site. Truck trips and passenger vehicle trips per day were based on TIA (Appendix C).
Resting Loss Evaporation and Diurnal Loss Evaporation (grams per vehicle per day). The vehicle resting
loss evaporative7 and diurnal8 loss emissions factors developed for trucks and passenger vehicles were
then multiplied by the average daily and annual vehicles, conservatively assumed equal to the average
daily trips to estimate emissions associated with vehicles on site idling and resting. Truck trips and
passenger vehicle trips per day were based on TIA(Appendix C).
Idling (grams per vehicle per minute). Truck idling was estimated using EMFAC emission factors that were
converted to per minute of idling per vehicle. The idling emissions were calculated by multiplying the per-
minute emission factors by the estimated idle duration of 15 minutes per truck trip, representing up to
three idling events of a maximum of 5 minutes of idling each instance.
Paved Road Dust (grams per mile). Vehicles that drive on paved roads generate fugitive dust by dispersing
the silt from the roads. Paved road dust PM10 and PM2.5 emission factors were developed pursuant to the
5 HC Emissions (HOTSOAK) that occur immediately after a trip are due to fuel heating as an engine remains hot for up to 35 minutes
after being switched off.
6 HC Emissions (RUNLOSS) that occur are a result of hot fuel vapors escape from the fuel system or overwhelm the carbon caniste r
while the vehicle is operating
7 Emissions that occur while the vehicle is sitting, caused by fuel permeation through rubber and plastic components. Emissions
are counted as resting loss emissions if the vehicle has not been operated for 35 minutes and has been stationary, while th e
ambient temperature is either constant or decreasing.
8 Emissions that occur when rising ambient temperatures cause fuel evaporation from vehicles sitting throughout the day. These
losses are from leaks in the fuel system, fuel hoses, connectors, as a result of the breakthrough of vapors from the carbon canister.
If a vehicle is sitting for a period of time, emissions from the first 35 minutes are considered as hot soak , and emissions from the
remaining period are considered as diurnal emissions, provided that the ambient temperature is increasing during the remaining
period of time.
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CalEEMod 2016.3.2 road dust equation and based on road surface silt loading factors from CalEEMod and
particle size multipliers from AP-42 Section 13.2.1 Paved Roads (EPA 2011). Emissions were calculated by
multiplying the paved road dust emission factors by the VMT.
Off-Road Equipment
While the exact operational off-road equipment is unknown at this time, it was assumed that four electric-
operated forklifts and one yard hostler would operate for 8 hours per day at the project site.
Table 6 presents the maximum daily emissions associated with operation of the project in 2022 at buildout.
The values shown are the maximum summer and winter daily emissions results from CalEEMod for area,
energy, and off-road emissions sources, plus the estimated mobile source emissions using a spreadsheet
model and EMFAC2017 and AP-42 emission factors. Complete details of the emissions calculations are
provided in Appendix B.
Table 6. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions
Emission Source
VOC NOx CO SOx PM10 PM2.5
Pounds Per Day
Existing Emissions
Area 1.12 <0.01 0.04 0.00 <0.01 <0.01
Energy 0.02 0.21 0.18 <001 0.02 0.02
Mobile 2.43 41.89 23.58 0.20 27.26 7.42
Existing Total 3.57 42.1 23.8 0.2 27.28 7.44
Proposed Project
Area 1.18 <0.01 0.01 0.00 0.48 0.44
Energy <0.01 0.03 0.03 <0.01 <0.01 <0.01
Mobile 3.15 75.49 28.99 0.33 47.27 12.46
Off-Road Equipment 0.38 3.82 4.02 0.01 0.20 0.18
Project Total 4.72 79.35 33.05 0.35 47.96 13.09
Net Total 1.15 37.25 9.25 0.15 20.68 5.65
SCAQMD Threshold 55 55 550 150 150 55
Threshold
Exceeded?
No No No No No No
Source: Appendix B.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate
matter with a diameter less than or equal to 10 microns (coarse particulate matter); PM2.5 = particulate matter with a diameter less
than or equal to 2.5 microns (fine particulate matter); SCAQMD = South Coast Air Quality Management District.
The values shown are the maximum summer or winter daily emissions results from CalEEMod, output and operational year 2022. The
total values may not add up exactly due to rounding.
Off-road equipment includes emissions from one diesel-fueled yard hostler. CalEEMod erroneously reports criteria air pollutant
emissions associated with electric off-road equipment, including the electric forklifts; therefore, those erroneous criteria air pollutant
emissions from electric forklifts are omitted.
As shown in Table 6, maximum daily operational emissions of VOC, NOx, CO, SOx, PM10, and PM2.5 generated
by the project would not exceed the SCAQMD’s significance thresholds, and long-term operational impacts
would be less than significant.
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As previously discussed, the SCAB has been designated as a federal nonattainment area for O3 and PM2.5,
and a state nonattainment area for O3, PM10, and PM2.5. The nonattainment status is the result of
cumulative emissions from various sources of air pollutants and their precursors within the SCAB, including
motor vehicles, off-road equipment, and commercial and industrial facilities. Construction and operational
activities of the project would generate VOC and NOx emissions (precursors to O3) and emissions of PM10
and PM2.5. However, as indicated in Tables 5 and 6, project-generated emissions would not exceed the
SCAQMD emission-based significance thresholds for VOCs, NOx, PM10, or PM2.5.
Cumulative localized impacts would potentially occur if a project were to occur concurrently with another off-
site project. Schedules for potential future projects near the project area are currently unknown; therefore,
potential impacts associated with two or more simultaneous projects would be considered speculative.9
However, future projects would be subject to CEQA and would require air quality analysis, and include, where
necessary, mitigation. Criteria air pollutant emissions associated with construction activity of future projects
would be reduced through implementation of control measures required by the SCAQMD. Cumulative PM10
and PM2.5 emissions would be reduced because all future projects would be subject to SCAQMD Rule 403
(Fugitive Dust), which sets forth general and specific requirements for all sites in the SCAQMD. In addition,
cumulative VOC emissions would be subject to SCAQMD Rule 1113 (Architectural Coatings).
Based on the previous considerations, the project would not result in a cumulatively considerable increase
in emissions of nonattainment pollutants, and impacts would be less than significant.
c) Would the project expose sensitive receptors to substantial pollutant concentrations?
The project would not expose sensitive receptors to substantial pollutant concentrations, as evaluated below.
Sensitive Receptors
Sensitive receptors are those individuals more susceptible to the effects of air pollution than the population
at large. People most likely to be affected by air pollution include children, the elderly, and people with
cardiovascular and chronic respiratory diseases. According to the SCAQMD, sensitive receptors include
sites such as residences, schools, playgrounds, childcare centers, long-term healthcare facilities,
rehabilitation centers, convalescent centers, and retirement homes (SCAQMD 1993). The nearest sensitive
receptors that are residential uses located approximately 200 feet southwest of the project site.
Localized Significance Thresholds
The SCAQMD recommends a localized significance threshold (LST) analysis to evaluate localized air quality
impacts to sensitive receptors in the immediate vicinity of the project as a result of project activities. The
impacts were analyzed using methods consistent with those in the SCAQMD’s Final Localized Significance
Threshold Methodology (SCAQMD 2008a). The project is located within Source-Receptor Area 5 (Southeast
LA County). This analysis applies the SCAQMD LST values for a 5-acre site within Source-Receptor Area 5
with a receptor distance of 50 meters (164 feet).
Project construction activities would result in temporary sources of on -site criteria air pollutant emissions
associated with off-road equipment exhaust and fugitive dust generation. According to the Final Localized
9 The CEQA Guidelines state that if a particular impact is too speculative for evaluation, the agency should note its conclusio n and
terminate discussion of the impact (14 CCR 15145).
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Significance Threshold Methodology, “off-site mobile emissions from the project should not be included in
the emissions compared to the LSTs” (SCAQMD 2008a). Trucks and worker trips associated with the project
are not expected to cause substantial air quality impacts to sensitive receptors along off-site roadways
since emissions would be relatively brief in nature and would cease once the vehicles pass through the
main streets. Off-site emissions from truck trips were limited to 1,000 feet of estimated on-site activity
within the LST analysis. The maximum daily on-site emissions generated by construction of the project in
each construction year are presented in Table 7 and compared to the SCAQMD localized significance
criteria for Source-Receptor Area 5 to determine whether project-generated on-site emissions would result
in potential LST impacts.
Table 7. Construction Localized Significance Thresholds Analysis
Year
NO2 CO PM10 PM2.5
Pounds per Day (On Site)a
2021 40.50 25.45 9.09 5.75
2022 12.54 16.49 0.65 0.61
Maximum 40.50 25.45 9.09 5.75
SCAQMD LST Criteria 165 1,855 42 10
Threshold Exceeded? No No No No
Source: SCAQMD 2008a; Appendix B.
Notes: NO2 = nitrogen dioxide; CO = carbon monoxide; PM10 = particulate matter with a diameter less than or equal to 10 microns (coarse
particulate matter); PM2.5 = particulate matter with a diameter less than or equal to 2.5 microns (fine particulate matter); SCAQMD =
South Coast Air Quality Management District; LST = localized significance threshold.
Maximum on-site emissions occurred during the overlap of the following phases: grading and site preparation.
a LST are shown for a 5-acre disturbed area corresponding to a distance to a sensitive receptor of 50 meters in Source-Receptor Area 5
(Southeast LA County).
As shown in Table 7, proposed construction activities would not generate emissions in excess of site -
specific LSTs.
CO Hotspots
Traffic-congested roadways and intersections have the potential to generate localized high levels of CO.
Localized areas where ambient concentrations exceed federal and/or state standards for CO are termed
“CO hotspots.” The transport of CO is extremely limited, as it disperses rapidly with distance from the
source. Under certain extreme meteorological conditions, however, CO concentrations near a congested
roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO
concentrations are associated with severely congested intersections operating at an unacceptable level of
service (LOS) (LOS E or worse is unacceptable). Projects contributing to adverse traffic impacts may result
in the formation of a CO hotspot. Additional analysis of CO hotspot impacts would be conducted if a project
would result in a significant impact or contribute to an adverse traffic impact at a signalized intersection
that would potentially subject sensitive receptors to CO hotspots. Due to continued improvement in
vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO
hotspots in the SCAB is steadily decreasing. Additionally, as discussed in Section 3.17 of this IS/MND,
transportation impacts would be less than significant. Based on these considerations, the project would
result in a less-than-significant impact to air quality with regard to potential CO hotspots.
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Operational Health Risk Assessment
In addition to impacts from criteria pollutants, certain projects may include emissions of pollutants
identified by the state and federal government as toxic air contaminants (TACs) or hazardous air pollutants.
State law has established the framework for California’s TAC identification and control project, which is
generally more stringent than the federal project, and is aimed at TACs that are a problem in California. The
state has formally identified more than 200 substances as TACs, including the federal hazardous air
pollutants, and is adopting appropriate control measures for sources of these TACs.
The Office of Environmental Health Hazard Assessment’s (OEHHA’s) most recent guidance is the 2015 Risk
Assessment Guidelines Manual (OEHHA 2015), which was adopted in 2015 to replace the 2003 Health
Risk Assessment (HRA) Guidance Manual. The Children’s Environmental Health Protection Act of 1999
(Senate Bill [SB] 25), which requires explicit consideration of infants and children in ass essing risks from
air toxics, requires revisions of the methods for both non-cancer and cancer risk assessment and of the
exposure assumptions in the 2003 HRA Guidance Manual. Cancer risk parameters, such as age-sensitivity
factors, daily breathing rates, exposure period, fraction of time at home, and cancer potency factors, were
based on the values and data recommended by OEHHA as implemented in HARP2 (Hot Spots Analysis and
Reporting Program). SCAQMD’s Modeling Guidance for American Meteorological Society/EPA Regulatory
Model (AERMOD) (SCAQMD 2018) and Health Risk Assessment Guidance for Analyzing Cancer Risks from
Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis (SCAQMD 2003b) provides guidance to
perform dispersion modeling for use in HRAs within the SCAB.
Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SCAQMD
recommends a carcinogenic (cancer) risk threshold of 10 in one million. Some TACs increase noncancer
health risk due to long-term (chronic) exposures. The Chronic Hazard Index (HIC) is the sum of the individual
substance chronic hazard indices for all TACs affecting the same target organ system. The HIC estimates
for all receptor types used the ‘OEHHA Derived’ calculation method, which uses high-end exposure
parameters for the inhalation and next top two exposure pathways and mean exposure parameters for the
remaining pathways for non-cancer risk estimates. The HIC is the sum of the individual substance chronic
hazard indices for all TACs affecting the same target organ system.10 A hazard index less than 1.0 means
that adverse health effects are not expected. Within this analysis, noncarcinogenic exposures of less than
1.0 are considered less than significant. The SCAQMD recommends a HIC significance threshold of 1.0
(project increment) and an acute hazard index of 1.0. The exhaust from diesel engines is a complex mixture
of gases, vapors, and particles, many of which are known human carcinogens. Diesel particulate matter
(DPM) has established cancer risk factors and relative exposure values for long-term chronic health hazard
impacts. No short-term, acute relative exposure values are established and regulated and are therefore not
addressed in this assessment.
CARB’s Air Quality and Land Use Handbook: A Community Health Perspective encourages consideration of
the health impacts of distribution centers that accommodates more than 100 trucks per day on sensitive
receptors sited within 1,000 feet from the source in the land use decision-making process (CARB 2005).
For the operational health risk, the operation year 2022 was assumed consistent with completion of project
construction. Emissions from the operation of the project include truck trips and truck idling emissions. For
risk assessment purposes, PM10 in diesel exhaust is considered DPM, originating mainly from truck
10 The Chronic Hazard Index estimates for all receptor types used the OEHHA Derived calculation method (OEHHA 2015).
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traveling on site and off site and trucks idling located at the loading docks. Truck travel and idling emission
rates were obtained from CARB’s EMFAC2017. Emission factors representing the vehicle mix and
emissions for 2022 were used to estimate emissions associated with operation of the project. Truck idling
would be limited to 5 minutes in accordance with CARB’s adopted Airborne Toxic Control Measure; however,
truck idling was conservatively assumed to idle for 15 minutes.11 Therefore, the analysis conservatively
overestimates DPM emissions from idling. All truck operations would occur Monday through Sunday.
Electric-powered forklifts will be operated in the loading dock areas.
Conservatively, a 2022 EMFAC2017 run was conducted and a constant 2022 emission factor data set was
used for the entire duration of the analysis (i.e., 30 years). Use of the 2022 emission factors would overstate
potential impacts since this approach does not include reductions in emissions due to fleet turnover or cleaner
technology with lower emissions. The truck travel DPM emissions were calculated by applying the exhaust PM10
emission factor from EMFAC2017 and the total truck trip number over the length of the distance traveled. In
addition, the on-site truck idling exhaust emissions were calculated by applying the idle exhaust PM10 emission
factor from EMFAC2017 and total truck trip over the total idling time (i.e., 15 minutes).
The dispersion modeling was performed using AERMOD (version 18081). The truck traffic was modeled as
a line of adjacent volume sources from I-605 to the project site and truck travel on site to estimate
emissions at proximate receptors. Based on the TIA, 80% of the truck trips were modeled exiting and
entering the project site to the north along Woodruff Avenue and 20 % were modelled exiting and entering
the project site to the south along Woodruff Avenue. Truck idling was modeled as stationary sources.
As previously described, health effects from carcinogenic air toxics are usually described in terms of cancer
risk. The SCAQMD recommends a carcinogenic (cancer) risk threshold of 10 in 1 million. Some TACs
increase non-cancer health risk due to long-term (chronic) exposures. A hazard index less than 1.0 means
that adverse health effects are not expected. Within this analysis, noncarcinogenic exposures of less than
1.0 are considered less than significant. The exhaust from diesel engines is a complex mixture of gases,
vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk
factors and relative exposure values for long-term chronic health hazard impacts. As stated previously, no
short-term, acute relative exposure values are established and regulated; thus, they are not addressed in
this assessment.
Dudek evaluated the project’s potential cancer and noncancer health impacts using exposure periods
appropriate to evaluate long-term emission increases (third trimester of pregnancy to 30 years). Emissions
dispersion of DPM was modeled using AERMOD, then cancer risk and noncancer health impacts
subsequently using the CARB HARP2 (Air Dispersion Modeling and Risk Tool, version 19121). The chemical
exposure results were then compared to SCAQMD thresholds to assess project significance. Principal
parameters of this modeling are presented in Table 8.
11 Although the project is required to comply with CARB’s idling limit of 5 minutes, on-site idling emissions was estimated for 15
minutes of truck idling, which would take into account on-site idling while the trucks are waiting to pull up to the loading dock,
idling at the loading dock, and idling during check-in and check-out.
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Table 8. Operational Health Risk Assessment American Meteorological Society/EPA Regulatory
Model Operational Principal Parameters
Parameter Details
Meteorological Data The SCAQMD requires the use of AERMOD for air dispersion modeling. The latest 5-year
meteorological data for Fullerton Municipal Airport station (Station ID 3166) from
SCAQMD were downloaded, then input to AERMOD. For cancer or chronic noncancer risk
assessments, the average cancer risk of all years modeled was used.
Urban versus Rural
Option
Urban dispersion option was selected due to the developed nature of the project area
and per SCAQMD guidelines. Los Angeles County’s population 9,818,605 was used in
the analysis (SCAQMD 2018).
Terrain
Characteristics
Digital elevation model files were imported into AERMOD so that complex terrain
features were evaluated as appropriate. Per SCAQMD guidance, the National Elevation
Dataset (NED) dataset with resolution of 1/3 arc-second was used (SCAQMD 2018).
Emission Sources
and Release
Parameters
Air dispersion modeling of operational activities was conducted using emissions
generated using EMFAC2017.
Source Release
Characterizations
Off-site and on-site truck travel were modeled as a line of adjacent volume sources, and
based on EPA methodology, the modeled sources would result in a release height of 3.4
meters, a plume height of 3.16 meters, and a plume width of 1.56 meters (EPA 2015).
The truck idling emissions were modeled as a stationary source with a 4-meter exhaust
height and 0.1-meter exhaust diameter (EPA 2015; SCAQMD 2003b; SJVAPCD 2006).
The project and nearby buildings were modeled to account for building downwash.
Note: AERMOD = American Meteorological Society/Environmental Protection Agency Regulatory Model; SCAQMD = South Coast Air
Quality Management District; EPA = U.S. Environmental Protection Agency.
See Appendix B.
This HRA evaluated impacts using a uniform Cartesian grid of receptors spaced 50 meters apart, at
residential receptors located approximately within 1,000 meters from the project site, and then converted
to discrete receptors.
For the operational health risk, the HRA assumes exposure would start in the third trimester of pregnancy
through 30 years for all residential sensitive receptor locations. The exposure duration for a student would
start at age 5 through age 10 at the nearby elementary school (AL Gauldin Elementary School). The
SCAQMD has also established noncarcinogenic risk parameters for use in HRAs since some TACs increase
non-cancer health risk due to long-term (chronic) exposures. Noncarcinogenic risks are quantified by
calculating a hazard index, expressed as the ratio between the ambient pollutant concentration and its
toxicity or relative exposure level, which is a concentration at or below which health effects are not likely to
occur. The chronic hazard index is the sum of the individual substance chronic hazard indices for all TACs
affecting the same target organ system, similarly calculated for acute hazard index. The results of the HRA
during operation are provided in Table 9.
Table 9. Operational Health Risk Assessment Results
Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
Maximum Individual Cancer Risk –
Residential
Per Million 7.71 10 Less than Significant
MICR—Student Per Million 0.30 1.0 Less than Significant
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Table 9. Operational Health Risk Assessment Results
Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
HIC Index Value 0.002 1.0 Less than Significant
Source: SCAQMD 2019; Appendix B.
Notes: CEQA = California Environmental Quality Act; MICR = maximum individual cancer risk; HIC = Chronic Hazard Index.
The results of the operational analysis demonstrate that the exhibit maximum individual cancer risk for the
student and residential receptors are below the 10 and 1.0 in a million thresholds, respectively and below
the HIC threshold. Therefore, no long-term impacts associated with exposing sensitive receptors to
substantial pollutant concentrations would occur, and the level of impact would be less than significant.
Effects of Criteria Air Pollutants
Construction and operation of the project would generate criteria air pollutant emissions; however,
estimated construction and operational emissions would not exceed the SCAQMD mass-emission daily
thresholds as shown in Tables 5 and 6, respectively. As previously discussed, the SCAB has been
designated as a federal nonattainment area for O3 and PM2.5 and a state nonattainment area for O3, PM10,
and PM2.5.
Health effects associated with O3 include respiratory symptoms, worsening of lung disease leading to
premature death, and damage to lung tissue (CARB 2019b). VOCs and NOx are precursors to O3, for which
the SCAB is designated as nonattainment with respect to the NAAQS and CAAQS. The contribution of VOCs
and NOx to regional ambient O3 concentrations is the result of complex photochemistry. The increases in
O3 concentrations in the SCAB due to O3 precursor emissions tend to be found downwind from the source
location to allow time for the photochemical reactions to occur. However, the potent ial for exacerbating
excessive O3 concentrations would also depend on the time of year that the VOC emissions would occur
because exceedances of the O3 ambient air quality standards tend to occur between April and October
when solar radiation is highest. The holistic effect of a single project’s emissions of O3 precursors is
speculative because of the lack of quantitative methods to assess this impact. Because construction and
operation of the project would not result in O3 precursor emissions (i.e., VOCs or NOX) that would exceed
the SCAQMD thresholds, as shown in Tables 5 and 6, the project is not anticipated to substantially
contribute to regional O3 concentrations and their associated health impacts.
Health effects associated with NOx include lung irritation and enhanced allergic responses (CARB 2019b).
Construction and operation of the project would not generate NOx emissions that would exceed the
SCAQMD mass daily thresholds; therefore, construction and operation of the project is not anticipated to
contribute to exceedances of the NAAQS and CAAQS for NO2 or contribute to associated health effects. In
addition, the SCAB is designated as in attainment of the NAAQS and CAAQS for NO 2, and the existing NO2
concentrations in the area are well below the NAAQS and CAAQS standards.
Health effects associated with CO include chest pain in patients with heart disease, headache, light -
headedness, and reduced mental alertness (CARB 2019b). CO tends to be a localized impact
associated with congested intersection s. CO hotspots were discussed previously as a less -than-
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significant impact. Thus, the project’s CO emissions would not contribute to the health effects
associated with this pollutant.
Health effects associated with PM10 and PM2.5 include premature death and hospitalization, primarily for
worsening of respiratory disease (CARB 2019b). As with O3 and NOX, and as shown in Tables 5 and 6, the
project would not generate emissions of PM10 or PM2.5 that would exceed the SCAQMD’s thresholds.
Accordingly, the project’s PM10 and PM2.5 emissions are not expected to cause an increase in related health
effects for this pollutant.
The California Supreme Court’s Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502 decision (referred to
herein as the Friant Ranch decision; issued on December 24, 2018), addresses the need to correlate mass
emission values for criteria air pollutants to specific health consequences, and contains the following
direction from the California Supreme Court: “The Environmental Impact Report (EIR) must provide an
adequate analysis to inform the public how its bare numbers translate to create potential adverse impacts
or it must explain what the agency does know and why, given existing scientific constraints, it cannot
translate potential health impacts further.” (Italics in original.) Currently, SCAQMD, CARB, and EPA have not
approved a quantitative method to reliably, meaningfully, and consistently translate the mass emission
estimates for the criteria air pollutants resulting from the proposed project to specific health effects. In
addition, there are numerous scientific and technological complexities associated with correlating criteria
air pollutant emissions from an individual pro ject to specific health effects or potential additional
nonattainment days.
In connection with the judicial proceedings culminating in issuance of the Friant Ranch decision, the
SCAQMD and the San Joaquin Valley Air Pollution Control District (SJVAPCD) filed amicus briefs attesting to
the extreme difficulty of correlating an individual project’s criteria air pollutant emissions to specific health
impacts. Both SJVAPCD and SCAQMD have among the most sophisticated air quality modeling and health
impact evaluation capabilities of the air districts in California. The key, relevant points from SCAQMD and
SJVAPCD briefs is summarized herein.
In requiring a health impact type of analysis for criteria air pollutants, it is important to understand how O3
and PM is formed, dispersed and regulated. The formation of O3 and PM in the atmosphere, as secondary
pollutants,12 involves complex chemical and physical interactions of multiple pollutants from natural and
anthropogenic sources. The O3 reaction is self-perpetuating (or catalytic) in the presence of sunlight
because NO2 is photochemically reformed from nitric oxide (NO). In this way, O3 is controlled by both
NOx and VOC emissions (NRC 2005). The complexity of these interacting cycles of pollutants means that
incremental decreases in one emission may not result in proportional decreases in O3 (NRC 2005). Although
these reactions and interactions are well understood, variability in emission source operations and
meteorology creates uncertainty in the modeled O3 concentrations to which downwind populations may be
exposed (NRC 2005). Once formed, O3 can be transported long distances by wind and due to atmospheric
transport, contributions of precursors from the surrounding region can also be important (EPA 2008).
Because of the complexity of O3 formation, a specific tonnage amount of VOCs or NOX emitted in a particular
area does not equate to a particular concentration of O3 in that area (SJVAPCD 2015). PM can be divided
into two categories: directly emitted PM and secondary PM. Secondary PM, like O3, is formed via complex
chemical reactions in the atmosphere between precursor chemicals such as SOx and NOx (SJVAPCD 2015).
Because of the complexity of secondary PM formation, including the potential to be transported long
12 Air pollutants formed through chemical reactions in the atmosphere are referred to as secondary pollutants.
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distances by wind, the tonnage of PM-forming precursor emissions in an area does not necessarily result
in an equivalent concentration of secondary PM in that area (SJVAPCD 2015). This is especially true for
individual projects, like the proposed project, where project-generated criteria air pollutant emissions are
not derived from a single “point source,” but from construction equipment and mobile sources (passenger
cars and trucks) driving to, from and around the project site.
Another important technical nuance is that health effects from air pollutants are related to the
concentration of the air pollutant that an individual is exposed to, not necessarily the individual mass
quantity of emissions associated with an individual project. For example, health effec ts from O3 are
correlated with increases in the ambient level of O3 in the air a person breathes (SCAQMD 2015). However,
it takes a large amount of additional precursor emissions to cause a modeled increase in ambient O3 levels
over an entire region (SCAQMD 2015). The lack of link between the tonnage of precursor pollutants and
the concentration of O3 and PM2.5 formed is important because it is not necessarily the tonnage of precursor
pollutants that causes human health effects; rather, it is the concentration of resulting O3 that causes these
effects (SJVAPCD 2015). Indeed, the ambient air quality standards, which are statutorily required to be set
by EPA at levels that are requisite to protect the public health, are established as concentrations of O3 and
PM2.5 and not as tonnages of their precursor pollutants (EPA 2018a). Because the ambient air quality
standards are focused on achieving a particular concentration region-wide, the tools and plans for attaining
the ambient air quality standards are regional in nature. For CEQA analyses, project -generated emissions
are typically estimated in pounds per day or tons per year and compared to mass daily or annual emission
thresholds. While CEQA thresholds are established at levels that the air basin can accommodate without
affecting the attainment date for the ambient air quality standards, even if a project exceeds established
CEQA significance thresholds, this does not mean that one can easily determine the concentration of O 3 or
PM that will be created at or near the project site on a particular day or month of the year, or what specific
health impacts will occur (SJVAPCD 2015).
In regard to regional concentrations and air basin attainment, the SJVAPCD emphasized that attempt ing to
identify a change in background pollutant concentrations that can be attributed to a single project, even
one as large as the entire Friant Ranch Specific Plan, is a theoretical exercise. The SJVAPCD brief noted
that it “would be extremely difficult to model the impact on NAAQS attainment that the emissions from the
Friant Ranch project may have” (SJVAPCD 2015). The situation is further complicated by the fact that
background concentrations of regional pollutants are not uniform either temporally or geographically
throughout an air basin, but are constantly fluctuating based upon meteorology and other environmental
factors. SJVAPCD noted that the currently available modeling tools are equipped to model the impact of all
emission sources in the San Joaquin Valley Air Basin on attainment (SJVAPCD 2015). The SJVAPCD brief
then indicated that, “Running the photochemical grid model used for predicting O 3 attainment with the
emissions solely from the Friant Ranch project (which equate to less than one-tenth of one percent of the
total NOx and VOC in the Valley) is not likely to yield valid information given the relative scale involved”
(SJVAPCD 2015).
SCAQMD and SJVAPCD have indicated that it is not feasible to quantify project-level health impacts based
on existing modeling (SCAQMD 2015; SJVAPCD 2015). Even if a metric could be calculated, it would not be
reliable because the models are equipped to model the impact of all emission sources in an air basin on
attainment and would likely not yield valid information or a measurable increase in O3 concentrations
sufficient to accurately quantify O3-related health impacts for an individual project.
