HomeMy WebLinkAboutPLN-21-00063 Staff ReportSTAFF REPORT
PLANNING DIVISION
DATE: JULY 14, 2021
TO: PLANNING COMMISSION
SUBMITTED BY: ALDO E. SCHINDLER, DIRECTOR OF COMMUNITY DEVELOPMENT
REVIEWED BY: CRYSTAL LANDAVAZO, CITY PLANNER
PREPARED BY: GUILLERMO ARREOLA, PRINCIPAL PLANNER
SUBJECT: PLN-21-0063 – PRESENTATION TO INTRODUCE THE RANCHO LOS
AM IGOS SOUTH CAMPUS SPECIFIC PLAN AND PROGRAM
ENVIRONMENTAL IMPACT REPORT.
LOCATION: RANCHO LOS AMIGOS SOUTH CAMPUS
ZONING: RANCHO LOS AMIGOS SOUTH CAMPUS SPECIFIC PLAN
REPORT SUMMARY
The City of Downey was awarded a Transit Oriented Development grant from the Los Angeles
County Metropolitan Transportation Authority (Metro). The purpose of the grant is to assist in
the development of a Transit Oriented Development Specific Plan for the Rancho Los Amigos
South Campus area surrounding the future Metro West Santa Ana Branch Transit Corridor
(WSAB) Gardendale Transit Station. Thus, the City created a specific plan to promote
development of transit-supportive uses around the proposed WSAB Gardendale Transit Station,
to be located along the southern border of the planning area. Additional complementary uses,
such as neighborhood commercial and open space linkages are encouraged as part of the
Specific Plan. In accordance with the California Environmental Quality Act (CEQA), a Program
Environmental Impact Report (PEIR) was prepared to analyze the potential development in the
specific plan area.
The Specific Plan area encompasses approximately 172 acres, however, 63% or 109 acres, of
the 172-acre area will remain unchanged, or is committed other projects being planned and
studied by the County and the Los Angeles Metropolitan Authority (METRO). The remainder of
the Specific Plan area, approximately 62.5 acres (37%) comprises the Project Site, referred to in
the PEIR as the Focus Area. The PEIR assesses only the Focus Area because this is the area
with potential for development. The Focus Area is planned and programmed for a mix of transit-
oriented residential, retail, and office uses, and more specifically, would allow development of
up to 700 dwelling units (DUs) and approximately 1,130,000 square feet (SF) of new, non-
residential (commercial, retail, office, public facilities, etc.) land uses.
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RECOMMENDATION
This presentation is intended to provide the Planning Commission and public an opportunity to
review and discuss the proposed project, including the draft PEIR. The presentation is for
discussion purposes only, and the Planning Commission is asked to consider and take public
comment on the Specific Plan and Environmental Impact Report, the Planning Commission will
not take any additional action at this meeting.
BACKGROUND
A new WSAB line will connect southeast LA County to downtown Los Angeles. The project is
expected to provide a direct connection to the Metro C Line (Green), Metro A Line (Blue) and
the LA County regional transit network. The WSAB 19-mile corridor project is currently
undergoing an Environmental Impact Statement (EIS)/Environmental Impact Report (EIR)
process to prepare the corridor for the WSAB.
This project is unique because the County of Los Angeles holds sole ownership of all properties
within the Specific Plan area. The City of Downey Community Development Department worked
closely with the County of Los Angeles, Metro, and community members to ensure that all
groups had input regarding the vision and future goals for the area. The Specific Plan Area
includes existing County facilities that will remain in use as well as areas with development
plans in the works for future County facilities.
The City held two Community Workshops throughout the preparation of the Specific Plan.
These workshops allowed stakeholders such as community members, residents, and business
owners, the opportunity to learn about the planning process and provide valuable feedback on
potential uses and the overall vision of the Specific Plan Area.
The goals for the Specific Plan were developed through extensive community input and focused
discussions with all stakeholders and reflect the intentions of the City of Downey’s General Plan,
which is to create a transit oriented, mixed-use, compact and multi-modal environment, promote
sustainable principles in design and development, and enhance the pedestrian scale and
function of the built environment. The Specific Plan seeks to establish a complementary mix of
cultural uses, public spaces, outdoor activities, stronger connections with local neighborhoods,
and promote a family-oriented, culturally-enriched, healthy lifestyle. Lastly, the Specific Plan
strives to enhance economic development successes in the area while supporting a flexible
variety of land uses that further regional transportation and transit planning objectives.
Given the intent of the Specific Plan area as a Transit Oriented Development, the Specific Plan
includes additional goals and guiding principles, such as encouraging transit-supportive
development site wide, and providing a balanced mix of uses around transportation centers and
transportation corridors, balanced, flexible, and diverse land uses that support economic
development and additional housing opportunities. The Specific Plan also strives to establish
land use regulations that support increased pedestrian and bicycle activity and transit usage;
and support improvements to public transportation infrastructure, including bus transit and
potential rail facilities.
On June 7, 2021, the Notice of Availability and the Public Hearing Notice of the pending
Program Environmental Impact Report review period and public hearing was published in
accordance with the requirements of the Downey Municipal Code. The review period for the
PEIR is from June 8th through July 22nd.
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DISCUSSION
Rancho Los Amigos South Campus Specific Plan (Specific Plan) – Project Description
The Specific Plan area is located amongst a mixture of single- and multi-family residential
neighborhoods, light industrial facilities, and medical related uses. The area is bounded to the
south by Gardendale Street, to the west by industrial facilities, single- and multi-family
neighborhoods within the City of South Gate, to the north by Imperial Highway (State Route 90)
and the Rancho Los Amigos National Rehabilitation Center, and to the east by an existing
single-family residential neighborhood and St. Pius X – St. Matthias Academy.
Districts
The Land Use Plan for the Rancho Los Amigos South Campus Specific Plan area provides for
the development of four districts: Flex Tech/Bio-Medical Sub-District, Transit Oriented
Development (TOD) Corridor Sub-District, Regional Public Facilities (RPF) Sub-District, and
Community Serving Uses (CS) Sub-District.
Rancho Los Amigos South Campus Specific Plan – Sub-Districts
Flex Tech/Bio-Medical (FTBM) Sub-District
The intent of the Flex Tech/Bio-Medical Sub-District is to promote job-creating office/medical
uses and supportive services related to one of the largest medical facilities in the region—the
Rancho Los Amigos Rehabilitation Center. The FTBM would integrate existing uses and plan
for the long-term potential redevelopment of the large industrial facilities currently in use and
encourage grouping a range of light industrial, office, and research uses together to create an
innovation hub within Downey.
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Regional Public Facilities (RPF) Sub-District
The intent of this Sub-District is to compliment regionally serving Los Angeles County facilities
that are currently under development. While all zones will accommodate the potential for public
uses, this sub-district encompasses the facilities currently under development, including the L.A.
County ISD/Probation Headquarters and County Administrative Offices.