Exhibit F PC Agenda Page 118
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Nonetheless, following the Supreme Court’s Friant Ranch decision, some EIRs where estimated criteria air
pollutant emissions exceeded applicable air district thresholds have included a quantitative analysis of
potential project-generated health effects using a combination of a regional photochemical grid model
(PGM)13 and the EPA Benefits Mapping and Analysis Program (BenMAP or BenMAP–Community Edition
[CE])14. The publicly available health impact assessments (HIAs) typically present results in terms of an
increase in health incidences and/or the increase in background health incidence for various health
outcomes resulting from the project’s estimated increase in concentrations of O3 and PM2.5.15 To date, the
five publicly available HIAs reviewed herein have concluded that the evaluated project’s health effects
associated with the estimated project-generated increase in concentrations of O3 and PM2.5 represent a
small increase in incidences and a very small percent of the number of background incidences, indicating
that these health impacts are negligible and potentially within the models’ margin of error. It is also
important to note that while the results of the five available HIAs conclude that the project emissions do
not result in a substantial increase in health incidences, the estimated emissions and assumed toxicity is
also conservatively inputted into the HIA and thus, overestimate health incidences, particularly for PM2.5.
As explained in the SJVAPCD brief and noted previously, running the PGM used for predicting O3 attainment
with the emissions solely from an individual project like the Friant Ranch project or the proposed project is
not likely to yield valid information given the relative scale involved. The five examples reviewed support
the SJVAPCD’s brief contention that consistent, reliable, and meaningful results may not be provided by
methods applied at this time. Accordingly, additional work in the industry and more importantly, air district
participation, is needed to develop a more meaningful analysis to co rrelate project-level mass criteria air
pollutant emissions and health effects for decision makers and the public. Furthermore, at the time of
writing, no HIA has concluded that health effects estimated using the PGM and BenMAP approach are
substantial provided that the estimated project-generated incidences represent a very small percent of the
number of background incidences, potentially within the models’ margin of error.
In summary, construction and operation of the project would not result in exceedances of the SCAQMD
significance thresholds for certain criteria pollutants, and potential health effects associated with criteria
air pollutants would be less than significant.
In addition, an analysis of the project’s potential to exceed the SCAQMD LSTs is presented above. The SCAQMD
developed the LST analysis in response to CARB Governing Board’s Environmental Justice Enhancement
Initiative I-4. LSTs represent the maximum emissions from a project that will not cause or contribute to an
13 The first step in the publicly available HIAs includes running a regional PGM, such as the Community Multiscale Air Quality model
or the Comprehensive Air Quality Model with extensions to estimate the increase in concentrations of O3 and PM2.5 as a result of
project-generated emissions of criteria and precursor pollutants. Air districts, such as the SCAQMD, use photochemical air quality
models for regional air quality planning. These photochemical models are large-scale air quality models that simulate the changes
of pollutant concentrations in the atmosphere using a set of mathematical equations characterizing the chemical and physical
processes in the atmosphere (EPA 2017).
14 After estimating the increase in concentrations of O3 and PM2.5, the second step in the five examples includes use of BenMAP or
BenMAP-CE to estimate the resulting associated health effects. BenMAP estimates the number of health incidences resulting
from changes in air pollution concentrations (EPA 2018b). The health impact function in BenMAP-CE incorporates four key sources
of data: (i) modeled or monitored air quality changes, (ii) population, (iii) baseline incidence rates, and (iv) an effect es timate. All
of the five example HIAs focused on O3 and PM2.5.
15 The following CEQA documents included a quantitative HIA to address Friant Ranch: (1) California State University Dominguez
Hills 2018 Campus Master Plan EIR (CSU Dominguez Hills 2019), (2) March Joint Powers Association K4 Warehouse and Cactus
Channel Improvements EIR (March JPA 2019), (3) Mineta San Jose Airport Amendment to the Airport Master Plan EIR (City of San
Jose 2019), (4) City of Inglewood Basketball and Entertainment Center Project EIR (City of Ingl ewood 2019), and (5) San Diego
State University Mission Valley Campus Master Plan EIR (SDSU 2019).
Exhibit F PC Agenda Page 119
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exceedance of the most stringent applicable NAAQS or CAAQS (which are health protective standards) at
the nearest sensitive receptor, taking into consideration ambient concentrations in each source receptor
area, project size, and distance to the nearest sensitive receptor. LSTs has been developed for NO2, CO,
PM10, and PM2.5. As presented above, the project’s localized construction emissions would not exceed site-
specific LSTs, and impacts would be less than significant.
d) Would the project result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people?
The occurrence and severity of potential odor impacts depend on numerous factors. The nature, frequency,
and intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each
contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can
be annoying and cause distress among the public and generate citizen complaints.
Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of
the project. Potential odors produced during construction would be attributable to concentrations of unburned
hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt pavement
application. Such odors would disperse rapidly from the project site and generally occur at magnitudes that
would not affect substantial numbers of people. In addition, in terms of odors during operation, land uses and
industrial operations associated with odor complaints include agricultural uses, wastewater treatment plants,
food-processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding
(SCAQMD 1993). The project entails operation of an industrial/warehouse facility and does not include any of
the aforementioned odor-generating uses or activities. Therefore, no impacts associated with other emissions,
including odors, would occur, and the level of impact would be less than significant.
3.4 Biological Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the
California Department of Fish and Game or
U.S. Fish and Wildlife Service?
Exhibit F PC Agenda Page 120
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Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
c) Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
d) Interfere substantially with the movement of
any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a
tree preservation policy or ordinance?
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any
species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Less-than-Significant Impact with Mitigation Incorporated. The project site is located in a highly developed
part of the City and is surrounded by an urbanized mix of land uses. The nearest open space area as
identified by the City’s General Plan is Independence Park, which is located approximately 0.4 miles to the
southwest of the project site. Due to the intervening development between the project site and this open
space area, there is no direct connection between the project site and this parkland area.
No native habitat is located on the project site or in the immediately surrounding area. The project site
consists of a fully developed parcel with an existing industrial use. Plant species surrounding the project
site are limited to non-native, ornamental species located within the public right-of-way, including turf grass
and palm species. These non-native, ornamental plant species form a non-cohesive plant community that
is not known to support any candidate, sensitive, or special-status plant species. Based on the developed
nature of the project site and surrounding area, wildlife species that could occur on site include common
species typically found in urbanized settings, such as house sparrow (Passer domesticus), mourning dove
(Zenaida macroura), and western fence lizard (Sceloporus occidentalis). As such, wildlife species that can
reasonably be expected to occur on the project site would not be considered candidate, sensitive, or
special-status wildlife species.
Exhibit F PC Agenda Page 121
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Ornamental landscape trees that are currently located on the project site may require removal prior to
construction of the project. Because of the existing deve lopment on the project s ite and the existing
development around the site, it is unlikely that the existing trees would provide desirable nesting
opportunities for bird/raptor species, especially considering that more suitable nesting options likely
occur within the broader project area. Nonetheless, per MM-BIO-1, if construction activities were to
occur during nesting season (typically between February 1 and September 1), the project applicant
would be required to conduct pre -construction nesting bird surve ys to ensure that no nests are located
within the ornamental trees adjacent to the project site, in accordance with California Fish and Game
Code Sections 3503, 3503.5, 3513, and 3800 . Compliance with MM-BIO-1 would ensure that the
project would not result in impacts to a protected bird species. Therefore, impacts associated with
candidate, sensitive, or special -status species would occur.
MM-BIO-1 Prior to the issuance of a demolition, grading, and/or building permit for activities during the avian
nesting season (i.e., February 1 and September 1), the project applicant shall submit a survey for
active nests to the City of Downey Building & Safety Division conducted by a qualified biologist a
maximum of 1 week prior to the activities to determine the presence/absence, location, and status
of any active nests on or adjacent to the project site. The nesting bird survey shall consist of full
coverage of the project footprint and an appropriate buffer, as determined by the biologist. If no
active nests are discovered or identified, no further mitigation is required. In the event that active
nests are discovered on site, a suitable buffer determined by the biologist shall be established
around any active nest. No ground-disturbing activities shall occur within this buffer until the
biologist has confirmed that breeding/nesting is completed and the young have fledged the nest.
Limits of construction to avoid a nest shall be established in the field by the biologist with flagging
and stakes or construction fencing. Construction personnel shall be instructed regarding the
ecological sensitivity of the fenced area. The results of the survey shall be documented and filed
with the City of Downey within 5 days after the survey.
b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
No Impact. No native habitat is located on the project site or in the immediately surrounding area. The
project site consists of a fully developed parcel with an existing industrial use. Plant species surrounding
the project site are limited to non-native, ornamental species located within the public right-of-way,
including turf grass and palm species. These non-native, ornamental plant species form a non-cohesive
plant community. Therefore, no impacts to riparian or sensitive vegetation communities would occur as
result of the project.
c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or
other means?
No Impact. No federally defined waters of the United States or state occur within the project site. This
includes the absence of federally defined wetlands and other waters (e.g., drainages) and state-defined
waters (e.g., streams and riparian extent. In addition, the project would be subject to typical restrictions
and requirements that address erosion and runoff (e.g., best management practices [BMPs]), including
Exhibit F PC Agenda Page 122
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40 December 2020
those of the Clean Water Act and National Pollutant Discharge Elimination System (NPDES) permit.
Therefore, no impacts to jurisdictional waters or wetlands would occur.
d) Would the project interfere substantially with the movement of any native resident or migratory fish or
wildlife species or with established native resident or migratory wildlife corridors, or impede the use of
native wildlife nursery sites?
No Impact. Although some local movement of wildlife is expected to occur within the broader City, the
City is not recognized as an existing or proposed Significant Ecological Area that links migratory
populations, as designated by the County (County of Los Angeles 20 19). The project site is located
within a highly urbanized area , and the site is currently surrounded by other industrial uses, which
would greatly prohibit any incidental wildlife movement, in the unlikely scenario that any movement
occurs in the project area. Construction of the project would not interfere with the movement of any
native residents, migratory fish, or wildlife species. Therefore, no impacts associated with wildlife
movement or wildlife corridors would occur.
e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a
tree preservation policy or ordinance?
No Impact. Ornamental landscape trees that are currently located on the project site may require
removal prior to construction of the pro ject. However, the City does not have any local policies or
ordinances protecting trees located on private property. As such, implementation of the project would not
conflict with local policies. Therefore, no impacts associated with local policies or ordinances protecting
biological resources would occur.
f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The project site is not located within any habitat conservation plan; natural community
conservation plan; or other approved local, regional, or state habitat conservation plan area. Therefore, no
impacts associated with an adopted conservation plan would occur.
3.5 Cultural Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in
the significance of a historical resource
pursuant to §15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
Exhibit F PC Agenda Page 123
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41 December 2020
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
c) Disturb any human remains, including those
interred outside of dedicated cemeteries?
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant
to §15064.5?
Less-than-Significant Impact. As defined by the CEQA Guidelines, a “historical resource” is considered to
be a resource that is listed in or eligible for listing in the National Register of Historic Places (NRHP) or
California Register of Historic Resources (CRHR), has been identified as significant in a historical resource
survey, or is listed on a local register of historical resources.
The proposed project includes demolition of an existing, 74,662-square-foot industrial building located at
12021-12023 Woodruff Avenue, Downey, California 90241 (subject property) on a 6.31-acre parcel (AIN
6284-025-018) originally developed in 1951 for Kirkhill Manufacturing Inc. No previously recorded
historical resources were identified within the project site as a result of the California Historical Resources
Information System records search, Native American Heritage Commission Sacred Lands File search,
extensive archival research, field survey, and property significance evaluation. However, 12021–12023
Woodruff Avenue, the project site, contains three buildings constructed over 45 years ago that could
potentially be eligible for listing in the CRHR/NRHP.
The criteria for listing resources in the CRHR were developed to be in accordance with previously
established criteria developed for listing in the NRHP. Thus, the criteria listed below is expressed in
accordance with the NRHP criteria. According to California Public Resources Code, Section 5024.1(c)(1–
4), a resource is considered historically significant if it (i) retains “substantial integrity,” and (ii) meets at
least one of the following criteria:
(1) Is associated with events that have made a significant contribution to the broad
pattern of our history
(2) Is associated with the lives of persons important in our past
(3) Embodies the distinctive characteristics of a type, period, region, or method of
construction, or represents the work of an important creative individual, or possesses high
artistic values
(4) Has yielded, or may be likely to yield, information important in prehistory or history
Under CEQA, a project may have a significant effect on the environment if it may cause “a substantial
adverse change in the significance of an historical resource” (California Public Resources Code, Section
21084.1; 14 CCR 15064.5(b)). If a site is listed or eligible for listing in the CRHR, included in a local register
of historic resources, or identified as significant in a historical resources survey (meeting the requirements
of California Public Resources Code, Section 5024.1(q)), it is a “historical resource” and is presumed to be
Exhibit F PC Agenda Page 124
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42 December 2020
historically or culturally significant for the purposes of CEQA (California Public Resources Code, Section
21084.1; 14 CCR 15064.5(a)).
In compliance with CEQA, the subject property was evaluated under the four CRHR criteria outlined above
to determine its eligibility for listing in the CRHR or NRHP, and accordingly, its historical significance.
As a result of the historic significance evaluations, the Kirkhill Manufacturing Inc. property located at
12021–12023 Woodruff Avenue (AIN: 6284-025-018) does not appear eligible for listing in the NRHP or
CRHR due to a lack of significant historical associations, architectural merit, and physical integrity.
Therefore, this property is not considered an historical resource for the purposes of CEQA. Furthermore, no
potential indirect impacts to historical resources were identified. A discussion of the resource and the
associated evaluation findings are presented below. Additional details are provided in the Cultural
Resources Technical Report prepared for the project and included as Appendix A.
Property Description. The subject property at 12021–12023 Woodruff Avenue proposed for demolition
features three geographically distinct, but interconnected building wings: the main office, the north
warehouse, and the south warehouse, constructed in 1951. The three wings are connected by interior
hallways, as well as, a paved, U-shaped access driveway and parking area that extends around the
perimeter of the building on the north, west, and south sides.
The main office wing (1951, multiple expansions) is a one-story, Mid-Century Modern-style building
featuring a flat roof and decorative breezeway block screens. The building is clad in a combination of flat
brick and scored stucco in broad sections. The flat roof extends out to form a covered walkway along the
front of the building. The primary entrance features a single, replaced full-lite door located at the center of
the east (main) elevation that is surrounded by two fixed windows and a fixed transom. The north and south
sections of the building show evidence of multiple modifications and expansion over time displayed by
incompatible rooflines and blunt transitions between exterior cladding materials.
The north warehouse (1951, multiple expansions) wing is located northwest of the main office and consists
of two different utilitarian-style sections: a two-story section clad in ribbed metal siding atop a concrete-
masonry unit substructure; and a tri-gable, one-story section which faces the western property line. The
two-story section of the north warehouse sits immediately behind the main office volume and features a
shallow, front-facing gable roof supported by heavy steel framing. The roof is clad in ribbed metal material
and contains multiple skylights as well as clerestory windows on the south elevation. The main entry point
for this section of the building is a large roll-up metal door. Additional doors are found throughout the
elevation, but they appear to function as emergency doors and not as primary points of entry. The one-
story, tri-gabled section of the north warehouse is located to the west of the two-story section. This segment
of the building is clad in a ribbed metal siding in both a metallic and white color. Each of the three, equally
sized bays contains a single or a double metal roll-up door that provides access to the interior areas. The
northern wall on this section is faced with concrete masonry to correspond with the two-story section.
The south warehouse (1951, multiple expansions) is located to the southwest of the main office wing and
south of the north warehouse. This building section features a front gable roof and a west elevation clad in
a ribbed metal material. The south elevation consists of a broad wall of built from concrete-masonry units
that run the length of this elevation. The entire stretch of this elevation is punctuated only by two full-leaf
Exhibit F PC Agenda Page 125
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doors, a metal roll-up door, a sliding glass door with a small metal awning, and two decorative breezeway
block screens shading a window on the east side of the elevation.
All three wing buildings have undergone extensive alterations and expansions between 1951 and present
(Figure 15, Expansion of the Kirkhill Manufacturing Inc. Building). Twenty-six (26) permits have been filed
for the property, and numerous observed alterations and review of aerial photographs are noted. A
complete description of these alterations, detailed descriptions of historical aerial photographs and
complete list of permits may be found in Appendix A.
Significance Evaluation. Thomas Kirk Hill founded The Mechanical Rubber Company in the City of Los
Angeles in 1919 to produce rubber seals and flexible connectors for plumbing and industrial use. In 1926,
the company was renamed the Kirkhill Rubber Company. As the demand for rubber products grew, the
company enlarged the original plant during the 1930s. Prompted by the escalation of the aeronautical
industry in Los Angeles County in response to World War II, the Kirkhill Rubber Company divided into two
separate companies in 1941: Kirkhill Rubber Company remained focused on the manufacturing of rubber
products related to plumbing and industrial goods, while the new branch of the company, Kirkhill
Manufacturing Inc., focused on the production of seals related to aerospace products. In 1949, the Kirkhill
Rubber Company completed a new, 360,000-square-foot facility in Brea, California, that was capable of
employing over 1,000 people. The Brea facility was expanded by 50,000 square feet in 1950, allowing it
to become the center of operations and production for both Kirkhill companies. In 1951, as North American
Aviation (a prominent aviation company) developed new, jet-propelled aircraft, Kirkhill Manufacturing Inc.
established a comparatively smaller plant in Downey to maintain close proximity to the rapid-paced-
development in the Downey aerospace industry. A permit for an expansion of the Downey plant in 1955
suggests that the plant employed only 60 people, which was a nominal fraction of the overall company
employment during this period (LAT 1950; Kirkhill Inc. 2019; City of Downey Permit 1955).
Based on a review of historical aerial photographs and building permits (see Appendix A for a complete
discussion of aerial photographs and building permits), the region of Downey that comprises the project
site remained undeveloped farmland until the late-1940s. The first industrial development along this
stretch of Woodruff Avenue between Stewart and Gray Road and Washburn Road did not take place until
the period between 1947 and 1951. The subject property, the Kirkhill Manufacturing Inc. building located
at 12021–12023 Woodruff Avenue, first appears in the 1952 historical aerial photograph, and Los Angeles
County Assessor data indicates that it was constructed in 1951. The original architect for the facility as well
as the architect(s) who designed the subsequent additions were not discovered during the course of
research for this project. Subsequent City of Downey permits and aerial photographs of the plant suggest
that the plant has undergone numerous, major expansions that have effectually tripled the square-footage
of the original Mid-Century Modern building (UCSB 2020; NETR 2020; Los Angeles Co. Assessor 2020).
The subject property is not eligible under NRHP/CRHR Criterion A/1 for its associations with historical events.
Archival research indicates that by the time the Downey branch facility of Kirkhill Manufacturing Inc. was
completed in 1951, parent company Kirkhill Rubber Company had already been manufacturing rubber
products for aerospace projects for 10 years, and the Downey location was secondary to the Brea location,
established 2 years earlier in 1949. Archival research indicates the Brea plant served as the center of
operations during the 1950s through the 1980s, a period when Downey earned a reputation as an
epicenter of aerospace engineering. However, the Downey location is not referenced in connection with any
specific achievement credited to the Kirkhill Manufacturing Inc. The plant in Downey has not made a
Exhibit F PC Agenda Page 126
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44 December 2020
significant contribution to the local, state, or national history. While the current tenants of the building,
Kirkhill Manufacturing Company Inc., continue to use the Kirkhill company name, the original Kirkhill
Manufacturing Inc. was sold and restructured multiple times during the 1990s. Therefore, the current
Kirkhill Manufacturing Company Inc. does not maintain continuous association to the company started by
Thomas Kirk Hill in 1919 that went on to assist in the engineering of aerospace industries. Moreover, with
subsequent additions and alterations, the building no longer represents the time period in which the events
for which the company gained notoriety within the field of aerospace design took place.
The subject property is not eligible under NRHP/CRHR Criterion B/2 for its association with significant
persons. Archival research did not indicate that any previous property owners or employees are known to
be historically significant figures at the national, state, or local level. As such, this property is not known to
have any historical associations with people important to the nation’s or state’s past.
The subject property is not eligible under NRHP/CRHR Criterion C/3 for architectural or engineering merit.
Construction of the subject property began in 1951, and the original building design would go on to receive
five major additions in the years 1954, 1955, 1971, 1973, and 1976. The original 1951 building was a
modest and unremarkable example of the Mid-Century Modern-style buildings designed for industrial and
commercial uses following the end of World War II. Furthermore, the popularity of the architectural style in
Southern California and its widespread use resulted in the creation of hundreds of buildings in this style
that have a higher level of integrity, association with notable architects, and a higher level of architectural
merit that that shown at the subject property. Therefore, the subject property cannot be considered a
distinctive example of a Mid-Century Modern industrial building, nor can it be considered representative of
a significant and distinguishable entity whose components lack individual distinction. Furthermore, as the
original architect was not discovered during the course of research for this project, the building is not known
to be the work of a master architect. The property as a whole has been altered beyond recognition,
diminishing the already modest architectural value of the property. These alterations and major additions
have caused the building to lose integrity in the areas of design, materials, and workmanship.
No evidence was found to warrant consideration under NRHP/CRHR Criterion D/4, which applies to
resources that may yield important information for prehistory or history. The property is also not eligible as
a contributor to a larger historic district.
The subject property (retains integrity of location, but does not retain requisite integrity of setting, design,
materials, workmanship, feeling, or association. Therefore, the subject property does not retain the
requisite integrity and does not rise to the level of significance required for designation at the national,
state, or local levels. A complete discussion of integrity is provided in Appendix A.
In consideration of a lack of significant historical associations, architectural merit, and physical integrity,
the Kirkhill Manufacturing Inc. property located at 12021–12023 Woodruff Avenue (AIN 6284-025-018) is
not eligible for NRHP or CRHR. Therefore, this property is not considered an historical resource for the
purposes of CEQA. No historical resources were identified near this property, and no additional potential
indirect impacts to historical resources were identified as a result of the record search. Therefore, impacts
associated with historical resources under CEQA would be less than significant.
Exhibit F PC Agenda Page 127
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45 December 2020
b) Would the project cause a substantial adverse change in the significance of an archaeological resource
pursuant to §15064.5?
Less-than-Significant Impact with Mitigation Incorporated. No archaeological resources were identified
within the project site through the California Historical Resources Information System records search or
Native American Heritage Commission Sacred Lands File review. An archaeological pedestrian survey was
not conducted as the project site is developed with no exposed ground surface.
A review of property permits and archival/historic maps was conducted to better understand land uses and
previous depths of disturbance as it relates to proposed ground disturbances. The review indicates the project
site remained undeveloped farmland until the late 1940s, and development within the project site was not
depicted in aerial images until 1952. Building permits indicate incremental development to the project site and
vicinity occurred from the 1950s through to the 1990s primarily along perimeter of the project site.
While past ground disturbance has significantly modified most areas with the potential to support
archaeological deposits within the project site, there remains some potential to encounter unknown
archaeological resources during construction in less developed areas during the course of project
construction. Management recommendations are provided in mitigation measure (MM) CUL-1 to reduce
potential impacts to unanticipated archaeological resources during construction activities. Therefore, with
incorporation of mitigation, potentially significant impacts to archaeological resources would be reduced to
a less-than-significant level.
MM-CUL-1 Inadvertent Discovery of Archaeological Resources. In the event that archaeological
resources (sites, features, or artifacts) are exposed during construction activities for 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.
c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
Less-than-Significant Impact. There is no indication that human remains are present within the
boundaries of the project site. Therefore, the likelihood of encountering human remains within the project
site is considered low. In the event human remains are inadvertently encountered dur ing construction
activities, impacts would be potentially significant. In accordance with Section 7050.5 of the California
Health and Safety Code, if human remains are found, the Los Angeles County Coroner shall be notified
within 24 hours of the discovery. No further excavation or disturbance of the site or any nearby area
reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined,
within two working days of notification of the discovery, the appropriate treatment and disposition of the
human remains. If the County Coroner determines that the remains are, or are believed to be, Native
American, they shall notify the Native American Heritage Commission in Sacramento within 48 hours. In
accordance with California Public Resources Code, Section 5097.98, the Native American Heritage
Exhibit F PC Agenda Page 128
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46 December 2020
Commission must immediately notify those persons it believes to be the Most Likely Descendant of the
deceased Native American. The Most Likely Descendent shall complete their inspection within 48 hours
of being granted access to the site. The designated Native American representative would then
determine, in consultation with the property owner, the disposition of the human remains. Compliance
with these requirements would ensure that human re mains, if discovered, are treated properly and that
significant effects to human remains would not occur in the event of an inadvertent discovery. Therefore,
with compliance with state law, impacts associated with human remains would be less than significant.
3.6 Energy
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VI. Energy – Would the project:
a) Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?
b) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation?
Less-than-Significant Impact. Implementation of the project would decrease the demand for electricity and
natural gas at the project site and an increase in petroleum consumption in the project area during
operation relative to existing uses. Detailed analysis is provided for the project below in the categories of
electricity consumption, natural gas consumption, and petroleum consumption.
Electricity
Construction Use
Temporary electric power for as-necessary lighting and electronic equipment would be provided by
Southern California Edison (SCE). The amount of electricity used during construction would be minimal, as
demand would primarily stem from use of electrically powered hand tools. The electricity used for
construction activities would be temporary and minimal; therefore, project construction would not result in
wasteful, inefficient, or unnecessary consumption of electricity. Impacts would be less than significant.
Operational Use
Project operation would require electricity for multiple purposes including, but not limited to, building
heating and cooling, lighting, appliances, and electronics. Additionally, the supply, conveyance, treatment,
Exhibit F PC Agenda Page 129
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47 December 2020
and distribution of water used by the project would indirectly result in electricity usage. CalEEMod was used
to estimate the electricity demand for the existing uses that have been demolished and for the project (see
Appendix B for calculations). Table 10 presents the net increase in electricity demand for the project.
Table 10. Estimated Annual Operational Energy Demand
Scenario kWh/Year
Existing Conditions
Buildings 490,189.00
Water/Wastewater 132,970.45
Total Existing Demand 623,168.45
Proposed Project
Buildings 286,401.00
Water/Wastewater 161,237.06
Total Project Demand 447,638.06
Net decrease in Electricity demand (project minus existing) -175,529.39
Source: Appendix B.
Notes: kWh = kilowatt-hour.
According to these estimations, the project would consume approximately 447,639 kilowatt-hours (kWh)
per year. The electricity consumption at the project site for the existing uses was also calculated using
CalEEMod and is estimated to be 623,168 kWh per year. As such, upon implementation of the project,
electricity demand and consumption at the project site would decrease by 175,529 kWh per year (Appendix
B). Electricity is supplied to the project site by SCE. Annual retail sales of electricity in SCE’s service area
are forecasted to be approximately 75 billion kWh in 2020 (CPUC 2018). The electricity consumption that
would be associated with the project represents approximately 0.0006% of SCE’s total forecasted electricity
sales in 2020. As such, the increase in electricity demand at the project site would be negligible relative to
the electricity use in SCE’s service area.
As described above, the electricity demand calculation for the project assumes compliance with Title 24
standards for 2019. Energy reductions from these measures were not accounted for in Table 10 in order
to provide a conservative estimate. As such, the project’s energy consumption could potentially be lower
than what is shown in Table 10.
In summary, electricity consumption would decrease at the project site due to the implementation of the
project and even without accounting for existing demand at the project, project electricity demand would
be minimal when compared to total demand in the region. The project would also comply with and
implement a variety of energy-efficiency measures, as described above, which would further reduce
operational electricity consumption. For these reasons, electricity consumption of the project would not be
considered inefficient or wasteful, and there would be no impact.
Exhibit F PC Agenda Page 130
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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48 December 2020
Natural Gas
Construction Use
Natural gas is not anticipated to be required during construction. Fuels used for construction would
primarily consist of diesel and gasoline, which are discussed under the subsection “Petroleum.” Any minor
amounts of natural gas that may be consumed as a result of project construction would be temporary and
negligible and would not have an adverse effect; therefore, construction would not result in wasteful,
inefficient, or unnecessary consumption of natural gas. Impacts would be less than significant.
Operational Use
Natural gas consumption during operation would be required for various purposes, including building
heating and cooling. CalEEMod was used to estimate electricity demand for the existing uses and for the
project (see Attachment A for calculations). Table 11 presents the net decrease in natural gas demand for
the project.
Table 11. Annual Operational Natural Gas Demand
Scenario kBTU/Year
Existing Uses 799,332
Proposed Project 121,909
Net decrease in Natural Gas Demand (Project minus Existing) -677,423
Source: Appendix B.
Notes: kBTU = thousand British thermal units.
According to these estimations, the project would consume approximately 121,909 thousand British
thermal units (kBTU) per year. The existing uses are estimated to consume 799,332 kBTU per year. As
such, upon implementation of the project, natural gas demand at the project site would decrease by
677,423 kBTU per year (Appendix B). The project’s natural gas demand is equivalent to 1,219 therms.
Natural gas is supplied to the project site by Southern California Gas Company (SoCalGas). In 2020, natural
gas demand is anticipated to be approximately 7,876 million therms per year in SoCalGas’ service area
(CEC 2017). Thus, the project’s expected demand represents approximately 0.00001% of SoCalGas’ 2020
demand. As such, the expected demand in natural gas consumption with the implementation of the project
is negligible compared to SoCalGas’ available supply.
As described above, the natural gas demand calculation for the project assumes compliance with Title 24
standards for 2019. However, this reduction was not accounted for in the modeling in order to provide a
conservative estimate. As such, the project’s natural gas use would be more efficient than what is required
and would likely be lower than the calculations presented above.
In summary, although natural gas usage would decrease due to the implementation of the project,
compared to existing conditions, the project would also comply with and implement a variety of energy-
efficiency measures, as described above, which would further reduce operational natural gas consumption.