Transit Oriented Development (TOD) Sub-District
The intent of this Sub-District is to create transit-supportive uses around the future Metro
Gardendale Transit Station, with the intent to facilitate access to the future WSAB Gardendale
Transit station. TOD villages can provide neighborhood serving commercial uses that will help
support residents and grow the district into a desirable place for professionals who will have the
ability to access a large portion of the region for job opportunities.
Community Serving (CS) Uses Sub-District
The intent of this Sub-District is to provide community open space and recreational uses
accessible to the surrounding sub-districts and adjacent established neighborhoods. The future
athletic complex will serve as an anchor for the area, with mature trees and existing landscaped
areas.
Adoption of the Specific Plan will require that both Specific Plans, SP 85-1 and SP 88-1, be
rescinded. The current specific plans are outdated and lack the vision and development
standards necessary to allow transit oriented development in the area and takes advantage of
the future WSAB Gardendale Transit Station. Rescinding the existing Specific Plans is standard
procedure when adopting a new specific plan.
General Plan Amendment
The General Plan, which is required by state law, serves as a guide to the long-term physical
development and growth of a community. It outlines goals that address the issues facing a
community and identifies policies and programs to accomplish those goals. The proposed
Rancho Los Amigos South Campus Specific Plan will require an amendment to the General
Plan to reflect the transit oriented Mixed Use land use designation within the Specific Plan area.
Similarly, the specific plan will require the re-zoning of the Specific Plan area to the Rancho Los
Amigo South Campus Specific Plan in order to will conform with the associated General Plan
Amendment.
ENVIRONMENTAL ANALYSIS
The environmental impact report (EIR) process, as defined by the California Environmental
Quality Act (CEQA), requires the preparation of an objective, full-disclosure document in order
to (1) inform agency decision-makers and the general public of the direct and indirect potentially
significant environmental effects of a proposed action; (2) identify feasible or potentially feasible
mitigation measures to reduce or eliminate potentially significant adverse impacts; and (3)
identify and evaluate reasonable alternatives to a project. In accordance with §15168 of the
State CEQA Guidelines (Title 14 of the California Code of Regulations [CCR]), the proposed
project is a specific plan with the proposed Program EIR (PEIR) that was prepared to assess
the potential environmental impacts associated with the programs and policies of the Specific
Plan.
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The Program Environmental Impact Report (PEIR) was prepared to assess the potential
impacts of the proposed specific plan. The PEIR provides detailed information about potentially
significant environmental impacts that may result from project implementation. The PEIR
developed mitigation measures to reduce the potential effects and acknowledged circumstances
where impacts cannot be reduced to a level of insignificance through mitigation or the adoption
of alternatives.
Scoping Meeting and Public Input
CEQA encourages lead agencies to solicit and consider input from other interested agencies,
citizen groups, and individual members of the public as early as possible in the EIR process.
CEQA also requires the Lead Agency to provide the public with a full disclosure of the expected
environmental consequences of a proposed project and with an opportunity to provide
comments.
The following process was used to obtain input regarding the Project, and in accordance with
CEQA, the PEIR. Throughout the preparation of the Specific Plan and PEIR, the City engaged
with and collected input from community residents and stakeholders through various community
outreach activities.
• On November 16, 2017, the City held a Community Workshop for the Project. Attendees
learned about the planning process, Project goals and objectives, and the overall Project
overview. Workshop attendees also participated in an interactive Post-It note
“brainstorming” exercise to identify treasures, challenges, and visions of the Specific
Plan area. Participants had the opportunity to provide their thoughts, concerns, and
hopes for the future of this corner of the City.
• On April 30, 2018, the City held a Land Use Workshop that focused on specific uses and
interrelationship of existing and planned land uses within the Specific Plan area.
• The City prepared and distributed a Notice of Preparation (NOP) that was available for
public review between February 14, 2019 and March 15, 2019. Responses received on
the NOP have been considered in this EIR, as described further below.
Pursuant to State CEQA Guidelines §15206, the Lead Agency is required to conduct at least
one scoping meeting for all projects of statewide, regional, or area-wide significance. The
scoping meeting is for jurisdictional agencies and interested persons or groups to provide
comments regarding, but not limited to, the range of actions, alternatives, mitigation measures,
and environmental effects to be analyzed. The City of Downey hosted a scoping meeting on
February 25, 2019, in the Barbara J. Riley Community Center, Downey, California. The meeting
was attended by 31 individuals, City staff, and consultants. Environmental issues raised
included transportation, air quality, roadway capacity, local/common wildlife and feral cat
population, public safety, and hazardous materials (related to demolition).
Focus Area
In addition, City staff met with County representatives in developing the Focus Area for the
PEIR. The environmental review had to consider the multiple concurrent development projects
and studies that were in the process during the creation of the plan and were considered when
developing the Specific Plan, which reduced the area under PEIR review, which included the
County of Los Angeles--Rancho Los Amigos South Campus Project, the Metro West Santa Ana
Branch (WSAB)/Metro Project, and the Downey Sports Complex.
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The area under review, the Focus Area, covers only 37 percent, or 62.5 acres of the entire
Specific Plan area. Over one-half (approximately 63 percent or 109 acres) of the approximately
172-acre Specific Plan area will either remain unchanged, or is committed to other projects
being planned and studied by the County and Metro. Potential environmental impacts
associated with the County and Metro projects are analyzed under separate environmental
documents. Accordingly, environmental impacts associated with the County and Metro projects
are not evaluated under this PEIR. The remainder of the Specific Plan area (approximately 37
percent or 62.5 acres) comprises the Project site, referred in this PEIR as the Focus Area. The
Focus Area is planned and programmed for a mix of transit-oriented residential, retail, and office
uses. Accordingly, this PEIR analyzes the Specific Plan’s proposed development within the
Focus Area.
The PEIR contains an environmental analysis of the existing/baseline conditions, Project
impacts, recommended mitigation measures, and unavoidable significant impacts. The PEIR
uses terms in accordance with CEQA to describe the level of significance of adverse impacts.
These terms are defined as follows:
• No Impact. The proposed Project would not have any measurable impact on the
environment.
• Less than Significant Impact. An impact that is adverse but that does not exceed the
defined thresholds of significance. Less than significant impacts do not require
mitigation.
• Less than Significant with Mitigation Incorporated. An impact that exceeds the defined
thresholds of significance and would or could cause a substantial adverse change in the
environment. Standard Conditions and Requirements, and Mitigation Measures are
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recommended to prevent the impact, eliminate the impact, or reduce it to a level that is
considered less than significant.
• Significant and Unavoidable. An impact that exceeds the defined thresholds of
significance and cannot be eliminated or reduced to a less than significant level through
the implementation of the Mitigation Program.
The following section describes measures that would be required of the Project to avoid
potential impacts; to minimize potential impacts; to rectify potential impact by restoration; to
reduce or eliminate potential impacts over time by preservation and maintenance operations; or
to compensate for the potential impact by replacing or providing substitute resources or
environment.