For these reasons, the natural gas consumption of the project would not be considered inefficient or
wasteful, and there would be no impact.
Exhibit F PC Agenda Page 131
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49 December 2020
Petroleum
Construction Use
Petroleum would be consumed throughout construction. Fuel consumed by construction equipment would
be the primary energy resource expended over the course of construction. Transportation of construction
materials and construction workers would also result in petroleum consumption. Heavy-duty construction
equipment, vendor trucks, and haul trucks would use diesel fuel. Construction workers would likely travel
to and from the project area in gasoline-powered vehicles. Construction is expected to take approximately
11 months, beginning in 2021 and ending in 2022. Once construction activities cease, petroleum use from
off-road equipment and transportation vehicles would end. Because of the short-term nature of
construction and relatively small scale of the project, the project’s petroleum consumption would be
negligible when compared to California’s daily total use of approximately 1.8 million barrels of petroleum.
As such, construction would not result in wasteful, inefficient, or unnecessary consumption of petroleum,
and impacts would be less than significant.
Operational Use
During operations, the majority of fuel consumption resulting from the project would involve the use of
motor vehicles traveling to and from the project site, as well as fuels used for alternative modes of
transportation that may be used by employees and customers of the project.
Petroleum fuel consumption associated with motor vehicles traveling to and from the project site is a
function of the VMT as a result of project operation. The annual VMT attributable to the project is expected
to be 5,514,728 VMT (Appendix B). Under existing conditions at the project site, the land uses that have
been demolished are estimated to be associated with 4,301,115 VMT per year (Appendix B). Fuel estimates
for the project and existing uses are provided in Table 12.
Table 12. Annual Operational Petroleum Demand
Scenario
Vehicle
MT CO2
kg CO2/
Gallon Gallons
Existing Uses
Gasoline 625.87 8.78 71,283.60
Diesel 2,981.57 10.21 292,024.49
Total Existing Petroleum Use 363,308.08
Proposed Project
Gasoline 436.49 8.78 49,714.12
Diesel 5,433.30 10.21 532,154.75
Total Project Petroleum Use 581,868.87
Net Increase in Petroleum Demand (Project minus Existing) 218,560.79
Sources: Trips and vehicle CO2 (Appendix B); kg CO2/Gallon (The Climate Registry 2019).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
As depicted in Table 12, the project would consume approximately 581,869 gallons of petroleum per year
during operation and the existing uses are estimated to consume approximately 363,308 gallons of
Exhibit F PC Agenda Page 132
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50 December 2020
petroleum per year. As such, the project would lead to an annual net increase o f 218,561 gallons of
petroleum consumption. By comparison, approximately 28.7 billion gallons of petroleum are consumed in
California per year (EIA 2019). The anticipated increase in consumption associated with 1 year of project
operation is 0.0008% of the statewide use.
Over the lifetime of the project, the fuel efficiency of the vehicles being used by the customers and
employees of the project is expected to increase. As such, the amount of petroleum consumed as a result
of vehicular trips to and from the project site during operation would decrease over time. Additionally, there
are numerous regulations in place that require and encourage increased fuel efficiency. For example, CARB
has adopted an approach to passenger vehicles that combines the control of smog-causing pollutants and
GHG emissions into a single, coordinated package of standards. The approach also includes efforts to
support and accelerate the number of plug-in hybrids and zero-emissions vehicles in California (CARB
2011). As such, operation of the project is expected to use decreasing amounts of petroleum over time due
to advances in fuel economy.
In summary, although implementation of the project would result in an increase in petroleum use during
operation, over time, vehicles would use less petroleum due to advances in fuel economy. Furthermore,
when viewed on a regional scale, the project is an urban infill project located within a major population
center and would serve an existing demand, commercial services, and employment opportunities within
proximity to existing neighborhoods. When compared with new development projects sited on previously
undeveloped land and away from population centers, infill projects are generally expected to involve fewer
VMT during operation and may even help reduce regional VMT by locating residences, services, and jobs
within proximity to existing businesses and neighborhoods. Given these considerations, the petroleum
consumption associated with the project would not be considered inefficient or wasteful, and impacts would
be less than significant.
b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less-than-Significant Impact. The project would be subject to and would comply with, at a minimum, the
California Building Energy Efficiency Standards (24 CCR, Part 6). Part 6 of Title 24 establishes energy
efficiency standards for nonresidential buildings constructed in California to reduce energy demand and
consumption. As such, the project would comply with the California code requirements for energy efficiency.
Part 11 of Title 24 sets forth voluntary and mandatory energy measures that are applicable to the project
under the California Green Building Standards, also known as CALGreen. CALGreen institutes mandatory
minimum environmental performance standards for all ground-up, new construction of commercial, low-
rise residential, high-rise residential, state-owned buildings, schools, and hospitals, as well as certain
residential and nonresidential additions and alterations. On this basis, the project would not conflict with
or obstruct a state or local plan for renewable energy or energy efficiency.
Exhibit F PC Agenda Page 133
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51 December 2020
3.7 Geology and Soils
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the
loss of topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the project, and potentially result
in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?
d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property?
e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative 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?
Exhibit F PC Agenda Page 134
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52 December 2020
a) Would the project 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.
No Impact. According to the City’s General Plan Safety Element, no active faults have been
identified within the City. According to Figure 5.5-1, Regional Earthquake Fault Lines, in the General
Plan Safety Element, the closest faults in the broader project region include the Norwalk Fault,
Whittier Fault, Compton–Los Alamitos Fault, and Newport–Inglewood Fault. None of these faults
underlie either the City or the project site (City of Downey 2005). Thus, although the project could
experience strong seismic ground shaking (see Section 3.7(a)(ii)), the project site is not susceptible
to surface rupture. Therefore, no impacts associated with fault rupture would occur.
ii) Strong seismic ground shaking?
Less-than-Significant Impact. Similar to other areas located in the seismically active Southern
California region, the City is susceptible to ground shaking during an earthquake. However, as
addressed in Section 3.7(a)(i), the project site is not located within an active fault zone, and the
site would not be affected by ground shaking more than any other area in the seismically active
region. Additionally, as set forth in Article VIII of the City’s Municipal Code, the City has adopted the
current California Building Code. As such, the project would be designed in accordance with all
applicable design provisions established in the current 2019 edition of the California Building
Code, which dictates specifications to ensure structural integrity during a seismic event.
A Geotechnical Report was prepared to address potential seismic-related impacts. The report
addresses potential seismic-related impacts based on the particular characteristics of the on-site soils
(Appendix D). Primarily because of the liquefaction potential found throughout the City (see Section
3.7(a)(iii)), preparation of a geotechnical report is required for most development projects. Therefore,
with adherence to these requirements, as set forth in the General Plan and in the project Geotechnical
Report (Appendix D to this MND), impacts associated with strong seismic ground shaking would be less
than significant.
iii) Seismic-related ground failure, including liquefaction?
Less-than-Significant Impact. Liquefaction typically occurs when a site is subjected to strong seismic
shaking, on-site soils are less cohesive, and groundwater is encountered near the surface. The factors
known to influence liquefaction potential include soil type and grain size, relative density,
groundwater level, confining pressures, and intensity and duration of ground shaking. In general,
materials that are susceptible to liquefaction are loose, saturated granular soils that have low fines
content under low confining pressures.
Per the General Plan Safety Element, the City has the combination of silts and sands soil types and
a relatively high water table that are conducive to liquefaction occurring during intense ground
shaking (City of Downey 2005). The California Department of Conservation has designated all areas
Exhibit F PC Agenda Page 135
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53 December 2020
in the City a liquefaction hazard zone (DOC 2020). As such, a geotechnical/soils report would be
prepared to address potential seismic-related impacts based on the particular characteristics of
the on-site soils.
As described in the Geotechnical Report (Appendix D) prepared for the project, the near-surface
soils encountered within the project site generally consist of low- to moderate-strength fill and
native alluvium, and the groundwater in the vicinity of the project site was estimated to be 50± feet
below existing grade. Because of the depth to groundwater, the potential for seismic-related failure
is low, but in order to limit the potential for excessive settlement of building foundations, remedial
grading will be necessary to remove and replace the existing fill and a portion of the near-surface
alluvial soils with compacted structural fill for support of the shallow foundation system. Soils to be
exposed at finished grade are expected to exhibit a very low expansion potential. Additionally, the
Geotechnical Report specifies that remedial grading should also remove any soils disturbed during
demolition, prior to placement of any compacted materials. The presence of the recommended
layer of newly placed compacted structural fill above the liquefiable soils would help to re duce
surface manifestations that could occur as a result of liquefaction. Based on the soil conditions,
new retaining walls would be designed for the site, and the structural engineer would incorporate
appropriate factors of safety in the design of the retaining walls. Foundations to support new
retaining walls would be designed in accordance with the general Foundation Design Parameters
found within Appendix D. Therefore, with adherence to these requirements as set forth in the
Geotechnical Report (Appendix D), impacts associated with seismic-related ground failure,
including liquefaction, would be less than significant.
iv) Landslides?
No Impact. The project site and surrounding area are predominantly flat and lack any substantial
topographical variations. No hillsides are located on or adjacent to the project site. Therefore, no
impacts associated with landslides would occur.
b) Would the project result in substantial soil erosion or the loss of topsoil?
Short-Term Construction Impacts
Less-than-Significant Impact. The project would include the demolition of an existing, 74,662 -square-
foot industrial building and constr uction of an approximately 44,162 -square-foot industrial building for
truck terminal use. The project site is located in an area that has been substantially altered by prior grading
and construction. Demolition and excavation would result in temporary soil disturbance. Common causes
of soil erosion from construction sites include stormwater, wind, and soil being tracked off site by vehicles.
However, construction activities would comply with all applicable state and local regulations for erosion
control. The project would be required to comply with standard regulations, including SCAQMD Rules 402
and 403, which would reduce construction erosion impacts. Rule 403 requires that fugitive dust be
controlled with best available control measures so that it does not remain visible in the atmosphere beyond
the property line of the emissions source (SCAQMD 2005). Rule 402 requires dust suppression techniques
be implemented to prevent dust and soil erosion from creating a nuisance off site (SCAQMD 1976).
Exhibit F PC Agenda Page 136
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54 December 2020
Additionally, the project site is larger than 1 acre and would be subject to NPDES Construction General
Permit requirements; thus, construction activities would be required to incorporate various temporary BMPs
designed to prevent erosion and siltation during construction. Therefore, with adherence to these regulatory
requirements, short-term demolition and construction impacts associated with soil erosion and topsoil loss
would be less than significant.
Long-Term Operational Impacts
Less-than-Significant Impact. Upon completion of construction, the project site would return to similar
existing conditions. Thus, there would be no exposure of soils on site such that substantial soil erosion or
loss of topsoil would occur. Therefore, long-term operational impacts would be less than significant.
c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as
a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence,
liquefaction or collapse?
Less-than-Significant Impact. According to the City’s General Plan Safety Element, the City has a
combination of silts and sands soil types (City of Downey 2005). The project site is underlain by Urban land-
Hueneme, drained-San Emigdio complex, which is described as discontinuous human-transported material
over mixed alluvium derived from granite and/or sedimentary rock (USDA 2020).
As addressed in Section 3.7(a)(iii), all areas in the City have been identified as being located in a
liquefaction hazard zone. As such, a geotechnical/soils report was prepared to address potential seismic-
related impacts, based on the particular characteristics of the on-site soils. In general, the report addresses
all potential seismic-related effects and includes design specifications to which construction of the project
would be required to adhere in order to reduce any potential liquefaction impacts. Refer to response
3.7(a)(iii) for further details. Additionally, as discussed in the Geotechnical Report, minor ground
subsidence is expected to occur in the soil below the layer of removed soil; however, any subsidence would
be within acceptable parameters and would not pose a structural threat (Appendix D). Notwithstanding,
adherence to the requirements and recommendations set forth in the Geotechnical Report would ensure
that impacts associated with potentially unstable soils would be less than significant.
Furthermore, as previously mentioned in 3.7(a)(iv), the City has relatively flat topography and is not known
to have any landslide zones. Therefore, impacts associated with unstable geologic units or soils would be
less than significant.
d) Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect risks to life or property?
Less-than-Significant Impact. Expansive soils are characterized by their potential “shrink/swell” behavior.
Shrink/swell is the cyclic change in volume (expansion and contraction) that occurs in certain fine -grained
clay sediments from the process of wetting and drying. Clay minerals such as smectite, bentonite,
montmorillonite, beidellite, vermiculite, and others are known to expand with changes in moisture content.
The higher the percentage of expansive minerals present in near-surface soils, the higher the potential for
substantial expansion.
Exhibit F PC Agenda Page 137
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55 December 2020
The project site is underlain by Urban land-Hueneme, drained-San Emigdio complex, which is described as
discontinuous human-transported material over mixed alluvium derived from granite and/or sedimentary
rock. As described in the Geotechnical Report, the near-surface soils have very low expansion potential
(Appendix D). Therefore, impacts associated with expansive soil would be less than significant.
e) Would the project 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?
No Impact. The project would connect to the existing municipal sewer system and would not require a septic
or alternative wastewater disposal system. Therefore, no impacts associated with the ability of soils to
support septic tanks would occur.
f) Would the project directly or indirectly destroy a unique paleontological resource or site or unique
geologic feature?
Less-than-Significant Impact with Mitigation Incorporated. A significant impact may occur if grading or
excavation activities would disturb paleontological resources within the project site. The project site has
been previously graded and consists of disturbed, paved land. Previous on-site development activities
affected the entirety of the project site, and as such, it follows that any paleontological resources that may
have once been located on the project site could have been previously disturbed. Furthermore, according
to the U.S. Department of Agriculture’s Web Soil Survey, the project site is underlain by Urban land-
Hueneme, drained-San Emigdio complex, which is described as discontinuous human-transported material
over mixed alluvium derived from granite and/or sedimentary rock (USDA 2020). Human-transported fill
materials generally do not contain significant paleontological resources on or very near the surface
immediately underlying the project site. Additionally, the soils underlying areas of artificial fill are Holocene-
age (less than 10,000 years old) alluvium which do not typically contain vertebrate fossils. However, the
possibility of a paleontological discovery cannot be discounted. Accordingly, destruction of paleontological
resources or unique geologic features during site-disturbing activities associated with construction of the
proposed project is considered a potential significant impact. Therefore, MM-GEO-1 is provided and would
be implemented to ensure potential impacts during construction activities to paleontological resources or
unique geologic features are reduced to a less-than-significant level.
MM-GEO-1 In the event that paleontological resources (fossil remains) are exposed during construction
activities for the proposed project, all construction work occurring within 50 feet of the find
shall immediately stop until a qualified paleontologist, as defined by the Society of Vertebrate
Paleontology’s 2010 guidelines, can assess the nature and importance of the find. Depending
on the significance of the find, the paleontologist may record the find and allow work to
continue or recommend salvage and recovery of the resource. All recommendations will be
made in accordance with the Society of Vertebrate Paleontology’s 2010 guidelines and shall
be subject to review and approval by the City of Downey. Work in the area of the find may only
resume upon approval of a qualified paleontologist.
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3.8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?
a) Would the project g enerate greenhouse gas emissions, either directly or indirectly, that may have a
significant impact on the environment?
Less-than-Significant Impact. Climate change refers to any significant change in measures of climate (e.g.,
temperature, precipitation, or wind patterns) lasting for an extended period of time (i.e., decades or longer).
The Earth’s temperature depends on the balance between energy entering and leaving the planet’s system,
and many factors (natural and human) can cause changes in Earth’s energy balance. The greenhouse effect
is the trapping and buildup of heat in the atmosphere near the Earth’s surface (the troposphere). The
greenhouse effect is a natural process that contributes to regulating the Earth’s temperature, and it creates
a livable environment on Earth. Human activities that emit additional GHGs to the atmosphere increase the
amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the
greenhouse effect and causing the Earth’s surface temperature to rise. Global climate change is a
cumulative impact; a project contributes to this impact through its incremental contribution combined with
the cumulative increase of all other sources of GHGs. Thus, GHG impacts are recognized exclusively as
cumulative impacts (CAPCOA 2008).
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the
atmosphere. As defined in California Health and Safety Code Section 38505(g) for purposes of administering
many of the state’s primary GHG emissions reduction programs, GHGs include CO2, methane (CH4), nitrous
oxide (N2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride (see also CEQA
Guidelines Section 15364.5).16 The three GHGs evaluated herein are CO2, CH4, and N2O because these gases
would be emitted during project construction and operation.
The Intergovernmental Panel on Climate Change developed the global warming potential (GWP) concept to
compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The reference gas
used is CO2; therefore, GWP-weighted emissions are measured in metric tons (MT) of CO2 equivalent (CO2e).
16 Climate-forcing substances include greenhouse gases (GHGs) and other substances such as black carbon and aerosols. This
discussion focuses on the seven GHGs identified in the California Health and Safety Code Section 38505; impacts associated
with other climate-forcing substances are not evaluated herein.
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Consistent with CalEEMod Version 2016.3.2, this GHG emissions analysis assumed the GWP for CH4 is 25
(i.e., emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO2), and the GWP for N2O is 298,
based on the Intergovernmental Panel on Climate Change’s Fourth Assessment Report (IPCC 2007).
As discussed in Section 3.3, Air Quality, the project is located within SCAQMD jurisdictional boundaries. In
October 2008, the SCAQMD proposed recommended numeric CEQA significance thresholds for GHG
emissions for lead agencies to use in assessing GHG impacts of residential and commercial development
projects as presented in its Draft Guidance Document—Interim CEQA Greenhouse Gas (GHG) Significance
Threshold (SCAQMD 2008b). This document, which builds on the previous guidance prepared by the
California Air Pollution Control Officers Association, explored various approaches for establishing a
significance threshold for GHG emissions. The draft interim CEQA thresholds guidance document was not
adopted or approved by the Governing Board. However, in December 2008, the SCAQMD adopted an
interim 10,000 MT CO2e per-year screening level threshold for stationary source/industrial projects for
which the SCAQMD is the lead agency (SCAQMD 2008c). The 10,000 MT CO 2e per-year threshold, which
was derived from GHG reduction targets established in Executive Order (EO) S-3-05, was based on the
conclusion that the threshold was consistent with achieving an emissions capture rate of 90% of all new or
modified stationary source projects.
The SCAQMD formed a GHG CEQA Significance Threshold Working Group to work with SCAQMD staff on
developing GHG CEQA significance thresholds until statewide significance thresholds or guidelines are
established. From December 2008 to September 2010, the SCAQMD hosted working group meetings and
revised the draft threshold proposal several times, although it did not officially provide these proposals in
a subsequent document. The SCAQMD has continued to consider adoption of significance thresholds for
residential and general land-use development projects. The most recent proposal issued by SCAQMD,
issued in September 2010, uses the following tiered approach to evaluate potential GHG impacts from
various uses (SCAQMD 2010):
Tier 1. Determine if CEQA categorical exemptions are applicable. If not, move to Tier 2.
Tier 2. Consider whether or not the project is consistent with a locally adopted GHG reduction plan that
has gone through public hearing and CEQA review, that has an approved inventory, includes
monitoring, etc. If not, move to Tier 3.
Tier 3. Consider whether the project generates GHG emissions in excess of screening thresholds for
individual land uses. The 10,000 MT CO2e per-year threshold for industrial uses would be
recommended for use by all lead agencies. Under option 1, separate screening thresholds are
proposed for residential projects (3,500 MT CO2e per year), commercial projects (1,400 MT CO2e
per year), and mixed-use projects (3,000 MT CO2e per year). Under option 2, a single numerical
screening threshold of 3,000 MT CO2e per year would be used for all non-industrial projects. If the
project generates emissions in excess of the applicable screening threshold, move to Tier 4.
Tier 4. Consider whether the project generates GHG emissions in excess of applicable performance
standards for the project service population (population plus employment). The efficiency targets
were established based on the goal of AB [Assembly Bill] 32 to reduce statewide GHG emissions
to 1990 levels by 2020. The 2020 efficiency targets are 4.8 MT CO 2e per-service population for
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project-level analyses and 6.6 MT CO2e per-service population for plan-level analyses. If the project
generates emissions in excess of the applicable efficiency targets, move to Tier 5.
Tier 5. Consider the implementation of CEQA mitigation (including the purchase of GHG offsets) to reduce
the project efficiency target to Tier 4 levels.
To determine the project’s potential to generate GHG emissions that would have a significant impact on
the environment, its GHG emissions were compared to the SCAQMD recommended quantitative threshold
of 3,000 MT CO2e per year.
Construction Greenhouse Gas Emissions
Construction of the project would result in GHG emissions, which are primarily associated with the use of
off-road construction equipment, on-road haul and vendor trucks, and worker vehicles. The SCAQMD Draft
Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold (SCAQMD 2008b)
recommends that “construction emissions be amortized over a 30-year project lifetime, so that GHG
reduction measures will address construction GHG emissions as part of the operational GHG reduction
strategies.” Thus, the total construction GHG emissions were calculated, amortized over 30 years, and
added to the total operational emissions for comparison with the GHG significance threshold of 3,000 MT
CO2e per year. The determination of significance, therefore, is addressed in the operational emissions
discussion following the estimated construction emissions.
CalEEMod was used to calculate the annual GHG emissions based on the construction scenario described in
Section 3.3. Construction of the project is anticipated to commence in March 2021, lasting a total of 11
months and reaching completion in January 2022. On-site sources of GHG emissions include off-road
equipment and off-site sources include haul trucks, vendor trucks, and worker vehicles. Table 13 presents
construction GHG emissions for the project from on-site and off-site emission sources.
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Table 13. Estimated Annual Construction Greenhouse Gas Emissions
Year
CO2 CH4 N2O CO2e
Metric Tons per Year
2021 383.26 0.09 0.00 385.51
2022 24.79 <0.01 0.00 24.96
Total 410.47
Amortized Emissions (over 30 years) 13.68
Source: Appendix B.
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
As shown in Table 13, the estimated total GHG emissions during construction of the project would be
approximately 410 MT CO2e. Estimated project-generated construction emissions amortized over 30 years
would be approximately 14 MT CO2e per year. As with project-generated construction air quality pollutant
emissions, GHG emissions generated during construction of the project would be short-term in nature,
lasting only for the duration of the construction period, and would not represent a long-term source of GHG
emissions. Because there is no separate GHG threshold for construction, the evaluation of significance is
discussed in the operational emissions analysis in the following text.
Operational Greenhouse Gas Emissions
CalEEMod Version 2016.3.2 was used to estimate potential project-generated operational GHG emissions
from area sources (landscape maintenance), natural gas combustion, electrical generation, water supply and
wastewater treatment, solid waste, and off-road equipment (electric forklifts). As with the air quality analysis,
mobile source GHG emissions were estimated using a spreadsheet model based on EMFAC2017 emission
factors. Emissions from each category—area sources, energy sources, mobile sources, solid waste, water
supply and wastewater treatment, and off-road equipment—are discussed in the following text with respect to
the project. For additional details, see Section 3.3 for a discussion of operational emission calculation
methodology and assumptions, specifically for area, energy (natural gas), and mobile sources. Operational
year 2022 was assumed to be the first full year of operation following completion of construction.
Area Sources
CalEEMod was used to estimate GHG emissions from the project’s area sources, including operation of
gasoline-powered landscape maintenance equipment, which produce minimal GHG emissions. It was
assumed that 100% of the landscaping equipment would be gasoline powered. Consumer product use and
architectural coatings result in VOC emissions, which are analyzed in air quality analysis only, and low to no
GHG emissions.
Energy Sources
The estimation of operational energy emissions was based on CalEEMod land use defaults and units or
total area (i.e., square footage) of the project’s land uses. For nonresidential buildings, CalEEMod energy
intensity value (electricity or natural gas usage per square foot per year) assumptions were based on the
California Commercial End-Use Survey database. Emissions are calculated by multiplying the energy use by
the utility carbon intensity (pounds of GHGs per kilowatt-hour for electricity or 1,000 British thermal units
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[kBTU] for natural gas) for CO2 and other GHGs. Annual natural gas (non-hearth) and electricity emissions
were estimated in CalEEMod using the emissions factors for SCE, which would be the energy source
provider for the project. CalEEMod default energy intensity factors (CO2, CH4, and N2O mass emissions per
kilowatt-hour) for SCE is based on the value for SCE’s energy mix. SB X1 2 established a target of 33% from
renewable energy sources for all electricity providers in California by 2020, and SB 350 calls for further
development of renewable energy, with a target of 50% by 2030. The CO2 emissions intensity factor for
utility energy use in CalEEMod was adjusted consistent with SCE’s 2018 Corporate Sustainability Report
Mobile Sources
All details for criteria air pollutants discussed in Section 3.3 are also applicable for the estimation of
operational mobile source GHG emissions. It was assumed that the warehouse would operate 7 days per
week; therefore, 365 days of vehicle emissions were assumed. Regulatory measures related to mobile
sources include AB 1493 (Pavley) and related federal standards. AB 1493 required that CARB establish
GHG emission standards for automobiles, light-duty trucks, and other vehicles determined by CARB to be
vehicles that are primarily used for noncommercial personal transportation in the state. In addition, the
National Highway Traffic Safety Administration and EPA have established corporate fuel economy standards
and GHG emission standards, respectively, for automobiles and light -, medium-, and heavy-duty vehicles.
Implementation of these standards and fleet turnover (replacement of older vehicles with newer ones) will
gradually reduce emissions from the project’s motor vehicles. The effectiveness of fuel economy
improvements was evaluated to the extent it was captured in the EMFAC2017 emission factors for motor
vehicles in 2022.
Solid Waste
The project would generate solid waste and therefore, would result in CO2e emissions associated with
landfill off-gassing. CalEEMod default values for solid waste generation were used to estimate GHG
emissions associated with solid waste.
Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the project require the use of electricity, which
would result in associated indirect GHG emissions. Similarly, wastewater generated by the project requires
the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater
treatment. Water consumption estimates for both indoor and outdoor water use and associated electricity
consumption from water use and wastewater generation were estimated using CalEEMod default values.
Off-Road Equipment
As explained in Section 3.3, while the exact operational off-road equipment is unknown at this time, it was
conservatively assumed that four electric-operated forklifts would operate for 8 hours per day at the project site.
The estimated operational (year 2022) project-generated GHG emissions from area sources, energy usage,
motor vehicles, solid waste generation, water usage and wastewater generation, and off -road equipment
are shown in Table 14.
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Table 14. Estimated Annual Operational Greenhouse Gas Emissions
Emission Source
CO2 CH4 N2O CO2e
metric tons per year
Baseline
Area <0.01 <0.01 <0.01 <0.01
Energy 198.84 0.01 <0.01 199.66
Mobile 3,575.26 0.39 0.08 3,607.44
Solid waste 11.12 0.66 0.00 27.54
Water supply and wastewater 45.61 0.33 0.01 56.42
Baseline Total 3,891.06
Project
Area <0.01 <0.01 <0.01 <0.01
Energy 80.06 <0.01 <0.01 80.37
Mobile 5,831.08 0.70 0.8 5,869.80
Solid waste 194.08 0.06 0.00 195.65
Water supply and wastewater 9.94 0.59 0.00 24.63
Off-road equipment 45.10 0.38 0.01 57.40
Project Total 6,227.85
Net Total 2,336.79
Amortized Construction Emissions 13.68
Operation + Amortized Construction Total 2,350.47
Source: Appendix B.
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
As shown in Table 14, estimated annual net-generated GHG emissions would be approximately 2,337 MT CO2e
per year as a result of project operation minus the existing baseline. Estimated net annual project-generated
operational emissions in 2022 and amortized project construction emissions of approximately 14 MT CO2e per
year would be approximately 2,350 MT CO2e per year. Net annual operational GHG emissions with amortized
construction emissions would not exceed the SCAQMD recommended threshold of 3,000 MT CO2e per year.
b) Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing
the emissions of greenhouse gases?
Less-than-Significant Impact. The project would not conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions of greenhouse gases, as evaluated below.
Consistency with California Air Resources Board’s Scoping Plan
The Scoping Plan (approved by CARB in 2008 and updated in 2014 and 2017) provides a framework for
actions to reduce California’s GHG emissions and requires CARB and other state agencies to adopt
regulations and other initiatives to reduce GHGs. The Scoping Plan is not directly applicable to specific
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projects, nor is it intended to be used for project-level evaluations.17 Under the Scoping Plan, however,
there are several state regulatory measures aimed at the identification and reduction of GHG emissions.
CARB and other state agencies have adopted many of the measures identified in the Scoping Plan. Most
of these measures focus on area source emissions (e.g., energy usage, high -GWP GHGs in consumer
products) and changes to the vehicle fleet (i.e., hybrid, electric, and more fuel-efficient vehicles) and
associated fuels (e.g., Low Carbon Fuel Standard), among others.
The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB
32 and establishes an overall framework for the measures that will be adopted to reduce California’s GHG
emissions. Table 15 highlights measures that have been, or will be, developed under the Scoping Plan and
presents the project’s consistency with Scoping Plan measures. The project would comply with all
regulations adopted in furtherance of the Scoping Plan to the extent required by law and to the extent that
they are applicable to the project.
Table 15. Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Transportation Sector
Advanced Clean Cars T-1 Consistent. The project’s employees would purchase
vehicles in compliance with CARB vehicle standards
that are in effect at the time of vehicle purchase.
Low Carbon Fuel Standard T-2 Consistent. This is a statewide measure that cannot be
implemented by a project applicant or lead agency.
Nonetheless, this standard would be applicable to the
fuel used by vehicles that would access the project site
(i.e., motor vehicles driven by the project’s employees
would use compliant fuels).
Regional Transportation-Related GHG
Targets
T-3 Not applicable. The project is not related to developing
GHG emission reduction targets. To meet the goals of
SB 375, the 2016–2040 RTP/SCS is applicable to the
project. The project would not preclude the
implementation of this strategy.
Advanced Clean Transit NA Not applicable. The project would not prevent CARB
from implementing this measure.
Last-Mile Delivery NA Not applicable. The project would not prevent CARB
from implementing this measure.
Reduction in VMT NA Not applicable. The project would not prevent CARB
from implementing this measure.
Vehicle Efficiency Measures
1. Tire Pressure
2. Fuel Efficiency Tire Program
3. Low-Friction Oil
T-4 Consistent. These standards would be applicable to
the light-duty vehicles that would access the project
site. Motor vehicles driven by the project’s employees
would maintain proper tire pressure when their
vehicles are serviced. The project’s employees would
17 The Final Statement of Reasons for the amendments to the CEQA Guidelines reiterates the statement in the Initial Statement of
Reasons that “[t]he Scoping Plan may not be appropriate for use in determining the significance of individual projects becaus e it
is conceptual at this stage and relies on the future development of regulations to implement the str ategies identified in the
Scoping Plan” (CNRA 2009).
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Table 15. Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
4. Solar-Reflective Automotive Paint
and Window Glazing
replace tires in compliance with CARB vehicle
standards that are in effect at the time of vehicle
purchase. Motor vehicles driven by the project’s
employees would use low-friction oils when their
vehicles are serviced. The project’s employees would
purchase vehicles in compliance with CARB vehicle
standards that are in effect at the time of vehicle
purchase. In addition, the project would not prevent
CARB from implementing this measure.
Ship Electrification at Ports (Shore
Power)
T-5 Not applicable. The project would not prevent CARB
from implementing this measure.
Goods Movement Efficiency Measures
1. Port Drayage Trucks
2. Transport Refrigeration Units Cold
Storage Prohibition
3. Cargo Handling Equipment, Anti-
Idling, Hybrid, Electrification
4. Goods Movement Systemwide
Efficiency Improvements
5. Commercial Harbor Craft
Maintenance and Design
Efficiency
6. Clean Ships
7. Vessel Speed Reduction
T-6 Not applicable. The project would not prevent CARB
from implementing this measure.
Heavy-Duty Vehicle GHG Emission
Reduction
• Tractor-Trailer GHG Regulation
• Heavy-Duty Greenhouse Gas
Standards for New Vehicle and
Engines (Phase I)
T-7 Consistent. Heavy-duty vehicles would be required to
comply with CARB GHG reduction measures. In
addition, the project would not prevent CARB from
implementing this measure.
Medium- and Heavy-Duty Vehicle
Hybridization Voucher Incentive Project
T-8 Consistent. The project medium- and heavy-duty
vehicles (e.g., delivery trucks) could take advantage of
the vehicle hybridization action, which would reduce
GHG emissions through increased fuel efficiency. In
addition, the project would not prevent CARB from
implementing this measure.
Medium and Heavy-Duty GHG Phase 2 NA Not applicable. The project would not prevent CARB
from implementing this measure.
High-Speed Rail T-9 Not applicable. The project would not prevent CARB
from implementing this measure.
Electricity and Natural Gas Sector
Energy Efficiency Measures (Electricity) E-1 Consistent. The project would comply with the current
Title 24 Building Energy Efficiency Standards. In
addition, the project would not prevent CARB from
implementing this measure.
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Table 15. Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Energy Efficiency (Natural Gas) CR-1 Consistent. The project would comply with the current
Title 24 Building Energy Efficiency Standards. In
addition, the project would not prevent CARB from
implementing this measure.
Solar Water Heating (California Solar
Initiative Thermal Program)
CR-2 Consistent. The project is not anticipated to require
substantial amounts of hot water to make solar water
heating feasible. Nonetheless, the project would
include solar water heating if necessitated and
feasible.
Combined Heat and Power E-2 Not applicable. The project would not prevent CARB
from implementing this measure.
Renewables Portfolio Standard (33%
by 2020)
E-3 Consistent. The electricity used by the project would
benefit from reduced GHG emissions resulting from
increased use of renewable energy sources.
Renewables Portfolio Standard (50%
by 2050)
NA Consistent. The electricity used by the project would
benefit from reduced GHG emissions resulting from
increased use of renewable energy sources.
SB 1 Million Solar Roofs
(California Solar Initiative, New Solar
Home Partnership, Public Utility
Programs) and Earlier Solar Programs
E-4 Not applicable. The project would not prevent CARB
from implementing this measure.
Water Sector
Water Use Efficiency W-1 Not applicable. The project would not prevent CARB
from implementing this measure.
Water Recycling W-2 Not applicable. The project would not prevent CARB
from implementing this measure.
Water System Energy Efficiency W-3 Not applicable. This is applicable for the transmission
and treatment of water, but it is not applicable for the
project. The project would not prevent CARB from
implementing this measure.
Reuse Urban Runoff W-4 Not applicable. The project would not prevent CARB
from implementing this measure.
Renewable Energy Production W-5 Not applicable. Applicable for wastewater treatment
systems. In addition, the project would not prevent
CARB from implementing this measure.
Green Buildings
State Green Building Initiative: Leading
the Way with State Buildings (Greening
New and Existing State Buildings)
GB-1 Consistent. The project would be required to be
constructed in compliance with state or local green
building standards in effect at the time of building
construction.
Green Building Standards Code
(Greening New Public Schools,
Residential and Commercial Buildings)
GB-1 Consistent. The project’s buildings would meet green
building standards that are in effect at the time of
design and construction.
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Table 15. Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Beyond Code: Voluntary Programs at
the Local Level (Greening New Public
Schools, Residential and Commercial
Buildings)
GB-1 Consistent. The project’s buildings would meet green
building standards that are in effect at the time of
design and construction.
Greening Existing Buildings (Greening
Existing Homes and Commercial
Buildings)
GB-1 Consistent. This is applicable for existing buildings
only; it is not applicable for portions of the project
except as future standards may become applicable to
existing buildings. For project building that would be
retrofitted, the buildings would meet current applicable
building standards at the time of design and
construction.
Industry Sector
Energy Efficiency and Co-Benefits
Audits for Large Industrial Sources
I-1 Not applicable. The project would not prevent CARB
from implementing this measure.
Oil and Gas Extraction GHG Emission
Reduction
I-2 Not applicable. The project would not prevent CARB
from implementing this measure.
Reduce GHG Emissions by 20% in Oil
Refinery Sector
NA Not applicable. The project would not prevent CARB
from implementing this measure.
GHG Emissions Reduction from Natural
Gas Transmission and Distribution
I-3 Not applicable. The project would not prevent CARB
from implementing this measure.
Refinery Flare Recovery Process
Improvements
I-4 Not applicable. The project would not prevent CARB
from implementing this measure.
Work with the Local Air Districts to
Evaluate Amendments to Their Existing
Leak Detection and Repair Rules for
Industrial Facilities to Include Methane
Leaks
I-5 Not applicable. The project would not prevent CARB
from implementing this measure.
Recycling and Waste Management Sector
Landfill Methane Control Measure RW-1 Not applicable. The project would not prevent CARB
from implementing this measure.
Increasing the Efficiency of Landfill
Methane Capture
RW-2 Not applicable. The project would not prevent CARB
from implementing this measure.
Mandatory Commercial Recycling RW-3 Consistent. During both construction and operation of
the project, the project would comply with all state
regulations related to solid waste generation, storage,
and disposal, including the California Integrated Waste
Management Act, as amended.
Increase Production and Markets for
Compost and Other Organics
RW-3 Not applicable. The project would not prevent CARB
from implementing this measure.
Anaerobic/Aerobic Digestion RW-3 Not applicable. The project would not prevent CARB
from implementing this measure.
Extended Producer Responsibility RW-3 Not applicable. The project would not prevent CARB
from implementing this measure.
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Table 15. Project Consistency with Scoping Plan Greenhouse Gas Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Environmentally Preferable Purchasing RW-3 Not applicable. The project would not prevent CARB
from implementing this measure.
Forests Sector
Sustainable Forest Target F-1 Not applicable. The project would not prevent CARB
from implementing this measure.
High GWP Gases Sector
Motor Vehicle Air Conditioning
Systems: Reduction of Refrigerant
Emissions from Non-Professional
Servicing
H-1 Consistent. The project’s employees would be
prohibited from performing air conditioning repairs and
would be required to use professional servicing.
SF6 Limits in Non-Utility and Non-
Semiconductor Applications
H-2 Not applicable. The project would not prevent CARB
from implementing this measure.
Reduction of Perfluorocarbons (PFCs)
in Semiconductor Manufacturing
H-3 Not applicable. The project would not prevent CARB
from implementing this measure.
Limit High GWP Use in Consumer
Products
H-4 Consistent. The project’s employees would use
consumer products that would comply with the
regulations that are in effect at the time of
manufacture.
Air Conditioning Refrigerant Leak Test
During Vehicle Smog Check
H-5 Consistent. Motor vehicles driven by the project’s
employees would comply with the leak test
requirements during smog checks.
Stationary Equipment Refrigerant
Management Program – Refrigerant
Tracking/Reporting/Repair Program
H-6 Not applicable. The project would not prevent CARB
from implementing this measure.
Stationary Equipment Refrigerant
Management Program – Specifications
for Commercial and Industrial
Refrigeration
H-6 Not applicable. The project would not prevent CARB
from implementing this measure.
SF6 Leak Reduction Gas Insulated
Switchgear
H-6 Not applicable. The project would not prevent CARB
from implementing this measure.
40% Reduction in Methane and
Hydrofluorocarbon (HFC) Emissions
NA Not applicable. The project would not prevent CARB
from implementing this measure.
50% Reduction in Black Carbon
Emissions
NA Not applicable. The project would not prevent CARB
from implementing this measure.
Agriculture Sector
Methane Capture at Large Dairies A-1 Not applicable. The project would not prevent CARB
from implementing this measure.
Notes: CARB = California Air Resources Board; GHG = greenhouse gas; SB = Senate Bill; RTP = Regional Transportation Plan; SCS = Sustainable
Communities Strategy; VMT = vehicle miles traveled; NA = not applicable; SF6 = sulfur hexafluoride; GWP = global warming potential.
Consistency with SCAG Connect SoCal
On September 3, 2020, the Southern California Association of Governments (SCAG) Regional Council
adopted the Connect SoCal Plan, the 2020-2045 RTP/SCS. Connect SoCal is a long-range visioning plan
Exhibit F PC Agenda Page 149
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that balances future mobility and housing needs with economic, environmental, and public health goals.
Connect SoCal charts a path toward a more mobile, sustainable , and prosperous region by making
connections between transportation networks, planning strategies, and the people whose collaboration can
improve the quality of life for Southern Californians. Connect SoCal embodies a collective vision for the
region’s future and is developed with input from local governments, county transportation commissions,
tribal governments, nonprofit organizations, businesses, and local stakeholders within the counties of
Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura.
Because the project is not growth inducing, this type of consistency analysis does not apply. However, the
major goals of the Connect SoCal are outlined in Table 16, along with the project’s consistency with them.
Table 16. Project Consistency with the SCAG Connect SoCal RTP/SCS
RTP/SCS Measure Proposed Project Consistency
Encourage regional economic prosperity and
global competitiveness.
Not applicable. The project would not inhibit SCAG from
encouraging regional economic prosperity and global
competitiveness.
Improve mobility, accessibility, reliability, and
travel safety for people and goods.
Not applicable. The project would not inhibit SCAG from
strengthening the regional transportation network for goods
movement.
Enhance the preservation, security, and
resilience of the regional transportation
system.
Not applicable. The project would not inhibit SCAG from
enhancing the resilience of the regional transportation system.
Increase person and goods movement and
travel choices within the transportation
system.
Not applicable. The project would not inhibit SCAG from
increasing person and goods movement and travel choices
within the transportation system.
Reduce greenhouse gas emissions and
improve air quality.
Consistent. The project would result in criteria air pollutant and
GHG emissions during construction and operation. However,
the project would not exceed the SCAQMD mass daily
significance thresholds during construction and operation.
Support healthy and equitable communities. Not applicable. The project would not inhibit SCAG from
supporting healthy and equitable communities.
Adapt to a changing climate and support an
integrated regional development pattern and
transportation network.
Not applicable. The project would not inhibit SCAG from
adapting to a changing climate and support an integrated
regional development pattern and transportation network.
Leverage new transportation technologies
and data-driven solutions that result in more
efficient travel.
Not applicable. The project would not inhibit SCAG from
leveraging technology for the transportation system.
Encourage development of diverse housing
types in areas that are supported by multiple
transportation options.
Not applicable. The project does not include housing and would
not inhibit SCAG from encouraging development of diverse
housing types.
Promote conservation of natural and
agricultural lands and restoration of habitats.
No conflict. The project would not impact natural lands during
construction or operation.
Source: SCAG 2020.
As shown in Table 16, the project would be consistent with all applicable measures in the SCAG Connect
SoCal RTP/SCS.
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Consistency with Executive Order S-3-05 and Senate Bill 32
• EO S-3-05. This EO establishes the following goals: GHG emissions should be reduced to 2000
levels by 2010, to 1990 levels by 2020, and to 80% below 1990 levels by 2050.
• SB 32. This bill establishes for a statewide GHG emissions reduction target whereby CARB, in
adopting rules and regulations to achieve the maximum technologically feasible and cost-effective
GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40%
below 1990 levels by December 31, 2030.
This section evaluates whether the GHG emissions tra jectory after project completion would impede the
attainment of the 2030 and 2050 GHG reduction goals identified in EO B-30-15 and EO S-3-05.
To begin, CARB has expressed optimism with regard to both the 2030 and 2050 goals. It states in the First
Update to the Climate Change Scoping Plan that “California is on track to meet the near -term 2020 GHG
emissions limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB
32” (CARB 2014, p. ES2). With regard to the 2050 target for reducing GHG emissions to 80% below 1990
levels, the First Update to the Climate Change Scoping Plan states the following (CARB 2014, p. 34):
This level of reduction is achievable in California. In fact, if California realizes the expected
benefits of existing policy goals (such as 12,000 megawatts of renewable distributed
generation by 2020, net zero energy homes after 2020, existing building retrofits under
AB 758, and others) it could reduce emissions by 2030 to levels squarely in line with those
needed in the developed world and to stay on track to reduce emissions to 80% below
1990 levels by 2050. Additional measures, including locally driven measures and those
necessary to meet federal air quality standards in 2032, could lead to even greater
emission reductions.
In other words, CARB believes that the state is on a trajectory to meet the 2030 and 2050 GHG reduction
targets set forth in AB 32, EO B-30-15, and EO S-3-05. This is confirmed in the 2017 Scoping Plan, which
states (CARB 2017):
The Scoping Plan builds upon the successful framework established by the Initial Scoping Plan
and First Update, while identifying new, technologically feasible and cost-effective strategies to
ensure that California meets its GHG reduction targets in a way that promotes and rewards
innovation, continues to foster economic growth, and delivers improvements to the
environment and public health, including in disadvantaged communities.
The project would not interfere with implementation of any of the above-described GHG reduction goals for
2030 or 2050 because the project would not exceed the SCAQMD’s draft interim threshold of 3,000 MT
CO2e per year (SCAQMD 2010). This threshold was established based on the goal of AB 32 to reduce
statewide GHG emissions to 1990 levels by 2020. Because the project would not exceed the threshold,
this analysis provides support for the conclusion that the project would not impede the state’s trajectory
toward the above-described statewide GHG reduction goals for 2030 or 2050. In addition, the project would
comply with laws and regulations that would reduce GHG emissions
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Furthermore, the project would not conflict with the state’s trajectory toward future GHG reductions. In
addition, since the specific path to compliance for the state in regards to the long -term goals will likely
require development of technology or other changes that are not currently known or available, specific
additional mitigation measures for the project would be speculative and cannot be identified at this time.
The project’s consistency would assist in meeting the City’s contribution to GHG emission reduction targets
in California. With respect to future GHG targets under SB 32 and EO S-3-05, CARB has also made clear its
legal interpretation that it has the requisite authority to adopt whatever regulations are necessary, beyond
the AB 32 horizon year of 2020, to meet SB 32’s 40% reduction target by 2030 and EO S-3-05’s 80%
reduction target by 2050; this legal interpretation by an expert agency provides evidence that future
regulations will be adopted to continue the state on its trajectory toward meeting these future GHG targets.
Based on the above considerations, the project would not conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing the emissions of GHGs, and no mitigation is required. This
impact would be less than significant.
3.9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?
b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous materials
into the environment?
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?
d) Be located on a site that 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?
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Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
e) For a project located within an airport land
use plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
result in a safety hazard or excessive noise
for people residing or working in the project
area?
f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
g) Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury or death involving wildland fires?
a) Would the project create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
Short-Term Construction Impacts
Less-Than-Significant Impact. The project would include the demolition of an existing, 74,662 -square-
foot industrial building and constru ction of an approximately 44,162 -square-foot industrial building.
During construction of the project, potentially hazardous materials would likely be handled on the project
site. These materials would include gasoline, diesel fuel, lubricants, and other petroleum-based products
required to operate and maintain construction equipment. Handling of these potentially hazardous
materials would be temporary and would coincide with the short-term construction phase of the project.
Although these materials would likely be stored on the project site, storage would be required to comply
with the guidelines set forth by each product’s manufacturer and with all applicable federal, state, and local
regulations pertaining to the storage of hazardous materials. Consistent with federal, state, and local
requirements, the transport of hazardous materials to and from the project site would be conducted by a
licensed contractor. Any handling, transport, use, or disposal of hazardous materials would comply with all
relevant federal, state, and local agencies and regulations, including the EPA, the California Department of
Toxic Substances Control (DTSC), the California Occupational Safety and Health Administration, Caltrans,
the Resource Conservation and Recovery Act, SCAQMD, and the Los Angeles County Certified Unified
Program Agency. Therefore, short-term construction impacts related to the transport, use, or disposal of
hazardous materials would be less than significant.
Long-Term Operational Impacts
Less-than-Significant Impact with Mitigation Incorporated. Potentially hazardous materials associated with
project operations would include materials used during typical cleaning and maintenance activities.
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Although these potentially hazardous materials would vary, they would generally include household
cleaning products, paints, fertilizers, and herbicides and pesticides. Many of these materials are considered
household hazardous wastes, common wastes, and/or universal wastes by the EPA, which considers these
types of wastes to be common to businesses and households and to pose a lower risk to people and the
environment than other hazardous wastes when properly handled, transported, used, and disposed of (EPA
2020). Federal, state, and local regulations typically allow these types of wastes to be handled and
disposed of with less stringent standards than other hazardous wastes, and many of these wastes do not
have to be managed as hazardous waste.
In addition, any potentially hazardous material handled on the project site would be limited in both quantity
and concentrations, consistent with other similar industrial uses located in the City, and any handling,
transport, use, and disposal would comply with applicable federal, state, and local agencies and
regulations. Furthermore, as mandated by the U.S. Occupational Safety and Health Administration (OSHA;
OSHA n.d.), all hazardous materials stored on the project site would be accompanied by a Material Safety
Data Sheet, which would inform employees and first responders as to the necessary remediation
procedures in the case of accidental release.
Due to the age of the on-site buildings and structures, it is likely that asbestos-containing materials (ACM)
and lead-based paints, as well as other building materials containing lead (e.g., ceramic tile), were used in
their construction. Demolition of these building and structures can cause encapsulated ACM (if present) to
become friable and, once airborne, would be considered a carcinogen.18 A carcinogen is a substance that
causes cancer or helps cancer grow. Demolition of the existing buildings and structures can also cause the
release of lead into the air if not properly removed and handled. The EPA has classified lead and inorganic
lead compounds as "probable human carcinogens" (EPA 2020). Such releases could pose significant risks
to persons living and working in and around the project area, as well as to project construction workers.
Abatement of all ACM and lead-based paints encountered during any future building demolition activities
would be required to be conducted in accordance with all applicable laws and regulations, including those
of the EPA (which regulates disposal), OSHA, U.S. Department of Housing and Urban Development,
Cal/OSHA (which regulates employee exposure), and SCAQMD.
For example, the EPA requires that all asbestos work performed within regulated areas be supervised by a
person who is trained as an asbestos supervisor (EPA Asbestos Hazard Emergency Response Act, 40 CFR
763). SCAQMD’s Rule 1403 requires that buildings undergoing demolition or renovation be surveyed for
ACM prior to any demolition or renovation activities. Should ACM be identified, Rule 1403 requires that
ACM be safely removed and disposed of at a regulated disposal site, if possible. If it is not possible to safely
remove ACM, Rule 1403 requires that safe procedures be used to demolish the building with asbestos in
place without resulting in a significant release of asbestos to the environment. Additionally, during
demolition, grading, and excavation, all construction workers would be required to comply with the
requirements of Title 8 of the California Code of Regulations, Section 1529 (Asbestos), which provides for
exposure limits, exposure monitoring, respiratory protection, and good working practices by workers
exposed to asbestos.
18 When dry, an ACM is considered friable if it can be crumbled, pulverized, or reduced to powder by hand pressure. If it cannot , it is
considered non-friable ACM. It is possible for non-friable ACM to become friable when subjected to unusual conditions, such as
demolishing a building or removing an ACM that has been glued into place.
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Cal/OSHA Regulation 29 (CFR Standard 1926.62) regulates the demolition, renovation, or construction
of buildings involving lead-based materials. It includes re quirements for the safe removal and disposal
of lead, and the safe demolition of buildings containing lead-based paints or other lead materials.
Additionally, during demolition, grading, and excavation, all construction workers would be required to
comply with the requirements of Title 8 of the California Code of Regulations, Section 1532.1 (Lead),
which provides for exposure limits, exposure monitoring, respiratory protection, and good working
practice by workers exposed to lead.
A Phase I Environmental Site Assessment (ESA) was prepared for the project site (Appendix E). The Phase
I ESA was performed in general conformance with the scope and limitations as detailed in the ASTM
Practice E1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site
Assessment Process. The Phase I ESA is designed to provide the project applicant with an assessment
concerning the environmental conditions (limited to the issues identified within the ESA) as they exist at
the project site.
Recognized Environmental Condition. A recognized environmental condition refers to the presence or likely
presence of any hazardous substances or petroleum products in, on, or at a property, due to release to the
environment, under conditions indicative of a release to the environment, or under conditions that pose a
material threat of a future release to the environment.
All or part of the project site has been occupied by a custom rubber products manufacturer since initial
construction in 1951, utilizing raw materials including polymers, talc, neoprene, carbon black, monomers,
and zinc as well as petroleum hydrocarbons such as lubricating oils, waste lubricating oil, and the process
oils. Process oils are currently stored in three interior aboveground storage tanks (ASTs) (two 3,000-gallon
ASTs and one 4,000-gallon AST) within the manufacturing area. In addition, the manufacturing area
includes an internal hydraulic system comprised of a network of below-grade trenches and overhead piping
that deliver a recirculated water and hydraulic oil mixture to the rubber presses and molding machines.
Furthermore, a central clarifier is present that is used primarily for boiler blowdown and cooling tower discharges.
The project site also operates a small electrical substation that includes one large pad-mounted transformer
and additional electrical equipment situated within a chain link fence within the central courtyard, with apparent
associated equipment on the interior adjacent wall. The transformer was not labeled indicating polychlorinated
biphenyls content. The electrical equipment is not original and has been replaced at least once or twice. No
staining or leakage was observed in the vicinity of the transformer equipment.
Historical Recognized Environmental Condition. A historical recognized environmental condition (HREC)
refers to a past release of any hazardous substances or petroleum products that has occurred in connection
with the project site and has been addressed to the satisfaction of the applicable regulatory authority or
meeting unrestricted use criteria established by a regulatory authority, without subjecting the project site
to any required controls.
A total of four steel underground storage tanks (USTs) were formerly operated at the project sit e, three of
which contained diesel to fuel the two boilers associated with rubber molding, and one of which contained
naphthene cutting oil. Three of the USTs (tanks 1, 2, and 3) were located along the exterior south side of
the project site and were removed in 1989. A fourth UST (tank 4 containing diesel) was abandoned in place
in the central courtyard area in or around 1989. During the removal of tanks 1 through 3, soil samples from
Exhibit F PC Agenda Page 155
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beneath the tanks were tested and a release was detected; therefore, additional site investigation,
excavation, and remediation work was performed in this area under the oversight of the Los Angeles County
Department of Public Works. Subsequently, a No Further Action (NFA) letter was issued for Closure Permit
Number 5999B by the Los Angeles County Department of Public Works, Waste Management Division
(currently Environmental Programs Division) dated August 6, 1992, which pertains to the three exterior
removed USTs. The abandoned-in-place UST was assigned a separate Closure Permit Number of 6000B,
which was not listed on the NFA letter. However, based on preliminary conversations with Los Angeles
County Department of Public Works staff, this appears to be an error in which tank 4 should have been
noted, as all four USTs appear to have been closed under this NFA letter.
As summarized above and further discussed in the Phase I ESA, the findings revealed evidence of an HREC
and environmental issues in connection with the project site. The Phase I ESA made a series of
recommendations that the project would need to adhere to through implementation of MM-HAZ-1.
Therefore, with incorporation of mitigation, long-term operational impacts associated with the use,
transport, and disposal of hazardous materials would be less than significant.
MM-HAZ-1 Based on the recommendations made in the Phase I ESA prepared by Partner Engineering, the
following shall occur prior to the issuance of building permits for the proposed on-site buildings
and structures:
1. A limited subsurface investigation shall be conducted in order to determine the
presence or absence of soil and/or soil vapor contamination due to the current
and historical use of the project site.
2. A Soil Management Plan should be prepared to appropriately handle the known oil
releases at the project site and any unknown releases associated with the current
and former industrial use.
3. The No Further Action letter dated August 6, 1992, pertaining to the historical
underground storage tanks (USTs) at the project site should be revised to clearly
include Closure Permit Number 6000B for the abandoned-in-place UST to avoid
confusion in the future as to whether it was officially closed.
4. An asbestos survey conducted in 1990 identified asbestos in the existing building
on the project site. It is not known if the survey was conducted for all equipment
and building materials at the time; therefore, an asbestos survey should be
performed and known asbestos-containing materials (ACMs) should be abated or
removed for safety purposes (or an operations and maintenance program should
be implemented in order to safely manage the known and suspect ACMs located
at the project site).
b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable
upset and accident conditions involving the release of hazardous materials into the environment?
Less-than-Significant Impact with Mitigation Incorporated: Refer to response provided in Section 3.9(a).
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c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school?
No Impact. The nearest school to the project site is Al Gauldin Elementary School (9724 Spry Street),
located approximately 0.3 miles southwest of the project site. In addition, the project would not emit
hazardous air emissions or handle hazardous or acutely hazardous materials. Therefore, no impacts
associated with emitting hazardous emissions or handling hazardous or acutely hazardous materials within
0.25 miles of school would occur.
d) Would the project be located on a site that 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?
Less-than-Significant Impact with Mitigation Incorporated. California Government Code Section 65962.5
requires the California Environmental Protection Agency to compile a list of hazardous waste and
substances sites (Cortese List). While the Cortese List is no longer maintained as a single list, the following
databases provide information that meets the Cortese List requirements (refer to Appendix E):
• List of Hazardous Waste and Substances sites from DTSC EnviroStor database (DTSC 2020; Health
and Safety Codes 25220, 25242, 25356, and 116395)
• List of Open, Active Leaking Underground Storage Tank Sites by County and Fiscal Year from the State
Water Resources Control Board GeoTracker database (SWRCB 2020; Health and Safety Code 25295)
• List of solid waste disposal sites identified by the State Water Resources Control Board with waste
constituents above hazardous waste levels outside the waste management unit (Water Code
Section 13273[e]; 14 CCR 18051)
• List of “active” Cease and Desist Orders and Cleanup and Abatement Orders from the State Water
Resources Control Board (Water Code Sections 13301 and 13304)
• List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the
Health and Safety Code, identified by DTSC
As summarized above and further discussed in the Phase I ESA, the findings revealed evidence of an HREC
and environmental issues in connection with the project site. A total of four steel USTs were formerly
operated at the project site, three of which contained diesel to fuel the two boilers associated with rubber
molding, and one of which contained naphthene cutting oil. During the removal of tanks 1 through 3, soil
samples from beneath the tanks were tested and a release was detected; therefore, additional site
investigation, excavation, and remediation work was performed in this area under the oversight of the Los
Angeles County Department of Public Works. Subsequently, an NFA letter was issued for Closure Permit
Number 5999B by the Los Angeles County Department of Public Works, Waste Management Division
(currently Environmental Programs Division) dated August 6, 1992, which pertains to the three exterior
removed USTs. As a result, the project site appears on the LUST [leaking underground storage tank]
Cleanup Site database maintained by the Regional Water Quality Control Board (RWQCB).
The Phase I ESA made a series of recommendations that the project would need to adhere to through
implementation of MM-HAZ-1. Therefore, with incorporation of mitigation, impacts associated with the
Exhibit F PC Agenda Page 157
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project being located on a site that is included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 would be less than significant.