The PEIR examined the following Issues:
Aesthetics Air Quality* Biological Resources*
Cultural Resources* Energy Greenhouse Gas Emissions
Hazards and Hazardous
Materials*
Hydrology and Water
Quality Land Use and Planning
Noise* Population and Housing Public Services and Recreation
Transportation Tribal Cultural Resources* Utilities and Service Systems
“*” includes suggested mitigation to reduce potential impacts resulting from the Project to a level considered
less than significant.
Based on the Notice of Preparation and existing conditions within the Specific Plan area and
surrounding area, no impacts associated with the following environmental issues would occur
and were therefore not further evaluated with the PEIR:
Agricultural and Forestry Resources Mineral Resources
Geology and Soils Wildfire
Mitigation Measures
The PEIR found that implementation of the Specific Plan has the potential to cause impacts on
the environment, unless mitigation measures are implemented through a Mitigation and
Monitoring Program that will reduce or eliminate potential impacts. Mitigation Measures are a
means to prevent, reduce or control adverse environmental effects of a project. Implementation
may reduce the impacts associated with the implementation of the specific plan to levels
considered less than significant. Mitigation measures may also minimize potential impacts by
limiting the degree or magnitude of the action and its implementation. In the case of contributing
historic structures, a mitigation measure may rectify the impact by repairing, rehabilitating, or
restoring the affected environment. Implementation of the Specific Plan may require mitigation
measures that reduce or eliminate a potential impact over time by preservation and
maintenance operations during the life of the action. Lastly, a mitigation measure may
compensate for a potential impact by replacing or providing substitute resources or
environments.
Air Quality
The proposed Specific Plan promotes development of the Focus Area, and a result, has the
potential to create impacts on air quality associated with air emissions generated by
construction and operation of the proposed uses. Mitigation measures propose to require
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additional studies for any residential project located closer than 500-feet to the Metrolink right-
of-way.
• MM AQ-1 - Proposed development projects that are not exempt from CEQA shall have
construction and operational air quality impacts analyzed using the latest available air
emissions model, or other analytical method determined in conjunction with the
SCAQMD. The results of the air quality impact analysis shall be included in the
development project’s CEQA documentation. To address potential localized impacts, the
air quality analysis may incorporate SCAQMD’s Localized Significance Threshold
analysis or other appropriate analyses as determined in conjunction with South Coast
AQMD. If such analyses identify potentially significant regional or local air quality
impacts, the City shall require the incorporation of appropriate mitigation to reduce such
impacts.
• MM AQ-2 - A project-specific Health Risk Assessment (HRA) shall be conducted for
future residential development proposed within 500 feet of the Metrolink right-of-way,
pursuant to the recommendations set forth in the CARB Air Quality and Land Use
Handbook. The HRA shall evaluate a project per the following SCAQMD thresholds:
a. Carcinogens: Maximally Exposed Individual risk equals or exceeds 10 in one million.
b. Non‐Carcinogens: Emit toxic contaminants that equal or exceed 1 for the Maximally
Exposed Individual.
The SCAQMD has also established non-carcinogenic risk parameters for use in HRAs.
Non-carcinogenic risks are quantified by calculating a “hazard index,” expressed as the
ratio between the ambient pollutant concentration and its toxicity or Reference Exposure
Level (REL). An REL is a concentration at or below which health effects are not likely to
occur. A hazard index less of than one (1.0) means that adverse health effects are not
expected. If projects are found to exceed the SCAQMD’s Health Risk Assessment
thresholds, mitigation shall be incorporated to reduce impacts to below SCAQMD
thresholds.
Biological Resources
Potential impacts to biological resources are limited to roosting bats sites and the nesting habits
of local birds. Between February 1st and August 31st there is potential for birds nesting in trees.
The PEIR also found the presence of roosting bats in the area. Both birds and bats are
protected by the Migratory Bird Treaty Act and California Fish and Game Code. Future
construction, demolition and tree maintenance activities should occur outside of general bird
breeding season (February 1st through August 31st) and roosting bat surveys should be
conducted throughout the entire Focus Area prior to demolition, construction, and tree
maintenance.
• MM BIO-1 – Applications for future development facilitated by the Specific Plan Project,
where the City has determined a potential for impacts to a nesting birds, shall be
required to comply with the following mitigation framework:
a. Future project-related construction, demolition, and tree maintenance activities
should occur outside of general avian breeding season (February 1 to through
August 31) to the extent feasible. If project-related construction, demolition, and tree
maintenance activities cannot occur outside general avian breeding season, a pre-
activity nesting bird survey shall be conducted prior to the onset of the
aforementioned activities, within a maximum of 14 days prior to commencement. The
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survey shall be conducted by a qualified biologist. The survey shall be conducted
within all suitable nesting habitat located within the area of activity, which includes a
250-foot survey buffer around the activity site to account for all potentially nesting
birds on and in the immediate vicinity. If no nesting birds are found, the project-
related activities may commence without potential impacts to nesting birds.
b. If any active nests or sign of nesting activity (e.g., carrying nesting material or food)
is observed during the pre-activity survey, a suitable buffer shall be established
around the nest as determined by a qualified biologist to ensure no direct or indirect
impacts occur to the nest. Many avian species that would nest in the area are
accustomed to urban environments and human activities; therefore, the buffer
distance shall be determined based on the location of the nest as well as the species
tolerance to human presence. A qualified biologist shall monitor the nesting activity
after the buffer is delineated and during typical project-related noises to verify that
the buffer is adequately placed and to confirm that breeding is not compromised by
the project. Any excessive noise or lighting that could potentially impact the nest
shall be directed away from the nest to the greatest extent feasible. The buffer shall
remain in place for the duration the nest is active as determined by a qualified
biologist.
c. If it is determined by the bat biologist that there is a substantial population of bats
using the structures in the Focus Area, the construction of bat houses on-site may be
recommended by the qualified biologist and in consultation with CDFW. The houses
would be constructed prior to any exclusionary actions and would be based upon
CDFW-approved designs. If determined necessary by CDFW, post-construction
monitoring shall occur seasonally (four times/year) for up to three years, or until the
mitigation can be considered successful. Success would be defined as the mitigation
roost or roosts being occupied by comparable numbers of bats belonging to the
same species as were present pre-construction.