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?
Less-than-Significant Impact. The project site is not located within an airport land use plan. The closest
airport to the project site is Compton/Woodley Airport, located approximately 7.2 miles southwest of the
site. Therefore, impacts associated with a safety hazard or excessive noise for people residing or working
in the project area would be less than significant.
f) Would the project impair implementation of or physically interfere with an adopted emergency response
plan or emergency evacuation plan?
Less-than-Significant Impact. There are various plans at the federal, state, and local level dealing with
responses to disasters and emergencies. Local emergency plans are considered extensions of the
California Emergency Plan, published by the State Office of Emergency Services, which provides for
authorities and responsibilities in the event of formal proclamation of emergencies. The Los Angeles County
of Disaster Preparedness is responsible for coordinating the various federal, state, local, quasi-local, and
private agencies involved in disaster and emergency response.
Local agencies, such as Downey, are responsible for responding to disasters and emergencies within their
borders. According the City’s General Plan, Safety Element, the City has an emergency operation plan,
consistent with the Standards Emergency Management System – Emergency Operations Plan. During an
emergency, the City would implement the Emergency Operations Plan, which includes setting up the
Emergency Operation Center. In a disaster, the Emergency Operation Center would become the command
post for coordinating manpower, equipment, resources and facilities. Using the communications network,
the disaster coordinator would be able to assemble information in the field, assess the situation throughout
the City, keep the general public informed at all times and determine proper channels to successfully
allocate available resources and disaster services (City of Downey 2005).
During emergencies, Rio Hondo Golf Course and Apollo Park are designated as casualty collection points.
When activated, these locations would be utilized by the county to air-evacuate the injured to medical
facilities. In the event that evacuation of parts of the City are necessary, the Downey Police Department
(DPD) would coordinate evacuation procedures based on possible evacuation routes (City of Downey
2005). Therefore, impacts associated with impairing of physically interfering with an adopted emergency
response plan or emergency evacuation plan would be less than significant.
g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury,
or death involving wildland fires?
Less-than-Significant Impact. According to California Department of Forestry and Fire Services’ (CAL FIRE’S)
Fire Hazard Severity Zone Map, the project site is not located in an area identified as being susceptible to
wildland fire (CAL FIRE 2007). Furthermore, the project site is surrounded by existing development in an
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urbanized portion of the City away from any urban-wildland interface. Therefore, no impacts associated with
wildland fire hazards would occur.
3.10 Hydrology and Water Quality
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground
water quality?
b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?
c) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would:
i) result in substantial erosion or siltation
on or off site;
ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on or 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?
The following analysis is based, in part, on the site-specific Low-Impact Development Plan (LID Plan) (Appendix F-1) and
the Preliminary Hydrology Calculations Report (Appendix F-2), both prepared by Thienes Engineering in July 2019.
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a) Would the project violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality?
Surface Water Quality
Less-than-Significant Impact: Construction of the project would include earthwork activities that could
potentially result in erosion and sedimentation, which could subsequently degrade downstream rece iving
waters and violate water quality standards. Stormwater runoff during the construction phase may contain
silt and debris, resulting in a short-term increase in the sediment load of the municipal storm drain system.
Substances such as oils, fuels, paints, and solvents may be inadvertently spilled on the project site and
subsequently conveyed via stormwater to nearby drainages, watersheds, and groundwater. To reduce the
potential for downstream water quality impacts, the project would comply with Municipal Code, Section 8024
(City of Downey 2020), which states that dust, water, mud, materials of construction, or debris shall be
contained on the building site. The project site is larger than 1 acre and would be subject to NPDES
Construction General Permit issued by the Los Angeles RWQCB. The permit requires the implementation of
stormwater controls and development of a stormwater pollution prevention plan to minimize the amount
of sediment and other pollutants from being discharged in stormwater runoff during construction, as well
as various temporary BMPs designed to prevent erosion and siltation, as well as the off-site conveyance of
various on-site constituents. Therefore, short-term construction impacts associated with water quality
standards would be less than significant.
Once operational, the project site would be developed with an approximately 44,162-square-foot industrial
building, and paved parking spaces and drive aisles. Collectively, these on-site areas would reduce the
potential for soils erosion and topsoil loss that could affect surface water quality. The project would be
subject to the requirements of the NPDES Municipal Separate Storm Sewer Systems (MS4) permit, which
regulates municipal discharges of stormwater and non-stormwater. Additionally, the project would include
a LID Plan (Appendix F-1) to comply with City efforts to retain stormwater runoff generating from new
construction projects. The project site must meet the requirements of the LID Standards Manual, which
would help to mitigate potential impacts to water quality.
The project site would be graded so that stormwater collected via the building’s roof and parking areas
would be collected by concrete catchbasins and conveyed via underground pipes to an underground
stormwater detention chamber and proprietary biofiltration system (Figure 13, Proposed Storm Drain
System). The biofiltration system would utilize plants and soil media to treat stormwater before ultimately
being discharged into the adjacent existing 36-inch public storm drain system within Washburn Road via
an underdrain system and sump pump. Therefore, impacts associated with water quality standards would
be less than significant.
Groundwater Quality
Less-than-Significant Impact: Similar to surface water quality, groundwater quality would be protected
during project construction through BMPs required by the NPDES permit. BMPs would include spill
prevention and cleanup guidelines, dewatering operations guidelines, and stormwater runoff prevention.
These BMPs would protect the groundwater from contamination by construction activities.
Exhibit F PC Agenda Page 160
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Under existing conditions, the project site is entirely impervious surfaces. However, upon completion of
construction, the project site would include 0.66 acres of pervious surfaces. The pervious surface area
would be located along the landscaping fronting Woodruff Avenue. Runoff from portions of the driveways
and landscaping would sheet flow to the public street without being routed to a LID BMP. However,
stormwater collected via the building’s roof and parking areas would be collected by concrete catchbasins
and conveyed via underground pipes to an underground stormwater detention chamber and proprietary
biofiltration system (Figure 13, Proposed Storm Drain System). The biofiltration system would utilize plants
and soil media to treat stormwater before ultimately being discharged via an underdrain system and sump
pump into the adjacent existing 36-inch public storm drain system within Washburn Road. Therefore,
impacts associated with groundwater quality would be less than significant.
b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater
recharge such that the project may impede sustainable groundwater management of the basin?
Groundwater Supplies
Less-than-Significant Impact: The City produces groundwater from the Central Basin. The Central Basin is
located in Los Angeles County, approximately 20 miles southeast 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, resulting in an Allowed Pumping
Allocation (APA) of 16,554 acre-feet per year (AFY). The City owns wells, twenty of which are currently
operational and have a combined pumping capacity of approximately 27,575 gallons per minute, or
approximately 44,500 AFY if operated continuously (City of Downey 2018).
In December 2013, the Supreme Court approved amendments to the Central Basin Judgment , which
implemented a water storage program. The Amended Central Basin Judgment states that a party may store
up to 50% of the party’s APA in an Individual Storage Account and 150 percent of the pa rty’s APA in a
Community Storage Account if space is available. In addition, the amendments allow parties to convert
unused APA to stored water and revised the amount of carryover to be equal to 60% of the party’s APA
minus the amount of carryover water set aside for storage. The purpose of the storage program creates an
added reliability in water supply from the Central Basin. In addition, the amendments allow for transfer of
water between Central Basin and West Basin by permitting parties with water rights in Central Basin to
increase production in Central Basin, while another party decreases production in West Basin by the
corresponding amount. Under the Central Basin Judgment, water rights are fixed and do not vary year to
year. Water producers cannot exceed their water rights by more than 20% or 20 acre-feet, whichever is
greater, in any year and an adjustment is made the following year (City of Downey 2018).
Furthermore, as a water purveyor, the City must be able to provide for the minimum health and safety water
requirements of the community at all times. Following the adoption of its Water Shortage Contingency Plan,
Ordinance No. 925, the City developed a four-stage water-rationing plan to be implemented during declared
water shortages. The four-stage water-rationing plan includes both voluntary and mandatory rationing,
Exhibit F PC Agenda Page 161
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which are to be implemented depending on the causes, severity, and anticipated duration of the water
supply shortage. The four-stage water-rationing plan is designed to allow for a minimum of 50% of the City’s
normal supply to be available during a severe or extended water shortage. Rationing program triggering
levels were established to ensure that this goal is met. Rationing stages are triggered by a supply shortage
due to drought conditions, contamination of one or a combination of sources, or some other type of
emergency (City of Downey 2018).
The City’s 2015 Urban Water Management Plan provides multiple-dry-year supply and demand analysis for
the City’s domestic water service area. As shown in Table 17, the City’s supplies can meet demands during
multiple dry years for the next 20 years. Therefore, impacts associated with groundwater supplies would
be less than significant.
Table 17. Supply and Demand Comparison – Multiple-Dry-Year Events
Scenarios
Supply and
Demand 2020 2025 2030 2035 2040
Multiple-dry-year
first-year supply
Supply totals 17,218 17,876 18,180 18,489 18,804
Demand totals 17, 218 17,876 18,180 18,489 18,804
Difference 0 0 0 0 0
Multiple-dry-year
second-year supply
Supply totals 17,592 18,264 18,575 18,891 19,213
Demand totals 17,592 18,264 18,575 18,891 19,213
Difference 0 0 0 0 0
Multiple-dry-year
third-year supply
Supply totals 17,592 18,264 18,575 18,891 19,213
Demand totals 17,592 18,264 18,575 18,891 19,213
Difference 0 0 0 0 0
Source: City of Downey 2018.
Groundwater Recharge
Less-than-Significant Impact: The project site overlies the boundaries of the Central Basin, which is subject
to the Amended Central Basin Judgment. The Water Replenishment District of Southern California, acting
as the watermaster for the Central Basin, is responsible for managing groundwater resources in this area.
Under existing conditions, the 6.31-acre project site is developed and comprised entirely of impervious
surfaces. Given these existing conditions and the project site’s small size of 6.31 acres in relationship to
the size of the Central Basin, the project site does not currently serve as a significant location for dedicated
groundwater recharge.
Upon completion of construction, the project would introduce 0.66 acres of pervious surfaces to the project
site as landscaping fronting Woodruff Avenue, which could potentially contribute to groundwater recharge.
As such, given that the project site does not currently serve as a significant location for groundwater
recharge and the project would introduce new pervious areas on site that could promote groundwater
recharge, the project is not expected to directly cause a decrease in groundwater supplies or interfere
substantially with groundwater recharge, and impacts are determined to be less than significant.
Exhibit F PC Agenda Page 162
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c) Would the project substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would:
i) result in substantial erosion or siltation on or off site;
Less-than-Significant Impact: There are no streams or rivers located on or near the project site.
Project construction would involve some earth-disturbing activities, including grading, that could
expose on-site soils to erosion and surface water runoff. However, inclusion of project BMPs would
reduce erosion and siltation from the project site occurring from construction activities. In addition,
the project site is located within a developed area, with industrial land uses surrounding the project
site; as such, the development of the project would not cause a significant change to surface bodies
of water in a manner that could cause siltation or erosion. Therefore, impacts associated with
altering of the existing drainage patterns and erosion would be less than significant.
ii) substantially increase the rate or amount of surface runoff in a manner which would result in
flooding on or off site;
Less-than-Significant Impact: As discussed in Section 3.10(b), the project would increase the
amount of pervious surfaces on the project site by adding landscaped area. However, the majority
of the project site would remain impervious surface. Pursuant to Municipal Code Section 5707, the
project has prepared a LID plan to comply with City efforts to retain stormwater runoff generating
from new construction projects. As described in the project’s LID plan, stormwater collected via the
building’s roof and parking areas would be collected by concrete catchbasins and conveyed via
underground pipes to an underground stormwater detention chamber and proprietary biofiltration
system (Figure 13, Proposed Storm Drain System). The biofiltration system would utilize plants and
soil media to treat stormwater before ultimately being discharged via an underdrain system and
sump pump into the adjacent existing 36-inch public storm drain system within Washburn Road.
Additionally, the Preliminary Hydraulics Calculations report analyzed hydraulic conditions in the
event of a 50-year peak storm event (per Los Angeles County Department of Public Works
Requirements) and determined that the project’s proposed drainage patterns would not result in
impacts to downstream facilities (Appendix F-2). Furthermore, the project would comply with
existing local, state, and federal regulations related to drainage and runoff. Therefore, the project
would not result in flooding on or off site. Therefore, impacts associated with altering the existing
drainage pattern and flooding would be less than significant.
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
Less-than-Significant Impact: As described in the project’s LID plan, stormwater collected via the
building’s roof and parking areas would be collected by concrete catchbasins and conveyed via
underground pipes to an underground stormwater detention chamber and proprietary biofiltration
system (Figure 13, Proposed Storm Drain System). The biofiltration system would utilize plants and
soil media to treat stormwater before ultimately being discharged into the adjacent existing 36 -
inch public storm drain system within Washburn Road via an underdrain system and sump pump.
Additionally, the Preliminary Hydraulics Calculations report analyzed hydraulic conditions in the
Exhibit F PC Agenda Page 163
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event of a 50-year peak storm event (per Los Angeles County Department of Public Works
Requirements) and determined that the project’s proposed drainage patterns would not result in
impacts to downstream facilities (Appendix F-2). Furthermore, the project would comply with
existing local, state, and federal regulations related to drainage and runoff. Furthermore, runoff
from public streets would be collected into existing gutters along Woodruff Avenue. Therefore,
impacts associated with stormwater drainage system capacity would be less than significant.
iv) impede or redirect flood flows?
No Impact: The project site does not contain any streams or rivers having the potential to be altered
by the project. The project site has been previously graded and is located within a highly urbanized
area. According to the City’s General Plan, the City had been subject to periodic flooding and flood
insurance requirement imposed by the Federal Emergency Management Agency (FEMA) until the
U.S. Army Corps of Engineers constructed improvements in 2000. These improvements included
raising levees adjacent to Rio Hondo River. As such, no properties within the City are considered by
FEMA to be within a 100-year flood zone (FEMA 2020). A 100-year flood zone is one of such
intensity that it has a 1% chance of occurring in any given year. However, according to FEMA, the
City is located within a 500-year flood zone, which has a 0.2% chance of a flood occurring in any
given year. Therefore, impacts associated with impeding or redirecting flood flows would not occur.
d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
No Impact: Due to the lack of an adjacent lake or other water body, the project site would not be susceptible
to seiche. Additionally, because of the site’s inland location, the project would not be subject to tsunami.
As addressed in Section 3.10(c)(iv), the City had been subject to periodic flooding and flood insurance
requirement imposed by FEMA until the U.S. Army Corps of Engineers constructed improvements in 2000.
These improvements included raising levees adjacent to Rio Hondo River. As such, no properties within the
City are considered by FEMA to be within a 100-year flood zone. Therefore, no impacts associated with
flood hazards, tsunami, or seiche would occur.
e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan?
Less-than-Significant Impact. Refer to responses provided in Sections 3.10(a) and 3.10(b).
Exhibit F PC Agenda Page 164
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3.11 Land Use and Planning
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established
community?
b) Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the purpose
of avoiding or mitigating an environmental
effect?
a) Would the project physically divide an established community?
No Impact. The physical division of an established community typically refers to the construction of a linear
feature (e.g., a major highway or railroad tracks) or removal of a means of access (e.g., a local road or
bridge) that would impair mobility within an existing community or between a community and outlying area.
Under the existing conditions, the project site is entirely developed and is the current location for KMC,
which manufactures rubber products. As such, the project is not used as a connection between established
communities. Instead connectivity within the area surrounding the project site is facilitated via local
roadways. As such, the project would not impede movement within an established community, or from one
established community to another. Therefore, no impacts associated with physically dividing an established
community would occur.
b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy,
or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less-than-Significant Impact. The project would consist of demolishing an existing industrial building and
constructing a new industrial building for truck terminal use. As shown in Table 18, the project would adhere
to policies set forth in the City’s General Plan to avoid and/or mitigate potential environmental impacts.
Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
Land Use Element
Policy 1.1.1 Maintain a balance of
uses
Residential uses occupy more than half of
the City’s land area. However, the City also
provides a mix of other land uses such as
open space, commercial, and
The project would
be consistent with
this policy.
Exhibit F PC Agenda Page 165
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Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
manufacturing. The project includes
demolition of an existing industrial building
and construction of an industrial tilt-up
building for truck terminal use. Therefore,
because the project would not include
residential uses, which is the primary land
use in the City, and would maintain an
industrial use, the project would continue to
provide the City with a mix of uses.
Policy 1.1.3 Provide an appropriate
amount of land area
for business and
employment.
Under existing conditions, the project site
currently contains an industrial building
for a rubber man ufacturing company. The
project would include the demolition o f
the aforementioned industrial building
and construction of an industrial tilt -up
building for truck terminal use. The
principal purpose of the project is for
transferring goods and breaking down and
assembling tractor-trailer transportation.
The project would generate approximately
15 to 30 jobs. Therefore, the project would
contribute to business and employment in
the City.
The project would
be consistent with
this policy.
Circulation Element
Policy 2.1.1
and
Program
2.1.1.1
Maintain a street
system that provides
safe and efficient
movement of people
and goods.
Maintain intersections
and street segments at
acceptable service
levels and not worsen
those intersections and
street segments
currently operating at
unacceptable levels.
A TIA (Appendix C) was prepared for the
project to assess the project’s potential
effects on the City’s circulation system. As
determined in the TIA, the project would not
result in conflicts with Policy 2.1.1 or
Program 2.1.1.1.
The project would
be consistent with
this policy.
Policy 2.3.1 Promote the safe and
efficient movement of
truck traffic through
the City.
The project site is located on Woodruff
Avenue, a City-designated truck route that
provides access to other City- designated
truck routes and regional highways. The
project’s location and proximity to these
routes would allow for trucks accessing the
project site to efficiently and safely navigate
throughout the City.
The project would
be consistent with
this policy.
Exhibit F PC Agenda Page 166
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Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
Policy 2.3,2 Minimize negative
impacts associated
with truck traffic.
The project site’s location along City-
designated truck routes would minimize
negative impacts associated with truck
traffic on other land uses throughout the
City, given that truck traffic would be
constrained to designated truck routes.
Additionally, a TIA (Appendix C) was
prepared for the project to assess the
project’s traffic effects and their consistency
with City LOS standards. The TIA concluded
that the project would not be inconsistent
with the LOS standards established by the
City.
The project would
be consistent with
this policy.
Policy 2.3.3 Discourage land uses
that attract high
amounts of truck
traffic.
The project would include the demolition of
an existing industrial building and
construction of an industrial tilt-up building
for truck terminal use. While the project
would result in an increase in truck traffic
accessing the site (see Section 3.17,
Transportation), the project would be
located on a parcel that has been
designated by the City’s General Plan for
industrial uses and zoned for industrial
uses. Moreover, this policy is a policy that is
implemented at the City level, and
implementation of the project would not
inhibit the City from discouraging the
development of land uses that attract high
amounts of truck traffic on sites that do not
already attract truck traffic elsewhere
throughout the City.
The project would
be consistent with
this policy.
Conservation
Policy 4.3.1 Reduce the
contaminant level of
stormwater and urban
runoff generated within
Downey.
To reduce the potential for downstream
water quality impacts, the project would
comply with Municipal Code, Section 8024
(City of Downey 2020), which states that
dust, water, mud, materials of construction,
or debris shall be contained on the building
site. Additionally, the project site is larger
than 1 acre and would be subject to NPDES
Construction General Permit issued by the
Los Angeles RWQCB. The permit requires
the implementation of stormwater controls
and development of a stormwater pollution
prevention plan to minimize the amount of
sediment and other pollutants from being
discharged in stormwater runoff during
The project would
be consistent with
this policy.
Exhibit F PC Agenda Page 167
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Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
construction, as well as various temporary
BMPs designed to prevent erosion and
siltation, as well as the off-site conveyance
of various on-site constituents.
Additionally, the project would include a LID
plan to comply with City efforts to retain
stormwater runoff generating from new
construction projects. The project site must
meet the requirements of the LID Standards
Manual, which would help to mitigate
potential impacts to water quality.
Policy 4.5.1 Pursue every
applicable means and
opportunities to reduce
air particulate and
pollutants within the
City and region.
Refer to Section 3.3. Air Quality. The project
would result in less-than-significant air
quality impacts. Additionally, development
of the project would involve the
development of a truck terminal use on a
site that is located proximate to regional
highways (I-605, I-105, and I-710), thereby
reducing the need for longer distance trips
that could result in additional air pollutant
emissions.
The project would
be consistent with
this policy.
Policy 4.6.1 Promote the
conservation of energy
by residents and
businesses to conserve
energy.
The project would be subject to and would
comply with, at a minimum, the California
Building Energy Efficiency Standards (24
CCR, Part 6). Part 6 of Title 24 establishes
energy efficiency standards for
nonresidential buildings constructed in
California in order to reduce energy demand
and consumption. As such, the project
would assist the City in its goal to promote
conservation of energy by businesses.
The project would
be consistent with
this policy.
Safety
Policy 5.2.1 Monitor the generation,
storage, and disposal
of hazardous materials.
During construction of the project,
potentially hazardous materials would likely
be handled on the project site. Although
these materials would likely be stored on
the project site, storage would be required
to comply with the guidelines set forth by
each product’s manufacturer and with all
applicable federal, state, and local
regulations pertaining to the storage of
hazardous materials. Consistent with
federal, state, and local requirements, the
transport of hazardous materials to and
from the project site would be conducted by
a licensed contractor. Any handling,
The project would
be consistent with
this policy.
Exhibit F PC Agenda Page 168
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Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
transport, use, or disposal of hazardous
materials would comply with all relevant
federal, state, and local agencies and
regulations, including the EPA, the California
DTSC, Cal/OSHA, Caltrans, the Resource
Conservation and Recovery Act, the
SCAQMD, and the Los Angeles County
Certified Unified Program Agency.
In addition, any potentially hazardous
material handled on the project site during
operation would be limited in both quantity
and concentrations, consistent with other
similar industrial uses located in the City,
and any handling, transport, use, and
disposal would comply with applicable
federal, state, and local agencies and
regulations. Further, as mandated by OSHA
(OSHA n.d.), all hazardous materials stored
on the project site would be accompanied
by a Material Safety Data Sheet, which
would inform employees and first
responders as to the necessary remediation
procedures in the case of accidental release
Policy 5.5.1 Minimize damage in
the event of a major
earthquake.
As set forth in Section 8001 of the City’s
Municipal Code, the City has adopted the
current California Building Code. As such,
the project would be designed in
accordance with all applicable design
provisions established in the current 2019
edition of the California Building Code,
which dictates specifications to ensure
structural integrity during a seismic event.
Additionally, the project would adhere to
building requirements set forth in the
Geotechnical Report to address potential
seismic-related impacts.
The project would
be consistent with
this policy.
Noise
Policy 6.1.1 Minimize noise impacts
onto noise-sensitive
uses.
Refer to Section 3.13, Noise. The project
would result in less-than-significant impacts
to noise-sensitive uses with implementation
of MM-NOI-1, which involves, among other
things, erection of a temporary construction
noise barrier to completely interrupt the line-
of-sight (and sound) from the project site to
nearby noise-sensitive residences.
Therefore, impact to noise-sensitive uses
The project would
be consistent with
this policy.
Exhibit F PC Agenda Page 169
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Table 18. Policy Consistency Analysis
Land Use
Element Policy
Number
Land Use Element
Policy Project-Applicable Component(s) Consistency Finding
would be minimized to the maximum extent
practicable.
Policy 6.2.1 Reduce noise
generated by vehicular
traffic.
This policy is a City-level policy to be
implemented by the City, and the project
would not affect the City’s ability take steps
to reduce noise generated by vehicular
traffic. Additionally, as discussed in Section
3.13, Noise, the project’s traffic noise
contribution as a result of trucks and
vehicles accessing the project site would
only be 0 to 1 dBA, which is not an audible
change in the context of context of
community noise (i.e., outside of a
controlled test environment), and off-site
traffic-related noise impacts were
determined to be less than significant.
The project would
be consistent with
this policy.
The project would be consistent with the aforementioned policies in the City’s General Plan adopted for the
purpose of avoiding or mitigating environmental effects. Therefore, impacts associated with land use plans,
policies, and regulations would be less than significant.
3.12 Mineral Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state?
b) Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan?
a) Would the project result in the loss of availability of a known mineral resource that would be of value to the
region and the residents of the state?
No Impact. According to the City’s Downey Vision 2025 Comprehensive General Plan Update Draft
Environmental Impact Report, the City does not have any known mineral resource areas (City of Downey
Exhibit F PC Agenda Page 170
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2004). Therefore, no impacts associated with mineral resources or locally important mineral resource
recovery site would occur.
b) Would the project result in the loss of availability of a locally important mineral resource recovery site
delineated on a local general plan, specific plan, or other land use plan?
No Impact. Refer to response provided in Section 3.11(a).
3.13 Noise
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels?
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise
levels in the vicinity of the project in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies?
Less-than-Significant Impact with Mitigation Incorporated. During project construction, the project would
result in a temporary increase in noise levels due to the use of construction equipment. During operation,
on-site employees and truck drivers would generate additional traffic on local streets. Traffic noise would
be a long-term source of noise from the project. The operation of the truck terminal would also result in on -
site noise from trucks entering, exiting, and maneuvering; and from air-conditioning (HVAC) equipment.
The City’s General Plan Noise Element addresses land use compatibility. The Noise Element states that an
exterior community noise equivalent level greater than 70 A-weighted decibels (adjusted for the frequency
Exhibit F PC Agenda Page 171
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89 December 2020
response of the human ear; dBA) is normally unacceptable for residential uses, transient lodging (i.e.,
motels and hotels), and schools, libraries, churches, hospitals and nursing homes (City of Downey 2005).
Noise levels are regulated by the City’s Municipal Code, Article IV, Chapter 6 (City of Downey 2020). The
sound limits apply to noise generation from one property to an adjacent property. The sound level limits
depend on the time of day, the duration of the noise, and land use. According to the City’s Municipal Code,
the maximum permissible sound pressure level measured at the property boundary of residential,
commercial, or manufacturing land uses from any noise source not operating on a public right-of-way shall
constitute a public nuisance when such noise level exceeds 5 decibels (dB) above the ambient noise level
at any period during the course of a 24-hour day. However, if a noise source is of a continuous nature and
cannot reasonably be discontinued for a 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 in Table 19 may be less than, but not greater than, the sound level limits that are listed in the table
(City of Downey 2020).
The nearest sensitive receptors that would potentially be impacted by noise generated during construction
and operation of the project are residential uses located approximately 200 feet southwest of the project
site. As defined in Table 19, residential land uses have a daytime noise standard of 55 dBA from 7:00 a.m.
to 10:00 p.m. and a nighttime noise standard of 45 dBA from 10:00 p.m. to 7:00 a.m.
Table 19. Exterior Noise Limits
Land Use Category
Noise Level (dBA)
Nighttime
10:00 p.m.–7:00 a.m.
Daytime
7:00 a.m.–10:00 p.m.
Residential 45 55
Commercial 65 65
Manufacturing 70 70
Source: City of Downey 2020.
Note: dBA = A-weighted decibels.
However, according to the City’s Municipal Code (Section 4606.5), construction, repair, or remodeling
equipment and devices and other related construction noise sources are exempted from the provisions of
the City’s noise ordinance, provided a valid permit for such construction, repair, or remodeling has been
obtained from the City. In any circumstance other than emergency work, no repair or remodeling is
permitted to take place between 9:00 p.m. of one day and 7:00 a.m. of the following day, and no repair or
remodeling is permitted to exceed 85 dBA across any property boundary at any time during the course of a
24-hour day (City of Downey 2020).
Ambient Noise Monitoring
Noise measurements were conducted at noise-sensitive receivers near the project site on July 8, 2020, to
characterize the existing noise levels. The measurements were made using calibrated SoftdB Piccolo
integrating sound level meters. The sound level meters meet the current American National Standards
Institute standard for a Type 2 (general purpose) sound level meter. The accuracy of the sound level meter
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was verified using a field calibrator before and after the measurements, and the measurements were
conducted with the microphone positioned approximately 5 feet above the ground.
Five short-term noise measurement locations (ST) that represent existing sensitive receivers were selected
near the Project Site. These locations are depicted as receivers ST1–ST5 on Figure 16, Noise Measurement
and Modeling Locations. The measured energy-averaged (Leq) and maximum (Lmax) noise levels are provided
in Table 20. The primary noise sources at the sites identified in Table 20 consisted of traffic along adjacent
roadways; birdsong, distant conversations, and distant construction noise represented secondary noise
sources. As shown in Table 20, the measured sound levels ranged from approximately 63 dBA Leq at ST2
to 72 dBA Leq at ST5. Table 20 provides the location, date, and time the noise measurements were taken.
The field noise data sheets are provided in Appendix G.
Table 20. Ambient Measured Noise Levels
Site Location
Measure
ment Date
Measurement
Time
Average
Sound
Level
(dBA Leq)
Maximum
Sound Level
(dBA Lmax) Noise Sources
ST1 Church; 12112
Woodruff Avenue
7/8/2020 2:00 p.m. –
2:15 p.m.
71.0 87.8 Traffic noise, birds,
distant conversations
ST2 Single-family
residential;
12102 Cornuta
Avenue
7/8/2020 2:26 p.m. –
2:41 p.m.
62.6 83.3 Traffic noise, birds,
rustling leaves
ST3 Single-family
residential
(mobile home
park); 12265
Woodruff Avenue
7/8/2020 2:57 p.m. –
3:12 p.m.
70.2 86.2 Traffic noise, birds,
distant construction
noise
ST4 Single-family
residential;
12448 Woodruff
Avenue
7/8/2020 3:33 p.m. –
3:48 p.m.
70.9 87.4 Traffic noise, birds
ST5 Multi-family
residential;
11253 1/2
Regent View
Avenue
7/8/2020 4:18 p.m. –
4:33 p.m.
72.2 88.4 Traffic noise, birds,
distant power-tool noise
Source: Appendix G.
Notes: dBA = A-weighted decibels; Leq = time-averaged equivalent noise level.
Short-Term Construction Impacts
Less-than-Significant Impact with Mitigation Incorporated. Construction of the project would generate noise
that could expose nearby receptors to elevated noise levels that may disrupt communication and routine
activities. The magnitude of the impact would depend on the type of construction activity, equipment,
duration of the construction, distance between the noise source and receiver, and intervening structures.
The following discussion addresses the noise levels estimated to result from construction of the project at
nearby sensitive receptors (i.e., residences).
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CalEEMod was used to identify the construction equipment anticipated for development of the project.
Based on this information, CalEEMod identified the anticipated equipment for each phase of project
construction, listed in Table 21.
Table 21. Construction Equipment by Phase
Construction Phase Equipment Quantity
Demolition Concrete/industrial saws 1
Excavators 3
Other material-handling equipment (rock
crusher and batch plant)
1
Rubber-tired dozers 2
Site Preparation Rubber-tired dozers 3
Tractors/loaders/backhoes 4
Grading Excavators 1
Graders 1
Rubber-tired dozers 1
Tractors/loaders/backhoes 3
Building Construction Cranes 1
Forklifts 3
Generator sets 1
Tractors/loaders/backhoes 3
Welders 1
Paving Pavers 2
Paving equipment 2
Rollers 2
Architectural Coating Air compressors 1
Source: Appendix B.
With the construction equipment noise sources identified in Table 21, a noise analysis was performed using
the Federal Highway Administration’s Roadway Construction Noise Model (RCNM) (FHWA 2008). Input
variables for RCNM consist of the receiver/land use types, the equipment type (e.g., backhoe, grader,
paver), the number of equipment pieces, the duty cycle for each piece of equipment (i.e., percentage of
time the equipment typically works in a given time period), and the distance from the noise -sensitive
receiver to the construction zone. The RCNM has default duty cycle values for the various pieces of
equipment, which were derived from an extensive study of typical construction activity patterns. Those
default duty cycle values were utilized for this analysis. Because the direct line of sight between the project
site and the nearest noise-sensitive receivers would be partially or completely blocked by intervening
buildings, a nominal 5 dB of acoustical shielding was assumed for most of the construction
equipment/activities.
Sensitive receptors near the project site include residential uses to the southwest and a church located
to the south east. The City’s municipal code exempts noise from construction equipment and devices and
other related sources provided that a valid permit for such work has been obtained from the City and that
such work takes place between 7:00 a.m. and 9:00 p.m. (City of Downey 2020). The results of the
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construction noise analysis using the RCNM are summarized in Table 22. As shown, the worst-case noise
levels from construction are predicted to range from approximately 61 dBA Leq (during the architectural
coating phase) to 73 dBA Leq (during the demolition phase) at the nearest noise-sensitive receivers (i.e.,
the residences, each located approximately 220 feet from the closest point of construction). More typically,
when construction would take place at various locations throughout the project site and the typical
distance19 between the nearest residences and construction would be approximately 400 feet, noise from
construction would range from approximately 51 dBA Leq to 70 dBA Leq. At the church located to the
southeast of the project site, the nearest construction activities would result in noise levels ranging from
approximately 52 dBA Leq to 69 dBA Leq. Typical construction noise at the church would range from
approximately 48 dBA Leq to 67 dBA Leq. The noise levels at the nearest residences would be up to 10
dBecibels higher than the measured ambient noise level in the area (as represented by receiver ST2). Thus,
construction best management practices would be required through MM-NOI-1 to avoid a potentially
significant short-term construction noise impact.
Table 22. Construction Noise Model Results Summary
Construction Phase
Construction Noise at Nearest Receiver Distances (Leq [dBA])
Residences to the Southwest Church to the Southeast
Nearest
Source/Receiver
Distance
(Approximately 220
feet)
Typical
Source/Receiver
Distance
(Approximately 400
feet)
Nearest
Source/Receiver
Distance
(Approximately 350
feet)
Typical
Source/Receiver
Distance
(Approximately 550
feet)
Demolition 73 70 68 67
Site Preparation 68 62 62 60
Grading 68 63 63 60
Building
Construction
63 60 59 57
Paving 64 59 58 56
Architectural Coating 61 51 52 48
Source: Appendix G.
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
MM-NOI-1 The following measures shall be implemented to reduce construction noise and vibration
emanating from construction of the project:
1. At least 30 days prior to commencement of construction, the project applicant’s
contractor shall provide written notice to all residential property owners and
19 For the purpose of estimating the construction and on-site operational noise, the “typical” distance from the nearby noise-sensitive
land uses to the construction activities was used. Construction equipment would typically be operating all over the project site,
both near and far from any one location in the vicinity of the project site. For example, construction near the southwestern project
boundary would take place within approximately 220 feet of existing residences, but during construction of other project
components, construction would be approximately 700 feet or more away from noise-sensitive receptors. Thus, the distance from
the nearby receivers to the “acoustic center” (the point from which the energy sum of all construction activity noise, near and far,
would be centered on an average or typical basis) is used. The acoustic center is calculated by taking the square root of the
product of the nearest and farthest distances (i.e., [Dac = (Dn*Df)0.5], where: Dac is the acoustic center distance, Dn is the nearest
estimated source-receiver distance, and Df is the farthest estimated source-receiver distance) (Caltrans 2013a).
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tenants within 300 feet of the project site that proposed construction activities
could affect outdoor or indoor living areas. The notice shall contain a description
of the project, a construction schedule including days and hours of construction,
and a description of noise-reduction measures.
2. Noise-generating construction activities (which may include preparation for construction
work) shall be permitted weekdays between 7:00 a.m. and 6:00 p.m., excluding federal
holidays. When a holiday falls on a Saturday or Sunday, the preceding Friday or following
Monday, respectively, shall be observed as a legal holiday.
3. Prior to commencement of demolition work, and throughout major construction
work up to but not including architectural coating, a temporary construction noise
barrier (8 feet in height) shall be erected along the southern project site boundary,
from the southwestern corner extending a distance of 75 feet to the east. This
barrier would completely interrupt the line-of-sight of the project site from
residences to the southwest.
4. All construction equipment powered by internal combustion engines shall be
properly muffled and maintained. No internal combustion engine shall be operated
on the site without a muffler. All diesel equipment shall be operated with closed
engine doors and shall be equipped with factory recommended mufflers.
Unnecessary idling of internal combustion engines shall be prohibited.
5. Air compressors and generators used for construction shall be surrounded by
temporary acoustical shelters. Whenever feasible, electrical power shall be used
to run air compressors and similar power tools.
6. The distance between construction equipment staging areas and adjacent
residences shall be maximized where feasible.
7. During construction, stationary construction equipment shall be placed such that
emitted noise is directed away from or shielded from sensitive receptors.
8. Stationary construction equipment that generates noise that exceeds 85 A-
weighted decibels at the property boundaries shall be shielded with a barrier that
meets a Sound Transmission Class rating of 25.
Effectiveness of the BMPs listed in MM-NOI-1 would vary from several decibels (which in general is a relatively
small change) to 10 or more decibels (which subjectively would be perceived as a substantial change),
depending upon the specific equipment and the original condition of that equipment, the specific locations of
the noise sources and the receivers, etc. Installation of the temporary construction noise barrier, for example,
would vary in effectiveness depending upon the degree to which the line-of-sight between the source and
receiver is broken; in this case, the barrier would provide a minimum noise reduction of 6 dB. Installation of
more effective silencers could range from several decibels to well over 10 dB. Reduction of idling equipment
could reduce overall noise levels from barely any reduction to several decibels. Cumulatively, however, these
measures would result in substantial decreases in the noise from construction. Therefore, with implementation
of mitigation, short-term construction noise impacts would be less than significant.
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Long-Term Operational Impacts
During operation, the project would be used to mobilize both imported and exported goods that pass
through the Ports of Los Angeles and Long Beach. Consequently, potential operational noise impacts
include off-site traffic noise (from additional project-related trucks and passenger vehicles) and on-site
noise from vehicle movements, loading/unloading, and stationary mechanical equipment.
Off-site Traffic Noise
Less-than-Significant Impact. The project has the potential to result in significant off-site noise impacts
from project-related traffic at nearby noise-sensitive land uses. Based upon information from Dudek
transportation specialists (Section 3.17), during the AM peak hour, implementation of the project would
result in a total of 11 passenger vehicles, 1 two-axle truck, 1 three-axle truck, and 3 four-or-more axle
trucks. During the PM peak hour, implementation of the project would result in a total of 10 passenger
vehicles, 1 two-axle truck, 1 three-axle truck, and 3 four-or-more axle trucks. In terms of average daily trips,
the project would generate approximately 75 passenger vehicle trips, 7 two-axle truck trips, 6 three-axle
truck trips, and 20 four-or-more axle truck trips. All passenger vehicle and truck trips would access and exit
the project site to the east, via Woodruff Avenue, and the truck trips would be limited to City of Downey
truck routes (shown on Figure 17).
Potential noise effects from vehicular traffic were assessed using the Federal Highway Administration’s
Traffic Noise Model Version 2.5 (FHWA 2004). Information used in the model included the Existing, Existing
plus Project, Year 2022, and Year 2022 plus Project traffic volumes. Noise levels were modeled at
representative noise-sensitive receivers. The receivers were modeled to be 5 feet above the local ground
elevation. The six receiver locations used for the short-term noise measurements were used to represent
existing off-site noise-sensitive land uses (residences and a church) (Figure 16, Noise Measurement and
Modeling Locations). The measured and modeled receiver locations are presented in Table 23.
The information provided from this modeling, along with the results from ambient noise survey
measurements, was compared to the noise impact significance criteria to assess whether project-related
traffic noise would cause a significant impact and, if so, where these impacts would occur. The results of
the comparisons for the off-site noise-sensitive land uses are summarized in Table 23.
Table 23. Summary of Off-Site Existing and Future (Year 2022) Unmitigated Traffic Noise
Levels (dBA CNEL)
Modeled Receptor Existing
Existing plus
Project
Future
(Year
2022)
Future (Year
2022) plus
Project
Maximum Project-
Related Noise Level
Increase (dB)
ST1 - Church; 12112
Woodruff Avenue
67 67 68 68 0
ST2 - Single-family
residential; 12102
Cornuta Avenue
64 64 64 64 0
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Table 23. Summary of Off-Site Existing and Future (Year 2022) Unmitigated Traffic Noise
Levels (dBA CNEL)
Modeled Receptor Existing
Existing plus
Project
Future
(Year
2022)
Future (Year
2022) plus
Project
Maximum Project-
Related Noise Level
Increase (dB)
ST3 - Single-family
residential (mobile
home park); 12265
Woodruff Avenue
69 69 69 69 0
ST4 - Single-family
residential; 12448
Woodruff Avenue
69 70 70 70 1
ST5 - Multi-family
residential; 11253 1/2
Regent View Avenue
70 70 70 71 1
Source: Appendix G.
Notes: dBA = A-weighted decibel; CNEL = Community Noise Equivalent Level; dB = decibel.
Traffic noise levels are rounded to the nearest whole numbers.
As shown in Table 23, the project would increase the traffic noise levels along the nearby arterial roadways
by 0 dBA to 1 dBA (when rounded to whole numbers). A change (either an increase or a decrease) of 1 dB
or less is not an audible change in the context of community noise (i.e., outside of a controlled test
environment). In addition, the project would not cause noise levels to exceed applicable City noise
standards. The project is not anticipated to result in significant traffic noise increases or cause an
exceedance of applicable traffic noise standards. Therefore, impacts associated with off-site traffic noise
would be less than significant.
On-Site Operational Noise
Less-than-Significant Impact. The principal use of the project would be for storage of and/or consolidation
of manufactured goods before the distribution to retail locations or other warehouses. Other than truck
parking and storage, all activities will occur within the industrial building. The project would include office
space uses ancillary to the warehouse operation.
Although the site currently is occupied by an industrial land use, implementation of the project would result in
changes to existing noise levels on the project site by developing new stationary sources of noise, including
outdoor HVAC equipment, and vehicle parking lot and truck loading dock activities. These sources may affect
noise-sensitive land uses in the vicinity of the project site. The following analysis evaluates noise from exterior
mechanical equipment and activities associated with vehicle parking lots and truck loading docks.
Outdoor Mechanical Equipment
The proposed warehouse space within the warehouse/office building would not be served by heating or air
conditioning equipment. However, the proposed office area would be equipped with single -packaged
rooftop HVAC units with air-handling capacity of 20 to 60 nominal tons. For the analysis of noise from HVAC
equipment operation, a Carrier WeatherMaker A HVAC unit was used as a reference.
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Noise level data provided by the manufacturer was used to determine the noise levels that would be
generated by the HVAC equipment. Based on the warehouse/office building’s roof design, there will be a
6-foot-high parapet extending along the perimeter of the office roof. Assuming that the HVAC equipment is
operating for a minimum period of 1 hour, the worst-case calculated noise levels at the nearest residential
property line (to the southwest) and the project sites’ northern, southern, eastern, and western property
boundaries are presented in Table 24. The calculation was performed at the worst-case location of each of
the project boundary lines—that is, the closest distance between the potential office location and the adjacent
property lines, to ensure that the shortest distance from equipment to property line was examined. The
maximum hourly noise level for the HVAC equipment operating at each examined point along the property
would range from approximately 26 dBA Leq at the nearest residences to the southwest to 31 dBA Leq at the
projects’ northern, southern, and eastern property boundaries. These levels are less than the City’s noise
standards for manufacturing (70 dBA Leq daytime or nighttime) and residential (55 dBA Leq daytime [7:00 a.m.
to 10:00 p.m.], 45 dBA Leq nighttime [10:00 p.m. to 7:00 a.m.]) and are well below the measured ambient
noise levels in the project area.
Table 24. Mechanical Equipment (HVAC) Noise
Receiver Location
Noise Level at Noise-Sensitive Use or Property Boundary
Noise Source
Average Noise Level
(dBA Leq)
Residences to southwest HVAC Equipment 26
Northern property boundary HVAC Equipment 31
Southern property boundary HVAC Equipment 31
Eastern property boundary HVAC Equipment 31
Western property boundary HVAC Equipment 27
Source: Appendix G.
Note: dBA = A-weighted decibel; Leq = equivalent continuous sound level; HVAC = heating, ventilation and air conditioning.
The results of the mechanical equipment operations noise analysis indicate that the project would comply
with the City’s noise ordinance. Mechanical equipment operation would result in noise at the project site
property boundaries/nearest noise-sensitive receiver boundaries that are less than the applicable noise
standards. Therefore, impacts associated with on-site HVAC noise would be less than significant.
Parking Lot Activity
A comprehensive study of noise levels associated with surface parking lots was published in the Journal of
Environmental Engineering and Landscape Management (Baltrënas et al. 2004). The study found that
average noise levels during the peak period of use of the parking lot (generally in the morning with arrival
of commuters, and in the evening with the departure of commuters), was 47 dBA at 1 meter (3.28 feet)
from the outside boundary of the parking lot. The parking area would function as a poin t source for noise,
which means that noise would attenuate at a rate of 6 dBA with each doubling of distance. The employee
parking lot is proposed to be situated on the east side of the warehouse/office building, adjacent to
Woodruff Avenue. The acoustic center of the parking area would be no closer than 40 feet from the eastern
property line of the project site (and approximately 470 feet from the nearest noise-sensitive land use, the
church to the southeast). At a distance of 40 feet, parking lot noise levels would be no greater than 25 dBA
Leq at the eastern property line, and approximately 4 dBA Leq at the nearest noise-sensitive land use. These
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noise levels are well below applicable City of Downey noise standards. Therefore, impacts associated with
parking lot noise would be less than significant.
Truck Loading Dock/Truck Yard Activity
The aforementioned parking lot study (Baltrënas et al. 2004) also examined noise levels associated with
cargo truck delivery activity. The study concluded that average noise levels from truck loading/unloading
areas was 96 dBA at 1 meter (3.28 feet) from the boundary of the truck activity area. The acoustic center
of truck loading dock activities would be located approximately 300 feet from the nearest residential
property line (located to the southwest), 95 feet from the northern and southern property boundaries, 150
feet from the western property boundary, and 310 feet from the eastern property boundary. Using the
outdoor attenuation rate of 6 dBA with each doubling of distance, truck loading activity at the residences
to the southwest would produce noise levels of approximately 56 dBA Leq. However, the existing intervening
buildings just south of the project site would provide a substantial amount of noise reduction by blocking
the direct line-of-sight between the truck loading dock area and the residences to the southwest. Because
of the height and size of the building, it is estimated that the noise from loading dock activities would be
reduced by approximately 14 dB or more. Thus, the loading dock noise at the nearest residences would be
approximately 42 dBA Leq, which would be below the City’s residential exposure limits of 55 dBA Leq daytime
(7:00 a.m. to 10:00 p.m.) and 45 dBA Leq nighttime (10:00 p.m. to 7:00 a.m.). The loading dock area noise
levels along the nearest property boundaries from truck loading activity (the northern and southern
boundaries) would average 67 dBA Leq; the noise levels at the other property boundaries would be lower
because of the greater distances. These levels are less than the City’s noise standards for manufacturing
(70 dBA Leq daytime or nighttime). Therefore, impacts associated with truck loading docks and truck yard
noise would be less than significant.
b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less-than-Significant Impact. Construction activities have the potential to expose persons to excessive
ground-borne vibration or ground-borne noise. Caltrans has collected ground-borne vibration information
related to construction activities indicating that continuous vibrations with a peak particle velocity of
approximately 0.1 inches/second begin to annoy people.20 The heavier pieces of construction equipment,
such as an excavator, would have peak particle velocities of approximately 0.089 inches/second or less at
a distance of 25 feet.21 Ground-borne vibration is typically attenuated over short distances. At the distance
from the nearest vibration-sensitive uses (i.e., residences) to the project site (approximately 220 feet), and
with the anticipated construction equipment, the peak particle velocity vibration level would be
approximately 0.003 inches/second. This vibration level would be well below the vibration threshold of
potential annoyance of 0.1 inches/second.
The major concern with regard to construction vibration is related to building damage. Construction
vibration as a result of the project would not result in structural building damage, which typically occurs at
vibration levels of 0.5 inches/second or greater for buildings of reinforced-concrete, steel, or timber
construction. The heavier pieces of construction equipment used would include typical construction
20 Caltrans. 2013b. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental
Engineering, Hazardous Waste, Air, Noise, Paleontology Office. September, 2013
21 DOT (U.S. Department of Transportation). 2018. Transit Noise and Vibration Impact Assessment Manual. DOT, Federal Transit
Administration. September 2018.
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equipment for this type of project, such as backhoes, front-end loaders, and flatbed trucks. Pile driving,
blasting, and other special construction techniques would not be used for construction of the project;
therefore, excessive ground-borne vibration and ground-borne noise would not be generated. Vibration
levels from project construction would be less than the thresholds of annoyance and potential for structural
damage. Furthermore, there would be no operational activities associated with the project. Therefore,
groundborne vibration impacts would be less than significant.
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?
No Impact. The closest public airport to the Project site is Compton/Woodley Airport, which is located
approximately 7.2 miles west/southwest of the project site in the City of Compton. The next-nearest airport
is Long Beach Municipal Airport, located approximately 7.4 miles to the south. According to the Los Angeles
County Airport Land Use Plan (ALUC 2014), the project site is not in proximity to the planning boundary or
airport influence area of any airports. No private airstrips are located within the vicinity of the project site
(AirNav 2019). Thus, air traffic noise associated with airports would not expose construction workers, staff,
or students to excessive noise levels. Therefore, no impacts associated with airport noise would occur.
3.14 Population and Housing
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?
a) Would the project induce substantial unplanned population growth in an area, either directly (for example,
by proposing new homes and businesses) or indirectly (for example, through extension of roads or
other infrastructure)?
Less-than-Significant Impact. The project would include the demolition of a n existing, 74,662 -square-
foot industrial building and construction of an approximately 44,162-square -foot industrial tilt -up
building (industrial building) for truck terminal use. No residential use or other land uses typically
associated with directly inducing population growth are included as part of the project.
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It is anticipated that construction workers would come from the local labor force, and given the temporary
nature of the construction work, it is unlikely construction workers would relocate to the area as a result of
the project. However, because the project is not a nonresidential use that typically induces substantial
population growth (i.e., universities, large business centers, or other uses that result in substantial
relocation of employees or stimulate substantial growth of the area through economic means), it is
assumed that the project would not likely induce substantial population growth through employees
relocating to the area.
SCAG is a metropolitan planning organization that represents the Counties of Ventura, Los Angeles, San
Bernardino, Orange, Riverside, and Imperial. As part of the 2016 –2040 RTP/SCS, SCAG has prepared
population, household, and employee projections for the region. Table 25 shows the employee projections
from 2012 to 2040 for the City of Downey.
Table 25. Employment Growth for the City of Downey
2012 2040
Employment 47,500 53,000
Source: SCAG 2016.
The proposed industrial building would introduce 15 to 30 new employees to the City of Downey. This
increase would be 0.2% to 0.5% of SCAG’s overall projected growth of 5,500 employees for the City from
2012 to 2040. As such, employee 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.
Furthermore, the project would connect to existing utilities and infrastructure already located in the project
area and would not construct new or extend existing utilities or infrastructure into areas not currently served
by such improvements. Therefore, impacts associated with both direct and indirect population growth
inducement would be less than significant.
b) Would the project displace substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere?
No Impact. The project site is currently developed with an existing industrial building. There are no existing
residential uses on the project site, and the project would not displace any existing housing or population.
Therefore, no impacts associated with displacing substantial numbers of existing people or housing would occur.
Exhibit F PC Agenda Page 182
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
100 December 2020
3.15 Public Services
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XV. PUBLIC SERVICES
a) 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 environmental impacts, in order to maintain acceptable
service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
a) 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 environmental impacts, in order to maintain acceptable
service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Less-than-Significant Impact: Fire services in the City are provided by the Downey Fire Department (DFD),
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 Fire Department. DFD has four stations in four corresponding fire
districts. The first-alarm response to structure fires in the City consists of three engine companies, one
ladder truck, a paramedic squad and a Battalion Chief (totaling 16 personnel). The project site would be
served by Fire Station 2 (9556 Imperial Highway), located approximately 0.6 miles southwest of the project
site. The estimated response times to service calls for DFD is 3 to 4 minutes. 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 nearest unit regardless of the jurisdictional
boundary (City of Downey 2005).
The project site is already within the DFD service area, and once operational, the project would continue to
be served by DFD. As previously discussed in Section 3.14, Population and Housing, the project would not
induce substantial population growth in the City. Because the project site currently supports existing
industrial operations, calls for service to the project site in comparison to the existing conditions would be
similar to the baseline conditions. Overall, it is anticipated that the project would be adequately served by
existing DFD facilities, equipment, and personnel. Therefore, impacts associated with the construction or
expansion of fire protection facilities would be less than significant.
Exhibit F PC Agenda Page 183
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101 December 2020
Police protection?
Less-than-Significant Impact: Police services in the City are provided by the 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. DPD (10911 Brookshire Avenue) would service the project site and is located
approximately 1 mile northwest of the project site. 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 aid
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 not
induce substantial population growth in the City. Because the project site currently supports existing
industrial operations, calls for service to the project site in comparison to the existing conditions would be
similar to the baseline conditions. Overall, it is anticipated that the project would be adequately served by
existing DPD facilities, equipment, and personnel. Therefore, impacts associated with the construction or
expansion of police protection facilities would be less than significant.
Schools?
Less-than-Significant Impact: Elementary through high school education in the City is provided by the Downey
Unified School District. As previously mentioned, the project would not induce substantial population growth in
the City. As such, a significant increase in school-age children requiring public education is not expected to occur,
and there would be no need for the development of additional schools. Therefore, impacts associated with the
construction or expansion of school facilities would be less than significant.
Parks?
Less-than-Significant Impact: Refer to response provide in Section 3.16(a).
Other public facilities?
Less-than-Significant Impact: As previously mentioned, the project would not induce substantial population
growth in the City. Employee 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, a substantial increase in
patronage at libraries, community centers, and other public facilities is not expected. Therefore, impacts
associated with other public facilities would be less than significant.
Exhibit F PC Agenda Page 184
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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102 December 2020
3.16 Recreation
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVI. RECREATION
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) 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?
Less-than-Significant Impact: As previously discussed in Section 3.14(a), Population and Housing, no
residential use or other land uses typically associated with directly inducing population growth are included
as part of the project. Additionally, the project is industrial in nature and does not include recreational
facilities. However, construction and operation of the project would generate temporary an d permanent
employees. It is anticipated that construction workers would come from the local labor force, and given the
temporary nature of the construction work, it is unlikely construction workers would relocate to the area as
a result of the project. However, this analysis conservatively assumes that all 15 to 30 new permanent,
employees would relocate to the area. However, employee 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, an increase in patronage at park facilities is not expected.
State law (the Quimby Act) authorizes cities to require developers to either dedicate land for parks and/or
provide a fee in lieu of land dedication. The City developed a fee amount charged for new housing units
constructed and has collected a significant amount used towards park maintenance. As part of a move
towards recovering costs associated with new developments, there is an opportunity to expand the fees
charged for development to fund park maintenance and upgrade (City of Downey 2005).
Therefore, because the project would not propose any recreational facilities, the number of permanent
employees would be well within SCAG’s overall growth projections for the City, and the City would continue
to maintain and upgrade existing parks; impacts associated with parks would be less than significant.
Exhibit F PC Agenda Page 185
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103 December 2020
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?
Less-than-Significant Impact: Refer to response provide in Section 3.16(a).
3.17 Transportation
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan, ordinance, or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?
b) 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?
This section analyzes the impacts of the project based on CEQA Guidelines Section 15064.3(b), which focuses on
newly adopted criteria (vehicle miles traveled, or VMT) pursuant to SB 743 for determining the significance of
transportation impacts. Pursuant to SB 743, the focus of transportation analysis changed from LOS or vehicle delay
to VMT. The related updates to the CEQA Guidelines required under SB 743 were approved on December 28, 2018.
Accordingly, for CEQA purposes, this section analyzes the project-related impacts pertaining to VMT.
A congestion-based (LOS) analysis has been prepared and is provided for informational purposes only in Appendix C.
a) Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadway, bicycle, and pedestrian facilities?
Less-Than-Significant Impact. The study area intersections analyzed in the TIA, Appendix C, with exception
of the I-605 freeway ramp intersections with Firestone Boulevard, are located within the jurisdiction of the
City of Downey, therefore, the following consistency requirements would apply.
Exhibit F PC Agenda Page 186
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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104 December 2020
Downey Vision 2025 Circulation Chapter
This analysis uses the LOS threshold provided in the Downey Vision 2025 Circulation Element of the current
General Plan (City of Downey 2005) for the intersections located within the City of Downey. The Circulation
Element defines acceptable LOS as “A,” “B,” “C,” or “D,” along with the following applicable policy and program:
Policy 2.1.1. Maintain a street system that provides safe and efficient movement of people and goods.
• Program 2.1.1.1. Maintain intersections and street segments at acceptable service levels and not
worsen those intersections and street segments currently operating at unacceptable levels.
For the purposes of this analysis, an intersection or street segment would be found inconsistent with the
City’s Circulation Chapter if project traffic causes a roadway to go from an acceptable LOS to a deficient
LOS. For intersections and roadway segments already operating at an unacceptable LOS, any increase in
the volume-to-capacity ratio for intersections and street segments would be found inconsistent with the
City’s Circulation Chapter. As shown in the TIA (Appendix C), the study area intersections located within the
City of Downey would not be inconsistent with the LOS D standard as defined in the Circulation Chapter,
and as set forth by Program 2.1.1.1 under Policy 2.1.1 noted above. Impacts related to applicable General
Plan policies/programs related to traffic would be less-than-significant.
Transit Facilities
Currently, the City of Downey is served by the Los Angeles County Metropolitan Transportation Authority
(Metro). Metrolink service in the City is provided via the Green Line at the Lakewood Boulevard Station ,
located approximately 1.5 miles southwest of the project site, as well as the Norwalk Station, located
approximately 1 mile southeast of the project site (Metro 2018).
Additionally, the following Metro bus lines are located within 0.5 miles of the project site:
• Line 115 operates between Playa Del Rey and the Norwalk Metrolink Station with a peak service
frequency of 15 minutes. Line 115 primarily operates along Firestone Boulevard within the City of
Downey (Metro 2020a).
• Line 127 operates between Compton Station/MLK Jr. Transit Center and the Downey Deport
Transit Center with a peak service frequency of 60 minutes. Line 127 primarily operates along
Bellflower Boulevard within the City of Downey (Metro 2020b).