• MM-BIO-2 – Applications for future development facilitated by the Specific Plan Project,
where the City has determined a potential for impacts to a bats, shall be required to
comply with the following mitigation framework:
a. A focused roosting surveys shall be conducted throughout the entire project site by a
qualified biologist to determine if bat species are presently using the on-site
structures for roosting. The survey shall focus on the buildings with the highest
potential of supporting roosting bats — those with large enough openings for bats to
enter and exit — and it will be conducted at dusk when bats would be exiting their
roosts. Exit counts shall be conducted so that no visible light shines on the roost area
or openings. Noise and other disturbance must be minimized or eliminated, so that
bats will emerge normally from roosts.
b. If there is evidence of established maternity bat roosts within the Project site, the
biologist shall recommend exclusionary devices or removal efforts, as necessary
based on specific species and situational criteria. Exclusionary devices shall not be
installed at the entrance to the roosts between April and August, during which time
the immature bats are unable to leave the roost. Exclusion devices, if needed, will be
installed in late August, after maternity season.
c. If it is determined by the bat biologist that there is a substantial population of bats
using the structures within the project site, the construction of bat houses on-site
may be recommended by the qualified biologist and in consultation with CDFW. The
houses would be constructed prior to any exclusionary actions and would be based
upon CDFW-approved designs. If determined necessary by CDFW, post-
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construction monitoring shall occur seasonally (four times/year) for up to three years,
or until the mitigation can be considered successful. Success would be defined as
the mitigation roost or roosts being occupied by comparable numbers of bats
belonging to the same species as were present pre-construction.
Cultural Resources
Mitigation measures for cultural resources are proposed to reduce the impacts of future
development facilitated by implementation of the Specific Plan. Prior to demolition and
construction, a number of mitigation measures are required that will help preserve the history of
the Focus Area, which include inventory documentation and commemorative programs that
document the historical significance of the Rancho Los Amigos and Los Angeles County Poor
Farm. Development of the site will require demolition and removal of previously disturbed areas,
as such, retention of a Qualified Archeologist is required to create a monitoring program and
provide Cultural Resources Sensitivity Training in the event archeological resources are
discovered.
• MM CR-1 - Recordation of the Historic District’s Site Plan. The buildings in the Historic
District were previously recorded in a HABS report; however, one contributing
component of the District was not recorded at the time: the landscape and site plan.
Prior to any demolition or ground disturbing activity, the property owner shall retain a
Qualified Preservation Professional to prepare a Historic American Landscape Survey
(HALS) Level I Standard Format documentation of the Historic District’s Site Plan and
landscape setting, including hardscape and softscape elements and features from the
historic period of significance, such as roadways, curbs, sidewalks, mature trees, fields,
gardens, and green spaces. The HALS documentation of the Historic District’s Site Plan
shall record the history of the contributing elements, as well as important events or other
significant contributions to the patterns and trends of history with which the property is
associated.
The HALS documentation of the District’s Site Plan shall include measured and
interpretive drawings, large-format black and white photographs, and written histories
documenting the District’s evolution over time. Field photographs and notes shall also be
included. All documentation components shall be completed in accordance with the
Secretary of the Interior’s Standards and Guidelines for Historic American Landscape
Survey (HALS standards).
The Qualified Preservation Professional shall submit the HALS documentation to the
National Park Service for transmittal to the Library of Congress, and archival copies shall
be sent to Rancho Los Amigos, County of Los Angles Natural History Museum, Rancho
Los Amigos Archives at University of Southern California, and Downey History Center.
The Qualified Preservation Professional shall submit proof of submittal to the City no
less than 30 days prior to the start of demolition of District contributing buildings,
structures, and features.
• MM CR-2 - Interpretive and Commemorative Program. The property owner shall retain a
Qualified Preservation Professional to develop and implement a publicly accessible
interpretive and commemorative program (Program) that captures and incorporates the
important cultural history, associations, and significance of the Rancho Los Amigos
Historic District for the public benefit, such that the cultural importance of the Los
Angeles County Poor Farm and Rancho Los Amigos is retained for future generations.
The Program’s requirements shall be outlined in a technical memorandum, including the
requirements for maintenance and operation of the program’s elements that may include
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but not be limited to an on- or off-site exhibit, commemorative marker, oral history, video,
or other publicly accessible media. The interpretive and commemorative program shall
be aimed at actively illustrating the following:
a. The growth and development of the Los Angeles County Poor Farm and Rancho Los
Amigos during the late 19th and early 20th centuries.
b. How the activities and events that occurred within the District were associated with
changing attitudes toward healthcare throughout the County, State, and Nation.
The technical memorandum detailing the Program’s requirements and implementation
schedule shall be prepared by a Qualified Preservation Professional and reviewed by
interested parties such as the Los Angeles Conservancy prior to commencement of
demolition and construction activities. The Qualified Preservation Professional shall
submit quarterly reports (i.e., January, April, July, and October) to the City documenting
the progress of the Program’s implementation. The Qualified Preservation Professional
shall submit documentation illustrating full implementation of the Program to the City
within three years of completion of construction.
• MM CR-3 – Salvage Plan and Inventory Report. Prior to the start of demolition, the
property owner shall retain a Qualified Preservation Professional to prepare a Salvage
Plan and Inventory Report outlining salvageable materials and reuse or disposal options.
The Qualified Preservation Professional shall conduct an inventory of the Historic District
contributors’ key character-defining physical features (e.g., decorative features, window
elements, shingling, etc.) appropriate for salvage and interpretation. The Salvage Plan
and Inventory Report shall include retention of LACO No. 1301 (Water Tower) for
inclusion in the interpretive program. Unsound, decayed, or toxic materials (e.g.,
asbestos, lead paint, etc.) need not be included in the salvage plan. Once salvageable
materials are identified, the Qualified Preservation Professional shall monitor their
collection by future applicants’ construction contractor(s) to ensure the items are
appropriately salvaged and are not damaged during removal. Salvage of materials can
occur prior to the start of demolition, or concurrently with demolition, as feasible.
Salvaged materials shall be stored on-site either in existing structures, or in an off-site
storage facility, to limit exposure to the elements (rain/sun, vandalism, and theft).
Salvaged materials shall first be made available for use in the interpretive program to be
developed under MM CR-2 or for use in any potential future restoration/rehabilitation
projects on the Focus Area. Salvaged materials that are not re-used on-site or in the
interpretative program shall be offered for donation to local historical societies,
preservation organizations, or the like, for curatorial and/or educational purposes, or to
the general public for reuse in rehabilitation of historic structures. Salvaged materials
offered for donation shall be advertised for a period of not less than 30 days on the
County’s website and in historic preservation websites, such as
Preservationdirectory.com and Oldhouseonline.com, and the Los Angeles Times, as well
as by posting in the Specific Plan area itself and by other means as deemed appropriate.
The Qualified Preservation Professional shall document these efforts in writing, to
include salvage methods, an inventory of salvaged materials, and a summary of all
measures taken to encourage receipt of salvaged materials by local historical societies,
preservation organizations, and the public.
Copies of notices and evidence of publication of such notices, along with a summary of
results from the publicity efforts, a list of materials that were donated (if any) and to
whom, and an explanation of why materials were not or could not be accepted, shall be
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included in a salvage summary document to be submitted to the City within 15 days of
the close of the 30-day (or more) notice period. Salvaged materials that are not re-used
on-site or in the interpretative program, or accepted for donation, may be disposed of by
the City upon receipt of the salvage summary document.