The nearest bus stops are located at Bellflower Boulevard/Washburn Road, serving Line 127, and Firestone
Boulevard/Steward and Gray Road, serving Line 115. Development of the project would not conflict with
the existing bus routes or bus stops. Impacts to transit would be less-than-significant.
Pedestrian and Bicycle Facilities
There are currently no designated bicycle facilities within the City of Downey, aside from the San Gabriel
River Trail, as shown in Figure 18, City of Downey Transit and Bicycle Facilities. The Southern California
Regional Bikeway shapefile identifies potential bicycle routes within the City, also identified in Figure 18.
Additionally, the Downey Bike Master Plan Implementation Phase 1 Downtown/Transit project under
Exhibit F PC Agenda Page 187
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105 December 2020
Capital Improvement Program 19-14 would include installation of Class II bicycle facilities on nine roadway
segments, bicycle parking facilities, and way-finding signs (City of Downey 2020b).
Woodruff Avenue, which runs adjacent to the eastern boundary of the project site, is generally built with
paved sidewalks and pedestrian facilities along both sides of the street. Additionally, the Woodruff Avenue
Pavement Rehabilitation project under Capital Improvement Project 14-14 would not only include
rehabilitation of asphalt pavement on the roadway but would also include miscellaneous repairs of existing
concrete sidewalks, curb and gutter, driveway approaches, and Americans with Disabilities Act-compliant
curb access ramps. Development of the project would not conflict with the existing pedestrian or bicycle
facilities and would include frontage improvements to pedestrian facilities around the project site. Impacts
to pedestrian or bicycle facilities would be less than significant.
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less-Than-Significant Impact. CEQA Guidelines Section 15064.3(b) focuses on VMT for determining the
significance of transportation impacts. As shown in the analysis below, the project’s impact due to conflict
or inconsistency with Section 15064.3(b) would be less than significant.
Vehicle Miles Traveled
The CEQA Guidelines state that “generally, vehicle miles traveled (VMT) is the most appropriate measure
of transportation impacts” and define VMT as “the amount and distance of automobile travel attributable
to a project….” It should be noted that “automobile” refers to on-road passenger vehicles, specifically cars
and light trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation
(for example, where models or data provide combined auto and heavy truck VMT). Other relevant
considerations may include the effects of the project on transit and non -motorized travel. The OPR
Technical Advisory (OPR 2018) provides guidance and tools to properly carry out the principles within SB
743 and how to evaluate transportation impacts in CEQA. The OPR Technical Advisory was utilized within
this analysis as the primary source of analysis of VMT and transportation -related impacts.
Screening Criteria for VMT Analysis
The Technical Advisory suggests that agencies may screen out VMT impacts using project size, maps, transit
availability, and provision of affordable housing.
Screening Threshold for Small Projects (110 daily trips or less). Table 26 uses trip generation rates from
the Institute of Transportation Engineers (ITE) Trip Generation, 10th edition (2017) and 9th edition (2012)
for land use category Intermodal Truck Terminal (ITE Code 30), and employee trip generation rate for
Manufacturing use. A trip credit for the existing full on-site operational activities of the existing site was
factored. After adjusting for the passenger car equivalent (PCE) factor, and using the City of Fontana Truck
Trip Generation Study Truck Terminal vehicle mix and percentage splits, the project would generate
approximately 232 net daily trips, 53 AM peak hour net trips (-5 inbound and 58 outbound), and 55 PM
peak hour trips (41 inbound and 14 outbound).
Exhibit F PC Agenda Page 188
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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106 December 2020
Table 26. Project Trip Generation for 12021 Woodruff Avenue Industrial Building Project
Land Use
ITE
Code Size/Units Daily
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Trip Rates1, 2
Intermodal Truck
Terminal
30 Acres 81.90 — — — — — —
Intermodal Truck
Terminal
30 TSF — 0.93 1.04 1.97 0.97 0.90 1.87
Manufacturing 140 Employees 2.47 0.27 0.10 0.37 0.13 0.20 0.33
Trip Generation
Woodruff Truck
Terminal
30 6.310 /Acres 517 19 27 46 18 24 41
Woodruff Truck
Terminal
30 44.162/TSF 0 41 46 87 43 40 83
Existing Site 140 200/ Employees 494 55 19 74 26 40 66
Existing Site Trip Generation (w/PCE)
Vehicle Mix3 Percent3
Passenger Vehicles 69.0% 341 38 13 51 18 28 46
Two-Axle Trucks 6.8% 34 4 1 5 2 3 5
Three-Axle Trucks 5.5% 27 3 1 4 1 2 3
Four+-Axle Trucks 18.7% 92 10 4 14 5 8 13
Vehicle Mix3 PCE Factor4
Passenger Vehicles 1.0 341 38 13 51 18 28 46
Two-Axle Trucks 2.0 67 7 3 10 4 5 9
Three-Axle Trucks 2.0 54 6 2 8 3 4 7
Four+-Axle Trucks 3.0 277 31 11 42 14 23 37
Existing Site Trip Generation W/PCE 740 82 29 111 39 60 99
Project Trip Generation (w/PCE)
Vehicle Mix5 Percent5
Passenger Vehicles 46.0% 238 19 21 40 20 18 38
Two-Axle Trucks 6.1% 32 2 3 5 3 2 5
Three-Axle Trucks 13.9% 72 6 6 12 6 6 11
Four+-Axle Trucks 34.0% 176 14 16 30 15 13 28
Vehicle Mix5 PCE Factor4
Passenger Vehicles 1.0 238 19 21 40 20 18 37
Two-Axle Trucks 2.0 63 5 6 11 5 5 10
Three-Axle Trucks 2.0 144 11 13 24 12 11 23
Four+-Axle Trucks 3.0 527 42 47 89 44 40 84
Project Trip Generation W/PCE 972 77 87 164 80 74 154
Total Net Project Trip Generation (Project - Existing) 232 -5 58 53 41 14 55
Notes: ITE = Institute of Transportation Engineers; TSF = thousand square feet; PCE = passenger car equivalent.
1 ITE 2017.
2 ITE 2012.
3 SCAQMD 2014.
4 PCE factors are assumed to be 1.0 for passenger vehicles, 2.0 for medium trucks, and 3.0 for heavy truc ks.
5 City of Fontana 2003.
Exhibit F PC Agenda Page 189
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107 December 2020
Since the project generates more than 110 trips per day, it cannot be assumed to cause a less -than-
significant transportation impact.
• Presumption of Less-than-Significant Impact for Affordable Residential Development: The project
does not propose affordable residential units and is not a residential development.
• Map-Based Screening for Residential and Office Projects: This criterion applies to residential and
office projects and currently, the City does not have VMT maps that can be used to identify areas
with low VMT for projects.
• Presumption of Less-than-Significant Impact Near High Quality Transit Corridor22: Figure 18, Transit
and Bicycle Facilities, illustrates the project’s location and transit facilities around the project.
Metro Bus Line 115 operates with a service frequency of 15 minutes, between Playa Del Rey and
the Norwalk Metrolink Station. Since the project is within 0.5 miles of a high-quality transit corridor
(i.e., a fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours) it can be presumed to have a less-than-significant impact. Additionally, the
Norwalk Metrolink station is located approximately 1 mile southeast of the project site.
Furthermore, the presumption of less than significant does not apply if the project:
• Includes more parking for use by residents, customers, or employees of the project than required
by the jurisdiction (if the jurisdiction requires the project to supply parking);
• Is consistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization; or
• Replaces affordable residential units with a smaller number of moderate or high-income residential units.
The project does not include more parking than required by the City of Downey, as discussed in the TIA and
detailed in Section 2, Project Description. Additionally, the project use (with the exception of westernmost
portion of the project site which is designated as a Parking Buffer) is consistent with the City of Downey
General Plan Land use designation of General Manufacturing. Furthermore, the project does not involve a
residential component. Therefore, the above items would not apply to the project, and the project can be
screened out under the proximity to high quality transit corridor screening criteria.
The project's employees would have access to a high-quality transit corridor, and the project would not
provide more parking for use than required by the jurisdiction. A project-level detailed VMT analysis would
not be required, and the project would not be inconsistent with CEQA Guidelines Section 15064.3,
subdivision (b); therefore, the impact would be less than significant. In addition, in an abundance of caution
and to further minimize an already less-than-significant impact related to VMT, the project would implement
a transportation demand management plan, as described in project design feature (PDF) TRA-1:
22 A Transit Priority Area is defined as a 0.5-mile area around an existing major transit stop or an existing stop along a high quality transit quality
corridor per definition below:
California Public Resources Code, Section 21064.3 - ‘Major transit stop’ means a site containing an existing rail transit station, a ferry terminal
served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes
or less during the morning and afternoon peak commute periods.
California Public Resources Code, Section 21155 - For purposes of this section, a ‘high-quality transit corridor’ means a corridor with fixed route
bus service with service intervals no longer than 15 minutes during peak commute hours.
Exhibit F PC Agenda Page 190
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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108 December 2020
PDF-TRA-1 Transportation Demand Management Plan: Prior to issuance of a Business License, the
tenant shall prepare a Transportation Demand Management plan to discourage single-
occupancy vehicle trips made by employees, and encourage them to use alternative modes
of transportation such as carpooling, taking transit, walking, and biking to/from the site.
Examples of trip reduction measures may include, but are not limited to:
• Transit passes
• Car-sharing programs
• Telecommuting and alternative work schedules
• Ride sharing programs
Furthermore, the project is intended to be used as a trucking terminal for distribution and logistics
purposes. On-site activities will include storage of and/or consolidation of manufactured goods before the
distribution to retail locations or other warehouses. Thus, the project will serve as an intermediary land use
between the Ports of Los Angeles and Long Beach and the next/final destination (warehouses) of the
products shipped through the trucks-trailers using the project.
There are four freeways that provide direct access to the City of Downey: I-710, I-605, I-5, and I-105. I-710
is located west of the City and accessible via three major streets: Florence Avenue, Firestone Boulevard,
and Imperial Highway. Figure 17 illustrates the truck routes in the City. Firestone Boulevard, Woodruff
Avenue, Stewart and Gray Road, and Bellflower Boulevard are designated truck routes that connect the City
with neighboring jurisdictions. The City of Downey is located approximately 14 miles and 12 miles northeast
of the Ports of Los Angeles and Long Beach, respectively.
The proximity to freeway and ports would reduce the project’s trips on other roadways and facilitate tractor
trailer traffic destined for pick-up/drop-off of containers. The Ports of Los Angeles and Long Beach are the
two largest container ports in the United States. The growth of the ports has been steady, and it is forecast
to double in the next two decades, according to its most recent forecast. The ports’ growth would have a
significant impact on local economy and directly or indirectly provide for more jobs in the region. Therefore,
the City would benefit from developing the site as a use that benefits from its proximity to the ports.
c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less-Than-Significant Impact. The project would not include construction of any new roadways,
modifications to any existing roadway or intersection geometry, or temporary road closures during
construction. Any and all improvements required within the public right-of-way 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 roadway facilities.
As the project is an industrial use expected to generate heavy truck traffic, a queuing analysis was completed at
both driveways. Additionally, since the project has the potential to add traffic to nearby freeway facilities, a
queuing analysis was conducted at freeway off-ramp intersections within the study area. Queuing was analyzed
utilizing the SimTraffic software, which calculates the 95th percentile (design) queue. All queuing analysis data
and SimTraffic queuing worksheets are further provided below and in the TIA.
Exhibit F PC Agenda Page 191
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109 December 2020
Future Year Conditions
Both project site access and freeway off-ramp facilities were analyzed and compared plus project conditions to
baseline future year conditions. For the purposes of this analysis, the baseline future year condition is the
Existing plus Ambient Growth plus Cumulative Project (EAC) scenario. The EAC scenario consists of existing traffic
volumes, ambient growth from the background growth of traffic within the study area, and cumulative projects.
Due to the Covid-19 pandemic, existing traffic volumes were adjusted and balanced. Counts were originally
obtained in July 2020 for the following signalized intersections adjacent to the project site:
• Woodruff Avenue/Washburn Road
• Woodruff Avenue/Stewart and Gray Road
Historical traffic counts and traffic volumes from the following signalized intersections were obtained and were
collected during a typical weekday non-holiday period in the year listed:
• Woodruff Avenue/Stewart and Gray Road – 2015
• Firestone Boulevard/Stewart and Gray Road – 2016
• I-605 southbound ramps/Firestone Boulevard – 2016
• I-605 northbound ramps – Hoxie Avenue/Firestone Boulevard – 2016
By calculating the difference between pre-Covid conditions and historical traffic count data, it was determined
that the July 2020 traffic volumes were substantially lower due to the Covid-19 pandemic. Thus, traffic volumes
collected in 2020 were adjusted and balanced to reflect the conditions of the historical traffic counts.
Subsequently, all traffic counts were grown 4 years (approximately 1% per year) according to the growth rates
listed from the year 2015 to 2020 Downey Regional Statistical Area as described in the Los Angeles County
Congestion Management Program (Metro 2010).
Once traffic counts at the signalized intersections were grown and balanced to reflect pre-Covid 2020 baseline
conditions, an ambient growth rate of 0.24% per year was derived from the growth rates listed in the Downey
Regional Statistical Area from the year 2020 to 2025. The growth was applied based upon the projected opening
year of the project being 2022; therefore, a total growth of 0.48% was added to the 2020 baseline existing traffic
volumes. Finally, the City of Downey Planning Department and the City of Norwalk Planning Department provided
a list of cumulative projects within the study area. Thereafter, the Project Trip Generation as shown in Table 26
was added to the EAC scenario so that the traffic impacts of the project could be fully analyzed. The TIA provides
additional detail and information for the analysis and discussion on traffic volumes.
Project Site Access
As discussed previously in Section 2, Project Description, access to the project site would be provided via two
driveways. Both driveways would be provided along Woodruff Avenue and would be approximately 40 feet wide:
• Driveway 1 (North) via Woodruff Avenue: Full access for passenger cars and inbound only (right-
in/left-in) for trucks (no truck exit)
• Driveway 2 (South) via Woodruff Avenue: Full access for passenger cars and outbound only (right-
out/left-out) for trucks (no truck entry)
Exhibit F PC Agenda Page 192
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110 December 2020
Both driveways would lead to passenger vehicle parking lots on the northeast and southeast corners of the
project site. The parking lots would be connected by a north–south through-lane, which provides additional
passenger vehicle parking spaces along the eastern boundary of the site. On the west side of both parking
lots would be a gated driveway leading to truck courts, truck parking stalls, and loading docks. The project
would include 56 parking spaces for passenger vehicles (52 standard, 2 accessible parking, and 2 van
accessible parking), 76 spaces for cargo containers, and 70 loading docks (refer to Figure 8, Site Plan).
As shown in Table 27, peak 95th percentile queues are not forecast to exceed any of the storage pocket
lengths at existing intersections or at either driveway. Therefore, the project will not create a significant
impact to the project driveways or adjacent intersections, and hazards due to geometric design features
will be less than significant.
Caltrans Freeway Off-Ramp
Due to the potential of the project to add traffic to Caltrans facilities within the study area, the following
Caltrans freeway off-ramps were analyzed for queuing impacts:
• I-605 southbound ramps/Firestone Boulevard
• I-605 northbound ramps - Hoxie Avenue/Firestone Boulevard
As shown in Table 28, peak 95th percentile queues are expected to exceed the storage pocket lengths in
the following intersections and lanes:
• PM Peak Hour: I-605 southbound ramps/Firestone Boulevard (southbound left-turn lane)
o This lane extends from the intersection to the freeway mainline, and it is expected that
forecasted queues would extend past the gore point and into the mainline.
• Both AM and PM Peak Hour: I-605 northbound ramps - Hoxie Avenue/Firestone Boulevard
(southbound right-turn lane)
o This is a storage lane and adjacent lanes possess queues that are not forecast to extend to
the freeway mainline.
However, when comparing the EAC scenario with the addition of the project, the forecasted queues will
either not change or will be slightly reduced from the baseline condition. For the I-605 southbound ramp,
approximately 45 feet of queue will be reduced with the addition of the project, approximately two vehicle
car lengths. For the I-605 northbound ramps, forecasted queues are expected to remain the same with the
addition of the project. Therefore, the project will not create a significant impact to the Caltrans freeway off-
ramps, and hazards due to geometric design features will be less than significant.
Exhibit F PC Agenda Page 193
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111 December 2020
Table 27. Existing plus Ambient Growth plus Cumulative Projects plus Project Driveway and Project Access Queuing Summary
Intersection Movement
Pocket
Length1
Existing plus Ambient Growth plus
Cumulative Projects
Existing plus Ambient Growth plus
Cumulative Project plus Project
Improvement
Warranted
AM Peak Hour PM Peak Hour AM Peak Hour PM Peak Hour
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
Woodruff
Avenue/Washburn
Road
SBL 125 90 No 61 No 82 No 56 No No
SBT3 175 143 No 132 No 143 No 139 No No
SBTR3 175 152 No 141 No 154 No 150 No No
Woodruff
Avenue/North
Project Driveway
EBLR4 150 — — — — 18 No 0 No No
NBL5 50 — — — — 0 No 12 No No
SBTR6 200 — — — — 0 No 0 No No
Woodruff
Avenue/South
Project Driveway
EBLR4 150 — — — — 79 No 48 No No
NBL5 200 — — — — 0 No 0 No No
SBTR6 125 — — — — 48 No 45 No No
Source: Appendix C.
Notes: SBL = southbound left lane; SBT – southbound through lane; SBTR = southbound through-right lane; EBLR = eastbound left-right lane; NBL = northbound left lane.
1 Measured in feet.
2 Based on 95th percentile (design) queue length in SimTraffic 10.
3 Length measured to approximate distance of south project driveway.
4 Length measured according to the distance as shown on the s ite plan from the driveway entrance to truck parking gate.
5 Length measured as available left-turn pocket or two-way left-turn lane.
6 Length measured as distance to nearest upstream driveway.
Exhibit F PC Agenda Page 194
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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112 December 2020
Table 28. Existing plus Ambient Growth plus Cumulative Projects plus Project Caltrans Off-Ramp Queuing Summary
Intersection Movement
Pocket
Length1
Existing plus Ambient Growth plus
Cumulative Projects
Existing plus Ambient Growth plus
Cumulative Project plus Project
Improvement
Warranted
AM Peak Hour PM Peak Hour AM Peak Hour PM Peak Hour
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
95th
Percentile
Queue2
Exceeds
Turn
Pocket
Length?
I-605 southbound
ramps/Firestone
Boulevard
SBL3 825 160 No 1,216 Yes 388 No 1,171 Yes No
SBR 275 229 No 241 No 254 No 237 No No
SBR 275 209 No 100 No 225 No 140 No No
I-605 northbound
ramps - Hoxie
Avenue/Firestone
Boulevard
SBL 275 60 No 210 No 69 No 208 No No
SBLT3 2,950 2,137 No 1,281 No 2,288 No 2,307 No No
SBT3 2,950 1,985 No 1,672 No 1,930 No 2,187 No No
SBR4 210 235 Yes 270 Yes 235 Yes 235 Yes No
Source: Appendix C.
Notes: SBL = southbound left lane; SBR – southbound right lane; SBLT = southbound through -left lane; SBT = southbound through lane.
1 Measured in feet.
2 Based on 95th percentile (design) queue length in SimTraffic 10.
3 Primary off-ramp lane; approximate length measured from freeway mainline. Length measured from stop bar to gore line at mainline.
4 While queue exceeds storage lane, the total length of the off-ramp is greater than the queue, therefore queue would not impact the mainline lanes.
Exhibit F PC Agenda Page 195
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
12818
113 December 2020
d) Would the project result in inadequate emergency access?
No Impact. Site access will be provided via the two driveways located along Woodruff Avenue. Emergency
vehicle access will be available at all driveways and facilitated within the entirety of the project site. The project
site would be accessible to emergency responders during construction and operation of the project. Therefore,
no impacts associated with an emergency response plan or emergency evacuation plan would occur.
3.18 Tribal Cultural Resources
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVIII. TRIBAL CULTURAL RESOURCES
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California
Native American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k), 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?
CEQA was amended in 2014 through Assembly Bill 52 (AB 52), which created a new category of “tribal culture
resources” (TCRs) that must be considered under CEQA and applies to all projects that file a notice of preparation,
notice of negative declaration, or MND on or after July 1, 2015. AB 52 requires lead agencies to provide notice to
and begin consultation with California Native American tribes that are traditionally and culturally affiliated with the
geographic area of a project if that tribe has requested, in writing, to be kept informed of projects by the lead agency
prior to the determination of whether a negative declaration, MND, or environmental impact report will be prepared.
If a tribe requests consultation within 30 days upon receipt of the notice, the lead agency must consult with the
tribe. AB 52 also specifies mitigation measures that may be considered to avoid or minimize impacts to tribal
cultural resources. Specifically, California Public Resources Code, Section 21074, provides the following guidance:
(a) Tribal Cultural Resources are either of the following:
Exhibit F PC Agenda Page 196
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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114 December 2020
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a
California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of Cultural
Resources.
(B) Included in a local register of cultural resources as defined in subdivision (k) of §5020.1.
(2) 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 §5024.1. In
applying the criteria set forth in subdivision (c) of §5024.1 for the purposes of this paragraph,
the lead agency shall consider the significance of the resource to a California Native American
tribe.
(b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the extent
that the landscape is geographically defined in terms of the size and scope of the landscape.
(c) A historical resource described in Section 21084.1, a unique archaeological resource as defined in
subdivision (g) of Section 21083.2, or a “nonunique archeological resource” as defined in subdivision
(h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision
(a).
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource,
defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural
value to a California Native American tribe, and that is:
i) 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)?
Less-than-Significant Impact. No previously recorded archaeological resources of Native American
origin or TCRs listed in the CRHR or a local register were identified within the project site through
the South Central Coastal Information Center records or Native American coordination. Additionally,
no specific, designated TCRs were identified by California Native American tribes as part of the
City’s AB 52 notification and consultation process (see Section 3.17(b)(ii) below for a description
of this process). As such, the project would not adversely affect TCRs that are listed or eligible for
listing in the state or local register. Therefore, impacts associated with TCRs listed in the CRHR or
a local register would be less than significant.
ii) 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?
Less-than-Significant Impact with Mitigation Incorporated. Under CEQA, an effect to a TCR is
considered a “substantial adverse change,” if it is shown that the change would materially impair
Exhibit F PC Agenda Page 197
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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115 December 2020
the significance of the historical resource. That is, a project that demolishes or materially alters in
an adverse manner those physical characteristics of a historical resource conveying its historic
significance would materially impair the significance of a historical resource. Therefore, such a
change would constitute a “substantial adverse change” under CEQA.
As previously mentioned, no Native American or tribal cultural resources were identified within the
project site as a result of the CHRIS records search. The NAHC was contacted on August 14, 2020,
for a review of their Sacred Lands File (SLF) as part of the process of identifying cultural resources
within or near the project site. The NAHC replied via email on September 17, 2020, stating that the
results of the SLF search were negative. Because the SLF search does not include an exhaustive
list of Native American cultural resources, the NAHC also suggested contacting an additional eight
Native American individuals and/or tribal organizations who may have direct knowledge of cultural
resources in or near the project site. No additional tribal outreach was conducted by Dudek;
however, in compliance with AB 52, the City has contacted all NAHC-listed traditionally
geographically affiliated tribal representatives that have requested project notification.
Pursuant to AB 52, lead agencies are required to notify California Native American Tribal
representatives (that have requested notification) who are traditionally or culturally affiliated with
the geographic area of the project. The City mailed notification letters for the project to all NAHC-
listed California Native American Tribal representatives that have requested project notification
pursuant to AB 52 on August 31, 2020.
As a result of the notification letters, one tribe requested consulting party status: the Gabrieleno
Band of Mission Indians – Kizh Nation. The response from representative Andrew Salas of the
Gabrieleno Band of Mission Indians – Kizh Nation was received on September 8, 2020. However,
after several unsuccessful attempts to contact the Gabrieleno Band of Mission Indians – Kizh
Nation to schedule a consultation meeting, no response has been received by the City, and
consultation between the City and the Gabrieleno Band of Mission Indians – Kizh Nation has not
occured to date. Given this lack of response, the City considers the AB 52 consultation process
completed.
There are no TCRs within the immediate vicinity of the project site that have been determined by
the City to be significant pursuant to the criteria set forth in Public Resources Code Section 5024.1.
However, the Gabrieleno Band of Mission Indians – Kizh Nation’s initial interest in consulting on
this project suggests that there is some potential for unknown subsurface TCRs to be present in
the project area. In the event that unknown subsurface TCRs are uncovered during construction
ground disturbance, and such resources are not identified and avoided or properly treated, a
potentially significant impact could result. However, implementation of MM-TCR-1 during project
construction would reduce impacts to TCRs to below a level of significance, as it would set forth
steps to ensure that that if potential TCRs are unearthed, they would be appropriately treated and
preserved. Therefore, impacts would be less than significant with mitigation incorporated. No
further mitigation is required.
MM-TCR-1 While no tribal cultural resources (TCRs) have been identified that may be affected by the project,
the following approach for the unanticipated discovery of TCRs has been prepared to reduce
potential impacts to unanticipated resources. Should a potential TCR be encountered, construction
Exhibit F PC Agenda Page 198
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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116 December 2020
activities near the potential TCR shall be temporarily halted within 50 feet of the potential TCR and
the City of Downey (City) shall be notified. The City will notify Native American tribes that have been
identified by the Native American Heritage Commission (NAHC) to be traditionally and culturally
affiliated with the geographic area of the project. If the unanticipated resource is archaeological in
nature, appropriate management requirements shall be implemented as outlined in mitigation
measure MM-CUL-1. If the City determines that the potential resource is a TCR (as defined by Public
Resources Code, Section 21074), tribes consulting under AB 52 would be provided a reasonable
period of time, typically five days from the date a new discovery is made, to conduct a site visit and
make recommendations regarding future ground disturbance activities as well as the treatment
and disposition of any discovered TCRs. A qualified archaeologist shall implement a plan for the
treatment and disposition of any discovered TCRs based on the nature of the resource and
considering the recommendations of the tribe(s). All activities shall be conducted in accordance
with regulatory requirements.
3.19 Utilities and Service Systems
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment, or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
b) Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry, and multiple dry years?
c) Result in a determination by the wastewater
treatment provider, which serves or may
serve the project that it has adequate
capacity to serve the project’s projected
demand in addition to the provider’s
existing commitments?
d) Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals?
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
Exhibit F PC Agenda Page 199
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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117 December 2020
a) Would the project require or result in the relocation or construction of new or expanded water, wastewater
treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the
construction or relocation of which could cause significant environmental effects?
Less-than-Significant Impact: As discussed in Section 3.10(b), the project would increase the amount of
pervious surfaces on the project site by adding landscaped area. However, the majority of the project site
would remain impervious surface. Pursuant to the City’s Municipal Code Section 5707, the project has
prepared a LID plan to comply with City efforts to retain stormwater runoff generated from new construction
projects. In addition, the project would not require or result in the relocation or construction of new or expanded
water, wastewater treatment, electric power, natural gas, or telecommunication facilities for the reasons
discussed below.
Water Facilities
The project would include the demolition of an existing, 74,662-square-foot industrial building and
construction of an approximately 44,162-square-foot industrial building for truck terminal use. No
residential use or other land uses typically associated with directly inducing population growth are included
as part of the project. Additionally, as is discussed below in Section 3.19(b), the project would have sufficient
water supplies during normal, dry, and multiple-dry years. The City of Downey Water Department provides
domestic water to the project site. The project would connect to an existing 12-inch-diameter water line in
Woodruff Avenue for domestic and irrigation purposes (Figure 12, Existing Utilities). Therefore, impacts
associated water facilities would be less than significant.
Wastewater Treatment Facilities
The City is located within the jurisdictional boundaries of the Sanitation Districts of Los Angeles County, District
No. 2. The County Sanitation District operates 11 wastewater treatment facilities, 10 of which are classified as
water reclamation plants. Wastewater generated by the City is treated at the JWPCP located in the City of Carson,
which has a design capacity of 385 million gallons per day (mgd) and currently processes an average flow of
321.6 mgd, and the Los Coyotes WRP located in the City of Cerritos, which has a design capacity of 37.5 mgd
and currently processes an average flow of 32 mgd (City of Downey 2004).
Under existing conditions, the project site supports an industrial building and contributes to the overall
wastewater generated within the City. As such, the project site would connect to an existing 21-inch-diameter
sewer line in Woodruff Avenue for sewage conveyance purposes (Figure 12, Existing Utilities). Upon completion
of construction, the project would be smaller than the existing onsite building and would employee fewer
workers. Thus, wastewater generated by the project is expected to be less than produced under existing
conditions. Therefore, impacts associated wastewater treatment facilities would be less than significant.
Stormwater Drainage Facilities
As discussed in Section 3.10(b), the project site is developed and is composed entirely of impervious
surfaces. Stormwater collected from on the existing building’s roof drains towards the southwest portion of
the project site and is conveyed through the site south of the project site, where it is discharged into an
existing storm drain within Washburn Road via a parkway culvert. Runoff from the vehicle parking lot and
the landscaped area fronting Woodruff Avenue sheet flows toward the street, where it then drains via a
Exhibit F PC Agenda Page 200
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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118 December 2020
parkway culvert located at the southeast portion of the site into an existing 36-inch public storm drain within
Woodruff Avenue.
As part of the project, the project site would be graded so that stormwater collected via the building’s roof
and parking areas would be collected by concrete catchbasins and conveyed via underground pipes to an
underground stormwater detention chamber and proprietary biofiltration system (Figure 13, Proposed
Storm Drain System). The biofiltration system would utilize plants and soil media to treat stormwater before
ultimately being discharged into the adjacent existing 36-inch public storm drain system within Washburn
Road via an underdrain system and sump pump. Furthermore, because the project site is located on level
or gently sloping topography and is surrounded by urban land uses, the project is not anticipated to
substantially modify existing topography or runoff patterns. Therefore, impacts associated with stormwater
drainage facilities would be less than significant.
Natural Gas and Electric Service
Southern California Gas Company would provide natural gas service to the project site. The project would
connect to an existing 4-inch-diameter underground gas line within Woodruff Avenue (Figure 12, Existing
Utilities). Therefore, impacts associated with natural gas facilities would be less than significant.
Electric Power Facilities
Southern California Edison would provide electric service. The project would connect to existing overhead
electrical lines on the west side of project site by undergrounded electric lines (Figure 12, Existing Utilities).
Therefore, impacts associated with electrical power facilities would be less than significant.
Telecommunications Facilities
The City of Downey is served by multiple telephone service providers. Since the project site is in an
urbanized area and is surroun ded by other industrial uses, there are existing telecommunication
facilities that would be able to serve the project site. Furthermore, an existing overhead telephone line
located within Woodruff Avenue is located adj acent to the project site (Figure 12, Existing Utilities).
Once the project is com pleted, future employees would be able to connect to existing
telecommunication services without the need for expansion or construction of new facilities. Therefore,
impacts associated with telecommunications facilities would be less than significant.
b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable
future development during normal, dry, and multiple dry years?
Less-than-Significant Impact: As discussed in Section 3.10(b), Hydrology and Water Quality, the City
produces groundwater from the Central Basin. The Central Basin 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, resulting in an APA of 16,554
Exhibit F PC Agenda Page 201
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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119 December 2020
AFY. The City owns wells, 20 of which are currently operational and have a combined pumping capacity of
approximately 27,575 gallons per minute, or approximately 44,500 AFY if operated continuously (City of
Downey 2018).
In December 2013, the Supreme Court approved amendments to the Central Basin Judgment which
implemented a water storage program. The Amended Central Basin Judgment states, a party may store up
to 50% of the party’s APA in an Individual Storage Account and 150% of the party’s APA in a Community
Storage Account if space is available. In addition, the amendments allow parties to convert unused APA to
stored water and revised the amount of carryover to be equal to 60% of the party’s APA minus the amount
of carryover water set aside for storage. The purpose of the storage program creates an added reliability in
water supply from the Central Basin. In addition, the amendments allow for transfer of water between
Central Basin and West Basin by permitting parties with water rights in Central Basin to increase production
in Central Basin, while another party decreases production in West Basin by the corresponding amount.
Under the Central Basin Judgment, water rights are fixed and do not vary year to y ear. Water producers
cannot exceed their water rights by more than 20% or 20 acre-feet, whichever is greater, in any year and
an adjustment is made the following year (City of Downey 2018).
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 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 monitored, 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 of Downey 2018).
Furthermore, as a water purveyor, the City must be able to provide for the minimum health and safety water
requirements of the community at all times. Following the adoption of its Water Shortage Contingency Plan,
Ordinance No. 925, the City developed a four-stage water-rationing plan to be implemented during declared
water shortages. The four-stage water-rationing plan includes both voluntary and mandatory rationing,
which are to be implemented depending on the causes, severity, and anticipated duration of the water
supply shortage. The four-stage water-rationing plan is designed to allow for a minimum of 50% of the City’s
normal supply to be available during a severe or extended water shortage. Rationing program triggering
levels were established to ensure that this goal is met. Rationing stages are triggered by a supply shortage
due to drought conditions, contamination of one or a combination of sources, or some other type of
emergency (City of Downey 2018).
The City’s 2015 Urban Water Management Plan provides normal-year, single-dry-year, and multiple-dry-year
supply and demand analysis for the City’s domestic water service area. Table 29 shows the supply and demand
of domestic water for a normal year.
Table 29. Supply and Demand Comparison – Normal Year
2020 2025 2030 2035 2040
Supply totals 18,715 19,430 19,761 20,097 20,439
Exhibit F PC Agenda Page 202
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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120 December 2020
Demand totals 18,715 19,430 19,761 20,097 20,439
Difference 0 0 0 0 0
Source: City of Downey 2018.
Table 30 shows the supply and demand of domestic water for a single-dry year.
Table 30. Supply and Demand Comparison – Single-Dry Year
2020 2025 2030 2035 2040
Supply totals 17,218 17,876 18,180 18,489 18,804
Demand totals 17,218 17,876 18,180 18,489 18,804
Difference 0 0 0 0 0
Source: City of Downey 2018.
Table 31 shows the supply and demand of domestic water for multiple-dry-years.
Table 31. Supply and Demand Comparison – Multiple-Dry-Year Events
Scenarios
Supply and
Demand 2020 2025 2030 2035 2040
Multiple-dry-year
first-year supply
Supply totals 17,218 17,876 18,180 18,489 18,804
Demand totals 17, 218 17,876 18,180 18,489 18,804
Difference 0 0 0 0 0
Multiple-dry-year
second-year supply
Supply totals 17,592 18,264 18,575 18,891 19,213
Demand totals 17,592 18,264 18,575 18,891 19,213
Difference 0 0 0 0 0
Multiple-dry-year
third-year supply
Supply totals 17,592 18,264 18,575 18,891 19,213
Demand totals 17,592 18,264 18,575 18,891 19,213
Difference 0 0 0 0 0
Source: City of Downey 2018.
As shown in Tables 29, 30, and 31, the City’s supplies can meet demands during normal, single-dry, and
multiple-dry years for the next 20 years. Because the City’s water demands can be met under normal, single-
dry, and multiple-dry years, and because supply would meet projected demand due to conservation measures,
the project’s water demands would be served by the City’s projected current and future supplies. Therefore, the
project would have sufficient water supplies available during normal, single-dry, and multiple-dry years. Thus,
impacts would be less than significant.
c) Would the project result in a determination by the wastewater treatment provider, which serves or may
serve the project that it has adequate capacity to serve the project’s projected demand in addition to the
provider’s existing commitments?
Less-Than-Significant Impact: A significant impact would occur if the wastewater treatment provider
indicates that a project would increase wastewater generation to such a degree that the capacity of the
facilities currently serving the project site would be exceeded. Wastewater generated by the City would be
treated at the JWPCP located in the City of Carson. JWPCP has a design capacity of 385 mgd and currently
processes an average flow of 321.6 mgd. Additionally, wastewater would be treated by the Los Coyotes
WRP located in the City of Cerritos. WRP has a design capacity of 37.5 mgd and currently processes an
Exhibit F PC Agenda Page 203
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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121 December 2020
average flow of 32 mgd (City of Downey 2004). Under existing conditions, the project site supports an
industrial building and contributes to the overall wastewater generated within the City. Upon completion of
construction, the project would be smaller than the existing on-site building and would employee fewer
workers. Thus, wastewater generated by the project is expected to be less than produced under existing
conditions. As such, wastewater generated by the project would be accounted for in the JWPCP and WRP
average dry-weather flow capacity and average wastewater flow. Therefore, impacts associated with
wastewater treatment capacity would be less than significant.
d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity
of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less-than-Significant Impact: A significant impact may occur if a project were to increase solid waste
generation to such a degree that existing and projected landfill capacities would be insufficient to
accommodate the additional solid waste.
The project involves the demolition of an existing, 74,662 -square-foot industrial building and
construction of an approximately 44,162-square-foot industrial building for truck terminal use. As
such, under existing conditions, the site contributes to the overall waste generated in the City. However,
upon completion of construction, the project would be smaller than the existing on -site building and
would employ fewer workers. Thus, it is anticipated that waste generated by the project would be less
than produced under existing conditions.
The City’s residents and businesses produce approximately 80,500 tons of waste per year. Thus, the City
must remain committed to waste reduction, diversion, and recycling. Large quantities of waste generated
by the City have been placed in local landfills, particularly the Puente Hills landfill in the City of Whittier.
With the Puente Hills landfill nearing capacity and the closure of other landfills in Los Angeles County, there
is a trend to transport waste to landfills further away, particularly to the Frank R. Bowerman landfill in the
City of Irvine. This trend is expected to continue as more waste would have to be transported to landfills
located farther away, such as the remote areas of Riverside and San Bernardino Counties. The impact on
residents, property owners, and businesses would be increased service fees to cover the costs of
transporting waste longer distances.
The City has implemented programs to reduce the amount of waste generated as well as reducing the
amount of wastestream sent to landfills by diverting items in the wastestream that may be recycled or
reused. In 1990, the City adopted a source reduction and recycling program in con formance with state
legislation (AB 1290). In 1996, Downey Area Recycling and Transfer facility was constructed as a materials
recovery facility where the solid waste collected from Downey and other communities is sorted for
recyclable and usable materials. Waste that cannot be reclaimed is then transported to landfills. The
programs have increased the amount of solid wastestream diverted from the landfills from 20% in 1990 to
48% in 2001, but has remained constant since then. Although the diversion rate is short of the 50% target
mandated by state law, the increases in the amount of materials recycled are significant. To continue efforts
towards increasing the amount of wastestream that is diverted and recycled, public information is provided
to continually remind residents and businesses of the importance of recycling (City of Downey 2005).
Therefore, impacts associated with landfill capacity would be less than significant.
Exhibit F PC Agenda Page 204
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e) Would the project comply with federal, state, and local management and reduction statutes and
regulations related to solid waste?
Less-than-Significant Impact: All collection, transportation, and disposal of solid waste generated by the
project would comply with all applicable federal, state, and local statutes and regulations. In particular, AB
939, the Integrated Waste Management Act of 1989, requires that at least 50% of solid waste generated
by a jurisdiction be diverted from landfill disposal through source reduction, recycling, or composting.
Regional agencies, counties, and cities are required to develop a waste management plan that would
achieve a 50% diversion from landfills (California Public Resources Code, Section 40000 et seq.). Residents
of the City currently use curbside recyclables and green waste containers to increase diversion (City of
Downey 2004). Furthermore, as mentioned in 3.19(d), solid waste generated by the project would not
generate waste in excess of state or local standards. Therefore, impacts associated with solid waste
disposal regulations would be less than significant.
3.20 Wildfire
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation
plan?
b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to,
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines, or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?
d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
CAL FIRE is responsible for designating fire hazard severity zones (FHSZs) within the State Responsibility Areas
throughout California. FHSZs are geographical areas with an elevated risk for wildfire hazard. The State Responsibility
Areas are the areas for which the state assumes financial responsibility for fire suppression and protection. CAL FIRE
Exhibit F PC Agenda Page 205
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also creates recommended maps for very high FHSZs within the Local Responsibility Areas, which are then adopted,
or modified and adopted, by local jurisdictions. Development within a State Responsibility Area is required to abide by
specific development and design standards. A review of CAL FIRE’s FHSZ maps and data revealed that the project site
is not located within a State Responsibility Area or a very high FHSZ (CAL FIRE 2007).
a) Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
Less-than-Significant Impact: The project site is currently developed and is located in a highly urbanized
setting. The project would not be located in or near a State Responsibility Areas or lands classified as very
high FHSZs. According to CAL FIRE’S Fire Hazard Severity Zone Map, the project site is not located in an
area identified as being susceptible to wildland fire (CAL FIRE 2007). Furthermore, the project site is
surrounded by existing development in an urbanized portion of the City away from any wildland-urban
interface. Therefore, impacts, including direct and indirect impacts, associated with wildfires would be less
than significant.
b) Due to slope, prevailing winds, and other factors, would the project exacerbate wild fire risks, and
thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled
spread of a wildfire?
Less-than-Significant Impact: Refer to response provided in Section 3.20(a).
c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may
result in temporary or ongoing impacts to the environment?
Less-than-Significant Impact: Refer to response provided in Section 3.20(a).
d) Would the project 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?
Less-than-Significant Impact: Refer to response provided in Section 3.20(a).
Exhibit F PC Agenda Page 206
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3.21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a
plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal or
eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects)?
c) Does the project have environmental effects
which will cause substantial adverse effects
on human beings, either directly or
indirectly?
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -
sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number
or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the
major periods of California history or prehistory?
Less-than-Significant Impact with Mitigation Incorporated: As previously discussed in Section 3.4,
Biological Resources, the project would result in no impacts to vegetation, riparian, wetland habitat, and
other sensitive natural communities, jurisdictional areas, movement of any native resident or migratory fish
or wildlife species, tree preservation ordinance, or habitat management plans. With implementation of MM-
BIO-1, the project would result in less-than-significant impacts regarding special-status wildlife.
As further addressed in Section 3.5, Cultural Resources, impacts to historic/built environment resources
would be adversely affected by the project, although potential impacts regarding inadvertent discovery of
Exhibit F PC Agenda Page 207
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cultural resources could occur during construction of the project. However, implementation of MM -CUL-1
would ensure that impacts would be less than significant.
As discussed in Section 3.18 , Tribal Cultural Resources, the project is subject to compliance with AB 52
(California Public Resources Code, Section 21074), which requires consideration of impacts to tribal
cultural resources as part of the CEQA process. AB 52 requires the City, as the lead agency responsible for
CEQA compliance for the project, to notify any groups (who have requested notification) of the project who
are traditionally or culturally affiliated with the geographic area of the project.
In accordance with AB 52, on August 31, 2020, the City sent notification letters to the tribal representatives
that have formally requested such notice under AB 52. As discussed in Section 3.19, no tribes entered into
consultation, and no TCRs were identified on the project site. Notwithstanding, implementation of MM-
CUL-1 and MM-TCR-1 would ensure the protection and preservation of TCRs if they were unexpectedly
discovered. Therefore, with incorporate of mitigation, impacts associated with TCRs would be less than
significant.
b) Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are cons iderable when
viewed in connection with the effects of past projects, the effects of other current projects, and the
effects of probable future projects)?
Less-than-Significant Impact with Mitigation Incorporated: As provided in the analysis in this MND, the
project would not result in significant impacts to aesthetics, agriculture and forestry resources, air quality,
energy, geology and soils, GHG emissions, hydrology and water quality, land use and planning, mineral
resources, population and housing, public services, recreation, transportation, utilities and service systems,
and wildfire. Mitigation measures recommended for biological resources, cultural resources, geology and
soils (paleontological resources), hazards and hazardous materials, noise, and tribal cultural resources
would reduce impacts to below a level of significance.
The project could incrementally contribute to cumulative impacts for projects occurring within the City. However,
with incorporation of mitigation identified herein, implementation of the project would not result in any residually
significant impacts that could considerably contribute to a cumulative impact. In the absence of residually
significant impacts, the incremental accumulation of effects would not be cumulatively considerable, and thus,
the project’s contribution to cumulative impacts would be less than significant.
c) Does the project have environmental effects which will cause substantial adverse effects on human beings,
either directly or indirectly?
Less-than-Significant Impact with Mitigation Incorporated: The potential for adverse direct or indirect
impacts to human beings was considered throughout this MND. Based on this evaluation, with incorporated
of mitigation outlined herein, there is no substantial evidence that construction or operation of the project
would result in a substantial adverse effect on human beings.
Exhibit F PC Agenda Page 208
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INTENTIONALLY LEFT BLANK
Exhibit F PC Agenda Page 209
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4 References and Preparers
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Exhibit F PC Agenda Page 215
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12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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133 December 2020
SDSU (San Diego State University). 2019. San Diego State University Mission Valley Campus Master Plan EIR
Additional Information Regarding Potential Health Effects of Air Quality Impacts. Prepared by Ramboll US
Corporation. December 2019. Accessed October. 2020. https://missionvalley.sdsu.edu/assets/pdfs/
FEIR/appendices/4_2_3_SDSU_MV_Health_Effects_Memo.pdf.
SJVAPCD (San Joaquin Valley Air Pollution Control District). 2006. Guidance for Air Dispersion Modeling. Prepared by L.
Villalvazo, E. Davila, and G. Reed. August 2006. Accessed October 21, 2020. https://www.valleyair.org/busind/
pto/tox_resources/modeling%20guidance.pdf.
SJVAPCD. 2015. Brief of Amicus Curiae in Support of Defendant And Respondent, County of Fresno, and Real Party in
Interest and Respondent, Friant Ranch, L.P., Sierra Club v. County of Fresno, Case No. S219783, filed April 13,
2015. https://www.courts.ca.gov/documents/7-s219783-ac-san-joaquin-valley-unified-air-pollution-control-
dist-041315.pdf.
SWRCB (State Water Resources Control Board). 2020. “GeoTracker: 12021 Woodruff Ave, Downey, CA 90241.”
Accessed August 3, 2020. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&
myaddress=Search+GeoTracker.
UCSB (University of California, Santa Barbara). 2020. Historic Aerial Photographs of Woodruff Avenue, Downey, CA
dating from 1928, 1938, 1947, 1952, 1956, 1957, 1960, 1968, 1976, 1977, 980, 1981, 1983, 1988,
1994, and 1998. Map & Imagery Laboratory (MIL) UCSB Library, Electronic Resource,
http://mil.library.ucsb.edu/ap_indexes/FrameFinder. Accessed August 04, 2020.
U.S. Census. 2019. “QuickFacts, Downey City, California.” Accessed August 4, 2020. https://www.census.gov/
quickfacts/downeycitycalifornia.
USDA (United States Department of Agriculture). 2020. Web Soil Survey. USDA Natural Resources Conservation
Service, Soil Survey Staff. Accessed August 3, 2020. https://websoilsurvey.sc.egov.usda.gov/
App/WebSoilSurvey.aspx.
Exhibit F PC Agenda Page 216
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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4.2 List of Preparers
City of Downey
Alfonso Hernandez, Planner
Dudek
Collin Ramsey, Project Manager
Patrick Cruz, Environmental Analyst
Lilli Martin, Environmental Analyst
Nicholas Lorenzen, Air Quality Specialist
David Larocca, Air Quality Specialist
Samantha Murray, Historic Resources Specialist
Linda Kry, Cultural Resources Specialist
Michael Greene, Acoustician
Dennis Pascua, Transportation Planner
Mladen Popovic, Transportation Planner
Carrie Kubacki, GIS and Graphics
Amy Seals, Technical Editing
Felisa Pugay, Formatting
Exhibit F PC Agenda Page 217
105
5
605
710
72
91
19
Imperial Highway
Foster Road
Artesia
Long Beach
Cerritos
Bellflower Norwalk
Lynwood
South
Gate
Cudahy
Downey
Santa Fe
Springs
Bell
Gardens
Maywood
Bell
Vernon
Commerce
Pico
Rivera
Montebello
Paramount
Project Location
12021 Woodruff Avenue Industrial Building Project
SOURCE: USDA NAIP 2016; Open Street Map 2019; USGS NHD 2020
0 5,2502,625 Feet
Project Boundary
City Limit
FIGURE 1
K e r n C o u n t y
Ve n t u r a
C o u n t y
395
101
48
47
57
134
118
91
138
39
159
133
142
187
126
170
1
213
150
23
71
22
34
72
90
55
18
83
241
27 66
19
60
13814
2
10
405
5
5
710
605
210
105 15
L O S
A N G E L E S
C O U N T Y
Project Site
Exhibit F PC Agenda Page 218
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Exhibit F PC Agenda Page 219
605
105
19
Washburn Road
t ewart and d
Imperial Highway
Foster R oad
Vicinity Map
12021 Woodruff Avenue Industrial Building Project
SOURCE: USDA NAIP 2016; Open Street Map 2019; USGS NHD 2020
0 1,250625Feet
Project Boundary
FIGURE 2
Exhibit F PC Agenda Page 220
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Exhibit F PC Agenda Page 221
Project Aerial
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019
0 10050Feet
Project Boundary
FIGURE 3
Exhibit F PC Agenda Page 222
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Exhibit F PC Agenda Page 223
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Photograph A View of the Project Site looking south from Woodruff Avenue.
Photograph C View of the Project Site looking east from Woodruff Avenue towards Driveway 1.
SOURCE: Dudek 2020
Photograph B View of the Project Site looking east from Woodruff Avenue towards the front office.
Photograph D View of the Project Site looking east from Woodruff Avenue towards Driveway 2.
FIGURE 4
Existing Site Photographs
12021 Woodruff Avenue Industrial Building ProjectExhibit F PC Agenda Page 224
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Exhibit F PC Agenda Page 225
Existing Zoning
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; City of Downey 2012
0 250125Feet
Project Boundary
Zoning
Commercial C-1
Manufacturing M-1
Manufacturing M-2
Parking Buffer P-B
Residential R-1 5000
Residential R-3
FIGURE 5
Exhibit F PC Agenda Page 226
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Exhibit F PC Agenda Page 227
General Plan Land Use Designation
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; City of Downey 2012
0 250125Feet
Project Boundary
Land Use
GM (General Manufacturing)
LDR (Low Density Residential)
MDR (Medium Density Residential)
NC (Neighborhood Commercial)
P (Public)
FIGURE 6
Exhibit F PC Agenda Page 228
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Exhibit F PC Agenda Page 229
Surrounding Land Uses and General Plan Land Use Designations
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; City of Downey 2012
0 250125Feet
Project Boundary
Land Use
GM (General Manufacturing)
LDR (Low Density Residential)
MDR (Medium Density Residential)
NC (Neighborhood Commercial)
P (Public)
FIGURE 7
Industrial Uses
Industrial Uses
Industrial Uses
Church
Restaurant
Church
Office/Medical
Office
Multi-Family
Residential
Single-Family
Residential
Adult Development
Center
Event
Center
Exhibit F PC Agenda Page 230
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Exhibit F PC Agenda Page 231
Site Plan
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; HPA Architecture 2020
001050Feet
FIGURE 8
Full Access P = Full Access Passenger Cars
INBD-T = Inbound Trucks (No Truck Exit)
OTBD-T = Outbound Trucks (No Truck Entry)
Driveway 1
(FA-P, INBD-T)
Driveway 2
(FA-P, OTBD-T)
Exhibit F PC Agenda Page 232
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Exhibit F PC Agenda Page 233
Proposed Zoning
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; City of Downey 2012
0 250125Feet
Project Boundary
Area to be rezoned as Manufacturing M-2
Zoning
Commercial C-1
Manufacturing M-1
Manufacturing M-2
Parking Buffer P-B
Residential R-1 5000
Residential R-3
FIGURE 9
Area to be rezoned
as Manufacturing M-2
Exhibit F PC Agenda Page 234
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Exhibit F PC Agenda Page 235
Architectural Elevations (North and South)
12021 Woodruff Avenue Industrial Building Project
FIGURE 10ASOURCE: HPA Architecture 2019
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Exhibit F PC Agenda Page 236
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Exhibit F PC Agenda Page 237
Architectural Elevations (East)
12021 Woodruff Avenue Industrial Building Project
FIGURE 10B
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SOURCE: HPA Architecture 2019
Exhibit F PC Agenda Page 238
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Exhibit F PC Agenda Page 239
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TREES
15 Gal
African Sumac
Rhus lancea 5 L
BOTANICAL/COMMON NAMESYMBOL
PLANTING LEGEND
WUCOLSSIZE QTY REMARKS
Cercidium 'Desert Museum'
Blue Palo Verde
Standard
Chitalpa tashkentensis
Chitalpa
L1924" Box Standard
L336" Box Multi
Irrigation System will comply with standards
348" Box
Total Landscape Area: 27,511 SF
Parking Area: 28,540 SF
Parking Landscape Area (Required): 2,854 SF (10%)
Parking Landscape Area (Provided): 20,804 SF (37%)
2701 GalAcacia redolens 'Low Boy'
Dwarf Acacia
ACCENTS
GROUNDCOVER
L
QTYSIZE REMARKSSYMBOL
SHRUBS
BOTANICAL/COMMON NAME WUCOLS
QTYSIZE REMARKSSYMBOLBOTANICAL/COMMON NAME WUCOLS
SIZE REMARKSSYMBOLBOTANICAL/COMMON NAME WUCOLS
Carex pansa
California Meadow Sedge
1,3004" Pots M
Texas Privet
Ligustrum j. TexanumL
1 Gal 65 L
Aftergow Echeveria
Echeveria 'Afterglow'
5 Gal M310
Callistemon 'Little John'
Dwarf Bottle Brush
5 Gal M383Clj
5 Gal 27 LAgave 'Blue Flame'
Blue Flame AgaveAbf
Carissa m. 'Green Carpet'
Prostrate Natal Plum
M7281 Gal
Yellow Day Lily
Hemerocallis hybridus-Yellow
1 Gal 112 L
2" layer shredded organic mulch in shrub areas, 1" layer in groundcover areas.
3/4" crushed rock decorative rock -Desert Gold. 3" layer over filter fabric.
4' boulders Desert Gold, available from Southwest Boulder. Bury 13 of boulder in
ground. - xx total
5' boulders Desert Gold, available from Southwest Boulder. Bury 13 of boulder
in ground.- xx total
Concrete mow curb, see Planting Detail sheet
3" layer crushed rock over filter fabric.
QTY
Parthenocissus tricuspidata
VINES
Boston Ivy
QTYSIZESYMBOLBOTANICAL/COMMON NAME
L1 Gal 8
WUCOLS REMARKS
TRANSFORMER
SECTION A-A'
0 15' 30' 60'
N
Landscape Plans
12021 Woodruff Avenue Industrial Building Project
FIGURE 11SOURCE: Hunter Landscape 2017
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Exhibit F PC Agenda Page 240
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Exhibit F PC Agenda Page 241
Existing Utilities
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; HPA Architecture 2020
001050Feet
FIGURE 12
Project Boundary
Existing Utilities
Existing 12" Water
Existing 15" Sewer
Existing 21" Sewer
Existing 36"
Stormdrain Line
Existing 4" Gas Line
Existing Overhead
Electrical Line
Existing Overhead
Telephone Lines
Exhibit F PC Agenda Page 242
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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Exhibit F PC Agenda Page 243
Proposed Storm Drain System
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; Thienes Engineering 2019
001050Feet
FIGURE 13
Exhibit F PC Agenda Page 244
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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Exhibit F PC Agenda Page 245
Proposed Wet Utilities
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019; HPA Architecture 2020
001050Feet
FIGURE 14
Project Boundary
Proposed Utilities
Proposed 3" Water Lateral
Proposed 6" Sewer Lateral
Existing Utilities
Existing 12" Water
Existing 15" Sewer
Existing 21" Sewer
Proposed 6"
Sewer Lateral
Proposed 3"
Water Lateral
Exhibit F PC Agenda Page 246
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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164 December 2020
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Exhibit F PC Agenda Page 247
SOURCE: Bing Maps 2020; Open Street Map 2019; Data for this graphic was taken from historical
aerial photographs of the Project site in 1952, 1963, 1972 and 1994 (NETR 2020; UCSB 2020)
0 10050Feet
Property Location
Orange - 1952 (Original Footprint)
Purple - 1963
Yellow - 1972
Blue - 1994
FIGURE 1
Expansion of the Kirkhill Manufacturing Inc. Building
12021 Woodruff Avenue Industrial Building ProjectExhibit F PC Agenda Page 248
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Exhibit F PC Agenda Page 249
Noise Measurement and Modeling Locations
12021 Woodruff Avenue Industrial Building Project
SOURCE: Bing Maps 2020; Open Street Map 2019
0 540270Feet
Project Boundary
Short Term Noise Location (ST)
FIGURE 1
Exhibit F PC Agenda Page 250
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Exhibit F PC Agenda Page 251
BELLFLOWER
PICO RIVERA
FIRESTON E BL
FLO R
FLORENCE AV
H L O X ST
TELEGRAPH RD
IMPERIAL HWY
CLETA
ST
MONTEBELLO
PICO
RIVERA
CITY OF
COMMERCE
BELL
GARDENS
SANTA FE
SPRINGS
DOWNEY
SOUTH
GATE
LYNWOOD
NORWALK
COUNTY
PARAMOUNT
BELLFLOWER
§¨¦I-605
§¨¦I-105
§¨¦I-5
§¨¦I-605
§¨¦I-105
§¨¦I-5
§¨¦I-710
DEPARTMENT OF PUBLIC WORKS
CITY OF DOWNEY
TRUCK ROUTE MAP
ROUTES WITHIN CITY
THRU ROUTES
CITY BOUNDARY
SOURCE: City of Downey 2018
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City of Downey Truck Route Map
12021 Woodruff Avenue Industrial Building Project
Exhibit F PC Agenda Page 252
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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Exhibit F PC Agenda Page 253
605
105
19
Washburn Road
tewart and d
Imperial Highway
Foster Road
Transit and Bicycle Facilities
12021 Woodruff Avenue Industrial Building Project
SOURCE: USDA NAIP 2016; Open Street Map 2019; USGS NHD 2020; Metro 2019; SCAG 2020
0 1,250625Feet
Project Boundary
Potential Bicycle Route
San Gabriel River Trail
Nearest Bus Stop along High
Quality Transit Corridor
LA Metro Route 115
LA Metro Route 127
Norwalk Green Line Station
Metro Green Line
FIGURE 1
Exhibit F PC Agenda Page 254
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
12021 WOODRUFF AVENUE INDUSTRIAL BUILDING PROJECT
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172 December 2020
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Exhibit F PC Agenda Page 255