• MM CR-4 – Mothballing Plan. The property owner shall retain a Qualified Preservation
Professional to prepare and implement a Mothballing Plan for LACO No. 1283 (Casa
Consuelo) and LACO No. 1301 (Water Tower). The Mothballing Plan shall outline the
proposed mothballing process in compliance with the Secretary of the Interior’s
Standards for the Treatment of Historic Properties and consistent with National Park
Service Preservation Brief No. 31, Mothballing Historic Buildings. The Plan shall include
at a minimum: a condition assessment; measures for structural stabilization as
necessary; pest control measures; weatherization efforts as necessary; and other
mothballing procedures, such as securing the building, providing adequate ventilation,
and developing a maintenance and monitoring plan. Once the buildings/structures have
been mothballed, the Qualified Preservation Professional shall review the resulting
condition of the buildings/structures and provide the City with documentation confirming
that the Plan has been carried out.
Mothballing shall be completed within one year of the initiation of construction activities
(construction and mothballing can occur simultaneous). Future applicants shall carry out
the Plan’s maintenance and monitoring procedures until such time as rehabilitation
and/or reuse of the buildings/structures occurs. While there is currently no proposed use
for these buildings/structures, any future rehabilitation project will be evaluated for
conformance with the Secretary of Interior’s Standards. Conditions of the mothballed
buildings/structures shall be reassessed and documented every five years by a Qualified
Preservation Professional and recommendations for necessary maintenance/structural
repairs shall be completed by the property owner within six months of every
reassessment.
• MM CR-5 – Avoidance and Protection of Retained Historic Resources During
Construction. Prior to the start of construction, a Qualified Preservation Professional
shall be retained by the property owner to develop a plan of action for avoidance and
protection of the retained historic resources in the Focus Area, the Administration
Building (LACO No. 1100); the grouping of the Power Plant (LACO No. 1300); Water
Tower (1301); and the Shop, Laundry and Ice Plant (LACO No. 1302), and the Moreton
Bay Fig Tree in coordination with the City. The plan shall include at a minimum:
a. Notation of the building/structure/feature on construction plans.
b. Pre-construction survey to document the existing physical condition of the
building/structure/feature.
c. Procedures and timing for the placement and removal of a protective barrier(s), such
as protective wood boards, bracing or framing to protect fragile fenestration and
other exposed architecture features and materials, protective fencing and/or concrete
or water-filled plastic K-rails around each retained building/structure/feature.
d. Monitoring of the installation and removal of protective barriers by the Qualified
Preservation Professional, or his or her designee.
e. Monitoring of the condition of the building/structure/feature at regular intervals during
the duration of demolition and construction including vibration monitoring and visual
inspections by a qualified Preservation Professional.
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f. Post-construction survey to document the condition of the building/structure/feature
after completion of the Project.
g. Preparation of a technical memorandum documenting the pre-construction and post-
construction conditions of historic structures and compliance with protective
measures outlined in this mitigation measure.
The plan shall comply with the Secretary of the Interior’s Standards for the Treatment of
Historic Properties (Standards) and shall be memorialized in a technical memorandum,
which shall be submitted to City for review and approval. The final approved plan shall
be submitted to City no later than 30 days prior to the start of construction including any
staging or demolition activities. The plan shall be provided to each construction
manager/foreman at the Project kick-off meeting for each phase of work. The technical
memorandum documenting the pre-construction and post-construction conditions shall
be submitted to the City within 30 days of completion of the Project and removal of the
protective barriers.
In addition, prior to the start of construction, future project applicants shall inform
construction personnel of the location and significance of the retained historic resources,
and of the avoidance and protective measures that shall be implemented. If work crews
are phased, the City shall ensure that each crew is provided with this information, video,
or other publicly accessible media. The interpretive and commemorative program shall
be aimed at actively illustrating the following:
a. The growth and development of the Los Angeles County Poor Farm and Rancho Los
Amigos during the late 19th and early 20th centuries.
b. How the activities and events that occurred within the District were associated with
changing attitudes toward healthcare throughout the County, state, and Nation.
The technical memorandum detailing the Program’s requirements and implementation
schedule shall be prepared by a Qualified Preservation Professional and reviewed by
interested parties such as the Los Angeles Conservancy and approved by the City prior
to commencement of demolition and construction activities. The Qualified Preservation
Professional shall submit quarterly reports (i.e., January, April, July, and October) to the
City documenting the progress of the Program’s implementation. The Qualified
Preservation Professional shall submit documentation illustrating full implementation of
the Program to the City within three years of completion of construction.
• MM CR-6 – Retention of a Qualified Archaeologist. Prior to any ground-disturbing
activities (i.e., demolition, pavement removal, pot-holing or augering, boring, drilling,
grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation,
trenching, or any other activity that has potential to disturb soil), the Applicant or their
designee shall retain a Qualified Archaeologist meeting the Secretary of the Interior’s
Professional Qualifications Standards for archaeology to oversee and ensure all
mitigation related to archaeological resources is implemented.
• MM CR-7 – Construction Worker Cultural Resources Sensitivity Training. Prior to any
ground disturbing activities (i.e., demolition, pavement removal, pot-holing or augering,
boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement,
grading, excavation, trenching, or any other activity that has potential to disturb soil), the
Qualified Archaeologist, or his/her designee, and a Native American representative
(selected from this Project’s California Native American Heritage Commission [NAHC]
contact list), shall conduct cultural resources sensitivity training for all construction
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personnel. In the event construction crews are phased, additional training shall be
conducted for new construction personnel. Construction personnel shall be informed of
the types of archaeological resources that may be encountered, the proper procedures
to be enacted in the event of an inadvertent discovery of archaeological resources or
human remains (see MM CR-10), confidentiality of discoveries, and safety precautions
to be taken when working with cultural resources monitors. The contractor shall ensure
and document that construction personnel are made available for and attend the training
and retain documentation demonstrating attendance. This training may be conducted in
coordination with paleontological resources training required by MM CR-12.
• MM CR-8 – Cultural Resources Monitoring Program (CRMP) Prior to any ground-
disturbing activity (i.e., demolition, pavement removal, pot-holing or augering, boring,
drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading,
excavation, trenching, or any other activity that has potential to disturb soil), the Qualified
Archaeologist shall prepare the CRMP based on the final City-approved Project design
plans. The CRMP shall include:
a. Provisions for Archaeological Monitoring. Full-time archaeological monitoring shall be
required for all construction-related ground-disturbing activity up to a depth of five
feet (depth at which archaeological sensitivity decreases). The CRMP shall outline
the archaeological monitor(s) responsibilities and requirements (MM CR-4).
b. Procedures for Discovery of Archaeological Resources. Procedures to be
implemented if an archaeological resource is discovered shall be fully defined in the
CRMP, including stop-work and protective measures, notification protocols,
procedures for significance assessments, and appropriate treatment measures. The
CRMP shall state that avoidance or preservation in place is the preferred manner of
mitigating impacts to archaeological resources, but shall provide procedures to follow
should the City determine that avoidance is infeasible.
If, based on the Qualified Archaeologist’s recommendation, it is determined that the
discovered archaeological resource constitutes a historical resource or unique
archaeological resource pursuant to CEQA, avoidance and preservation in place
shall be the preferred manner of mitigating impacts to such a resource. Preservation
in place may be accomplished by, but is not limited to, avoidance, incorporating the
resource into open space, capping, or deeding the site into a permanent
conservation easement. If the City determines that preservation in place is infeasible
and data recovery through excavation is the only feasible mitigation available, the
Qualified Archaeologist in coordination with the City shall prepare and implement an
Archaeological Resources Data Recovery and Treatment Plan that provides for the
adequate recovery of the scientifically consequential information contained in the
archaeological resource. The City shall consult with appropriate Native American
representatives in determining treatment of resources that are Native American in
origin to ensure cultural values ascribed to the resource, beyond that which is
scientifically important, are considered.
c. Reporting Requirements. The CRMP shall outline provisions for weekly, monthly,
and final reporting. The Qualified Archaeologist shall prepare weekly status reports
detailing activities and locations observed (with maps) and summarizing any
discoveries for the duration of monitoring to be submitted to the City via email for
each week in which monitoring activities occur. Monthly progress reports
summarizing monitoring efforts shall be prepared and submitted to the City for the
duration of ground-disturbing activity. The Qualified Archaeologist shall prepare a
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draft CRMP and submit it to the City within 30 days of completion, or within 120 days
of completion of treatment for significant discoveries if treatment extends beyond the
cessation of monitoring. The final Archaeological Resources Monitoring Report shall
be submitted to the City within 15 days of receipt of City comments. The Qualified
Archaeologist shall also submit the final Archaeological Resources Monitoring Report
to the South Central Coastal Information Center. If human remains are encountered,
a confidential report documenting all activities shall be submitted to the NAHC within
90 days of completion of any treatment.
d. Curation Requirements. Any historic-period archaeological materials that are not
Native American in origin shall be curated at an American Association of Museums
accredited repository that meets 36 Code of Federal Regulations (CFR) 79.9
standards. If no accredited repository accepts the collection, then it may be curated
at a non-accredited repository as long as it meets the minimum 36 CFR 79.9
standards. If neither an accredited nor a non-accredited repository accepts the
collection, then it may be offered to a public, non-profit institution with a research
interest in the materials, or donated to a local school or historical society in the area
for educational purposes, to be determined by the Qualified Archaeologist in
consultation with the City. Disposition of Native American archaeological materials
shall be determined through consultation between Native American representatives,
the Qualified Archaeologist, and the City.
e. Protocols for Native American Input. The CRMP shall outline the role and
responsibilities of Native American Tribal representatives. It shall include
communication protocols, an opportunity and timelines for review of cultural
resources documents related to archaeological discoveries that are Native American
in origin, and provisions for Native American monitoring in the event of
archaeological discoveries that are Native American in origin. The CRMP shall
include provisions for Native American monitoring during testing and data recovery
efforts for discovered resources that are Native American in origin.
• MM CR-9 – Archaeological Monitoring. All ground-disturbing activity (i.e., demolition,
pavement removal, pot-holing or augering, boring, drilling, grubbing, vegetation removal,
brush clearance, weed abatement, grading, excavation, trenching, or any other activity
that has potential to disturb soil) to a depth of 5.0 feet (depth at which archaeological
sensitivity decreases) shall be monitored by an archaeological monitor(s) familiar with
the types of resources that could be encountered and shall work under the Qualified
Archaeologist’s direct supervision. The Qualified Archaeologist shall determine the
number of archaeological monitors required on-site during ground-disturbing activities
based on the construction scenario, pieces of equipment operating at the same time, the
distance between those pieces of equipment, and the pace at which equipment is
working, with the goal of monitors being able to effectively observe soils as they are
exposed. The archaeological monitor(s) shall keep daily logs detailing the types of
activities and soils observed, and any discoveries. Archaeological monitor(s) shall have
the authority to halt and re-direct ground-disturbing activities in the event of a discovery
until it has been assessed for significance and treatment implemented, if necessary,
based on the Qualified Archaeologist’s recommendations in coordination with the City,
and the Native American representatives if the resource is Native American in origin,
and in accordance with the CRMP protocols and procedures (see MM CR-5).
• MM CR-10 – Unanticipated Discovery. In the event that human remains are discovered
or unearthed, all earth-disturbing work within a 100-meter radius of the location of the
human remains shall be temporarily suspended or redirected by the applicant until a
forensic expert retained by the applicant has identified and evaluated the nature and
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significance of the find, in compliance with State CEQA Guidelines §15064.5(f). If human
remains of Native American origin are discovered or unearthed, the applicant shall
contact the consulting tribe, as detailed in MM TCR-1, regarding any finds and provide
information after the archaeologist makes his/her initial assessment of the nature of the
find, so as to provide Tribal input concerning significance and treatment. After the find
has been appropriately mitigated, as determined and documented by a qualified
archaeologist, work in the area may resume.
• MM CR-11 – Retention of a Qualified Paleontologist. Prior to start of any ground-
disturbing activities (i.e., demolition, pavement removal, pot-holing or auguring, boring,
drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading,
excavation, trenching, or any other activity that has potential to disturb soil), the property
owner shall retain a Qualified Paleontologist meeting the Society of Vertebrate
Paleontology (SVP) standards (SVP, 2010). The Qualified Paleontologist shall provide
technical and compliance oversight of all work as it relates to paleontological resources,
shall attend the Project kick-off meeting and Project progress meetings on a regular
basis, and shall report to the Project Site in the event potential paleontological resources
are encountered.
• MM CR-12 – Construction Worker Paleontological Resources Sensitivity Training. Prior
to the start of any ground-disturbing activities (i.e., demolition, pavement removal, pot-
holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed
abatement, grading, excavation, trenching, or any other activity that has potential to
disturb soil), the Qualified Paleontologist, or his/her designee, shall conduct construction
worker paleontological resources sensitivity training. In the event construction crews are
phased, additional training shall be conducted for new construction personnel. The
training shall focus on the recognition of the types of paleontological resources that
could be encountered within the Focus Area, the procedures to be followed if they are
found, confidentiality of discoveries, and safety precautions to be taken when working
with paleontological monitors. The property owner shall ensure that construction
personnel are made available for and attend the training and retain documentation
demonstrating attendance. This training may be conducted in coordination with cultural
resources training required by MM CR-7.
• MM CR-13 – Paleontological Resources Monitoring. Full-time paleontological resources
monitoring shall be conducted for all ground disturbing activities at or below five feet
(depth at which paleontological resources sensitivity increases). The Qualified
Paleontologist shall spot check the excavation on an intermittent basis and recommend
whether the depth or frequency of required monitoring should be revised based on
his/her observations. Paleontological resources monitoring shall be performed by a
qualified paleontological monitor (meeting the standards of the SVP) under the direction
of the Qualified Paleontologist. The number of paleontological monitors required to be
on-site during ground disturbing activities shall be determined by the Qualified
Paleontologist and shall be based on the construction scenario, specifically the number
of pieces of equipment operating at the same time, the distance between these pieces of
equipment, and the pace at which equipment is working, with the goal of monitors being
able to effectively observe soils as they are exposed. Monitors shall have the authority to
temporarily halt or divert work away from exposed fossils in order to recover the fossil
specimens.
Any significant fossils collected during project-related excavations shall be prepared to
the point of identification and curated into an accredited repository with retrievable
storage. Monitors shall prepare daily logs detailing the types of activities and soils
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observed, and any discoveries. The Qualified Paleontologist shall prepare weekly status
reports detailing activities and locations observed (with maps) and summarizing any
discoveries for the duration of monitoring to be submitted to the City of Downey via email
for each week in which monitoring activities occur. Monthly progress reports
summarizing monitoring efforts shall be prepared and submitted to the City for the
duration of ground disturbance. The Qualified Paleontologist shall prepare a draft
Paleontological Resources Monitoring Report and submit it to the City within 30 days of
completion of the monitoring program, or within 120 days of completion of treatment for
significant discoveries should treatment extend beyond the cessation of monitoring. The
final Paleontological Resources Monitoring Report shall be submitted to the City within
15 days of receipt of City comments. If significant fossils are recovered, the final report
shall also be filed with the Natural History Museum of Los Angeles County and the
certified repository.
• MM CR-14 – Inadvertent Discovery of Paleontological Resources. If construction or
other Project personnel discover any potential fossils during construction, regardless of
the depth of work or location, work at the discovery location shall cease in a 50-foot
radius of the discovery until the Qualified Paleontologist has assessed the discovery and
made recommendations as to the appropriate treatment. If the find is deemed significant,
it shall be salvaged following the standards of the SVP (SVP, 2010) and curated with a
certified repository.
Hazards and Hazardous Materials
Project implementation will promote development of the specific plan area, and result in
demolition of existing structures in the Focus Area. Demolition of structures built prior to the
1978 may contain asbestos and lead-based paints. The mitigation measures address the
transport, use, or disposal of hazardous materials associated with future demolition of existing
structures and development in the Focus Area. Furthermore, a Phase I Environmental Site
Assessment is required to identify current environmental conditions prior to demolition or
construction activities, and to determine if further sampling/remedial activities are required.
• MM HAZ-1 – Prior to any renovation, or demolition, grading or building permit approval,
a formal Phase I Environmental Site Assessment (ESA) shall be prepared for any
vacant, commercial, and industrial properties involving hazardous materials or waste.
The Phase I ESA shall be prepared in accordance with ASTM Standard Practice E
1527-13 or the Standards and Practices for All Appropriate Inquiry (AAI), prior to any
land acquisition, demolition, or construction activities. The Phase I ESA would identify
specific Recognized Environmental Conditions (RECs), which may require further
sampling/remedial activities by a qualified hazardous materials Environmental
Professional with Phase II/site characterization experience prior to land acquisition,
demolition, and/or construction. The Environmental Professional shall identify proper
remedial activities, if necessary.
• MM HAZ-2 – If the contractor discovers unknown wastes or suspect materials during
construction that are believed to involve hazardous waste or materials, the contractor
shall:
a. Immediately cease work in the suspected contaminant’s vicinity, and remove workers
and the public from the area;
b. Notify the County’s Project Engineer;
c. Secure the area as directed by the Project Engineer; and
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d. Notify the implementing agency’s Hazardous Waste/Materials Coordinator.
The Hazardous Waste/Materials Coordinator shall advise the responsible party of further
actions that shall be taken, if required.
Noise
Impacts related to noise and vibrations may occur during the construction phase of the project.
Noise reduction programs are required for all construction and demolition activities to reduce
any noise impacts on the surrounding residential areas. Additionally, mitigation measures must
be implemented to protect any historic structure located within 100 feet of construction activity.
• MM NOI-1 – To reduce construction-related noise impacts, where construction activities
would exceed the standards established in DMC §4606.5 (Construction Noise), the
Applicant shall require construction contractors to implement a site-specific Noise
Reduction Program, which includes the following measures, ongoing through demolition,
grading, and/or construction:
a. Equipment and trucks used for project construction shall utilize the best available
noise control techniques (e.g., improved mufflers, equipment redesign, use of intake
silencers, ducts, engine enclosures, and acoustically-attenuating shields or shrouds),
wherever feasible.
b. Impact tools (e.g., jackhammers, pavement breakers, and rock drills) used for
construction shall be hydraulically or electronically powered wherever possible to
avoid noise associated with compressed air exhaust from pneumatically powered
tools. However, where use of pneumatic tools is unavoidable, an exhaust muffler
shall be used (this muffler can lower noise levels from the exhaust by up to
approximately 10 dBA). External jackets on the tools themselves shall be used
where feasible (this can achieve an approximately 5.0-dBA reduction. Quieter
procedures shall be used, such as drills rather than impact equipment, whenever
feasible.
c. Stationary construction-related noise sources shall be located as far from adjacent
receptors as possible, and they shall be muffled and incorporate insulation barriers,
or other measures to the extent feasible.
• MM NOI-2 – Prior to demolition, grading, or building permit approval, the Applicant shall
submit to the Planning Division and Community Development Department a list of
measures to respond to and track complaints pertaining to construction noise, ongoing
throughout demolition, grading, and/or construction. At minimum, these measures shall
include the following:
a. A procedure to the public for notifying the City’s Code Compliance Officer and Police
Department (during regular construction hours and off-hours);
b. A requirement for a sign to be posted by the Applicant on-site specifying the
permitted construction days and hours, and notification procedure, and who to notify
in the event of a noise-related concern. The sign shall also include the construction
contractor’s telephone numbers (during regular construction hours and off-hours);
and
c. A requirement for a preconstruction meeting to be held with the Applicant and
general contractor/on-site project manager to confirm that noise measures and
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practices (including construction hours, neighborhood notification, posted signs, etc.)
are completed.
• MM NOI-3 – Vibratory Equipment for Historic Buildings. To avoid or minimize potential
construction vibration damage to structural or finish materials on on-site historic
buildings, the condition of such materials shall be documented by a qualified
preservation consultant, prior to initiation of construction. During construction, the
contractor shall install and maintain at least two continuously operational automated
vibrational monitors on any on-site historic structures within 100 feet of active
construction activity. The monitors must be capable of being programmed with two
predetermined vibratory velocities levels: a first-level alarm equivalent to a 0.45 inch per
second at the face of the building and a regulatory alarm level equivalent to 0.5 inch per
second at the face of the building. The monitoring system must produce real-time
specific alarms (via text message and/or email to on-site personnel) when velocities
exceed either of the predetermined levels. In the event of a first-level alarm, feasible
steps to reduce vibratory levels shall be undertaken, including but not limited to
halting/staggering concurrent activities and utilizing lower-vibratory techniques. In the
event of an exceedance of the regulatory level, work in the vicinity shall be halted and
the historic structure visually inspected for damage. Furthermore, once construction has
been completed, a qualified preservation consultant shall conduct a final visual
inspection of the on-site historic structures to determine if any damage has occurred.
Results of the inspections must be logged and submitted to the City. In the event
damage occurs to historic finish materials due to construction vibration, such materials
shall be repaired in consultation with a qualified preservation consultant.
• MM NOI-4 – Vibratory Equipment for Residential Receptors. Use of high impact, heavy-
duty equipment shall be limited to the extent feasible within 25 feet of residential
receptors. Where feasible, equipment or alternative techniques that would generate
vibration velocities not exceeding 0.04 in/sec PPV at 25 feet shall be utilized.
• MM NOI-5 – Notify Residences. Prior to large bulldozers, large loaded trucks, and
vibratory compactor/rollers being operated at the Specific Plan area within 50 feet of an
occupied residence, the Project Contractor(s) shall notify the affected residential
property owners in writing of upcoming construction including the anticipated start and
end dates and hours of operation. This restriction does not apply to trucks on a public
right-of-way.
Tribal Cultural Resources
Similar to the Cultural Resources section above, future demolition and construction activities
associated with the implementation of the Specific Plan may affect tribal and cultural resources,
thus mitigation measures are proposed to appropriately identify and preserve resources in the
event of a discovery. Inadvertent discovery of archaeological resources require the services of a
Qualified Archaeologist, and if those resources are found to be Native American in origin, a
Native American monitor from a culturally and geographically affiliated Tribe shall be contacted.
• MM TCR-1 – Inadvertent Discovery of Archaeological Resources. In the event that
archaeological resources are encountered during ground-disturbing activities, all activity
within a 100-foot radius of the find shall cease and the CRMP protocols and procedures
for discoveries shall be implemented (see MM CR-8). The Qualified Archaeologist shall
evaluate the discovery for potential significance. If the Qualified Archaeologist
determines that the resource may be significant (i.e., meets the definition for historical
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resource in CEQA Guidelines §15064.5(a) or unique archaeological resource in PRC
§21083.2(g)), the Qualified Archaeologist shall develop an appropriate treatment plan for
the resource in accordance with the CRMP. When assessing significance and
developing treatment for resources that are Native American in origin, the Qualified
Archaeologist and the City shall consult with the appropriate Native American
representatives. The Qualified Archaeologist shall also determine if work may proceed in
other parts of the Project Site while treatment for cultural resources is being carried out.
• MM TCR-2 – Native American Monitoring. In the event the Qualified Archaeologist
determines that an archaeological discovery is Native American in origin, the Applicant
or their designee shall retain a qualified Native American monitor to provide monitoring
during testing and data recovery efforts of the discovered resource in accordance with
CRMP protocols and procedures (see MM CR-8). The Native American monitor shall be
selected from a Tribe that is culturally and geographically affiliated with the Specific Plan
area (according to this Project’s NAHC contact list). In the event of a discovery, the City
shall also determine if Native American monitoring of any future ground-disturbing
activities is warranted.
Significant and Unavoidable Impacts
Most of the potentially significant impacts resulting from the project may be reduced to a level
considered Less than Significant with the implementation of the mitigation measures listed for
each of the topics above; however, implementation of the proposed Specific Plan may still result
in potentially significant impacts to Air Quality, Cultural Resources, and Greenhouse Gas
Emissions, even after mitigation.
To approve a project with unavoidable significant impacts, the City of Downey must adopt a
Statement of Overriding Considerations. The City is currently considering this option, which
CEQA allows when a project has the potential for impacts that are significant and unavoidable.
In adopting such a statement, the lead agency is required to balance the benefits of a project
against its unavoidable environmental impacts in determining whether to approve the project. If
a project’s benefits are found to outweigh the unavoidable adverse environmental effects, the
adverse effects may be considered “acceptable” (State CEQA Guidelines §15093(a)).
Air Quality
The proposed Specific Plan has the potential to result in a cumulative considerable net increase
of pollutants. However, implementation of mitigation measures would ensure that future
development projects have feasible mitigation measures incorporated as necessary to reduce
potential impacts. The Project would not result in a cumulatively considerable net increase of
pollutants for the region. The region itself is considered non-attainment under applicable federal
or state ambient air quality standard. The South Coast Air Quality Management District
(SCAQMD) has developed strategies to reduce criteria pollutant emissions outlined in the Air
Quality Management Plan (AQMP) pursuant to the federal Clean Air Act mandates. Therefore,
individual projects will include fugitive dust controls during construction, including frequent water
applications and comply with SCAQMD rules and regulations. Potential construction within the
Specific Plan area will not cause non-attainment in the region but will be a potential contributor
despite adhering to SCAQMD rules and regulations.
Cultural Resources
While the Project involves adoption of a land use plan and does not propose any development,
future development could potentially result in direct impacts through the physical demolition,
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destruction, or alteration of potential historical resources within the Focus Area. Future
development within the Focus Area assumes the demolition of contributor and non-contributor
buildings and would remove remaining features of the Historic District’s original 1888 Site Plan.
A contributor building is a structure that contributes to the significance of a historic district.
Several mitigation measures are proposed, however, the impacts to the Historic District would
remain significant and unavoidable since the Historic District would no longer be eligible for
National Register of Historic Places and may be delisted from the California Register of
Historical Resources. There are five individually eligible buildings and structures in the Specific
Plan area, and four with the Focus Area. All five of the structures will be retained. However, the
PEIR includes a number of mitigation measures that would reduce the impacts on these
individual structures.
Greenhouse Gas Emissions
The PEIR clarified that future development in the Focus Area would need to be analyzed on a
project-by-project basis to determine the extent of each project’s potential contribution to global
climate change and appropriate mitigation measures specific to each project. Due to the
uncertainty of timing of future development, and project-specific details, future development has
the potential to exceed SCAQMD recommended threshold of 3,000 MT CO2e per year.
Therefore, impacts are considered significant and unavoidable in the PEIR.
These three issues could not be reduced (mitigated) to a less than significant level through the
adoption of mitigation measures or project alternatives. Therefore, should the City choose to
approve the project, the City will need to identify project benefits that outweigh the identified
significant environmental impacts. Should the Planning Commission choose to recommend
project approval to the City Council, a statement of overriding considerations will be required.
CORRESPONDENCE
As of the date that this report was printed, staff has not received any correspondence regarding
this application.
CONCLUSION
This presentation is intended to provide the Planning Commission and public an opportunity to
review and discuss the proposed project, including the draft PEIR. The presentation is for
discussion purposes only, and the Planning Commission is asked to consider and take public
comment on the Specific Plan and Environmental Impact Report, the Planning Commission will
not take any additional action at this meeting.
It is recommended that the Planning Commission receive and file this report.
LINKS
A. Rancho Los Amigos South Campus Specific Plan and Program Environmental Impact
Report – https://www.downeyca.org/our-city/departments/community-
development/planning/rancho-south-campus
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